Thank you for the opportunity to review the Agnes Vegetative Fuels Reduction proposed project in the Fishhook/Galice Late-Successional reserve, Siskiyou National Forest. This proposal was reviewed by the Regional Ecosystem Office Late-Successional Reserve (LSR) workgroup, who concluded that the preferred alternative D, as described, was consistent with the objectives for managing LSRs under the Northwest Forest Plan. Additional review would be required if changes are made in the final decision that involve LSR silvicultural treatments not previously considered by the work group or in the LSR Assessment.

Background: On June 25, 2003, the Siskiyou National Forest presented a proposed fuels reduction project to the Regional Ecosystem Office Late-Successional Reserves (LSR) interagency work group for review.

Location and Project Area: The project is located on the Gold Beach Ranger District of the Siskiyou National Forest in southwestern Oregon, in the Fishhook/Galice Late-Successional Reserve, Oregon Klamath physiographic province. The planning area is adjacent to the northwest boundary of the Biscuit Fire of 2002. The project lies adjacent to a narrow residential corridor that extends nine miles along the Rogue and Illinois Rivers, and includes 114 structures. The area is known locally as Agnes, Illahe, and Oak Flat. The Siskiyou National Forest Wildfire Prevention Plan and Analysis of 1998 identified this area as having a high risk of fire ignition. The proposed units were selected as an accessible place to start treatment, with boundaries based on existing roads, streams, and ridgelines, for control of prescribed fire.

Objectives: This project has three objectives:

• Develop and maintain a defensible Wildland-Urban Interface protecting the residential area from high intensity fires originating in the LSR, and protecting the LSR from fires originating in the residential area.
• Reintroduce fire as an ecological disturbance process in the ecosystem.
• Maintain and restore unique habitats including the savanna and oak woodland habitats (identified as unique in the LSR assessment), as well as, the black oak habitat (identified by the interdisciplinary team during project analysis). Information regarding the value of these habitats, their present declining trend, and the desirability of maintaining and restoring the diversity they provide to the LSR can be found on page 81 of the LSR assessment.

Management Direction: The project implements the four primary goals of the National Fire Plan which are to:

• Improve fire prevention and suppression
• Reduce hazardous fuels
• Restore fire-adapted ecosystems
• Promote community assistance

The project design is in accordance with:

• Northwest Forest Plan (specific to Oregon Klamath Province, ROD, C-12)
• Southwestern Oregon LSR Assessment (10/95)
• Siskiyou National Forest Land and Resource Management Plan (1989)

Proposed treatments will:

• Reduce risk of stand replacing fire in mixed-conifer forest (ROD, C-12,13)
• Increase assurance of long-term habitat maintenance
• Maintain LSR effectiveness
• Improve conditions for wildlife and watershed (ROD, C-17)
• Benefit late-successional habitat and diversity
• Avoid adverse effects on late-successional associated species

The prescription for treatments would increase the amount of snags and coarse wood to levels consistent with both the LSR assessment and the DecAid tool. In order to achieve the objectives for fuels and unique habitats, while preserving structural diversity, some treatment of trees 20-34 inches d.b.h. (diameter at breast height) will be necessary.

Prescription Summary: The interdisciplinary team developed the following prescription proposal that would preferentially select for removal Douglas-fir that are competing with black oak:

Alternative D of the Agnes Vegetative Fuels Reduction Environmental Assessment describes this proposal in more detail and is attached for your information. If you have any questions, please contact Shawne Mohoric, Chair, LSR Work Group, (503) 808-2175.

cc: Rolando Mendez, Wildlife Biologist, Gold Beach
Connie Risley, Hydrologist, Gold Beach
REO Reps
LSR Workgroup

Alternative D consists of timber harvest and prescribed fire using a stand scale treatment approach. It also specifies a tree diameter range and quantifies the amount of tree removal within those ranges. For the purpose of determining appropriate silvicultural treatments, the vegetation in the project area was classified in three categories: non-forested prairie, hardwood-shrub ecotone, and mixed conifer-hardwood forest.

• Non-forested prairie: No trees would be removed from this area through timber harvest. Prescribed fire would be used to maintain these areas. Some small conifers would be killed through burning.
• Hardwood-shrub ecotone: This naturally low fuel type would be maintained and restored by cutting and removing conifers, primarily Douglas fir, less than 19 inches diameter. Trees in this diameter range are predominantly less than 110 years old, corresponding to the period of encroachment. Conifers less than 7 inches in diameter may be cut and left on site prior to burning. These may be piled and burned where needed to minimize damage to white oak, black oak, and large pine trees from the proposed underburn as well as future fires. At least 10 percent of the area would be seeded with native grasses.
• Mixed conifer-hardwood forest: The prescription in these areas would reduce the quantity of fuel, with an emphasis on removing vegetation that provides vertical and horizontal fuel connectivity. The prescription is also designed to reduce conifer competition with black oaks, and maintain late successional forest function. Conifers, primarily Douglas fir, less than 34 inches diameter would be removed.

Tree removal would be accomplished by means of a timber sale. Logs from these trees would be moved from the stands to existing roads by tractor, skyline, and helicopter equipment. No roads or temporary spurs would be constructed. Vegetative fuels generated during harvest would be treated to reduce the fuel loading in more densely vegetated areas. Approximately 275 acres are proposed for tree removal treatment (100 acres in the ecotone, 175 acres in the mixed conifer-hardwood forest), and approximately 3.6 million board feet of timber would be harvested.

Excessive slash remaining after harvest would be pulled away from the bases of oaks. The area would be underburned.

Following harvest, up to eleven of the remaining conifer trees per acre would be girdled to create snag habitat and large woody material. This would include conifers that could not be removed without damaging the oaks.

To prepare roadside areas to serve as containment lines for the application of prescribed fire and to reduce the potential for traffic-generated fire ignition and spread, small trees and brush within 150 feet of the road would be cut. Trees four to eight inches diameter would be pruned. These roadside treatments would include Riparian Reserve within 150 feet of the road.

Prescribed burning of natural fuels: Approximately 300 to 400 acres are proposed for treatment by prescribed burning only. No trees would be removed, regardless of vegetative condition. Of these acres, 150 are within the inventoried Roadless Area. The remaining 150 to 200 acres are precluded from tree removal in order to protect perennial Riparian Reserves, sensitive plants and animals, or other resources.