Appendix a North Nestucca Restoration Project Project Design

Appendix A

Appendix A North Nestucca Restoration Project Project Design Criteria Table of Contents Subject Page # Introduction 2 Project Design Criteria Applicable to All Action Alternatives 3 Thinning and Harvesting Actions - Silviculture 3 Thinning and Harvesting Actions / Wildlife 3 Thinning and Harvesting Actions / Coarse Woody Debris (CWD) 3 Thinning and Harvesting Actions / Botany 4 Thinning and Harvesting Actions / Streams and riparian vegetation 4 Thinning and Harvesting Actions / Fire and fuel management 5 Thinning and Harvesting Actions /Wildland-Urban Interface 7 System Roads Associated with Commercial Thinning 8 Wet Season Log Hauling (Generally October 16 through June 30) 8 Roads 8 Scenic Quality 9 Mitigation Common to All Alternatives 10 Proposed, Endangered, Threatened, or Sensitive Species (PETS), and Essential Fish Habitat 11 Fish 11 Wildlife 11 Specific to the Spotted Owl 13 Specific to the Marbled Murrelet 14 Commercial Thinning (in Critical Habitat) 15 Hazard Tree Removal (In Critical Habitat): 15 Sensitive Wildlife 17 Botany 20 Water Quality 21 Heritage Resources 21 Soils 22 Temporary roads and skyline landings 23 Post-harvest Mitigation Actions 24 Dead wood creation 24 Maintain or improve grass, forb, and shrub habitats 25 Planting and tending young trees in commercially thinned stands 25 Road Closure 25 Roadside maintenance adjacent to key forest roads 26

North Nestucca Environmental Assessment Page 1

Appendix A

Appendix A Table of Contents Subject Page # Monitoring Activities 26 Forest Plan Standards and Guides 27 Contract and Operations 27 Effectiveness Monitoring 27 Threatened and Endangered Species 27 Vegetation Management 27 Wildlife Habitat Treatments 28 Road Treatments 28 Heritage 28

Tables Page # Table A-1: Stream Buffer requirements 4 Table A-2: Fire & Fuels Road Treatments 6 Table A-3: Describes the breeding periods for the northern spotted owl and marbled murrelet 11 used in the analysis of project activities Table A-4: Disturbance/disruption distances for northern spotted owls during the breeding 14 period (March 1 – September 30). Table A-5: Disturbance/disruption distances for marbled murrelets during the breeding period 16 (April 1 – September 15). Table A-6: Seasonal and Daily Timing Restrictions for Thinning Units and Roads for Northern 17 Spotted Owls & Marbled Murrelets

Introduction Design criteria for actions identified in the North Nestucca Restoration Project EA (EA) were developed to ensure the project is consistent with the standards and guides of the 1990 Siuslaw Forest Land and Resource Management Plan (SLRMP), as amended by the 1994 Northwest Forest Plan (NFP). Other requirements were followed, including those described in consultation documents for federally listed species or designated critical habitat and those in the Late-Successional Reserve Assessment (LSRA) for Oregon’s Northern Coast Range Adaptive Management Area (USDA, USDI 1998). The objectives of this project are linked to the project needs identified in the EA, chapter 1: speed development of late successional forest habitat, improve habitat diversity, improve watershed function, and maintain key forest roads. The design criteria apply to all action alternatives, unless otherwise specified. Appropriate specialists will be consulted before any design criteria for proposed activities are changed. Forest Service direction, regulations, and standards and guides for resource protection may change over time. If changes occur prior to completion of any project actions, then the actions should be modified to reflect mandatory changes.

North Nestucca Environmental Assessment Page 2

Appendix A

Project Design Criteria Applicable to All Action Alternatives This section discusses criteria related to the design of treatments and actions (i.e., Project Design Criteria), applicable to all Action Alternatives. These criteria are to be employed during on the-ground project designation/implementation and are designed to address overall objectives (attain the Purpose and Need) and resource objectives and manage consequences (obtain compliance with Standards and Guidelines). Other criteria that manage consequences during actual operations are termed “mitigation measures” and are discussed later in this Appendix.

Thinning and Harvesting Actions - Silviculture

Wildlife • Leave a minimum of 10% untreated areas in each stand. This includes stream-adjacent buffers and in-operable areas. Untreated areas help to vary densities in and between stands, and they increase habitat diversity (LSRA p. I-9). • Three to 10 percent of the stand will be in gaps less than one acre in size. Gaps over ½ acre in size should not occupy more than five percent of the stand area (LSRA p. 100 and I-9) • Favor retention and release of species that comprise the minor component in stands, considering both hardwood and conifer species (LSRA p. I-9). • Retain and release the larger conifer and hardwood trees, conifer trees with relatively large limbs and cavities (LSRA p. 92, I-9) • Retain trees with defects, such as cavities, broken tops, or forks, especially the larger trees (LSRA p.92, I-9). • Retain trees with large nests (greater than 12” in diameter).

Coarse Woody Debris (CWD) • Retain the larger snags (where safely feasible) and down wood. • Protect existing snags larger than or equal to 20 inches in diameter at breast height (dbh) and ten percent of snags between nine and 20 inches in dbh (snag use will be greater in the size classes closer to 20 than to nine) where it will address safety, felling and yarding concerns. Retain any snags knocked over during project activities as down wood (LSRA p. 92).

Botany • Retain an average of at least 40 trees per acre in managed stands and minimize soil disturbance and compaction to maintain habitat for survey and manage and sensitive fungi species in the project area.

Streams and riparian vegetation • Hydrologist, Fish Biologist and Engineering staff will determine season of log haul for system and temporary roads. Minimize log hauling on roads during the wet-season (generally October 16

North Nestucca Environmental Assessment Page 3

Appendix A

to June 30), where such use could adversely affect water quality. • Implement protective vegetation leave areas or buffers around all streams, potentially unstable areas, and wet sites to maintain stream temperature, maintain stream-adjacent slope stability (including headwalls), and protect riparian vegetation. • Determine width of no-harvest buffers, based on site-specific factors such as flow regime (i.e., perennial, intermittent, or ephemeral), presence or absence of conifers, and slope-stability conditions. Buffers will at least include the inner gorge adjacent to streams and the active floodplain. The following table lists the minimum buffer widths for this project. Increase buffer widths where needed to avoid unstable areas (SLRMP: FW-087, -088, -089, -112).

Table A-1: Stream Buffer requirements Stream type Buffer Widths1 Containing or adjacent to coho Minimum 100 feet and minimum retention of first two rows of plantation salmon Critical Habitat conifers Minimum 75 feet from stream and minimum retention of first two rows of plantation conifers (includes debris-flow prone tributaries identified in-field Within 1000 feet upstream of coho by soils specialist and GIS analysis); or salmon Critical Habitat Where plantation conifers do NOT exist within 75 feet of channel, a minimum buffer of 75 feet and the first row of plantation conifer that is encountered upslope of the 75 foot buffer will not be removed. Minimum buffer of 30 feet where plantation conifers exist within 30 feet of channel, and two rows of plantation conifer will not be removed; or Containing or adjacent to other perennial streams Where plantation conifers do NOT exist within 30 feet of channel, a minimum buffer of 30 feet and the first row of plantation conifer that is encountered upslope of the 30 foot buffer will not be removed. Containing or adjacent to other At least 15 feet from intermittent streams and minimum retention of first intermittent streams single row of plantation conifers. 1Buffers will at least include the inner gorge adjacent to streams and the active floodplain.

• Debris flow-prone tributaries will be assessed in-field by appropriate. • Gaps will be at least 150 feet from coho Critical Habitat and 90 feet from all other stream channels. • Directionally fell trees away from buffers to protect riparian vegetation from damage. Retain trees accidentally felled into buffers to minimize stream sedimentation or damage to riparian vegetation. Some trees may be removed as determined by a fish biologist or hydrologist (SLRMP: FW-091). • Locate landings to minimize the need for skyline corridors through riparian buffers. Limit skyline corridors to 12 feet wide. Corridor width may appear wider in areas where trees adjacent to the corridor are cut to meet the silvicultural prescription. Where skyline corridors pass through riparian buffers, remove no more than 20 percent of the canopy in a given 1,000 feet of stream (SLRMP: FW-091).

North Nestucca Environmental Assessment Page 4

Appendix A

• Add aggregate to and/or reshape roads prior to log hauling, where needed, to ensure proper drainage and reduce potential impacts to streams. • Minimize blading of ditches, monitor roads during periods of heavy rain, and use straw bales to trap sediment, where necessary, to reduce stream sedimentation from aggregate-surfaced roads. • Where temporary roads will be open and unused over the winter, build waterbars, and place straw bales or use other erosion control measures to prevent stream sedimentation and excessive loss of the road surface. • Suspend log hauling when it is determined that active erosion control measures cannot prevent sediment from entering streams.. Include a hydrologist in making determinations about use of straw bales and suspension of log hauling.

Fire and fuel management • Any prescribed burning will require an approved burn plan that meets the parameters identified in FSM 5150. • Treat residual logging slash within 25 feet of county roads and key forest roads to reduce the risk of human-caused fire. Treatment may include piling, scattering, hauling, directional felling, chipping or mastication. Units and roads that will require treatment are listed in the following table. Identify specific areas in the timber sale contract or on implementation maps.

North Nestucca Environmental Assessment Page 5

Appendix A

Table A-2 - Fire& Fuels Road treatments Unit Road 302016 8170 302017 8170 302023 8170 302024 8170 302025 TIL-857 302028 8170 302031 8170 302035 8170 302036 8170 302039 8172 302044 8172 302050 8172 302057 1106 302071 8377 302072 8377 302073 8377 302074 8377 302075 8377 302076 8300 302077 8377 302090 1004 302092 8377 302094 1004 302096 1004 302103 8376 302106 1004 302115 8376 302116 8300 302124 8376 302127 1034 302131 1034 302135 1034 302136 1034 302140 1034 302149 1034 302271 1500 302331 1533 302333 1533 302364 1500

• If scattering of landing slash will not adequately address the fire hazard, pile and burn landing slash within 25 feet of open-system roads. Seed burned areas with native,

North Nestucca Environmental Assessment Page 6

Appendix A

certified weed-free seed, if the landing is larger than 1/5 acre (about 95’ X 95’) and have a native (non-rock) surface. • To reduce the potential for wildfire, do not create down wood within 50 feet of county and key forest roads unless the tops are kept outside. Identify specific roads in the timber- sale contract or on implementation plan maps.

Wildland-Urban Interface If there are any structures within 300 feet of stand boundaries, defensible space will be created to reduce the risk of wildfire. At this time, there are no such structures identified in the Project Area. Units 94, 200, and 247 are adjacent to private property boundaries and will need to be assessed for any defensible space needs at time of implementation.

• Treat areas within 300 feet of structures to reduce fire risk. Thin stand density to an average 70 trees per acre or lower to allow for underburning or for hand-pile burning and to reduce the risk of a running crown fire. Wider spacing in stands permits heat to escape, minimizing crown damage and creating a fuel break that will not easily support a running crown fire. Based on past results, no more than 10 percent of the residual trees will be damaged by fire. Count damaged trees towards meeting the down woody debris requirement. Treat residual logging slash so that ground fuels are 10 tons per acre or less. Treatment can include handpile and burn, underburning, hauling, directional felling, chipping or mastication. Consider whole-tree yarding and slash disposal on landings to potentially eliminate the need additional slash treatment.

Wildland Urban Interface treatment areas Total Unit Location Between (Lat/Long) Remarks Structures Westside of unit on a 45° 11'1.073"N by 123° 53'33.249"W AND 302333 8 North to South line that 45° 11'3.128"N by 123° 53'43.348"W runs 1300 feet.

1. Units that are adjacent to private land but have no structures at this time will be re- evaluated for structures during the BD appraisal. These stands are listed below: 301002, 302013, 302020, 302025, 302029, 302052, 302053, 302054, 302057, 302061, 302067, 302069, 302070, 302073, 302077, 302080, 302094, 302096, 302106, 302109, 302116, 302117, 302121, 302125, 302127, 302129, 302131, 302135, 302136, 302140, 302165, 302233, 302271, 302331, 303001, 303003.

North Nestucca Environmental Assessment Page 7

Appendix A

System Roads Associated with Commercial Thinning

Wet Season Log Hauling (Generally October 16 through June 30) • When selecting key and non-key roads for potential log haul during the wet season, consider the length of the collector road, slope position and aspect of the road, road condition, and projected cost for additional rock to support wet-season operations. Preferred candidates for wet-season haul include short, stable ridgetop roads or roads not located on north aspects. Refer to the project Transportation Plan for additional information. • Include non-key roads—expected for use as part of wet-season haul routes—in the timber-sale contract’s specified road reconstruction provisions, if any reconstruction is needed. If no reconstruction is planned, specify dry-season, pre-haul maintenance. Specify road reconditioning, removal of accumulated surface organics, brushing, cleaning culvert inlets, removing slide and slough material, and removal of down trees to open roads. Level existing waterbars, replace failing ditch-relief culverts, and apply needed surfacing materials (if needed). • During wet-season haul, limit potential sedimentation of streams by using standard erosion control methods such as filter cloth, diverting sediment onto stable, naturally vegetated slopes, or using catch basins to allow settling out of suspended sediment. Where necessary, install culverts or create ditches to disconnect water flow in ditches from streams. Use the guidelines in the Siuslaw Road Rules (2011-DRAFT) to suspend log hauling when ground conditions will result in unacceptable road or resource impacts.

Roads • Use the Forest Roads Analysis to determine the need for long-term access on system roads. • Repair and maintain key roads that will be used as haul routes. Limit repair and maintenance work to what is needed to make the haul routes stable and safe for a mix of commercial and public use. Design actions to improve the structural strength and stability of roads, improve drainage of road surfaces, and resurface roads where needed. Actions include replacing inadequate or failing ditch-relief culverts, repairing surface patching on asphalt roads, repairing structural patches on failing road fills, resurfacing roads with either gravel or asphalt, and seeding of exposed soils. • Consider retention and repair of asphalt segments near or adjacent to fish habitat and those asphalt segments that connect to existing paved access roads administered by other road management agencies. • Consider conversion from asphalt to gravel surfacing where it is economically more beneficial in the long term than repairing failed asphalt surfacing and sub grade (e.g., where individual asphalt segments are isolated from other asphalt roads). Asphalt to gravel conversion should only occur where it would not adversely affect fish habitat (e.g., locations with few or no live stream crossings), and where it maintains or restores the objectives of the aquatic conservation strategy. • Stabilize and close roads not needed for continuous access.

North Nestucca Environmental Assessment Page 8

Appendix A

• Where needed for project access, temporarily reopen closed roads. • Clean road ditches in a manner to minimize sediment erosion from the ditch. Ditch cleaning will be implemented during the dry season only. Maintain as much vegetation as possible in the ditch to trap fine sediments and prevent it from being transported to stream channels. • Use high quality rock near stream crossings, particularly streams important to coho, to reduce erosion from roads. • Where water bars are temporarily removed from project-maintained roads to facilitate harvest operations, add rock if needed at these sites to maintain a hardened road surface and reduce the potential for erosion. • Minimize down-stream movement of sediment from culvert replacement sites, prior to and during construction, by isolating sites that have surface flow. • Replace water bars, remove temporary culverts, and close project-maintained roads when the project is completed. Follow the Water Bar Placement Guide for Siuslaw Forest Roads. • Locate road drainage (cross drains) in areas that will not discharge over unstable slopes. If unstable roads are to be used, stabilize them prior to their use. • Purchasers will replace closure devices that were removed for harvest operations. Appropriate closure devices generally include earthen mounds or large boulders. These requirements will be included in the timber-sale contract or waived if they do not apply. • Locate and design road-closure devices to ensure effectiveness and to facilitate parking for dispersed recreation use. • Danger Trees along roadsides will be identified, assessed, and treated according to the Forest Service Pacific Northwest Region (Region 6) policy as detailed in FSM 7733, R6/PNW Supplement No. 7730-2007- 2, June 8, 2007. Any trees over 18" in diameter that need to be felled for safety reasons will be reported to the unit wildlife biologist in the event that emergency consultation is required.

Scenic Quality • The goal for all work is to enhance and protect the natural scenic qualities of North Nestucca - the coast range foothills, the valley edges, the creek and river corridors, the settings of small coast towns. • Wherever possible, contour waste piles, fill disposal, and grade road entrances and points along roads to blend with the surrounding topography. Continue patterns of topography and drainage patterns from above to below roads. • Avoid creating a smooth continuous slope. Generally aim for a rolling, natural grade. Create small shelves in continuous grades to allow native vegetation to establish. Grade to continue surrounding natural grade, and to meet surrounding natural grade. • Site landings to involve minimal impact on natural vegetation and grade, and continue natural patterns of topography and drainage from above to below the landing site as much as possible with other considerations.

North Nestucca Environmental Assessment Page 9

Appendix A

• Obliterate landings wherever possible. Recontour to blend with surrounding topography, and to continue natural patterns of topography and drainage across the old landing site as much as possible.

Mitigation Common to All Alternatives ______The Forest Service is required by the Council on Environmental Quality (CEQ) Regulations to implement the procedural provisions of NEPA to identify all relevant, reasonable mitigation measures that could improve the project or reduce adverse environmental effects. Mitigation, as defined in the CEQ Regulations (40 CFR 1508.20), includes:

• Avoiding the impact altogether by not taking a certain action or parts of an action. • Minimizing impacts by limiting the degree or magnitude of the action and its implementation. • Rectifying or eliminating the impact over time by preservation and maintenance operations during the life of the actions. • Compensating for the impact by replacing or providing substitute resources or environments. • Rectifying the impact by repairing, rehabilitating, or restoring the affected environment.

The Action Alternative proposes commercial tree harvest and removal that would be accomplished by private contractors. Contracts for commercial harvest operations would require mitigation measures to be incorporated as contract requirements. Forest Service contract officers are responsible for enforcing the implementation of contract provisions.

Proposed mitigation measures and standard operating procedures designed to avoid or minimize adverse effects (or implement positive effects) for the Action Alternative are identified by resource topic area. These measured are specific to implementation of actions considered within this EA. Standards and Guidelines and mitigation measures identified in the Siuslaw National Forest Land and Resource Management Plan as amended by the Northwest Forest Plan are incorporated by reference as required measures.

Proposed, Endangered, Threatened, or Sensitive Species (PETS), and Essential Fish Habitat

Fish • The project has been designed with appropriate Design Criteria so that there will be no impacts to ESA listed species (including Critical Habitat) or to essential fish habitat (EFH). Table A-1 contains the specific criteria. • Proposals to modify stream crossings from hard (e.g., pavement) to soft (e.g., aggregate) will require an evaluation by aquatic specialists to determine if the modification changes the level of

North Nestucca Environmental Assessment Page 10

Appendix A

effect on aquatic resources. The evaluation will include a determination that the proposed changes do not retard or prevent attainment of Aquatic Conservation Strategy objectives.

Wildlife Project activities must include the most current requirements from the US Fish and Wildlife Service (FWS) for federally listed wildlife. These requirements are described in a biological assessment (BA) and corresponding letter of concurrence (LOC) for either habitat modification (Habitat Modification FY 2011- 2012; FWS reference: 13420-2010-I-0105) or disturbance (Disturbance FY 2010-2013; FWS reference 13420-2009-I-0152). The programmatic Oregon and Washington BA, biological opinion and LOC (FWS Reference 13420-2007-F-0055) describe the aquatic and riparian restoration activities and practices that have been consulted on. The following is a summary of the most relevant (but not all) criteria from the current habitat modification and disturbance BA’s and LOC’s (Habitat Modification BA and LOC 2011-2012; Disturbance BA and LOC 2010-2013). The proposed action includes all field processes needed to plan, evaluate, prepare and complete activities regardless of funding source(s), as well as activities conducted on private lands under the Wyden Authority. Such processes include, but are not limited to: road construction; falling,-bucking and yarding; loading; hauling; site preparation; burning; brushing; piling; scarification; planting; and coarse woody debris and snag creation. A wildlife biologist will participate in the planning and design of all projects affecting listed species.

Table A-3 describes the breeding periods for the northern spotted owl and marbled murrelet used in the analysis of project activities.

CRITICAL BREEDING SPECIES BREEDING PERIOD PERIOD

Northern Spotted Owl March 1 – September 30 March 1 – July 7

Marbled Murrelet April 1 – September 15 April 1 – August 5

• For northern spotted owls, burning within the disruption distance of an occupied nest or predicted nest patch between March 1 and July 7 is prohibited. If the current nest tree is not known, the disruption distance will be measured from the edge of a 300 meter buffer (nest patch) around the known or predictive site. For marbled murrelets, burning within the disruption distance of occupied or unsurveyed suitable habitat, or unsurveyed potential nesting structure, between April 1 and August 5 prohibited. • No blasting would occur during these species’ entire breeding period (Table A-3) as part of any proposed activity. North Nestucca Environmental Assessment Page 11

Appendix A

• Use of ICS Type I helicopters within the disruption distance of owl occupied nest locations or predicted nest patches during the breeding period (March 1 – September 30) is prohibited. If the current nest tree is not known, the disruption distance will be measured from the edge of a 300 meter buffer (nest patch) around the known or predictive site. Use of ICS Type I helicopters within the disruption distance of occupied murrelet habitat, unsurveyed suitable murrelet habitat, and unsurveyed murrelet potential structure during the entire breeding period (April 1- September 15) is prohibited. • Use of ICS Type II, III, or IV helicopters within the disruption distance of owl occupied nest locations or predicted nest patches during the critical breeding period (March 1 – July 7) is prohibited. If the current nest tree is not known, the disruption distance will be measured from the edge of a 300 meter buffer (nest patch) around the known or predictive site. Use of ICS Type II, III, IV helicopters within the disruption distance of occupied murrelet habitat, unsurveyed suitable murrelet habitat, and unsurveyed murrelet potential structure during the critical breeding period (April 1- August 5) is prohibited. • Individual Tree Removal does not include the removal of (1) individual trees with owl or murrelet nesting structure from areas where, in the opinion of the unit biologists, the loss of such a tree would limit nesting by owls or murrelets, or (2) known spotted owl nest trees or murrelet nest trees from occupied murrelet habitat. A known spotted owl nest tree or a murrelet nest tree from occupied murrelet habitat may be removed only when it is an immediate danger and when the tree is not currently being used by nesting owls or murrelets or their young and will be covered under a separate consultation. • To minimize the risk of attracting predators to activity areas, all garbage (especially food products) would be contained or removed daily from the vicinity of any activity. • Any treatments in suitable habitat will maintain suitable habitat functionality. Any treatments in Critical Habitat will maintain current habitat functionality. • No new permanent roads will be built in critical habitat. Any treatments in critical habitat will maintain pre-treatment habitat functionality at the stand scale. • Although actions might extend into the next time period(s) within a given year, no actions may occur in a more restrictive time period. For example, an activity slated to begin during the July 8 - August 5 time period may extend into the August 6 - September 30 time period, or even the October 1 - February 28 time period, because the potential level of effect would be the same or less. For this example, actions may not ever occur between March 1 and July 7, because the potential level of effect might be greater.

Specific to the Spotted Owl • No activity will occur within the disruption distance (Table A-4) for that activity from a known or predicted nest site. If current nest tree is not known, disruption distance will be measured from the edge of a 300 meter buffer (nest patch) around the known or predictive site. Disruption distances

North Nestucca Environmental Assessment Page 12

Appendix A

have both a spatial and temporal component. No harvest treatment within a known nest patch or predicted nest patch is addressed by this assessment.

North Nestucca Environmental Assessment Page 13

Appendix A

Table A-4 - Disturbance/disruption distances for northern spotted owls during the breeding period (March 1 – September 30). DISRUPTION DISTURBANCE DISRUPTION DISTANCES DISTANCES DURING DISTANCES DURING DURING THE CRITICAL DISTURBANCE SOURCE THE LATE BREEDING THE BREEDING PERIOD BREEDING PERIOD PERIOD (MAR 1 – SEP 30) (MAR 1 – JUL 7) (JUL 8 – SEP 30) Road brushing and 440 yards (0.25 mile) 0 yards 0 yards maintenance on all roads Hauling on open roads 0 yards 0 yards 0 yards Use of chainsaws 440 yards (0.25 mile) 65 yards 0 yards Heavy equipment 440 yards (0.25 mile) 35 yards 0 yards Tree climbing 440 yards (0.25 mile) 35 yards 0 yards Burning 440 yards (0.25 mile) 440 yards (0.25 mile) 0 yards 2 Use of Type I helicopter 880 yards (0.5 mile) 440 yards (0.25 mile) 440 yards (0.25 mile) Use of Type II, III or IV 3 440 yards (0.25 mile) 120 yards 0 yards helicopter Use of fixed-wing aircraft 440 yards (0.25 mile) 120 yards 0 yards Pile driving 440 yards (0.25 mile) 60 yards 0 yards Rock crushing 440 yards (0.25 mile) 180 yards 0 yards 1 Noise disturbance distances were developed from a threshold of 92 dB (USFWS 2003a). Smoke disturbance distances are based on a FWS white paper (USFWS 2008b).

2 Type I helicopters seat at least 16 people and have a minimum capacity of 5,000 lbs. Both a CH-47 (Chinook) and UH-60 (Blackhawk) are Type I helicopters. Kmax helicopters are considered “other” for the purposes of disturbance. Sound readings from Kmax helicopter logging on the Olympic NF registered 86 dB at 150 yards (Piper 2006).

3 All other helicopters (including Kmax).

Specific to the Marbled Murrelet Project activities (including associated road construction, site burning and other disturbances) would not take place within the disruption distance (Table A-5) of a known occupied marbled murrelet stand during the critical nesting season. The unit wildlife biologist may increase the distance or modify the timing based on site-specific information. See Table A-6 for a list of units and roads where restrictions apply. Activities associated with projects (including associated road construction) within the disruption distance of known occupied or unsurveyed suitable murrelet habitat, or potential nesting structure, and implemented between April 1 and September 15 would not begin until 2 hours after sunrise and would end 2 hours before sunset except when compliant with Option 3 of the Level 2 March 26, 2004 policy for the management of potential nesting structure. See Table A-6 for a list of units and roads where restrictions apply.

North Nestucca Environmental Assessment Page 14

Appendix A

In units which contain trees with potential murrelet nesting structure the unit wildlife biologist will be involved to insure that the potential nest structure is managed in accordance with options 2 or 3 of the Level 2 policy for the management of potential nesting structure. ln thinning and individual tree removal actions that may affect the Critical Habitat of the marbled murrelet will comply with the standards of the May 13, 1997 biological opinion (USDI 1997a). For the North Nestucca Restoration Project, the following design criteria from the 1997 BO apply:

Commercial Thinning (in Critical Habitat) • No suitable marbled murrelet nest trees will be removed (individual trees with at least one potential nesting platform). The unit wildlife biologist will make the determination of whether a tree is considered a suitable nest tree. • Suitable nest trees will be protected by designing prescriptions for forest stands surrounding them (within 0.5 mile) that: a. provide protection from potential windthrow; b. require no openings within one tree length surrounding a potential nest tree; c. ensure no damage to any potential nest tree limbs Hazard Tree Removal (In Critical Habitat): Note that all Hazard Trees (Danger Trees) along roadsides will be identified, assessed, and treated according to the Forest Service Pacific Northwest Region (Region 6) policy as detailed in FSM 7733, R6/PNW Supplement No. 7730-2007-2, June 8, 2007. • Remove only trees that represent an immediate danger, defined as trees with a risk factor of 7 or 8 in Long Range Planning for Developed Sites in the Pacific Northwest: The Context of Hazard Tree Management (Harvey and Hessburg 1992). • Consider both safety and biological significance when identifying hazard trees. • Consider topping, limbing or other measures to conserve potentially valuable marbled murrelet nest trees. • Unsurveyed potential murrelet nest trees are not allowed to be removed within the breeding season.

North Nestucca Environmental Assessment Page 15

Appendix A Table A-5. Disturbance/disruption distances for marbled murrelets during the breeding period (April 1 – September 15).

DISRUPTION DISTANCES WITH DISRUPTION DISTANCES DURING THE DAILY TIMING RESTRICTIONS *, BREEDING PERIOD unless noted otherwise DISTURBANCE DISTANCES (APR 1 – SEP 15) DURING THE BREEDING (AUG 6 – SEP 15) DISTURBANCE SOURCE PERIOD Standard 17 Prohibits disruption to Occupied Habitat (APR 1 – SEP 15) Standard 18 requires daily timing restrictions* during the entire breeding period, when adjacent to suitable habitat and potential nesting structure unless in compliance with the Level 2 March 26, 2004 Policy, option 3. Road brushing & maintenance on 0 yards 0 yards 440 yards (0.25 mile) well-traveled roads with no daily timing restrictions with no daily timing restrictions 0 yards 0 yards Log hauling on all open roads 440 yards (0.25 mile) with no daily timing restrictions with no daily timing restrictions Road brushing & maintenance on 440 yards (0.25 mile) 100 yards 0 yards less-traveled roads Road repair such as culvert 440 yards (0.25 mile) 100 yards 0 yards replacement Use of chainsaws 440 yards (0.25 mile) 100 yards 0 yards Tree climbing 440 yards (0.25 mile) 100 yards 0 yards Use of heavy equipment 440 yards (0.25 mile) 100 yards 0 yards Burning 440 yards (0.25 mile) 440 yards (0.25 mile) 0 yards 2 Use of a Type I helicopter 880 yards (0.5 mile) 440 yards (0.25 mile) 440 yards (0.25 mile) Use of a Type II, III or IV helicopter 3 440 yards (0.25 mile) 120 yards 0 yards

Use of fixed-wing aircraft 440 yards (0.25 mile) 120 yards 0 yards Pile driving 440 yards (0.25 mile) 100 yards 0 yards Rock crushing 440 yards (0.25 mile) 180 yards 0 yards

* Daily timing restrictions: Activities would not begin until 2 hours after sunrise and would end 2 hours before sunset. 1 Noise disturbance distances were developed from a threshold of 92 dB (USFWS 2003a). Smoke disturbance distances are based on a FWS white paper (USFWS 2008b). Visual/predation disturbance distances for marbled murrelets are based on a FWS white paper (USFWS 2003b). 2 Type I helicopters seat at least 16 people and have a minimum capacity of 5,000 lbs. Both a CH-47 (Chinook) and UH-60 (Blackhawk) are Type I helicopters. Kmax helicopters are considered “other” for the purposes of disturbance. Sound readings from Kmax helicopter logging on the Olympic NF registered 86 dB at 150 yards (Piper 2006). 3 All other helicopters (including Kmax).

North Nestucca Environmental Assessment Page 16

Appendix A

Sensitive Wildlife The following information is from Region 6 Bald Eagle Policy Following Delisting and During the Five- Year Monitoring Period:

• No project or associated activities would be implemented between January 1 and August 31 within 0.25 mile or a 0.5-mile sight distance of a known bald eagle nest site, unless the unit biologist verifies that the nest is unoccupied. • No activity within 0.25 mile or a 0.5-mile sight distance of a bald eagle winter roost shall be implemented between October 15 and April 15 unless the roost is verified to be unoccupied by the unit wildlife biologist.

Table A-6 displays the list of thinning units and roads for which seasonal or timing restrictions apply. These restrictions may apply to all or a portion of the unit or road shown. The unit wildlife biologist is responsible for providing the information on specific areas where the restrictions apply prior to project implementation.

Table A-6 - Seasonal and Daily Timing Restrictions for Thinning Units and Roads for Northern Spotted Owls & Marbled Murrelets

Units or Roads with seasonal or Daily Timing Restrictions Apply Operating Season Timing Restrictions (4/1 – 9/15) Units 301002 8/6-3/31 Yes 302007 8/6-3/31 Yes 302013 3/1-2/28 Yes 302016 8/6-3/31 Yes 302017 8/6-3/31 Yes 302018 8/6-3/31 Yes 302020 3/1-2/28 Yes 302022 8/6-3/31 Yes 302023 8/6-3/31 Yes 302024 8/6-3/31 Yes 302025 8/6-3/31 Yes 302026 3/1-2/28 No 302028 8/6-3/31 Yes 302029 3/1-2/28 Yes 302031 8/6-3/31 Yes 302032 3/1-2/28 Yes 302033 3/1-2/28 Yes 302035 3/1-2/28 Yes 302036 8/6-3/31 Yes

North Nestucca Environmental Assessment Page 17

Appendix A

Units or Roads with seasonal or Daily Timing Restrictions Apply Operating Season Timing Restrictions (4/1 – 9/15) 302039 3/1-2/28 Yes 302041 8/6-3/31 Yes 302044 8/6-3/31 Yes 302046 8/6-3/31 Yes 302050 8/6-3/31 Yes 302052 3/1-2/28 No 302053 8/6-3/31 Yes 302054 3/1-2/28 Yes 302057 3/1-2/28 Yes 302058 3/1-2/28 Yes 302060 3/1-2/28 Yes 302061 3/1-2/28 No 302067 8/6-3/31 Yes 302069 8/6-3/31 Yes 302070 3/1-2/28 Yes 302071 8/6-3/31 Yes 302072 3/1-2/28 Yes 302073 8/6-3/31 Yes 302074 8/6-3/31 Yes 302075 3/1-2/28 Yes 302076 3/1-2/28 Yes 302077 8/6-3/31 Yes 302078 8/6-3/31 Yes 302080 8/6-3/31 Yes 302084 8/6-3/31 Yes 302085 8/6-3/31 Yes 302088 8/6-3/31 Yes 302090 8/6-3/31 Yes 302092 3/1-2/28 Yes 302094 8/6-3/31 Yes 302096 8/6-3/31 Yes 302097 8/6-3/31 Yes 302100 8/6-3/31 Yes 302101 8/6-3/31 Yes 302103 3/1-2/28 Yes 302106 8/6-3/31 Yes 302109 8/6-3/31 Yes 302112 8/6-3/31 Yes 302115 3/1-2/28 Yes 302116 3/1-2/28 Yes 302117 8/6-3/31 Yes North Nestucca Environmental Assessment Page 18

Appendix A

Units or Roads with seasonal or Daily Timing Restrictions Apply Operating Season Timing Restrictions (4/1 – 9/15) 302118 8/6-3/31 Yes 302121 3/1-2/28 Yes 302123 3/1-2/28 Yes 302124 3/1-2/28 Yes 302125 8/6-3/31 Yes 302126 3/1-2/28 Yes 302127 8/6-3/31 Yes 302129 3/1-2/28 Yes 302131 8/6-3/31 Yes 302132 3/1-2/28 Yes 302134 3/1-2/28 Yes 302135 8/6-3/31 Yes 302136 8/6-3/31 Yes 302140 8/6-3/31 Yes 302142 8/6-3/31 Yes 302149 8/6-3/31 Yes 302164 3/1-2/28 Yes 302165 3/1-2/28 Yes 302166 3/1-2/28 Yes 302180 7/8 - 2/28 Yes 302184 3/1-2/28 Yes 302208 3/1-2/28 Yes 302209 3/1-2/28 Yes 302233 3/1-2/28 Yes 302271 3/1-2/28 Yes 302331 3/1-2/28 Yes 302333 3/1-2/28 Yes 302359 3/1-2/28 Yes 302364 8/6-3/31 Yes 302367 8/6-3/31 Yes 303001 3/1-2/28 Yes 303003 3/1-2/28 Yes Roads 1400000 ANYTIME 1400148 ANYTIME No 1400148 ANYTIME Yes on portions * 1400150 ANYTIME No 1400133 ANYTIME Yes 1400144 ANYTIME Yes 1400145 ANYTIME Yes 1404000 ANYTIME Yes

North Nestucca Environmental Assessment Page 19

Appendix A

Units or Roads with seasonal or Daily Timing Restrictions Apply Operating Season Timing Restrictions (4/1 – 9/15) 1404111 ANYTIME Yes 1404112 ANYTIME Yes 1404113 ANYTIME Yes 1404114 ANYTIME Yes 8530000 ANYTIME Yes on portions * 8530123 ANYTIME No 8530124 ANYTIME Yes 8533000 ANYTIME Yes 8533111 ANYTIME Yes 8533114 ANYTIME Yes on portions * 8533115 ANYTIME Yes on portions * 8533116 ANYTIME Yes 8533117 ANYTIME Yes 8533119 ANYTIME Yes 8533120 ANYTIME Yes 8533126 ANYTIME Yes 8593000 ANYTIME Yes 8594000 7/8 - 2/28 on portions Yes 8594111 7/8 - 2/28 on portions Yes 8594115 ANYTIME Yes 8594118 ANYTIME Yes 8594119 7/8 - 2/28 Yes 8595000 ANYTIME No 8595111 (?) 8/6 - 3/31 on portions Yes 8595119 (?) 8/6 - 3/31 on portions Yes 8598000 ANYTIME No 8598111 ANYTIME No 8598116 ANYTIME No *Check with the District Wildlife Biologist for specific locations.

Botany • In stand 30223, do not cut any trees greater than 25 inches diameter breast height in order to protect habitat for the checker-mallow.

Invasive Plant Prevention and Management: • Treat units and roads identified as having English holly, cherry laurel, English ivy, Scotch broom, and blackberry prior to project implementation by manually pulling or mechanically cutting. • Seed new temporary construction and landings with a mix of certified weed-free native blue wild rye and Alaska brome grass seed.

North Nestucca Environmental Assessment Page 20

Appendix A

• Whenever possible, maintain native surfaces on temporary roads rather than using imported rock. • All heavy equipment (excluding passenger vehicles) shall be clean and free of soil, vegetative matter, or other debris that may contain or hold weed seeds prior to entering National Forest System lands (WO-B/BT 6.36). • Erosion control materials (seed, straw, hay) must be certified free of weed seed and plant parts. The USFS will provide certified native grass seed for site restoration.

• Inspect material sources (e.g., rock quarries or soil borrow sites) on site and ensure that they are weed-free before use and transport. Inspection will be provided at no cost by the Forest botanist or other FS personnel trained in weed identification.

Water Quality • Follow Siuslaw Plan standards and guides (FW-114 through FW-118) to meet water-quality standards outlined in the Clean Water Act for protecting Oregon waters, and apply practices as described in General Water Quality Best Management Practices, Pacific Northwest Region, November 1988, and National Best Management Practices for Water Quality Management on National Forest System Lands (2012). Design criteria, including these practices, are incorporated throughout the project, such as in project location, design, contract language, implementation, and monitoring. The State has agreed that compliance with these practices will ensure compliance with State Water Quality Standards (Forest Service Manual 1561.5, R-6 Supplement 1500-90- 12). • If the total oil or oil products storage at a work site exceeds 1,320 gallons, or if a single container (e.g., fuel truck or trailer) exceeds a capacity of 660 gallons, the purchaser shall prepare and implement a Spill Prevention Control and Countermeasures (SPCC) Plan. The SPCC plan will meet applicable EPA requirements (40 CFR 112), including certification by a registered professional engineer. (SLRMP: FW-119, 120, 122). • Suspend log hauling when it is determined that active erosion control measures cannot prevent sediment from entering streams.. Include a hydrologist in making determinations about use of straw bales and suspension of log hauling.

Heritage Resources • Changes to current unit configurations and/or addition of new project activities, like the establishment of new harvest landings, will require consultation with the Forest Archaeologist in order to protect known and unknown resources. • Should heritage resources be discovered as a result of any project activities, earth-disturbing activities must be suspended in the vicinity of the find, in accordance with federal regulations (NHPA and 36 CFR 800). The Forest Archaeologist must be notified to evaluate the discovery and recommend a subsequent course of action.

North Nestucca Environmental Assessment Page 21

Appendix A

• The Arthur Riggs Homestead site located within the project area during archaeological survey will be buffered from earth-disturbing activities. Contact the Forest Archaeologist for specific location information.

Soils • Yarding systems will be designated that meet all applicable standards and guides, that are economically viable, and that minimize soil disturbance. In some cases, skyline logging systems may be utilized as the primary method of log removal over less expensive systems, in order to reduce the development of the transportation system or to provide increased protection to other resources. Skyline logging that minimizes the amount of side-hill yarding or yarding through riparian buffers is preferred. Existing roads and landings should be utilized as much as possible. Limit the construction of new temporary roads as much as possible. • Ground-based equipment would be limited to the dry season (generally July 1 through October 15), unless otherwise restricted by other resource concerns or waived by Forest Service personnel and consistent with ESA consultation. With the use of ground-based yarding systems, always utilize existing skid roads and landings as much as possible. At the completion of harvest activities, spur roads, tractor skid roads or forwarder roads should be water barred and scarified, as is necessary. • Ground -based equipment are limited to side slopes less than 30 %. Ground-based skidding equipment shall stay on designated skid trails. Ground-based skid trails will be pre-designated and pre-approved before use. Existing skid roads should always be used before new skid road locations are approved. They should not usually exceed 15 feet in width, and the objective is to maintain a 10 to 12 foot width throughout the length. Where practical the skidder, cat, shovel or forwarder should travel on slash. Traveling on slash has been shown to reduce off site soil erosion or lessen soil compaction. Skid roads will at least be 100 feet apart with conventional line pulling operations, and 40 to 60 feet apart with processor / forwarder operations. • Where operable (when whole tree yarding is not utilized), harvested trees should be topped and limbed in the units in order to provide small limbs and needles for nutrient recycling. This objective has to be tempered with the need to reduce fuel loading to control potential wild fires, and to meet site specific standards for slash accumulation. This practice, coupled with limbs that normally break off during yarding, will serve to address soil nutrient, displacement, and erosion concerns. • Outside of areas designated for full-log suspension and lateral yarding, use one-end log suspension on all areas designated for cable yarding systems to reduce soil displacement and compaction (SLRMP: FW-107). In areas of gentle to moderate slope or broken terrain, small sections of ground lead may be acceptable along some skyline corridors (on a case-by-case basis). Cable corridor spacing should be set to both minimize damage to standing timber and the soil resource.

North Nestucca Environmental Assessment Page 22

Appendix A

• The reopening of temporary, unclassified roads should usually occur in the dry season, generally considered July 1 through October 15 to avoid surface erosion from exposed soil. These roads should be storm proofed if they are approved to remain open through extended periods of wet weather. Unclassified or temporary roads used outside the standard operating season, should generally be rocked, snow covered, or frozen to reduce the potential for erosion, unless other mitigating or extenuating circumstances are present. Where practical, at the completion of harvest activities, limbs and woody debris should be placed on areas of exposed soil to reduce the potential for off site soil erosion. • Trees, not designated for harvest in riparian buffers that need to be cut to facilitate harvest operations, should be dropped into the stream if possible to aid in woody debris recruitment. Avoid disturbance to the existing large down woody debris concentrations created by the initial entry as much as practical, especially with ground based operations. • As required by law and regulation, units should be designed to maintain long term slope stability. Depending on site specific conditions, actively unstable or potentially highly unstable areas may need to be protected from harvest operations with no-cut buffers. On the other hand, thinning or partial cuts on unstable areas may be considered if the harvest prescription reduces current stocking levels and improves the growth and vigor of the remaining trees, so that root strength and evapotranspiration rates are maintained or increased over the longer term.

Temporary roads and skyline landings • A team of appropriate resource specialists and sale administrators will review road sites before preparing road plans for timber-sale contracts. This group will review any changes in road plans before incorporating them into contracts. • Limit new temporary roads to stable ridges and benches to minimize soil disturbance. No new Forest classified (system) roads will be built. Where feasible, design the logging plan to minimize the need for new temporary roads (SLRMP: FW-162, 163). • If the horizontal alignment of temporarily reopened roads needs adjustment, favor the cut-bank side of the road prism to minimize disturbance to side-cast areas and established vegetation. • Scatter slash created through road building in the stands. • Use new temporary roads during the dry season (generally July 1 through October 15) whenever possible to avoid adding rock to native surfaces and to reduce costs. Identify these roads in the timber-sale contract. • Limit to dry season (generally July 1 through October 15), as much as possible, the use of the temporarily reopened non-system roads. This would minimize the need for additional rock and to reduce costs. If a road is to be used during the wet season (generally October 16 through June 30), surface with rock aggregate where needed. Surfacing depth should allow for log trucks using constant reduced tire pressures. • Spot rocking of wet sites that may be present on existing (or newly created) non-system roads used during the dry season (generally July 1 through October 15), should be limited to the

North Nestucca Environmental Assessment Page 23

Appendix A

improvement of structural strength in the low strength soil area only. Spot rocking should be limited to what is needed to reduce rutting or to provide additional traction for a safe driving surface. • If rock is needed for wet sites that may be present on existing non-system roads used during the dry season, limit rock to what is needed for traction, not structural strength. For the timber sale contract, identify existing non-system roads to be used during the dry season (generally July 1 through October 15). • To minimize sedimentation from roads, waterbar and close temporary roads between operating seasons or as soon as the need for the road ceases. • To reduce soil erosion, seed exposed soils with native, certified weed-free species; or spread landing slash over landing sites (unless tree planting is planned) and spur roads, especially those with native (non-rock) surfaces. This practice will be more cost effective than machine piling and burning of landing piles and will help stabilize disturbed soils. The district wildlife biologist or botanist will recommend certain native-surface roads for seeding. • Evaluate (include a hydrologist, soil scientist, or geologist) temporary roads used for timber removal, especially those used during the wet season (generally October 16 through June 30) to determine need for ripping. Identify roads to be ripped in the timber-sale contract if ripping is to be done by the timber-sale contractor • Build skyline-cable landings in stable areas with stable cut bank slopes. Use existing landings where feasible (SLRMP: FW-115, 117). • Purchasers will replace closure devices that were removed for harvest operations. Appropriate closure devices generally include earthen mounds or large boulders. These requirements will be included in the timber-sale contract or waived if they do not apply. Post-harvest Enhancement Actions With implementation of the North Nestucca Project, there may be an opportunity to improve various forest resource conditions in proximity to the proposed treatment activities. These opportunities are not necessary or critical for implementing the Proposed Action or Action Alternative, but may be considered a Post Harvest Enhancement Projects. Implementation of these projects is contingent on funding and may or may not occur. They may be financed through: collections generated via scheduled timber sale receipts from implementing the North Nestucca Project (i.e., Knutson-Vandenberg funds), Forest Service appropriated resource and restoration funding, or stewardship contract agreements. These other improvement projects (or activities) that may be associated with the Action Alternatives are described below. Potential resource impacts from the entire list of other project activities would be considered during future environmental analysis processes.

Dead wood creation • Create dead wood (cavity development, snags, and down wood) within and adjacent to plantations following prescriptions based on DecAID and the Late-Successional Reserve

North Nestucca Environmental Assessment Page 24

Appendix A

Assessment, for Oregon’s North Coast Adaptive Management Area (refer to Appendix B for additional information). • Retain un-thinned areas where existing deadwood will remain and where additional small dead wood will be recruited through tree mortality. • Do not create deadwood within 100 feet of any road or perennial stream. • Defer creating deadwood in harvested units until one or more years after harvest to allow for canopy recovery, where needed, and to allow for blow-down. At that time, monitor the canopy cover and deadwood levels created by windthrow before additional deadwood is created. Ensure canopy cover remains at or above 40 percent in thinned areas of units. Canopy gaps > ¼ acre are not used for this calculation. • Within plantations, include majority of deadwood in clumps, with at least one clump for each five acres. In general, maintain distance between larger clumps (>1/4 ac.) at 300 to 600 feet. • Use deadwood clumps to create gaps around dominant or co-dominant conifers, or hardwoods greater than 6” dbh. • Maintain an average clump size of ½ acre; do not exceed 1 acre: Clump Size Clump Radius ¼ ac. 60’ ½ ac. 85’ ¾ ac. 100’ 1 ac. 118’ • To reduce the potential for Douglas-fir bark beetle infestations, minimize felling more than 5 trees per acre for down wood during the period from May 1 through June 15 (adult beetle flight season). • All deadwood creation activities must comply with the requirements set forth in the current Biological Opinion(s) from the Fish and Wildlife Service for federally listed wildlife.

Maintain or improve grass, forb, and shrub habitats • Grass, forb, and shrub habitats have been declining in the Forest, including the planning area, for many years. Facilitate persistence of these components through planting gaps, yarding corridors, native surface temporary roads, de-compacted gravel roads or landings where soil types, slopes and aspect are appropriate. Plant with native grass and forb species seed, certified weed-free.

Planting and tending young trees in commercially thinned stands • See individual stand prescriptions for planting specifications. • Protect seedlings from excessive wildlife browsing with Vexar tubing, with the exception of Sitka spruce and western hemlock. • Implement manual-release treatments, if needed to reduce shrub competition around planted trees to aid their survival and establishment.

North Nestucca Environmental Assessment Page 25

Appendix A

Road Closure • Close roads needed for intermittent project access. Use closure devices such as earth berms, boulders, guardrail barricades, or gates, depending on access needs, length of road, and amount of time between project entries. Locate and design closure devices to be effective. • To the extent possible, defer road closures until harvest, post-harvest mitigation, and post-harvest enhancement actions are completed. • Planners and engineers will review the project sites before preparing design plans for road- closure contracts. Planners and engineers will review any changes in design plans before they are incorporated into contracts. • Implement road closure actions during the dry season (generally July 1 to October 15). • Design water bars to facilitate proper drainage of surface water and to prevent ponding. Place water bars in areas where drainage will not destabilize road fills. • To keep streams within their channels when culverts are obstructed, build water bars immediately above existing culverts to become the overflow point. Use the Waterbar Placement and Construction Guide for Siuslaw Forest Roads to determine water-bar spacing and design (SLRMP: FW-123). • Use an interdisciplinary process to determine new sites for waste material before contracts are advertised, and to review existing waste sites to determine need for redesign or relocation. Where feasible, avoid placing waste material in areas that would impact access to future projects. • Where applicable, seed disturbed sites with a native, certified weed-free seed mixture that includes species that will enhance wildlife forage.

Roadside maintenance adjacent to key forest roads Roadside maintenance includes actions that remove trees (conifer or hardwoods) from road prisms, and thin some plantations adjacent to key roads. The objectives are to prevent cutbank failure and reduce road maintenance costs caused by trees falling from cutbanks; and reduce shading and leaf litter on roads to improve drainage, reduce organic debris, and improve drying of road surfaces. Design criteria for these actions include: • Reestablish clearing limits in plantations from 10 feet above top of cut to 10 feet below top of fill. Commercial timber sales, firewood permits, or service contracts are appropriate tools for completing the work. • Maintain appropriate road drainage and erosion control during thinning and salvage operations. • Restrict harvest equipment to the road surface. Minimize soil disturbance when downhill yarding. Leave trees on site, where removal causes substantial damage to the road or road prism. Require one-end suspension of the leading end of logs, when yarding. Monitoring Activities Monitoring items include those required for implementation and effectiveness monitoring. Implementation monitoring determines if the project design criteria and Siuslaw Forest Plan standards

North Nestucca Environmental Assessment Page 26

Appendix A

and guides, as amended by the Northwest Forest Plan, were followed. Effectiveness monitoring evaluates whether applying the management activities achieved the desired goals, and if the objectives of the standards and guides were met. Findings resulting from project observations and monitoring are expected to help influence the design of future projects and development of future monitoring plans. .Implementation Monitoring

Forest Plan Standards and Guides

Before a contract is advertised, it will be reviewed for consistency with the standards and guides of both the Northwest and Siuslaw Plans, and project design criteria.

Contract and Operations • Involve appropriate specialists to ensure activities are implemented as designed, when developing timber sale, roadside salvage or thinning, road decommissioning and other projects. The appropriate specialists will also participate periodically during contract work, especially when unusual circumstances arise that may require a contract modification. • Identify key checkpoints to ensure that problem situations are addressed in the specifications. These checkpoints include a plan-in-hand review and a contract review of specifications before the next phase of work begins. • During thinning operations, monitor the consistency of the silvicultural prescriptions in achieving the desired leave-tree stocking, variable spacing, and species and structural diversity. This implementation monitoring is imperative in those stands that are being treated using "Designation by Description" or "Designation by Prescription" methods. With each of these methods, the number and type of leave trees have been specified contractually, but only boundary trees and gaps are physically designated on the ground.

Effectiveness Monitoring • Monitoring will be tiered to the Siuslaw Forest Plan. Involve the appropriate specialists in the various monitoring tasks identified below.

Threatened and Endangered Species • To show actual levels of effects to listed species, complete and submit project implementation and monitoring forms to the appropriate regulatory agency. Reports to the US Fish and Wildlife Service are prepared at the end of the calendar year and submitted by February 15.

Vegetation Management • Monitor thinning effectiveness in achieving the desired leave tree stocking, variable spacing, species diversity and structural diversity. Adjust post-thinning prescriptions for planting and dead

North Nestucca Environmental Assessment Page 27

Appendix A

wood creation, where necessary to enhance stand spacing variability, and structural and species diversity. • Monitor planting effectiveness in achieving survival. • Monitor created snags and wildlife trees by observing effects of treatments. Focus observations on the location and rate of decay, and use by cavity nesters. • Evaluate stands for existing snags and down wood within 5 years after the thinning treatment. Modify down wood and snag creation numbers, if necessary, to meet the snag, down wood, and wolf tree objectives. • Observe all thinned stands to determine if snags or down wood are being created by bark beetles, or other insects or diseases. • Evaluate riparian leave areas as to their effectiveness in maintaining stream shade. • For a period of five years after project activities are completed, monitor project sites that have a high risk of invasive plant infestation. Conduct monitoring annually and focus on effectiveness of invasive plant management as well as detection of new infestations. Refer to the botanist report for specific treatment areas and prescriptions.

Wildlife Habitat Treatments • Sample post-harvest canopy closures in stands with different residual trees per acre. The information will provide a more accurate picture of how canopies respond to thinning in the watershed, both short-term and long-term. • Sample all post-harvest densities to quantify cavity nester use of created snags. Sample stands at approximately 1, 3, 5 and 10 years after harvest for evidence of both cavity nesting and foraging.

Road Treatments • Review excavated slopes after road-stabilization activities and note areas where eroded materials enter stream channels. Eliminate or reduce erosion, if the surface is eroding and could adversely affect aquatic habitat. • Observe road surface treatments such as water bars to determine effectiveness and effects on the stability of the outer portion of the road prism.

Heritage

• Within one-year of commercial timber harvest or temporary road construction: a) Monitor all “high probability areas” for previously unidentified cultural resources. b) Monitor a sample of non-high probability areas for previously unidentified cultural resources. • Evaluate and document the effectiveness of the cultural resources survey design based on monitoring results in a report that is submitted to SHPO.

North Nestucca Environmental Assessment Page 28

North Nestucca EA Silviculture Data Appendix B - 1

Pre & Post Treatment Information Mean Tree Information Estimated Total Minimum # of Trees Midpoint Treatment Percent of Stand Year of Stand Size Harvest Harvest Area Not per Acre Elevation Area Stand Not Number Origin MBF/ Acre MBF/Unit Treated Number of Trees/Acre Quadratic Mean Diameter Age * QMD Height Treated

Years Inches Feet Trees/A Feet Acres Acres MBF/Acre MBF Acres Pre Post Pre Post 301002 1961 51 14.6 80 188 1,000 100 89 14 1,250 11 11 188 80 14.6 18.5 302007 1966 46 14.9 81 204 1,400 53 47 11 515 6 12 204 70 14.9 18.5 302013 1971 41 10.8 79 264 1,100 74 51 8 405 23 32 264 70 10.8 13.8 302016 1973 39 13.9 73 187 1,500 10 9 10 90 1 10 187 70 13.9 16.8 302017 1963 49 15.2 86 177 1,200 183 163 12 1,954 20 11 177 80 15.2 18.5 302018 1973 39 14.5 90 208 1,100 21 19 11 207 2 10 208 80 14.5 17.8 302020 1986 26 10.1 64 237 1,300 63 55 7 383 8 13 237 70 10.1 12.9 302022 1974 38 10.8 69 163 900 26 18 6 106 8 32 163 70 10.8 18 302023 1964 48 14.2 87 245 600 65 57 14 797 8 12 245 60 14.2 18 302024 1961 51 14.7 89 245 1,000 130 82 14 1,142 48 37 245 65 14.7 18.7 302025 1971 41 13 85 250 900 82 72 13 935 10 12 250 70 13 17.5 302026 1970 42 14.2 66 188 1,400 11 8 12 95 3 28 188 85 14.2 17.6 302028 1974 38 10.4 67 320 1,000 59 43 8 346 16 27 320 70 10.4 14.1 302029 1969 43 13.5 83 225 1,100 41 37 13 481 4 10 225 80 13.5 16.7 302031 1972 40 12.5 64 280 1,000 17 14 12 163 3 20 280 60 12.5 18 302032 1974 38 10 70 167 1,700 48 43 7 299 5 11 167 70 10 12 302033 1970 42 13.2 82 244 1,100 44 38 14 527 6 14 244 60 13.2 16.8 302035 1965 47 12.3 78 233 700 251 211 11 2,321 40 16 233 85 12.3 15.6 302036 1961 51 14.3 68 231 1,300 59 51 12 607 8 14 231 80 14.3 17.7 302039 1982 30 10.9 69 240 1,000 60 53 8 423 7 12 240 70 10.9 13.9 302041 1966 46 13.4 79 217 1,000 73 65 10 653 8 11 217 80 13.4 17 302044 1982 30 10.9 69 240 900 79 68 8 545 11 14 240 60 10.9 13.9 302046 1968 44 16.4 101 275 1,200 7 6 16 98 1 12 275 60 16.4 21.1 302050 1967 45 15.9 82 238 1,000 88 79 15 1,189 9 10 238 70 15.9 19.6 302052 1968 44 12.3 81 245 800 92 82 13 1,066 10 11 245 70 12.3 16.4 302053 1973 39 14.2 76 230 1,000 61 54 11 589 7 12 230 90 14.2 17.5 302054 1975 37 12.3 62 203 1,200 53 47 13 616 6 11 203 60 12.3 15.5

North Nestucca Environmental Assessment 1 North Nestucca EA Silviculture Data Appendix B - 1

Years Inches Feet Trees/A Feet Acres Acres MBF/Acre MBF Acres Pre Post Pre Post 302057 1977 35 13.6 76 371 600 52 39 10 393 13 24 371 90 13.6 19.1 302058 1979 33 11.8 76 247 600 213 188 9 1,690 25 12 247 70 11.8 14.9 302060 1970 42 10.8 87 264 700 149 133 8 1,061 16 11 264 60 10.8 15.4 302061 1961 51 14.7 84 234 800 137 122 15 1,833 15 11 234 60 14.7 20.3 302067 1980 32 11.5 73 241 600 69 62 9 561 7 10 241 70 11.5 14.6 302069 1965 47 13.9 93 310 900 93 83 10 829 10 11 310 90 13.9 17.1 302070 1985 27 10.3 66 238 800 144 130 8 1,038 14 10 238 70 10.3 13.1 302071 1981 31 11.7 78 216 1,000 56 48 9 435 8 14 216 60 11.7 14.2 302072 1985 27 10.3 66 238 1,700 37 32 8 253 5 14 238 60 10.3 13.1 302073 1967 45 14.5 86 206 900 66 56 15 846 10 15 206 70 14.5 18.9 302074 1961 51 15 74 300 1,800 63 53 16 850 10 16 300 60 15 21 302075 1985 27 10.4 71 267 1,600 47 42 8 333 5 11 267 60 10.4 12.5 302076 1986 26 10.1 64 237 1,800 47 42 8 333 5 11 237 70 10.1 12.9 302077 1981 31 11.3 73 200 1,400 64 53 9 477 11 17 200 60 11.3 13.3 302078 1959 53 14.2 82 193 1,000 21 18 15 270 3 14 193 60 14.2 17.9 302080 1969 43 13.1 93 252 500 46 40 10 400 6 13 252 90 13.1 16.4 302084 1980 32 11.8 62 180 650 10 8 7 59 2 16 180 90 11.8 13.8 302085 1954 58 17.2 100 280 500 11 9 15 137 2 17 280 90 17.2 21.1 302088 1947 65 18.2 107 247 500 13 11 15 171 2 12 247 100 18.2 22.4 302090 1950 62 16.2 104 222 500 32 25 14 351 7 22 222 100 16.2 20.9 302092 1975 37 12.4 79 250 1,700 32 28 12 331 4 13 250 60 12.4 15 302094 1971 41 12.8 67 192 600 98 82 14 1,153 16 16 192 60 12.8 15.7 302096 1959 53 14.3 99 167 800 53 44 14 610 9 18 167 70 14.3 17.2 302097 1959 53 16 98 233 1,000 11 9 15 131 2 20 233 70 16 20.2 302100 1985 27 10.3 66 238 700 35 31 8 247 4 11 238 60 10.3 13.1 302101 1975 37 12.5 75 206 700 74 62 12 739 12 16 206 60 12.5 16.2 302103 1961 51 17.3 92 269 1,600 83 73 16 1,162 10 12 269 70 17.3 24.1

North Nestucca Environmental Assessment 2 North Nestucca EA Silviculture Data Appendix B - 1

Years Inches Feet Trees/A Feet Acres Acres MBF/Acre MBF Acres Pre Post Pre Post 302106 1973 39 13 80 253 800 94 84 11 923 10 11 253 70 13 19.5 302109 1968 44 15 96 286 1,300 61 55 16 874 6 10 286 60 15 19.9 302112 1964 48 13 80 160 800 9 8 11 88 1 11 160 60 13 16 302115 1970 42 13.1 104 288 1,400 42 37 13 483 5 12 288 50 13.1 17.5 302116 1975 37 12.3 82 210 1,400 35 31 12 376 4 11 210 60 12.3 15.4 302117 1963 49 13.4 81 240 700 54 44 11 481 10 19 240 60 13.4 17.7 302118 1974 38 12.4 78 242 1,200 80 65 13 849 15 19 242 70 12.4 15.8 302121 1986 26 10.1 64 237 1,000 48 43 8 345 5 10 237 60 10.1 12.9 302123 1983 29 10.7 68 239 1,200 70 43 8 343 27 39 239 60 10.7 13.6 302124 1984 28 10.5 67 239 1,400 61 51 8 405 10 17 239 60 10.5 13.4 302125 1976 36 13.1 82 228 1,000 15 13 11 146 2 12 228 70 13.1 16.3 302126 1986 26 10.1 64 237 900 34 30 8 242 4 12 237 60 10.1 12.9 302127 1973 39 12.9 78 283 600 191 161 9 1,446 30 16 283 90 12.9 15.1 302129 1971 41 13.6 100 313 1,200 35 16 14 224 19 54 313 60 13.6 15.2 302131 1964 48 14.4 93 200 1,200 59 52 14 723 7 12 200 70 14.4 18 302132 1974 38 12.2 71 289 1,300 85 69 13 892 16 19 289 70 12.2 16.2 302134 1974 38 12.8 79 229 1,300 45 40 14 562 5 11 229 60 12.8 15.8 302135 1965 47 14 93 320 700 139 124 15 1,860 15 11 320 60 14 17.3 302136 1969 43 11.9 78 363 900 77 68 10 679 9 12 363 70 11.9 16.3 302140 1977 35 12.1 76 186 800 110 99 10 988 11 10 186 70 12.1 14.6 302142 1963 49 16.4 84 225 1,000 13 11 14 149 2 18 225 90 16.4 20.6 302149 1977 35 12.4 87 264 700 42 36 14 505 6 14 264 70 12.4 16.2 302164 1962 50 17.4 82 200 800 29 25 16 407 4 12 200 60 17.4 21 302165 1978 34 11.3 71 272 400 127 111 8 890 16 12 272 70 11.3 13.2 302166 1979 33 12.9 66 232 700 44 38 11 417 6 14 232 70 12.9 15.7 302180 1967 45 14.5 88 276 600 211 179 12 2,149 32 15 276 80 14.5 18 302184 1969 43 12.4 84 260 900 81 49 11 540 32 39 260 70 12.4 16

North Nestucca Environmental Assessment 3 North Nestucca EA Silviculture Data Appendix B - 1

Years Inches Feet Trees/A Feet Acres Acres MBF/Acre MBF Acres Pre Post Pre Post 302208 1969 43 12.7 90 273 900 25 20 11 220 5 20 273 70 12.7 15.5 302209 1979 33 11.7 67 272 800 46 40 11 436 6 14 272 70 11.7 13.7 302233 1959 53 13.6 97 314 300 112 91 12 1,097 21 18 314 70 13.6 18.5 302271 1957 55 18 97 114 800 93 21 10 210 72 77 114 80 18 20 302331 1971 41 16.7 88 113 1,400 23 19 10 187 4 18 113 70 16.7 18.1 302333 1959 53 12.7 77 347 500 175 157 10 1,567 18 10 347 100 12.7 17.1 302359 1964 48 14.2 99 111 900 55 49 7 342 6 11 111 70 14.2 15.5 302364 1958 54 15.1 88 182 1,800 111 42 14 581 69 62 182 90 15.1 17.6 302367 1976 36 11 64 330 2,100 40 35 8 278 5 13 330 100 11 13.6 303001 1975 37 12.3 77 242 700 31 21 11 231 10 32 242 80 12.3 17.7 303003 1967 45 13.9 93 283 900 94 73 13 949 21 22 283 70 13.9 18

Total 6,299 5,228 1,044 58,577 1,070 Average 42 13.0 80 246 932 68 57 11 982 16 15 247 72 13.0 16.5

North Nestucca Environmental Assessment 4 North Nestucca EA Silviculture Data Appendix B - 1

Pre & Post Treatment Coarse Woody Debris Prescriptions Area Proposed Gap- Under- Stand Average Percent Proposed for Quantity of # of Snags to Thinning Planting Planting Stand Square Feet of Basal Crown Closure Created Gaps # of Trees to be Felled as be Created Area # of Snags to be Created Area Area Number Area/Acre Gaps CWD in Adjacent Stands

Pre Post Pre Post Acres Acres /Acre Total /Acre Total Total Acres Acres 301002 219 149 87 79 89 0 0 3 268 3 268 18 0 0 302007 247 131 88 77 43 4 6 3 129 3 129 10 1 0 302013 168 73 87 73 46 5 8 3 137 3 137 13 1 0 302016 197 108 86 75 9 0 0 3 27 3 27 2 0 0 302017 223 149 86 79 163 0 0 3 489 3 489 33 0 0 302018 239 138 88 78 19 0 0 3 56 3 56 4 0 0 302020 132 64 85 72 51 4 6 3 152 3 152 11 1 0 302022 104 124 81 76 16 2 3 3 47 3 47 5 1 0 302023 269 106 89 74 51 6 9 3 153 3 153 12 1 0 302024 289 124 90 76 82 0 0 3 245 3 245 23 0 0 302025 230 117 89 76 67 5 8 3 201 3 201 15 1 0 302026 207 144 86 79 8 0 0 3 24 3 24 2 0 0 302028 189 76 89 73 38 5 8 3 115 3 115 11 1 0 302029 224 122 88 77 37 0 0 3 111 3 111 7 0 0 302031 239 106 89 74 12 1.5 3 3 36 3 36 3 1 0 302032 91 55 80 71 40 3 5 3 119 3 119 9 0 0 302033 232 92 89 73 34 4 6 3 101 3 101 8 1 0 302035 192 113 87 77 211 0 0 3 633 3 633 45 0 0 302036 258 137 89 78 51 0 0 3 152 3 152 11 0 0 302039 156 74 86 73 48 5 8 3 144 3 144 11 1 0 302041 213 126 87 77 65 0 0 3 196 3 196 13 0 0 302044 156 63 86 70 61 7 11 3 183 3 183 14 2 0 302046 403 146 92 76 5 1 2 3 15 3 15 1 0 0 302050 328 147 90 78 74 5 8 3 223 3 223 16 1 0 302052 202 103 88 75 75 7 12 3 225 3 225 17 1 0 302053 253 150 89 80 54 0 0 3 161 3 161 11 0 0 302054 168 79 86 72 42 5 8 3 127 3 127 10 1 0

North Nestucca Environmental Assessment 5 North Nestucca EA Silviculture Data Appendix B - 1

Pre Post Pre Post Acres Acres /Acre Total /Acre Total Total Acres Acres 302057 374 179 93 81 39 0 0 3 118 3 118 9 0 0 302058 188 85 87 74 178 10 15 3 533 3 533 38 3 0 302060 168 78 87 72 124 9 14 3 371 3 371 27 2 0 302061 276 135 89 76 112 10 15 3 337 3 337 25 3 0 302067 174 81 87 73 56 6 9 3 169 3 169 12 1 0 302069 327 144 92 79 83 0 0 3 249 3 249 17 0 0 302070 138 66 85 72 120 10 15 3 359 3 359 26 3 30 302071 161 66 86 71 43 5.5 7 3 128 3 128 10 1 24 302072 138 56 85 70 30 2 5 3 89 3 89 7 0 0 302073 236 136 88 77 50 6 9 3 151 3 151 12 1 0 302074 368 144 92 76 47 6 9 3 141 3 141 11 1 0 302075 158 51 87 69 37 5 8 3 110 3 110 8 1 0 302076 132 64 85 72 38 4 6 3 113 3 113 8 1 0 302077 139 58 84 70 47 6 9 3 141 3 141 12 2 25 302078 212 105 87 74 16 2 3 3 48 3 48 4 0 0 302080 236 132 89 79 40 0 0 3 120 3 120 8 0 0 302084 137 93 84 76 8 0 0 3 25 3 25 2 0 0 302085 452 219 93 82 9 0 0 3 27 3 27 2 0 0 302088 446 274 92 84 11 0 0 3 34 3 34 2 0 0 302090 318 238 90 83 25 0 0 3 75 3 75 6 0 0 302092 210 74 88 72 25 3 5 3 74 3 74 6 0 0 302094 172 81 85 72 73 9 14 3 220 3 220 18 2 0 302096 186 113 85 76 40 4 7 3 119 3 119 10 0 0 302097 325 156 90 78 8 1 2 3 23 3 23 2 0 0 302100 138 56 85 70 28 3 5 3 84 3 84 6 0 0 302101 176 86 86 73 55 7 11 3 164 3 164 13 2 0 302103 439 222 92 80 67 6 9 3 200 3 200 15 1 0

North Nestucca Environmental Assessment 6 North Nestucca EA Silviculture Data Appendix B - 1

Pre Post Pre Post Acres Acres /Acre Total /Acre Total Total Acres Acres 302106 233 145 89 78 77 7 12 3 231 3 231 17 1 0 302109 351 130 91 76 49 6 9 3 146 3 146 11 2 0 302112 147 84 83 72 8 0.5 1 3 23 3 23 2 0 0 302115 270 84 90 71 33 4 6 3 100 3 100 8 1 0 302116 173 78 86 72 28 3 5 3 85 3 85 6 0 15 302117 235 103 89 74 39 5 8 3 116 3 116 10 1 0 302118 203 95 88 75 58 7 9 3 175 3 175 14 2 0 302121 132 54 85 69 39 4 6 3 117 3 117 9 1 0 302123 149 61 86 70 36 7 11 3 108 3 108 13 2 0 302124 144 59 86 70 45 6 9 3 134 3 134 11 1 0 302125 213 101 88 75 12 1 2 3 37 3 37 3 0 0 302126 132 54 85 69 27 3 5 3 9 3 9 6 0 0 302127 257 112 90 77 161 0 0 3 482 3 482 34 0 0 302129 316 76 91 72 13 3 5 3 9 3 9 6 0 16 302131 226 124 87 76 48 4 7 3 143 3 143 11 1 0 302132 235 100 90 75 61 8 12 3 24 3 24 15 2 0 302134 205 82 87 72 36 4 6 3 12 3 12 8 1 20 302135 342 98 92 74 112 12 18 3 336 3 336 25 3 0 302136 280 101 92 75 63 5 9 3 189 3 189 14 0 0 302140 149 81 84 73 92 7 12 3 275 3 275 20 1 0 302142 330 208 90 82 11 0 0 3 32 3 32 2 0 0 302149 221 100 89 75 33 3 5 3 99 3 99 8 0 0 302164 330 144 89 76 23 2.5 4 3 69 3 69 5 1 0 302165 189 67 88 72 103 8 13 3 310 3 310 23 2 0 302166 211 94 88 74 35 3 5 3 105 3 105 8 0 0 302180 316 141 91 78 179 0 0 3 537 3 537 38 0 0 302184 218 98 89 75 43 6 10 3 129 3 129 15 1 0

North Nestucca Environmental Assessment 7 North Nestucca EA Silviculture Data Appendix B - 1

Pre Post Pre Post Acres Acres /Acre Total /Acre Total Total Acres Acres 302208 240 92 89 74 18 2 4 3 54 3 54 5 0 0 302209 203 72 88 72 37 3 5 3 110 3 110 8 0 0 302233 317 131 91 77 83 8 13 3 250 3 250 20 2 0 302271 201 175 83 80 21 0 0 3 63 3 63 17 0 0 302331 172 125 82 76 19 0 0 3 56 3 56 4 0 0 302333 305 159 92 81 157 0 0 3 470 3 470 31 0 0 302359 122 92 80 74 49 0 0 3 146 3 146 10 0 0 302364 226 152 87 80 42 0 0 3 125 3 125 20 0 0 302367 218 101 90 77 35 0 0 3 104 3 104 7 0 0 303001 200 137 88 78 21 0 0 3 63 3 63 6 0 0 303003 298 124 91 76 65 8 12 3 195 3 195 17 2 0

Total 4904 324 511 14,356 14,356 1,134 66 130 Average 229 109 88 75 85

North Nestucca Environmental Assessment 8 Silviculture Logging Systems North Nestucca Environmental Assessment Appendix B-2

302013 1971 74 4 17 0 2 51 31% 0 51 0 302013 0 0 0.0 0 29 627

302016 1973 10 0 0 1 0 9 10% 0 9 0 302016 12 300 1.2 0 11 0 302017 1963 183 12 2 6 0 163 11% 15 148 0 302017 20 300 2.0 0 58 0 302018 1973 21 0 0 2 0 19 10% 0 19 0 302018 0 0 0.0 0 7 0 302020 1986 63 2 0 6 0 55 13% 15 40 0 302020 32 320 3.5 0 32 1,200 302022 1974 26 6 0 0 2 18 31% 0 18 0 302022 0 0 0.0 0 10 0 302023 1964 65 8 0 0 0 57 12% 0 57 0 302023 0 0 0.0 0 6 0 302024 1961 130 9 0 37 2 82 37% 8 74 0 302024 8 550 1.5 0 46 0 302025 1971 82 6 0 4 0 72 12% 12 60 0 302025 27 200 1.9 0 37 355 302026 1970 11 0 0 3 0 8 27% 0 8 0 302026 0 0 0.0 0 5 0 302028 1974 59 6 6 0 4 43 27% 3 40 0 302028 4 250 0.3 0 28 0 302029 1969 41 2 0 2 0 37 10% 7 30 0 302029 13 475 2.1 0 10 0 302031 1972 17 0 0 2 1 14 18% 6 8 0 302031 16 125 0.7 0 12 0 302032 1974 48 3 0 1 1 43 10% 1 42 0 302032 4 125 0.2 0 38 422 302033 1970 44 3 1 2 0 38 14% 0 0 38 302033 0 0 0.0 0 0 0 302035 1965 251 22 15 0 3 211 16% 32 179 0 302035 48 350 5.8 0 71 1,263 302036 1961 59 3 0 5 0 51 14% 14 37 0 302036 11 500 1.9 0 26 0 302039 1982 60 3 0 4 0 53 12% 2 51 0 302039 2 150 0.1 0 20 755 302041 1966 73 3 0 4 1 65 11% 11 54 0 302041 15 450 2.3 0 28 401 302044 1982 79 11 0 0 0 68 14% 0 68 0 302044 0 0 0.0 0 27 0 302046 1968 7 0 0 1 0 6 14% 0 6 0 302046 0 0 0.0 0 1 0 302050 1967 88 3 0 6 0 79 10% 30 49 0 302050 48 300 5.0 0 25 0 302052 1968 92 8 0 0 2 82 11% 10 72 0 302052 15 500 2.5 0 24 0 302053 1973 61 4 0 3 0 54 12% 15 39 0 302053 8 900 2.5 0 14 363 302054 1975 53 1 0 5 0 47 11% 30 17 0 302054 23 900 7.1 0 14 0 302057 1977 52 10 0 3 0 39 25% 11 28 0 302057 22 200 1.5 0 31 0 302058 1979 213 10 0 15 0 188 12% 20 168 0 302058 33 200 2.5 0 73 0 302060 1970 149 5 1 10 0 133 11% 0 133 0 302060 0 0 0.0 0 35 0 Silviculture Logging Systems North Nestucca Environmental Assessment Appendix B-2

Stand Acres Deferred Skid Trails* Estimated # New Estimated # Year of Stand Stream Silv. Logging Treated Percent Logging System Acres Avg. of Landings Temp HCC # Unstable HCC # of Landings Origin Size Buffer Defferal System Acres Untreated Heli- Total # Length Acres Within Road Roads Soil Acres Ground Skyline Off Roads (acres) Acres Acres Deferral copter (ft) Prism Length 302061 1961 137 14 0 0 1 122 11% 17 105 0 302061 9 550 1.7 0 27 0 302067 1980 69 6 0 1 0 62 10% 0 62 0 302067 0 0 0.0 0 16 0 302069 1965 93 10 0 0 0 83 11% 6 77 0 302069 3 375 0.4 0 22 0 302070 1985 144 6 0 7 1 130 10% 41 89 0 302070 45 320 4.0 0 25 0 302071 1981 56 3 0 0 5 48 14% 45 3 0 302071 26 200 1.8 0 20 0 302072 1985 37 3 0 0 2 32 14% 22 10 0 302072 40 300 4.1 0 18 0 302073 1967 66 2 8 0 0 56 15% 15 41 0 302073 28 200 1.9 0 32 0 302074 1961 63 1 0 9 0 53 16% 35 18 0 302074 37 430 5.5 0 27 0 302075 1985 47 3 0 0 2 42 11% 26 16 0 302075 30 380 3.9 0 21 0 302076 1986 47 1 0 4 0 42 11% 30 12 0 302076 42 375 5.4 0 30 0 302077 1981 64 2 0 8 1 53 17% 9 44 0 302077 12 210 0.9 0 35 0 302078 1959 21 3 0 0 0 18 14% 0 18 0 302078 0 0 0.0 0 8 310 302080 1969 46 3 0 3 0 40 13% 0 40 0 302080 0 0 0.0 0 10 245 302084 1980 10 1 0 0 1 8 19% 8 0 0 302084 8 250 0.8 0 8 0 302085 1954 11 0 0 1 1 9 18% 2 7 0 302085 5 185 0.3 0 3 392 302088 1947 13 2 0 0 0 11 15% 5 6 0 302088 7 400 1.0 0 7 588 302090 1950 32 5 0 0 2 25 22% 16 9 0 302090 21 230 1.7 0 21 414 302092 1975 32 2 0 1 1 28 13% 11 17 0 302092 5 725 1.3 0 15 0 302094 1971 98 12 0 0 4 82 16% 44 38 0 302094 37 500 6.4 0 35 0 302096 1959 53 6 0 0 3 44 17% 23 21 0 302096 35 400 5.0 0 40 0 302097 1959 11 0 0 2 0 9 19% 0 9 0 302097 0 0 0.0 0 5 0 302100 1985 35 1 0 3 0 31 11% 6 25 0 302100 16 150 0.8 0 17 0 302101 1975 74 8 3 0 1 62 16% 8 54 0 302101 17 230 1.3 0 22 0 302103 1961 83 6 0 0 4 73 12% 38 35 0 302103 73 400 10.0 0 36 0 302106 1973 94 7 0 3 0 84 11% 26 58 0 302106 26 350 3.1 0 25 0 302109 1968 61 3 0 2 1 55 10% 6 49 0 302109 14 235 1.1 0 13 667 302112 1964 9 1 0 0 0 8 11% 0 8 0 302112 0 0 0.0 0 3 0 302115 1970 42 4 0 1 0 37 12% 7 30 0 302115 30 150 1.5 0 16 888 302116 1975 35 2 0 1 1 31 11% 21 10 0 302116 44 370 5.6 0 35 0 302117 1963 54 5 5 0 0 44 19% 0 0 44 302117 0 0 0.0 0 0 0 302118 1974 80 5 9 0 1 65 19% 1 64 0 302118 18 175 1.0 0 21 0 302121 1986 48 2 0 3 0 43 10% 9 34 0 302121 21 100 0.8 0 22 0 Silviculture Logging Systems North Nestucca Environmental Assessment Appendix B-2

Stand Acres Deferred Skid Trails* Estimated # New Estimated # Year of Stand Stream Silv. Logging Treated Percent Logging System Acres Avg. of Landings Temp HCC # Unstable HCC # of Landings Origin Size Buffer Defferal System Acres Untreated Heli- Total # Length Acres Within Road Roads Soil Acres Ground Skyline Off Roads (acres) Acres Acres Deferral copter (ft) Prism Length 302123 1983 70 5 0 0 22 43 39% 0 43 0 302123 0 0 0.0 0 21 0 302124 1984 61 5 0 0 5 51 17% 27 24 0 302124 50 350 6.0 0 25 0 302125 1976 15 0 0 2 0 13 13% 0 13 0 302125 0 0 0.0 0 3 0 302126 1986 34 2 0 2 0 30 12% 9 21 0 302126 30 200 2.0 0 18 404 302127 1973 191 25 0 0 5 161 16% 30 131 0 302127 44 350 5.3 0 78 0 302129 1971 35 3 15 0 1 16 54% 1 15 0 302129 15 200 1.0 0 20 853 302131 1964 59 4 0 3 0 52 12% 18 34 0 302131 31 350 3.7 0 22 0 302132 1974 85 8 8 0 0 69 19% 7 62 0 302132 15 170 0.9 0 31 0 302134 1974 45 1 3 0 1 40 11% 2 38 0 302134 3 225 0.2 0 13 0 302135 1965 139 10 0 3 2 124 11% 18 106 0 302135 36 220 2.7 0 64 421 302136 1969 77 0 0 9 0 68 12% 15 53 0 302136 18 275 1.7 0 43 1,116 302140 1977 110 7 0 1 3 99 10% 36 63 0 302140 64 285 6.3 0 63 0 302142 1963 13 1 1 0 0 11 16% 0 11 0 302142 0 0 0.0 0 8 0 302149 1977 42 3 3 0 0 36 14% 22 14 0 302149 35 300 3.6 0 20 0 302164 1962 29 2 0 2 0 25 14% 0 25 0 302164 0 0 0.0 0 8 0 302165 1978 127 7 0 8 1 111 13% 15 96 0 302165 34 170 2.0 0 37 0 302166 1979 44 1 0 5 0 38 14% 0 38 0 302166 0 0 0.0 0 8 0 302180 1967 211 20 6 0 6 179 15% 66 113 0 302180 45 350 5.4 0 46 0 302184 1969 81 4 28 0 0 49 39% 0 49 0 302184 0 0 0.0 0 16 0 302208 1969 25 2 2 0 1 20 20% 0 20 0 302208 0 0 0.0 0 5 0 302209 1979 46 3 3 0 0 40 13% 14 26 0 302209 45 210 3.3 0 33 0 302233 1959 112 17 0 0 4 91 19% 77 14 0 302233 70 500 12.0 0 34 0 302271 1957 93 7 0 63 2 21 77% 5 16 0 302271 27 250 2.3 0 11 0 302331 1971 23 4 0 0 0 19 18% 6 13 0 302331 7 425 1.0 0 15 426 302333 1959 175 11 0 2 5 157 10% 49 108 0 302333 43 425 6.3 0 48 3,543 302359 1964 55 4 0 2 0 49 11% 8 41 0 302359 6 450 0.9 0 18 0 302364 1958 111 6 11 50 2 42 62% 0 42 0 302364 8 325 0.9 0 24 0 302367 1976 40 2 0 2 1 35 13% 14 21 0 302367 16 350 1.9 0 22 0 303001 1975 31 2 7 0 1 21 32% 0 21 0 303001 0 0 0.0 0 10 917 303003 1967 94 6 15 0 0 73 22% 14 59 0 303003 43 200 3.0 0 27 0

6,302 455 169 329 115 5,234 17% 1,189 3,954 91 1,725 244 192 0 2,206 16,570 Silviculture Logging Systems North Nestucca Environmental Assessment Appendix B-2

Re-Open Existing Temp Roads (ft) 326 0

550

0 3,536 0 560 0 0 0 1,925 0 0 923 1,193 0 0 6,563 0 500 2,083 0 0 2,512 1,371 826 262 766 1,777 0 Silviculture Logging Systems North Nestucca Environmental Assessment Appendix B-2

Re-Open Existing Temp Roads (ft) 3,748 0 0 1,533 438 0 438 0 0 882 0 1,444 251 0 0 0 0 0 4,608 2,686 0 406 0 0 1,927 0 0 0 0 0 0 925 Silviculture Logging Systems North Nestucca Environmental Assessment Appendix B-2

Re-Open Existing Temp Roads (ft) 0 1,160 315 0 10,977 0 0 714 818 4,574 3,895 4,509 0 1,964 0 556 0 7,753 0 0 0 2,347 0 1,410 0 3,175 0 0 327 1,526

90,979 Silviculture Logging Systems North Nestucca Environmental Assessment Appendix B-2

Re-Open Existing Temp Roads (ft) Total Appendix C

North Nestucca EA Roads Analysis

Comments Road Number Beginning Termini ATM Class+ Maint miles Type Surface Haul Season Length Seg OBML - Current OPML - Current OBML Proposed OPML Proposed to Miles Proposed Store Miles Proposed for Reconst Stream Proposed to Culverts Replace Stream Proposed to Culverts for Remove or Decom Storage Mt Road inside

1004000 Co Rd 870 Key-SHC 3.48 Asph A/S 3.48 2 2 2 2 3.48 12 This is the asphalt portion of road from beginning termini to MP 3.48; asphalt in need of repair in several locations; deep fills, crack sealing; 12 stream pipes identified for replacement in 2011 Nestucca Roads CE; connects county roads to other key roads; easements(s) on file for FS use over pvt in sec. 19, 24, 30

MP 3.48; This is the aggregate portion of road starting at 1106 jct; in better repair than asphalt portion; 3 stream pipes 1004000 Key-SHC 0.92 Agg A/S 6.70 2 2 2 2 3 jct 1106 identified for replacement in the 2011 Nestucca Roads CE; road gets routine local use, connects county and key roads; haul would go as far as 1004130 jct

1004112 1004 Non-key 1.62 Agg A/S 1.62 1 2 2 2 1.00 3 0 This segment starts at 1004 jct and goes to 121 jct (1.62 miles); propose to leave open for public use; 3 stream pipes to replace under 2012 Nestucca Roads CE; haul planned from stands 53, 54, 61, 80, 85 and 90; A/S haul recommended with 2-3 inch full lenth lift

1004112 1004121 Non-key 0.70 Agg A/S 1.09 1 2 1 1 1.09 This segment of rd begins at the 121 (MP 1.62) jct and goes west to NF bdry at MP 2.31; lower mid-slope road; crosses swales that could have drainage pipes, but have none; draining poorly due to location and design; planned for haul w/ stand 53; no other stands along this segment; propose for storage

This segment of road begins at the NF bdry w/ pvt, sec line 13/14; ends at 1106118 jct; this section entirely on pvt 1004112 MP 2.31 Non-key 0.24 Agg A/S 0.24 1 2 2 2 1 land; plan to leave open; easement on file; haul may occur from stands 53 and 54, depending on haul direction; 1 str pipe recommended for replacement under 2012 Nestucca Roads CE

1004113 1004112 Non-key 1.10 Agg A/S 1.10 1 2 1 1 1.10 1 Planned for haul from stands 80, 84, 85, and 88; also needed for stand management in future analysis; store after sale; one stream pipe for removal w/ storage under 2012 Nestucca Roads CE; one waterbar causing high fill scour; coordinate storage w/ pvt land owner east, at end of rd

Gentle grades; OK project road; no stream crossings; planned for haul w/ stand 054; store for continued mngmt of 1004121 1004112 Non-key 0.45 Agg Dry 0.45 1 2 1 1 0.45 stand 054

This segment of rd is open, getting used; starts at 1004 and goes to MP 0.81; 4 stream pipes identified for removal 1004127 1004 Non-key 0.81 Agg Dry 0.81 1 2 1 1 0.81 4 w/ storage under 2012 Nestucca Roads CE; planned for haul from stands 106 and 114; plan to store for continued mngmt of stands 106 and 114

1004128 1004 Non-key 1.48 Agg Dry 1.48 1 2 1 1 1.48 1 Planned for haul from stand 125; also younger plantation along rd so will be needed for future entries; one stream pipe crossing mod prior to remove w/storage; under 2012 Nestucca Roads CE

1004129 1004 Non-key 0.46 Agg A/S 0.46 1 2 1 1 0.46 1 Haul planned from stands 78 and 97; one stream pipe for removal w/ storage under 2012 Nestucca Rds CE

1004130 1004 Non-key 0.91 Agg A/S 0.91 1 2 1 1 0.91 This is the segment of road from the 1004 to 119 jct; will be used for haul from stand 69; a 2-4' rock lift recommended from 131 jct to 119 jct for A/S; no stream pipes this segment; plan to store

North Nestucca Environmental Assessment 1 Appendix C

North Nestucca EA Roads Analysis

This is the segment from 119 jct to end of road; two stream pipes for removal w/ storage under 2012 Nestucca 1004130 MP 0.91 Non-key 0.45 Agg Dry 0.45 1 2 1 1 0.45 2 Roads CE; road had tension cracks; repair under maint; rock crumbling; will be used for haul from stand 069 and for future mngmt of stand 69; recommend dry season haul

1004131 1004130 Non-key 0.30 Agg Dry 0.80 1 2 1 1 0.80 Western portion will be used for haul from stand 069; easement confirmed for haul sec 14 if needed; no stream pipes; one DR and drainage issue at MP 0.126

1023000 1034 Non-key 0.47 Agg A/S 0.47 1 2 1 1 0.47 This segment of road is from 1034 to 117 jct; getting moderate use connecting to 117; planned for haul from stand 142; plan to store rd after sale; no stream pipes

This segment starts at EB at MP 1.92 (NE of stand 164) and goes to ending termini at 1024 jct; road open and 1023000 MP 1.92 Non-key 2.00 Agg A/S 2.48 1 2 1 1 2.48 4 getting routine use; 4 stream pipes recommended for removal w/ storage under 2012 Nestucca Roads CE; road planned for haul w/ stands 164, 166, and 180

This segment starts at 1023 and ends at MP 0.3; haul planned from stand 142; no streams; plan to store for 1023117 1023 Non-key 0.30 Agg A/S 0.30 1 2 1 1 0.30 ongoing mngmt of stand 142

1023117 MP 0.3 Non-key 0.00 Agg N/A 0.38 1 2 DE DE This segment starts at MP 0.3, just north of stand 142 and goes to end of rd at 1004; no managed stands; parallels upper reach of Farmer Ck; no stream crossings; plan to decom

Planned for haul from stands 184, 209 and stands from 1023 rd; several other stands along 1024 rd and its tribs; so 1024000 1034 Non-key 2.50 Agg A/S 3.19 2 2 2 2 needed for future management

1024112 1024 Non-key 1.10 Agg Dry 1.10 1 2 1 1 1.10 Planned for haul from stand 165; no stream pipes; ridge system; needed for ongoing mngmt of stand

1024113 1024 Non-key 0.44 Agg Dry 0.44 1 2 1 1 0.44 Planned for haul w/ stand 184; no stream crossings; rd blocked at entrance by 80-100 cy of waste material; ramp over or remove under maintenance; rd needed for ongoing mngmt of stand 184

Planned for haul w/ stand 209; no stream crossings; small slide across rd, could clean w/ maintenance; rd needed 1024114 1024 Non-key 0.64 Agg A/S 0.64 1 2 1 1 0.64 for ongoing mngmt of stand 209

Key road connects Hwy 101 to 1004 rd; planned for haul from several stands; 10 stream pipes identified for Hwy 101 Key-SHC 6.70 Agg A/S 6.70 2 3 2 2 11 1034000 replacement under 2011 Nestucca Roads CE I; fill failure adjacent to Farmer Cr; see geo-tech report; FS jurisdiction begins at 1024 rd jct; Co Rd has jurisdiction from Hwy 101 to 1024 rd

Planned for haul from stand 149; also accesses deferred stand 146 at end of 116 rd; road needed for ongoing 1034115 1034 Non-key 0.20 Agg Dry 0.20 1 2 1 1 0.20 management of stands; some tension cracks in rd, review for spec work at sale time; has some steep adverse grades

First 0.3 mile planned for haul from stand 149; otherwise, accesses deferred stand 146 so needed for future mngmt; 1034116 1034 Non-key 0.30 Agg N/A 0.59 1 2 1 1 0.59 road basically a continuation of rd 115; consider making two roads one and change in INFRA; store w/ 115 rd under TS; flatter, ridgetop location

North Nestucca Environmental Assessment 2 Appendix C

North Nestucca EA Roads Analysis

CO RD 1106000 Key-SHC 1.30 Agg A/S 3.90 2 2 2 2 9 Haul planned from stands 52, 57 and 69; possibly a few stands off 1004, too; Key road connecting NFS 1004 to Co 891 Rd 871; 9 stream pipes identified for replacement, 8 under 2012 Nestucca Roads CE and 1 in 2011 Nestucca Roads CE I; several DR pipes ID'd for replacement

This segment starts at 1106 and ends at EB at MP 1.16; changed INFRA from decommissioned road to open road 1106118 1106 Non-key 1.16 Agg A/S 1.16 1 2 2 2 1 (OPML 2) to reflect current ground conditions; recently used by Stimson's for logging; most of road is on Stimson's land w/ FS easement; planned for haul from stands 52, 53 and 69; one stream pipe identified for replacement under 2012 Nestucca Roads CE; coordinate activity w/ Stimson

Planned for haul from stands 57 and 69; no streams; road connects 1106 and 1004130; project road, plan to 1106119 1106 Non-key 0.82 Agg A/S 0.82 1 2 1 1 0.82 close/store after sale

RD.11, 1107000 SEC.2SEC Non-key 0.30 Agg A/S 0.30 1 2 1 2 This is the open segment of the road from Co Rd 885 to locked gate; segment entirely on pvt land, Stimsons; gate .15 has no FS lock; need key from Stimsons to enter; current FS easement in place; road planned for haul from stand 233; keep open, coordinate activity w/ Stimson

This is the closed portion of the road from gate at MP 0.3 to the end of rd; planned for haul from stand 233; needed 1107000 MP 0.3 Non-key 1.10 Agg A/S 1.55 1 1 1 1 3 for ongoing mngmt of stand 233 and future mngmt of deferred stands 234, 237 and 252; road continues east on to pvt land in sect 15, so assuming it is needed by pvt landowner as well; plan to keep rd closed at gate; three pipes for potential removal w/ storage; coordinate activity w/ pvt landowner in NE quarter of section 15

1500000 Hwy 22 Key-SHC 6.80 Agg A/S 6.80 2 2 2 2 Segment of rd w/in Nestucca watershed is approx 6.8 miles from Hwy 22 to approx 1588 jct; Key road; connects Hwy 22 and Co Rd 130

1500115 1500 Non-key 1.80 Agg Dry 1.93 1 1 1 1 Analyzed under Gauldy EA - Recent decision to store rd to MP 1.63; decom the last 0.3 mi; planned for haul under N.Nest stand 367; defer decom until afer stand thinned

Analyzed under Gauldy EA - Recent decision to store rd; planned for haul w/ stand 367; plan to store rd w/ TS 1500117 1500115 Non-key 0.36 Agg Dry 0.36 1 1 1 1 contract

This segment goes from the beginning termini to MP 3.0; analyzed under Gaulder EA, recent decision to leave this 1503000 1500 Non-key 2.50 Agg A/S 3.00 2 2 2 2 segment open; haul planned w/ N. Nest stands 002 and 359; and deferred stands 001 and 357; plan to leave open per Gauldy decision

Analyzed under Gauldy EA - Recent decision to decom 0.19 mi; accomplished in 2010 contract; accesses N Nest 1503112 1503 N/A 0.00 Agg N/A 0.00 DE 1 DE DE stand 002

Key rd connects Co Rd 886 to 1500 rd and Hwy 22; planned for haul w/ stands 331 and 333; analyzed under recent 1533000 1500 Key-SHC 3.31 Agg A/S 3.31 2 2 2 2 Gauldy EA

1533 Non-key 0.30 Agg Dry 1.02 1 2 1 1 1533113 Analyzed under Gauldy EA - Recent decision to store rd; planned for haul w/ stand 333 and accesses deferred stands 347 and 351; also accesses pvt land (Stimson) plan to store rd w/ TS contract; coordinate w/ pvt land owner

North Nestucca Environmental Assessment 3 Appendix C

North Nestucca EA Roads Analysis

Analyzed under Gauldy EA - Recent decision to store rd; accomplished in 2010 contract; planned for haul w/ N Nest 1533114 1533 Non-key 0.23 Agg Dry 0.23 1 1 1 1 stand 333; re-store rd w/ TS

Analyzed under Gauldy EA - Recent decision to store rd; planned for haul w/ N Nest stand 333; plan to store rd w/ 1533117 1533 Non-key 0.10 Agg Dry 0.10 1 2 1 1 TS contract

1588000 1500 Non-key 0.50 Agg A/S 0.50 2 2 2 2 Anazyzed under Gauldy EA; keep open; used for haul from stands 002 and 359

This is the portion of rd from Co Rd 857 to the locked gate at the Forest bdry, sec 3; key road; does not connect to 8170000 Co Rd 857 Key-SHC 5.14 Agg A/S 5.14 2 2 2 2 9 other key rds or community so am proposing to down grade to non-key from 8170117 jct north to end (total downgrade 0.6 miles); haul planned from several stands; 9 stream pipes and several DR pipes are due for replacement; 5 of 9 stream pipes proposed for replacement under 2011 Nestucca roads CE; rd crosses pvt land at beg termini; easement on file

8170112 8170 Non-key 0.00 Agg N/A 0.14 1 1 1 1 Planned for haul from stand 035; accesses deferred stands 38 and 43; existing EB is worn, OHVs are breaching; jurisdiction ends at FS bdry; store road with TS contract

8170113 8170 Non-key 0.46 Agg Dry 0.46 1 2 1 1 0.46 Planned for haul w/ stand 035; store rd after sale, needed for ongoing mngmt; no stream pipes; fairly stable

8170114 8170 Non-key 0.50 Agg Dry 1.22 1 2 1 1 1.22 1 First half mile of road will be used for haul from stand 36; also accesses deferred stands 42 and 45; road needed for future and onging mngmt of stands; one pipe to remove w/ storage under 2012 Nestucca Rds CE

Road is actually blocked by Simpson gate at MP 0.22; gate has no FS lock; need Simpson key for entry; rd will be 8170117 8170 Non-key 0.29 Agg A/S 0.29 1 2 1 2 used for haul from stand 025; keep rd in current status; coordinate any management activity w/ Stimson, pvt landowner; rd crosses onto pvt past gate; per land exchange agreement, FS retained use rights to 118 rd; GIS mapping error needs corrected to end rd at 118

Road is behind locked gate located on NFS 8170117; planned for haul from stand 25; approx 80 cy of fill material 8170118 8170117 Non-key 0.52 Agg A/S 0.52 1 1 1 1 at jct w/ 117; ramp over or remove prior to haul; rd needed for ongoing mngmt of stand 25; also, OHV users are maintaining/using rd behind EB; needs monitored; Dec, 2011 update: road is to be reconstructed under recent BLM proposal to connect this road to 111 road below in order to access BLM lands up East Beaver Creek; anticipate reconstruction would bring road up to A/S haul standards

8170119 8170 Non-key 1.29 Agg Dry 1.29 1 2 1 1 1.29 1 Planned for haul w/ stands 3, 17 and 18; also, needed for future management of deferred stands 4 and 5; one stream pipe recommended to remove w/ storage under 2012 Nestuuca Rds CE; store rd for ongoing mngmt needs; temp road leaves end of 119 west and ties in to pvt land and new rd construction

8171000 8170 Non-key 1.78 Agg A/S 1.78 1 2 1 2 5 Haul planned from stands 18, 22 and 24; better travelled non-key road; has 5 stream pipes recommended for replacement, two under 2012 Nestucca Roads CE and three under 2011 CE I

North Nestucca Environmental Assessment 4 Appendix C

North Nestucca EA Roads Analysis

This segment of rd starts at Co Rd and ends at 117 jct; it's key rd, but recommend downgrade to non-key; 8172000 Co Rd 857 Key-SHC 2.13 Agg A/S 2.13 1 2 1 2 1 planned for haul from stands 46 and 50; needed for future management of deferred stands 11 and 44; one stream pipe mod priority for replacement, covered under 2012 Nestucca Rds CE

This segment of rd starts at 117 jct and goes to end of rd; rock depth and quality decreases; rd is mostly ridgetop 8172000 Jct 117 Non-key 2.65 Agg Dry 2.65 1 2 1 1 2.65 1 and upper ridgetop location; planned for haul from stands 13, 29, 32 and 33; also has deferred stands 30, 37 and 39 so needed for future management; one stream pipe recommended for removal w/ storage under 2012 Nestucca Rds CE; team recommends storage w/ a guardrail barricade

8172115 8172 Non-key 0.12 Agg A/S 0.12 1 2 1 2 Very short rd to landing and rock pit; planned for haul from stand 46; rock pit has approx 80 cy of 1/2" crushed rock; assuming ours; plan to keep rd open for pit access and dispersed site camping

8300000 Co Rd 858 Key-SHC 2.68 Agg A/S 2.68 2 2 2 2 0.1 2 County rd to 8376 jct; FS jurisdiction begins at southern jct w/ 8376; one stream pipe recommended for replacement under 2012 Nestucca Rds CE; passes through pvt and BLM, easements on file; key road w/ OHV allowed use; mileage discrepency w/ INFRA

8300118 MP 0.72 Non-key 0.13 Agg Dry 0.13 1 2 1 1 0.13 This segment of rd goes from 8377 jct to east edge of stand 92; haul planned from stand 92; will need jct reconstructed if haul going north on 8377; plan to store after haul

Road is a tie through road from 83 to 8377; interior portion accesses 40 ac of managed BLM lands (they have a 8300121 8300 Non-key 0.30 Agg Dry 0.64 1 2 2 2 sale currently layed out); agreements for use on file; stable rd; no streams and located upper ridge; would like to propose storage; but, will propose ML2 (open) due to BLM access needs; west end of rd planned for haul w/ stand 92 and east end planned for haul from stand 076

8300123 8300121 Non-key 0.18 Agg Dry 0.18 1 2 1 1 0.18 Road planned for haul from stand 076; also access BLM managed land to the west; BLM has a sale currently layed out; plan to store w/ FS sale after BLM sale is completed; coordinate w/ BLM; no streams; fairly stable, shorter rd

This rd segment starts at 83 rd jct and ends at Forest Bdry at section line between 35/36; includes haul from stands 8335000 8300 Non-key 0.30 Agg Dry 1.40 1 2 2 2 116 and 129 off of 112 rd; no streams, gentle grades; plan to keep open for access to state lands including "Hinds Sight Hemtic Progeny Area"; possible study area

Short stable rd to landing that accesses N. Nestucca stand 116; also will be needed for future management of stand 8335111 8335 Non-key 0.20 Agg A/S 0.20 1 2 2 2 122; no streams or drainage issues; dispersed site at landing in use; plan to keep road open post sale for rec use; add site to MVUM?

8335112 8335 Non-key 0.36 Agg Dry 0.36 1 2 1 1 0.36 This segment starts at 8335 jct and ends at 113 jct; haul planned from stand 129 w/ N. Nest; no stream crossings on this segment, plan to store after use w/ sale

North Nestucca Environmental Assessment 5 Appendix C

North Nestucca EA Roads Analysis

Haul planned from stand 129 w/ N. Nestucca; two stream pipes, recommended for remove w/ storage under 2012 8335113 8335112 Non-key 0.30 Agg Dry 0.30 1 2 1 1 0.30 0.1 2 Nestucca Rds CE; road has 200' slump; recommend specified road work list; review again at sale prep; store rd post sale for future use when re-entering stand 129

8376000 8300 Key-SHC 5.16 Agg A/S 5.16 2 2 2 2 3 Key road; propose for down grade to non-key; haul will occur from several stands in N. Nest; direction of haul depends on whether County portion of rd 83 is repaired; 8376 has 3 stream pipes recommended for replacement under 2012 Nesttuca Rds CE; some lower priority; Beaver Pond water overflowing road and trash rack at pond cmp ; constantly plugging; rd crosses BLM, agreements in place; contact rec about potential dispersed sites for MVUM

8376113 8376 Non-key 1.23 Agg A/S 1.23 1 2 2 2 Planned for haul w/ stands 118, 123 and 124; rd passes through state land in sec. 28; agreement on file; plan to leave road open for access to state land; no streams or drainage issues; upper ridgetop location

8376114 8376113 Non-key 0.30 Agg Dry 0.30 1 1 1 1 Haul planned from stand 124; rd blocked at both ends; junctions very obscure; no streams or drainage issues

Hauled planned from stand #118; no streams, ridgetop location but rd is slipping and has tension cracks; trees 8376115 8376113 Non-key 0.30 Agg Dry 0.30 1 2 1 1 0.30 growing in prism; store rd for future use; needs EB and water bars; recommended for storage under 2011 Nestucca Rds CE I

Road data and mapping in error; road decom started at MP 1.36 instead of MP 0.0; updated INFRA/maps to reflect 8376117 8376 Non-key 1.36 Agg Dry 1.36 1 2 1 1 1.36 1 current ground condition; road is planned for haul from stand 101; will be needed for long term management of stands 100/101 and for managed stands on BLM lands in section 22 so store after use; road crosses BLM lands; check agreements; one pipe recommended for removal w/ storage under 2012 Nestucca Rds CE; other pipes recommended for removal w/ storage would implact BLM and would need corrdination; see road log

Planned for haul from stand 109; upper ridgetop location; needed for future management; store after use; GIS 8376124 8376 Non-key 0.20 Agg Dry 0.20 1 1 1 1 request, road is mapped following skid trail; drop last 2-3 tenths; INFRA mileage OK, but INFRA incorrect calling rd OPML 2; have changed to OPML 1

8376141 8376113 Non-key 1.98 Agg A/S 1.98 1 2 1 1 1.98 Road planned for haul from stands 121 and 126; also accesses state land in section 28 and BLM land in section 32; coordinate storage w/ state and BLM; may need to start storage at MP 0.85, which is west bdry of state land

8376147 8376113 Non-key 0.24 Agg Dry 0.24 1 2 1 1 0.24 Haul planned from stand 118; located on flat ground; coordinate storage w/ State; road mapped incorrectly; shows our road on to state; our jurisdiction ends at NF boundary

8377000 8376 Key-SHC 3.78 Agg A/S 3.78 2 2 2 2 2 Key road that links Blaine community to Clarence Creek area; couple of stream pipes w/ moderate priority to replace under 2012 Nestucca Rds CE; otherwise fair condition

North Nestucca Environmental Assessment 6 Appendix C

North Nestucca EA Roads Analysis

8377 Non-key 0.30 Agg Dry 0.30 1 1 1 1 8377114 Planned for haul from stand 72; EB is worn down; store rd with Timber Sale

8377115 8377 Non-key 0.10 Agg A/S 0.20 1 2 1 1 0.20 Planned for haul from stand 77; accesses deferred stand 82; no stream crossings; flat and short upper ridgetop location; recommend A/S with a 2-4" full length lift; plan to store for continued mngmt of stands 77 and 82

8377116 8377 Non-key 0.10 Agg A/S 0.10 1 2 1 1 0.10 Planned for haul from stand 77; no stream crossings; flat and short upper ridgetop location; recommend A/S with a 2-4" full length lift; plan to store for continued mngmt of stand 77

Planned for haul from stand 77; dry season or extended season w/ lift; road has failed at MP 0.33; see geo-tech 8377 Non-key 0.43 Agg Dry 0.43 DE 2 1 1 0.43 0.1 8377117 report; needs reconstructed prior to haul; no stream pipes; upper ridge top location; store for continued mngmt of stand 77

Planned for haul from stand 75; dry season or extended season w/ lift; road has small failure at 120'; fix under 8377119 8377 Non-key 0.40 Agg Dry 0.40 1 2 1 1 0.40 maintenance prior to haul ; no stream pipes; starts ridge top and drops to upper RT location; store for cont mngmt of stand 75

8377125 8377 Non-key 0.07 Agg Dry 0.07 1 2 1 1 0.07 Planned for haul from stand 73; store road after use; no streams; flat grades; store for continued mngmt of stand 73

Planned for haul from stand 73; store road after use; easement in section 22 across pvt on file; consult pvt land 8377139 8377 Non-key 0.20 Agg Dry 0.65 1 2 1 1 0.65 1 owner about storing road, and about bad pipe on pvt portion; one stream pipe recommended for removal w/ storage on NF lands under 2012 Nestucca Rds CE, another should be replaced on pvt portion; question why our jurisdiction continues past last pvt land bdry

Road accesses more pvt and state land than NF lands; planned for haul from stand 70; four stream pipes 8503000 Co Rd 863 Non-key 1.60 Agg A/S 2.30 1 2 1 2 4 recommended for replacement and covered under Nestucca Legacy Roads 2012 CE; high priority, do we have easement through pvt and cooperative road agreement w/ State?

8503111 8503 Non-key 0.50 Agg Dry 0.50 1 2 1 1 0.50 Planned for haul from stand 70; has minor drainage issues; no streams, flatter grades; upper ridgetop location; planned for storage under 2011 Nestucca Rds CE I

8503112 8503111 Non-key 0.30 Agg Dry 0.30 1 2 1 1 0.30 1 Planned for haul from stand 70; one stream pipe recommended to remove with storage after sale under 2011 Nestucca Rds CE I; upper ridgetop location; crosses state land

This segment starts at the beginning off BLM rd and ends at the 112 jct; planned for haul w/ stands 132 and 134; BLM Rd Non-key 0.97 Agg A/S 0.97 DE 2 1 2 1 8505000 begins on BLM land; check agreements; plan to leave open for rec access to ridgetop system; one stream pipe recommended for replacement under 2012 Nestucca Roads CE

Haul planned from stand 132; one stream pipe recommended for removal w/ storage under 2012 Nestucca Rds CE; 8505112 8505 Non-key 0.68 Agg Dry 0.68 DE 2 1 1 0.68 1 road built to low standard w/ little structural strength; INFRA distance updated; GIS mapping OK; temp rd in stand 132 leaves from end of "system" road

North Nestucca Environmental Assessment 7 Appendix C

North Nestucca EA Roads Analysis

8505113 8505112 Non-key 0.30 Agg Dry 0.30 DE 2 1 1 0.30 Haul planned from stand 132; no streams; very low standard road; chest high in ferns; store for continued mngmt of stand 132 using barricade and water bars

This segment starts at beginning termini and goes to MP 1.86 or to the OHV trail to Battle Lake; Road planned for 8573000 Co Rd 851 Non-key 1.86 Agg A/S 1.86 2 2 2 2 2 1 haul from stands 58 and 60; Bays Creek undercutting rd w/in first 500' of FS maint jurisdiction; geo-tech report on file; recommend to keep open; 2 str pipes recommend to replace under 2012 Nestucca Rds CE, a 4th pipe (fish passsage) is covered under 2011 Nestucca Legacy Roads CE I; FS has maint agreemt w/ county for approx first 0.2 mi; meadows along this segment of road have attracted ongoing OHV; meadow habitat potentially degraded with continued use

8573000 MP 1.86 Non-key 2.54 Agg A/S 2.54 2 2 1 1 2.54 1 This segment starts at MP 1.86 or at the OHV trail to Battle Lake; planned for haul from stands 58 and 60; several deferred stands along rd on ridgetop; one stream pipe recommended to remove w/ storage under 2012 Nestucca Rds CE; ridgetop location for most of this segment; needed for ongoing and future mngmt of stands

8573115 8573 Non-key 0.93 Agg Dry 0.93 1 2 1 1 0.93 2 Haul planned from stand 58; 2 stream pipes recommend for removal w/ storage

Totals 93.3 109.8 32.2 4.8 69 29

North Nestucca Environmental Assessment 8 Appendix D

Appendix D North Nestucca Project Aquatic Conservation Strategy Objectives Consistency Assessment

Introduction

Alternatives 1and 2 have been evaluated to determine how consistent they are with the nine Aquatic Conservation Strategy objectives of the Northwest Forest Plan. The North Nestucca Project Environmental Analysis (EA) and the Nestucca Watershed Analysis (WA), provide the context for the responses to the Aquatic Conservation Strategy objectives.

Objective 1—Maintain and restore the distribution, diversity, and complexity of watershed and landscape-scale features to ensure protection of the aquatic systems to which species, populations, and communities are uniquely adapted.

Alternative 1 (No Action) The existing distribution, diversity, and complexity of watershed and landscape-scale aquatic features would remain on their current restoration trajectory; which can be either towards or away from desired features, depending on which characteristic is assessed. Desired restoration opportunities would be delayed. For example, the desire to increase habitat complexity by accelerating large wood recruitment into some project area streams would not occur until stands adjacent to the creek mature and naturally enter the channel; a process that is likely to take longer under Alternative 1.

Alternative 2 (Proposed Action) Actions—including commercial and non-commercial thinning (coarse woody debris creation) and understory planting—are designed to accelerate development of late-successional forest, increase terrestrial and aquatic bio-complexity, and increase the diversity of landscape features to maintain or restore upland, riparian, and landscape communities.

Commercial and non-commercial thinning projects are expected to encourage the rate of development of large conifers in riparian and upslope areas, understory complexity, and species diversity. Understory planting projects are expected to increase vegetation species diversity and accelerate the development of multiple stand layers; increasing the complexity of these landscape scale features.

North Nestucca Environmental Assessment Page 1

Appendix D

Vegetative complexity would be maintained within No-cut riparian buffers. Riparian buffer widths would vary, depending on fish presence, stream size, slope stability, shade cover, sediment delivery potential and other water quality considerations.

Objective 2—Maintain and restore spatial and temporal connectivity within and between watersheds. Lateral, longitudinal, and drainage network connections include floodplains, wetlands, upslope areas, headwater tributaries, and intact refugia. These network connections must provide chemically and physically unobstructed routes to areas critical for fulfilling life- history requirements of aquatic and riparian-dependent species.

Alternative 1 (No Action) The existing spatial and temporal connectivity within and between watersheds would be maintained. As evidenced in the WA and EA, these conditions are currently less than ideal. Eventually, connectivity would be restored in the project area, as road systems age, decay, and fail, producing a large influx of sediment and debris. As long as poorly functioning road systems remain in their current state without maintenance, they would remain a chronic source of fine sediment and continue to block the flow of wood and sediment needed for properly functioning streams.

Alternative 2 (Proposed Action) Spatial and temporal connectivity within and between watersheds would be improved by implementing projects recommended in Alternative 2. Specific activities that would achieve this objective include maintaining roads and thinning. Design criteria (Appendix A) are intended to maintain or restore connectivity, particularly in riparian areas.

Road maintenance activities include ditch cleaning, waterbar installation, and resurfacing. This maintenance improves the connectivity of drainage networks by increasing the ability of the road system to drain water and sediment. Thinning would encourage the rate at which plantations become mature stands, increasing the connectivity among existing mature stands within and between watersheds.

No-cut buffers along all streamcourses are designed to protect riparian areas from disturbance and maintain a high level of connectivity along these corridors. In addition, temporary road construction would be limited to ridges or generally flat terrain; and no new stream crossings are planned. These criteria serve to minimize the disturbance of intact riparian areas.

Objective 3—Maintain and restore the physical integrity of the aquatic system, including shorelines, banks, and bottom configurations.

Alternative 1 (No Action) The existing physical integrity of shorelines, banks, and stream bottoms would be maintained. No actions to improve these conditions would occur. Natural re-growth of native riparian vegetation may or may not occur in desired locations.

North Nestucca Environmental Assessment Page 2

Appendix D

Alternative 2 (Proposed Action) Project design criteria are intended to maintain the physical integrity of shorelines, banks, and stream bottoms. In the long term, road maintenance would reduce management-related sediment inputs due to chronic erosion of the road prism and related road-stream crossing failures. The physical integrity of the aquatic system would be maintained by no-cut buffers along all stream channels. Additionally, road construction, and reconstruction activities are designed to minimize impacts at project sites. New temporary road construction is limited to stable areas, such as ridges or generally flat terrain; and no stream crossings are planned. These actions maintain physical integrity of riparian areas by conducting these activities outside of (or away from) hydrologically connected riparian areas.

Objective 4—Maintain and restore water quality necessary to support healthy riparian, aquatic, and wetland ecosystems. Water quality must remain within the range that maintains the biological, physical, and chemical integrity of the system and benefits survival, growth, reproduction, and migration of individuals composing aquatic and riparian communities.

Alternative 1 (No Action) No actions to maintain or restore water quality would occur under this alternative. Riparian areas directly adjacent to streams would not be treated (i.e., planted with conifers, or thinned to increase growth) to improve streamside shading (which would decrease solar radiation to streams) and otherwise support optimal stream temperatures and dissolved oxygen.

Alternative 2 (Proposed Action) Although no stream in the treatment area is listed as water quality limited for sediment, temperature, or dissolved oxygen, these parameters are also of interest since planned actions can potentially benefit or affect them. Some or all of these parameters may be affected by planned commercial and non- commercial (coarse woody debris) thinning; road maintenance; and meadow maintenance. Actions are designed to maintain or restore water quality. Temperature, dissolved oxygen, and sediment conditions would be maintained in the near term by implementing design criteria, such as variable-width, no-harvest buffers adjacent to all stream channels and wetlands in thinned stands.

In the long term, thinning and road maintenance activities are expected to improve water quality sooner than under the no-action alternative. Thinning encourages the rate of growth of vegetation adjacent to streams, increasing the canopy cover and shaded area, thereby decreasing in-stream heating due to direct incidental solar radiation. Thinning accelerates recruitment of large wood to streams, thereby accelerating associated direct shade to streams and increased retention of in-stream gravels. Water flowing through gravel is subject to decreased exposure to solar radiation, thereby reducing the rate at which water is heated. Road resurfacing and waterbar installation improves water drainage and sediment diversion off the road before it reaches road-stream crossings. Ditch cleaning reduces the road failure risk associated with plugged culverts.

North Nestucca Environmental Assessment Page 3

Appendix D

No planned temporary road construction crosses surface water, so this action would not affect stream temperature, sediment production, or turbidity. Yarding systems were designed to minimize stream crossings, minimizing or eliminating potential effects to temperature, sediment production, and turbidity. Where yarding across streams is planned, implementing design criteria (e.g., limiting the extent of canopy disturbance by having designated yarding corridors, and requiring full-suspension of logs as they are yarded across streams) would protect shade, preventing undue increases in stream temperature; and avoiding delivery of fine sediments, preventing undue increases in stream turbidity. No planned action is expected to affect the level of coliform bacteria in surface or subsurface water in the planning area.

Objective 5—Maintain and restore the sediment regime under which aquatic ecosystems evolved. Elements of the sediment regime include the timing, volume, rate, and character of sediment input, storage, and transport.

Alternative 1 Nno Action) Existing conditions including a degrading road system and overstocked plantations have produced adversely altered watershed functions and processes. Sediment regimes, under which aquatic ecosystems evolved, would continue to be adversely impacted by the no-action alternative.

Alternative 2 (Proposed Action) All elements of the sediment regime were considered in the design of the project. Road-related actions were chosen to maintain and restore the sediment regime under which aquatic ecosystems evolved. Frequency of landslides, rates of bank erosion, and volumes of sediment input are affected by factors, such as vegetative conditions in riparian or landslide-prone areas and concentration of flow from roads and landings. The sediment regime will be restored by thinning in managed stands to improve vegetative conditions in treated riparian areas, and maintained by avoiding landslide-prone areas.

Road maintenance is intended, in part, to remove or minimize concentration of water flow from roads and to restore connections between surface and subsurface flow between inter-fluvial and fluvial areas. Road treatments decrease effects of past actions on the sediment regime by reducing the rate and volume of sediment delivery due to chronic surface erosion. By locating new temporary roads on ridges or generally flat terrain, and avoiding stream crossings, the risk of sediment delivery from these sources would be greatly reduced, if not eliminated. Associated work sites may continue to produce small amounts of sediment during and immediately after rain events throughout the first winter until the sites are revegetated and stable. Any short-term increases in sediment production or turbidity are expected to be minor and limited to headwaters and well within the range typical of high winter flows or natural streambank erosion.

Based on observations of past thinning sales with similar prescriptions, riparian buffers, soils, and landforms, there is no evidence that the project would increase rates of shallow or deep seated landslides.

North Nestucca Environmental Assessment Page 4

Appendix D

Objective 6—Maintain and restore in-stream flows sufficient to create and sustain riparian, aquatic, and wetland habitats and to retain patterns of sediment, nutrient, and wood routing. The timing, magnitude, duration, and spatial distribution of peak, high, and low flows must be protected.

Alternative 1 (No Action) Current, adversely degraded conditions that affect in-stream flows would be maintained. The opportunity to rehabilitate road drainage patterns would be delayed until natural processes produce failures at these crossings.

Alternative 2 Road maintenance activities are most likely to affect in-stream flows. There is high natural variability in discharge that is related directly to annual or seasonal precipitation. As such, it is difficult to predict how, when, and where proposed activities would affect the timing, magnitude, duration, and spatial distribution of peak, high, and low flows. However, it is expected that the effects described below are likely to occur, if proposed actions are implemented. Road drainage networks can alter the timing, magnitude, duration, and spatial distribution of peak, high, and low flows in a watershed. Installation of waterbars, ditch cleaning, and road resurfacing is designed to improve natural processes of streamflow regulation at both the local and watershed scale.

Plantation thinning is not expected to result in measurable changes in streamflow at both the project and the watershed scales, due to the amount of remaining vegetation (which results in minor changes in evapo-transpiration rates), low elevation of the project area (because the area receives minimal snow, patterns of snow interception and retention would not be altered), and the small portions of the watersheds that would be affected.

Objective 7—Maintain and restore the timing, variability, and duration of floodplain inundation and water table elevation in meadows and wetlands.

Alternative 1 (No Action) Current, adversely degraded conditions affecting floodplain inundation would be maintained. For example, the opportunity to accelerate large wood recruitment to planning area streams, improving connectivity to the floodplains, would be postponed or not occur.

Alternative 2 (Proposed Action) Design criteria, such as no-cut riparian buffers and full-log suspension requirements over streams would protect floodplains. In the long term, plantation thinning and under-planting would increase the rate of large-conifer development in riparian areas, which would increase the future supply of large wood to some floodplains and stream channels, restoring floodplain function.

North Nestucca Environmental Assessment Page 5

Appendix D

Objective 8—Maintain and restore the species composition and structural diversity of plant communities in riparian areas and wetlands to provide adequate summer and winter thermal regulation, nutrient filtering, appropriate rates of surface erosion, bank erosion, and channel migration and to supply amounts and distributions of coarse woody debris sufficient to sustain physical complexity and stability.

Alternative 1 (No Action) Existing plant communities in riparian areas would be maintained. These conditions are less than ideal. For example, the WA recommends riparian planting and thinning to increase future canopy closure to reduce solar radiation and optimize stream temperature. Without these efforts, less-desirable species (e.g., blackberry) would continue to impede the colonization of desirable riparian species (e.g., big-leaf maple, western red cedar), resulting in continued degradation of thermal regimes and distribution and supply of coarse woody debris.

Alternative 2 (Proposed Action) Plantation thinning, understory planting, snag and coarse woody debris creation, are intended to restore species composition and structural diversity of plant communities in riparian areas. Habitat elements such as large standing conifers and downed wood, multi-layered canopies, and species diversity would be improved by these activities. Silvicultural prescriptions include retention of larger diameter trees and favor less common tree species in stands. Variation of species composition would be promoted within stands, with the retention of the hardwood component being emphasized.

Design criteria, such as no-cut riparian buffers and yarding restrictions, are intended to maintain species composition and structural diversity of plant communities.

Objective 9—Maintain and restore habitat to support well-distributed populations of native plant, invertebrate, and vertebrate riparian-dependent species.

Alternative 1 (No Action) Existing, degraded habitat conditions for riparian-dependent species would be maintained. Opportunities to improve habitat conditions would be postponed or not occur; relying completely on natural processes to reverse the current trend and to produce a trend towards recovery of populations of native plant, invertebrate, and vertebrate riparian-dependent species.

Alternative 2 (Proposed Action) All activities are designed to restore natural processes or encourage development of habitat for native riparian-dependent species. Design criteria such as no-cut riparian buffers and locating temporary roads on ridges to avoid stream crossings are intended to maintain habitat for riparian-dependent species. Restoring habitat for riparian-dependent species is promoted by encouraging the development of late- successional and old-growth forest habitat in plantations in and adjacent to riparian areas.

North Nestucca Environmental Assessment Page 6

Appendix D

Summary

Alternative 1 In the short term, roads not maintained to standard provide the greatest risk to meeting the nine Aquatic Conservation Strategy objectives. Roads would deteriorate and eventually fail, especially at stream crossings. When roads fail, aquatic resources are often substantially, detrimentally affected, at least for a short term. As such, degraded water quality would continue, until natural processes have removed sediments associated with road fills—a process which could take decades. In the long term, restoration of complex aquatic and terrestrial elements—such as large wood in streams and uplands, and stands with diverse tree species and sizes—would depend on natural processes and take much longer to develop than under Alternative 2. Therefore, this alternative is not expected to meet the objectives of the Northwest Forest Plan’s Aquatic Conservation Strategy, because current watershed conditions would not be maintained or improved.

Alternative 2 The project includes some actions that would result in short-term increases in sediment production at specific sites. For example, haul has the potential to increase fine sediment delivery and transport. Any stream channel disturbances or adverse water quality impacts are designed be mitigated to small, isolated short-term effects. At the watershed scale, changes in water quality, turbidity or sediment production would not be detectable. Design criteria were developed to minimize short-term adverse impacts to aquatic resources and to retain desirable watershed conditions (Appendix A). Overall, proposed actions would maintain or restore riparian vegetation and aquatic conditions and processes by maintaining roads; promoting the development of late-successional forest habitat in stands (e.g., thinning, under-planting, and creating dead wood), both within and outside of riparian areas. Therefore, actions proposed by Alternative 2 are expected to meet the nine objectives of the Aquatic Conservation strategy.

North Nestucca Environmental Assessment Page 7

Appendix E Appendix E North Nestucca Environmental Assessment

Response to Comments

The 30-day public comment period for the proposed North Nestucca Environmental Assessment opened on October 17, 2012 and closed on November 16, 2012. Three comment letters, emails or phone calls were received. Comments were received from the following:

Commenter Name Organization Type of Comment Date Received ID DA Dick Artley Himself Email/attachments 10/21/2012 AG Andy Geissler American Forest Resource Council Email/letter 11/14/2012 DH Doug Heiken Oregon Wild Email/letter 11/13/2012 All comments submitted were considered and addressed. Examples of comments which are most helpful are those which:

 Provide new information pertaining to the preferred alternative or an alternative in the analysis;  Identify a new issue or expand upon an existing issue;  Identify a different (alternative) way to meet the purpose and need of the project;  Provide an opinion regarding one or more alternatives, including the basis or rationale for that opinion;  Point out a specific flaw in the analysis, or;  Identify a different source of credible research, which if used in the analysis could result in different effects.

It should be noted that all comments received are valuable. Alternative preferences, values and feelings also contribute to increased understanding and were carefully read and considered. The following narrative contains the comments, grouped by commenter, followed by the Forest Service’s response.

North Nestucca Environmental Assessment Page 1

Appendix E 1. Proposed Project Comment Summary and Forest Service Responses

# ID Comment Response Please include these opposing view source documents in the References section of the final The reference section of the EA is for those references cited in the document. The EA. When describing the environmental effects of the timber sale activities to the countless 1 DA references cited by the commenter are contained in the text of the comments in Appendix E, natural resources in the project area please cite the resource damage described in the source and thus are part of the public record. documents contained in the attachments. The EA contains an in depth analysis of the effects of the action, and meets the It violates the law to give the public a skewed (one sided) description of the environmental requirements for a “hard look”. An EA contains an analysis of the effects of an action to effects of a proposed project as you have done in this pre-decisional EA. I suggest you the level where the responsible official can make an informed decision. The EA is not 2 DA become familiar with the meaning of “hard look.” You should also read the Administrative expected to be an exhaustive compendium of all of the analysis conducted for the project. Procedures Act. Addition information is available in the specialist’s reports which are part of the public record. The opposing views quoted in Attachment #1 were authored and/or signed by 237 different There are 211 references cites in Appendix F. Of those references 74 (35%) are from unbiased Ph.D. biological scientists with no connection to the USDA. Does it surprise you scientific journals. Nineteen (9%) of the references are publications from universities and an that about 77% of the source documents listed in the References section of this pre- additional 10 (5%) are publications from various State of Oregon agencies. Thirty nine 3 DA decisional EA that drove the project are authored by USDA employees with financial (19%) are publications of the USDA Forest Service. Other federal agencies, books, incentives to portray logging as ecosystem-friendly? Intelligent Americans will meeting proceedings and other sources compose the remainder.. immediately detect bias towards logging in the References. The opposing views quoted in Attachment #4 were authored and/or signed by 52 different The Forest Service acknowledges that road related activities have the potential to cause 4 DA unbiased Ph.D. biological scientists with no connection to the USDA. They indicate that resource damage. That is why extensive analysis and development of Project Design road construction inflicts more resource damage than any logging-related activity. Criteria to prevent or mitigate these effects is such an important part of the document. The attachments contain statements by over 500 nationally recognized Ph.D. biological scientists who describe how and why logging and road construction inflict long-term, The Forest Service acknowledges that thinning projects like these do have impacts on the irreversible damage to countless natural resources in the forest. Of course Forest natural environment. However, projects like this are focused on areas that have already 5 DA Supervisors and District Rangers who manage the public land in a competent manner they been impacted by previous management practices. These projects Are designed and would halt all commercial timber sales their jobs would be in jeopardy. This provides a intended to encourage the development of more natural based processes in these areas. financial incentive to harm the natural resources in the forest with unneeded commercial timber sales. The Forest Service does not claim does not claim to know more about the ecological impacts of road building and thinning activities than 500 scientists quoted in the attachment. Does the Responsible Official believe their TMA and silviculturist know more about the However, we do have a more in depth knowledge of this specific local site and the 6 DA ecological impacts of logging and roading than the 500 scientists quoted in the conditions present. We do utilize, as much as possible, the available scientific literature in attachments? Yes or No. Please explain. developing treatments for these managed plantations. And we constantly review new literature and refine our methods in trying to restore natural functions in these managed plantations. After reading the quotes in the attachments does the Responsible Official feel comfortable The decision maker does not reject the conclusions of these 500 scientists. They are part of 7 DA basing his decision to proceed with the North Nestucca timber sale based on the advice of the environmental documents reviewed by the decision maker in making his decision.

North Nestucca Environmental Assessment Page 2

Appendix E the TMA and silviculturist? This rejects the research conclusions of 500 scientists. Why However, a suite of applicable environmental laws, court decisions, as well as management does this reflect sound decision making? plans and policies are all considered in making a decision concerning this specific project. Please do not discount the scientist’s observations by claiming:

1) there will be no compelling, major adverse natural resource impacts because the timber 1.) The Forest Service acknowledges that there will be environmental impacts from this sale planning is guided by BMPs and the forest plan unless the Responsible Official project. The Project Design Criteria included in this decision will be legally binding on any identifies the specific guidance, where it is applied and how the guidance will mitigate the actions resulting from this project and they will be included in any contract provisions likely impact to the resources. developed for this project. In addition, all provisions from other applicable environmental

laws will have to be met and included in contract provisions and project implementation. 2) claiming they are not site-specific to this timber sale. All the damage discussed by the This includes such things as the National Environmental Policy Act (NEPA), the scientists is clearly intended to apply in all cases where an action occurs. If the Responsible Endangered Species Act, the Clean Water Act, The National Forest Management Act, the Official still claims the scientists’ predictions do not apply because they are not sit-specific Equal Justice Act, the national Forest Management Act, and many others. 8 DA then the Responsible Official must not include and literature in the References section of 2.) All of the potential damages and impacts discussed by the various scientists must be the final NEPA document that does not mention the name “North Nestucca.” considered in the analysis. Site specific conditions must be considered in so far as how they

interact with the various impacts. The site specific conditions could ameliorate the impacts, 3) rejecting the opposing views because they are “opinions” won’t work. View and opinion or even accentuate the impacts. are synonyms. 3.) Views and opinions can be considered to be opinions. But, it is the deciding official

tasks to weigh all of the factors in coming to a conclusion. And, it is the job of the The Responsible Official must “base decisions on a consideration of the relevant factors and Interdisciplinary Team to provide the official all of the information needed to make an must “engage in a substantial inquiry into the facts, one that is searching and informed decision. careful.” When the Responsible Official fails to cite literature in the References section of the EA describing the likely adverse effects of logging-related activities he does not consider the relevant factors. In order to assure that the logs will be processed by local labor in the woods and the logs are 9 DA hauled to local mills the sale must be sold under the small business authority (SBA). The We operate under the Small Business Association guidelines for all timber sales. pre-decisional EA does not indicate this will be the case. The purpose of this project is not to generate a wood product for the local community. The Northwest forest Plan provides clear direction that only projects designed to restore natural systems and functions are allowed. The generation of a wood product is a byproduct of the restoration objectives. That byproduct may have a value in the local economy, but that In the final EA please identify the names of the local communities that need economic help alone would not justify implementation of this project. There are mills in several of the 10 DA by providing more raw materials for wood products. surrounding communities and we receive regular enquiries about the availability of various forest products. We receive multiple bids on most, if not all, of the timber sales that we make available. This public interest in the availability of forest products is universal throughout the district. Naming of individual communities would serve no useful purpose for this project. Not all local communities have a timber extraction-based economy. In the final EA please The purpose of this project is not to generate a wood product for the local community. The 11 DA include the economic analysis showing that the particular communities needing economic Northwest forest Plan provides clear direction that only project designed to restore natural

North Nestucca Environmental Assessment Page 3

Appendix E help by providing more raw material for wood products: systems and functions are allowed for lands with these planning designations. The generation of a wood product is a byproduct of the restoration objectives. That byproduct 1) have a timber-based economy, and may have a value in the local economy, but that alone would not justify implementation of 2) the economy is in jeopardy because of the lack of timber this project. There are mills in several of the surrounding communities and we receive regular enquiries about the availability of various forest products. We receive multiple bids on most, if not all, of the timber sales that we make available. This public interest in the availability of forest products is universal throughout the district. Naming of individual communities would serve no useful purpose for this project. The quote below from the USFS survey discussed above proves that the Proposed Action in Timber harvest is a byproduct of the restoration objectives in this project. Timber harvest is the North Nestucca pre-decisional EA is the antithesis of what the American public want only allowed under the Northwest Forest Plan when it is a byproduct of restoration done to their precious national forest land: activities. thinning from below has been determined to be a viable tool in restoring natural 12 DA processes in these plantations. The survey also stated that provision of natural resources to “The public sees the restriction of mineral development and of timber harvest and grazing dependent communities is still seen as somewhat important. as being more important than the provision of natural resources to dependent communities (although this is still seen as somewhat important).” (Pg. 28) Ranger Buckingham, you are arrogant enough to accept your salary provided by the 13 DA American public to caress your corporate masters and still consider yourself a public Comment noted. servant. The Hebo Ranger District has a long history of creating economically viable timber sales. 14 AG AFRC would like to see all timber sales be economically viable. We have not had a problem selling one of our sales in more than 20 years and for the past five years commonly have more than one bidder on every sale. Appropriate harvesting systems should be used to achieve an economically viable sale and We plan for the most economical harvesting system allowed within our Forest Plan 15 AG increase the revenues to the government. guidelines. As discussed at our meeting with AFRC two years ago, the Siuslaw sale contracts allow a We would like to see flexibility in the EA and contract to allow a variety of equipment variety of equipment. At that time AFRC representatives planned to use our contract specs 16 AG access to the sale areas. as examples for other Forests in Region 6 to follow. We are still using those specifications and our operators often express appreciate for that part of our contract. Though some of the proposal area is planned for cable harvest, there are opportunities to Those types of equipment are authorized on many portions of the analysis area where 17 AG use certain ground equipment such as fellerbunchers and processors in the units to make resource considerations allow. cable yarding more efficient. We feel that there are several ways to properly harvest any piece of ground, and certain 18 AG Comment noted restrictive language can limit some potential bidders, thus driving the bid value down. Including language in the EA and contract that specifies damage tolerance levels rather than Where possible, our contract language specifies damage tolerance limits rather than firm 19 AG firm restrictions gives the operator flexibility to utilize their equipment to its maximum restrictions. efficiencies. For example, quantifying a residual stand damage threshold rather than entirely restricting 20 AG activity during certain months will allow an operator the flexibility to alter their yarding Comment noted. techniques to meet the threshold throughout the seasons instead of having to completely

North Nestucca Environmental Assessment Page 4

Appendix E shut down during certain months. Constructing forest roads is essential if active management is desired, and we are glad to 21 AG see that the Forest Service is proposing the roads that are needed to access and treat as much Comment noted. as the project area as possible in an economically feasible way. Year-round haul is desirable for most operators that we work with. However, environmental protection measures are often expensive and may limit year-round haul in The ability to yard and haul timber in the winter months will often make the difference some areas, especially in marginally viable harvest units. 22 AG between a sale selling and not, and we are glad that the Forest Service has designed this We will continue to offer extended season of haul provided there is no effect to listed Coho project to allow for year round timber haul. habitat or species. This may include additional mitigations for road improvement to allow haul during wet seasons. Purchasers to date have shown a willingness to work with the Forest Service to this end The project has analyzed for a minimum road system that accounts for sustained ecosystems We also understand the Forest Service’s financial challenge of maintaining a large road while providing options for multiple resource management. We agree with your conclusion 23 AG system; however, there are ways to negate these costs while still adding critical new roads that stored roads with water bars and some culverts removed can be an inexpensive to its system and keeping existing ones. solution. Stored roads remain on the system for future use while reducing maintenance costs. Existing roads proposed for decommissioning have an interdisciplinary review and have been determined no longer needed for multiple resource management. Newly constructed roads in this project are built to low standard in order to reach restoration and management We encourage the Forest Service to carefully consider the future management needs and goals for one time use. They are temporary. They have no purpose beyond this entry and 24 AG added costs of fully decommissioning roads throughout their landscape. generally are inexpensive to barricade and water bar. Environmental costs, economic feasibility, and future access needs are carefully analyzed for each road when we have to consider decommissioning.

With the need of increasing stand complexity stated in the EA, we would like to voice our 25 AG Comment noted. support of gap cuts and thinning across all diameter classes. We would like the Forest Service to use prescriptions that focus on residual stand In some cases diameter limits are the best and most cost-effective tool that we have to meet 26 AG conditions and to avoid diameter limits that may hinder this desired condition. the desired condition. We would also like the Forest Service to consider thinning heavier on certain stands in their Heavy thinnings are often considered for that reason, However, most of our stands are so 27 AG LSR to promote species diversity. dense that windthrow concerns prevent us from conducting heavy thinnings at this time. AFRC is glad to see that the Forest Service is being proactive in treating riparian reserves. 28 AG However, we feel that the Forest Service could be treating a much higher percentage of the Comment noted. riparian reserves based on the best available science and the expertise of your ID team. The analysis in the EA from pages 97-103 makes it clear that the reduction in large trees for Reduction of large trees for wood recruitment into streams is recognized as a limiting factor 29 AG wood recruitment into streams is the primary threat to the recovery of coho salmon. for coho in freshwater habitat Large wood recruitment into coho habitat from the no-thin buffers is still expected to occur, Yet this project excludes such manipulation by placing excessively large no-thin buffers in 30 AG with the predominant large wood recruitment occurring from the 99% of LFH (coho) stream the areas that are capable of large wood recruitment to coho streams. corridors in the Project area that are not adjacent to the proposed thinning.

North Nestucca Environmental Assessment Page 5

Appendix E These no-thin buffers are being implemented to limit any stream temperature changes, The Forest Service desires to maintain the streams as un-impaired for temperature. No-thin 31 AG despite the fact that the EA recognizes that none of the streams within the project area buffers will help to maintain current conditions. harvest units are temperature impaired. However, they are impaired by lack of large trees for future wood recruitment. So why are Not thinning the buffers eliminates the risk that thinning operations in the buffer might 32 AG treatments being designed to favor one water quality element that is not impaired at the cost cause sediment runoff into critical fish habitat. of another that is impaired? We would like the Forest Service to start designing riparian reserve treatments on a site- specific basis. Using a hard number for setting a minimum no-thin buffer undermines site The riparian reserve treatments proposed by this Project were developed at the plantation specific conditions and local knowledge. AFRC is in support of each ranger district’s staff site scale with close coordination between multiple resource specialists. Minimum no-thin 33 AG making professional on the ground decisions on how to best manage their resources rather buffers were established to be variable based upon site scale conditions and the multiple than using an arbitrary number designated by a regulatory agency that has never even effects of riparian stand treatments. visited the project area. Perhaps future projects could include an alternative that proposes riparian treatments based 34 AG on local knowledge & needs to compare to the alternatives that are based on outsider Comment noted. opinions. We would also like the Forest Service to consider including or referencing some of the following pieces of scientific research into their analysis. Much controversy surrounding any type of thinning in riparian reserves has surfaced, and we think the following information would be useful in justifying the kinds of beneficial treatments the BLM implements. Individual specialists review the literature to determine which publications are most 35 AG Dolloff a Keim et al., 2002a nd Warren, 2003 relevant to their analysis. The district will request the complete citations from the Naiman et al., 2002 commenter so that this information can be available for future analyses. McEnroe, 2010 Minor (1997 McDade et al. (1990) Welty et al. (2002) The project design features recommends releasing the larger conifers. This is a good Appendix A contains direction for managing any trees containing potential murrelet objective if the largest conifers are just the largest in the plantation, but if there are legacy 36 DH structure found within stands proposed for treatment . The stands proposed for treatment trees that may harbor marbled murrelets or red tree voles, it may be more important to are less than 70 years old and do not contain any red tree vole nesting structure. buffer those trees rather than release them Pages 18 and 19 of the EA did not display properly. Some of the text appears to be missing. 37 DH Online posting of EA corrected to include inadvertently omitted text. Is that because this is a draft EA. 38 DH Will there be an opportunity to comment on a final EA? The 30 day comment period for this EA is complete. Mature, hardwood-dominated stands do have a variety of shrubs in the understory. The EA describes the mature hardwood stands as having salmonberry dominated However, salmonberry is the most common shrub in most of those understories at this time. understories. This seems to be a bit of an oversimplification. The understory of the stands 39 DH Since the proposed hardwood stand treatments were not economically viable, we dropped we saw on our field tour seemed relatively diverse in terms of species composition. Maybe them from consideration in this analysis and did not further quantify understory species in the diversity (or lack thereof) should be quantified somehow. this analysis.

North Nestucca Environmental Assessment Page 6

Appendix E This design criteria was incorporated from the North Coast Late Successional Reserve Assessment (LSRA) guidelines for coarse woody debris management (CWD) on page 92 and are required to be followed in order for the project to be exempt from REO review. The LSRA provides guidance and flexibility to implement certain activities that have been shown to have a high probability of achieving the goals and objectives outlined in the Why retain only 10% of snags 9-20” dbh? