Summary
The Regional Ecosystem Office (REO) has performed a review of the Mt. Baker-Snoqualmie National Forest (MBS) Forest-wide LSR Assessment (LSRA), which addresses the following 16 LSRs and associated late-successional additions:

- LSR RW111 - LSR RW112 - LSR RW113 - LSR RW114 -
- LSR RW115 - LSR RW116 - LSR RW117 - LSR RW118 -
- LSR RW119 - LSR RW120 - LSR RW121 - LSR RW122 -
- LSR RW123 - LSR RW124 - LSR RW125 - LSR RW802 -

For the purposes of this memorandum, the sixteen LSRs, the 42,596 acres of mapped LSOGs and the 5,521 acres of unmapped LSRs (occupied northern spotted owl, marbled murrelet, and larch mountain salamander sites) will be collectively referred to as LSRs.

In light of its review, which was based in large measure on the analysis and recommendations of the REO-led interagency Late-Successional Reserve (LSR) Work Group, the REO finds that the MBS Forest-wide LSRA provides a sufficient framework and context for future projects and activities within the LSRs. Future silviculture and salvage activities described in Chapter 3 of this LSRA that meet both the criteria and objectives of the LSRA and the Standards and Guidelines (S&Gs) in the Northwest Forest Plan (NFP) are exempt from project-level REO review. The Conclusions and Clarifications Section of this memorandum provides additional details on REO findings related to this assessment, including a discussion of proposed projects to create grizzly bear foraging habitat in the mountain hemlock zone based on criteria (page 78) of the LSRA.

Basis for the review
Under the S&Gs for the NFP, a management assessment should be prepared for each large LSR (or group of smaller LSRs) before habitat manipulation activities are designed and implemented. As stated in the S&Gs, these assessments are subject to REO review. The REO review focuses on the following:

1. The review considers whether the assessment contains sufficient information and analysis to provide a framework and context for making future decisions on projects and activities. The eight specific subject areas that an assessment should generally include are found in the NFP (S&Gs, page C-11). The REO may find that the assessment contains sufficient information or may identify topics or areas for which additional information, detail, or clarity is needed. The findings of the review are provided to the agency or agencies submitting the assessment.

2. The review also considers treatment criteria and potential treatment areas for silviculture, risk-reduction, and salvage activities if addressed in the LSRA. When treatment criteria are clearly described and their relationship to achieving desired late-successional conditions are also clear, subsequent projects and activities within the LSR(s) may be exempt from further REO review, provided they are consistent with the LSRA criteria and NFP S&Gs. The REO authority for developing criteria to exempt these actions is found in the S&Gs (pages C-12, C-13, and C-18). If such activities are not described in the LSRA and exempted from further review by this memo, they remain subject to future REO review.

Scope of the Assessment and Description of the Assessment Area
The MBS is located on the west side of the Cascade Mountain Range in Northern Washington. The MBS LSRs comprise approximately 40% of the National Forest. The LSRA team analyzed the LSR network in conjunction with adjacent Designated Conservation Areas that are in wilderness, and other non-timber producing land allocations to determine habitat condition and the effectiveness of the LSRs.

About 50% of the LSRs are in the Pacific silver fir zone and 32% are in the mountain hemlock zone. Only 17% of the LSRs are in western hemlock zone and the remaining 1% includes Douglas fir, subalpine fir, parkland and no-vegetation zones. Approximately, 70% of the LSRs are greater than 80 years in age.

The basis for this review is the LSRA dated September 2000 and revised in July 2001. A field visit on February 7, 2001 with Forest staff and the LSRA work group provided additional information about habitat conditions, new development concerns and the possibility of providing grizzly bear foraging habitat in the LSR.

Review of the Assessment
The REO reviewed the LSRA in light of the eight subject areas identified in the S&Gs (page C-11). The assessment provides both a general description of the LSR network and specific analyses of individual LSRs. The MBS encompasses the northernmost LSRs covered by the NFP. The LSRA documents the importance of the LSRs serving as a functioning network of dispersal corridors for various species. Containing over 30% mountain hemlock zone habitat, the LSRs are home to grizzly bear, gray wolf, lynx, wolverines and mountain goats. At lower elevations bald eagles and marbled murrelets are present. Some species such as the grizzly bear, may require a certain percentage of habitat other than late-successional old-growth.

The LSRA provides a good description of the available habitat for spotted owls in terms of connectivity and condition. Priorities for silviculture treatment are based on the ability to increase the proportion of functioning habitat in each LSR as well as improve connectivity. At the stand level, priorities are based on increasing patch size and reducing edge.

