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Memorandum |
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Date: |
May 13, 2003 |
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To: |
Elaine M. Brong, OR/WA State Director, Bureau of Land Management |
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From: |
Anne Badgley, Executive Director /s/Anne Badgley |
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Subject: |
Timbered Rock Fire Salvage and Elk Creek Late-Successional Reserve Restoration – Butte Resource Area Clarification |
This memorandum is in response to your request dated May 1, 2003 regarding clarification of interpretation of key concepts for the Timbered Rock Fire Salvage and Elk Creek Late-Successional Reserve Restoration – Butte Resource Area. The Late-Successional Reserves (LSR) interagency work group reviewed proposals for the Timbered Rock Environmental Impact Statement on May 1, 2003. The workgroup has provided several recommendations and findings as outlined below and requested additional review of the final proposed action (see item 3).
Your memo asked questions about four issues:
1. The 10 acre salvage stand-replacing standard and guideline (C-14) and Regional Ecosystem Office/LSR Work Group exemption criteria – stand or project area basis
The District requested clarification on scale of application of this Standard and Guideline (S&G) from the LSR Work Group. The Work Group concluded that the S&G listed on page C-14, number 1, is the standard that defines the appropriate threshold for salvage activities.
“The potential for benefit to species associated with late-successional forest conditions from salvage is greatest when stand-replacing events are involved. Salvage in disturbed sites of less than 10 acres is not appropriate because small forest openings are an important component of old-growth forests.”
The Work Group concluded that proposals to salvage stands less than ten (10) acres in size within the burn perimeter would generally not be consistent with objectives for managing LSRs. Departures from this S&G would require a plan amendment.
Treatments to reduce risk, however, can be designed to meet site-specific objectives for risk management. The Record of Decision (C-15) recognized that there may be instances where departure from salvage S&Gs may be necessary to reduce future risk of fire or insect damage to late-successional conditions. In these situations, the ROD states “salvage to reduce such risks should focus only on those areas where there is a high risk of large-scale disturbance.”
2. Use of snag and coarse woody debris levels from South Cascades Late-Successional Reserve Assessment (LSRA) and potential modification for dry vegetation within areas with frequent wildfire histories and moderate to high risks
The Work Group concluded that if proposed amounts of standing dead and down wood proposed for retention in salvage units were estimated from the DECAID tool, then the proposed action would be consistent with objectives for managing LSRs. Alternatively, the District could submit for review, an LSRA amendment with standing dead and down wood amounts derived from local data.
3. Research deviation from standards and guidelines
The REO Research Monitoring Group (RMG) reviewed Attachment 2 (“Research Review Clarification”) to your memorandum of May 1, 2003. That attachment stated:
“… pending completion of the REO memo, we request written concurrence that under the NWFP: 1) authority to conduct the research assessment and exempt research as appropriate [r]ests with the appropriate agency official; 2) no REO/RMG/RMC review of proposed or new research activities is required under the NWFP; and 3) the agency official has discretion regarding how to conduct the assessment and documentation process.”
Since the REO memorandum clarifying NWFP provisions related to review and assessment of new research proposals was finalized on May 12, 2003, no advance concurrence is needed. Instead, the final memorandum is attached for your information. It includes findings that are consistent with your three statements (above), as well as other information that may be helpful during the assessment process.
4. South Cascade LSRA estimated maximum treatments and need for additional project review of proposed treatment levels
As per our letter dated February 10, 1998, your LSRA provides sufficient framework and context for decisions involving future projects and activities. The letter also noted that project plans would be fine-tuned through Watershed Analysis, NEPA, and other site-specific treatment determinations. Once the final proposed action for the Timbered Rock EIS has been submitted, the LSR work group will complete its review based upon the silvicultural, risk, and salvage activities described in Chapter 4 of the LSRA.
It appears that you and your staff have done a thorough job evaluating the potential impacts related to the proposed salvage and restoration activities. If you have any questions regarding the above conclusions, how to access the DECAID tool, or other related questions, please do not hesitate to contact Shawne Mohoric (503-808-2175).
Attachment:
cc:
Mary Smelcer, Acting District Manager, BLM Medford District Officer
Debbie Pietrzak, BLM, Regional Ecosystem Office Representative
Shawne Mohoric, LSR Work Group
Chair
1827/ShM