The REO finds the LSRA provides a sufficient framework and context for designing future actions. The assessment provides specific objectives and criteria, and identifies possible treatments to achieve and maintain desired conditions. The descriptions of current conditions (forest structure, composition, and vegetation patterns) provide a framework for identifying, designing, and prioritizing treatments. The LSRA includes treatment types and management strategies at two scales; the stand scale and the broader scale of landscape priorities. Species-specific priorities are also included.

The REO finds the proposed silviculture, salvage and risk reduction treatments listed in Chapter 3 to be consistent with the NFP Standards and Guidelines with the following clarifications and assumptions.

Clarifications and Assumptions

Grizzly Bear Foraging Habitat
The grizzly bear is a threatened species inhabiting the Washington Cascades. The current population in this area is estimated at less than 50 and perhaps as low as 5 to 20 individuals (Almack et al., 1993). All LSRs except 123, 124, and 125 are in the North Cascades Grizzly Bear Recovery Zone. Because of private ownership, available food supplies for the grizzly at lower elevations have diminished. As late- successional habitat in LSRs develop over time, areas of berry production in LSRs will decrease. Continued wildfire suppression will prevent the creation of new berry fields.

The mountain hemlock zone has been identified in the LSRA as particularly valuable for providing grizzly foraging habitat. Development of closed forest conditions in the mountain hemlock zone is naturally slow due to high snow pack depth and duration. This vegetative zone can provide effective early seral foraging habitat for more than 100 years post-disturbance (pg. 56). In the mountain hemlock zone, 70% of the vegetation is 80 years or older. Adjacent wilderness also contains high percentages of intact late-successional and old-growth forest (referred to in the LSRA as LOS) mountain hemlock zone vegetation thus allowing maintenance of a functioning network of mountain hemlock LOS.

The North Cascades Recovery Area Technical Team has drafted habitat objectives for Bear Management Units (BMUs) within the North Cascades Recovery Area, as per the Grizzly Bear Recovery Plan. The LSRA describes (pages 56-57) the limiting habitat features for each BMU, and treatments (pages 77-78) that would occur within those BMUs where foraging habitat is limited. Projects to create early-successional habitat will meet the descriptions noted in the LSRA and be consistent with the final BMU habitat criteria, (expected to be completed by October 2001). Projects required for the recovery of listed threatened and endangered species take precedence over LSR standards and guidelines (C-11, C-17). REO assumes that in addition to meeting foraging habitat needs, other habitat components necessary for grizzly bear recovery, such as security habitat, will also be pursued as per the grizzly bear recovery plan.

Coarse Woody Debris and Snags
The LSRA proposes to incorporate snag objectives using the program DecAid developed by Bruce Marcot (Marcot et al., in press). DecAid describes three different levels of snag and CWD retention, depending on management objectives. Based on discussion with the Forest on August 7, 2001, the Forest clarified that snags would be retained according to DecAid "high levels." The Forest also agreed that they would use the DecAid model for determining diameter of CWD to be retained in salvage units and manage for the high levels described in DecAid. Until the DecAid model is available, REO suggests the Forest use Wildlife Habitat Relationships of Oregon and Washington, Johnson and O'Neil Managing Directors (Chapter 24: Wood Legacies, Table 10), or reference Spies, et al., 1988 for meeting snag and CWD diameter objectives.

Risk Reduction
Treating natural fuels to reduce risk where there is a threat to public safety (LSRA, p. 76) will be exempt from REO review when the fuels are less than 3 inches in diameter, on the assumption that smaller fuels are responsible for fire spread.

Stream Improvement Projects
The LSRA proposes the removal of individual down logs from the LSRs for use in stream improvement projects. The REO assumes the logs would be used in the context of C-17 for Habitat Improvement Projects where the effect on late-successional associated species is negligible. Logs used in habitat improvement projects that are taken from outside the habitat improvement project area (i.e., that area where the improvement effects would be expected to directly occur) need to meet the salvage criteria standards and guidelines listed (page C-14).

Conclusion
This LSRA addresses sixteen LSRs, 42,596 acres of mapped LSOGs and 5,521 acres of unmapped LSRs located on the MBS NF. The REO concurs in the recommendations of the interagency LSR Work Group that, based on a review of the relevant documentation and discussions with Forest staff, the LSRA provides a sufficient framework and context for decision-makers to proceed with project development and analysis. As identified above, silviculture and salvage activities described in Chapter 3 of this LSRA, with the assumptions and clarifications noted above, that meet both the criteria and objectives of the LSRA and the Standards and Guidelines (S&Gs) in the Northwest Forest Plan (NFP), are exempted from project-level REO review.

cc:
REO
RIEC
LSR Work Group

1674/ly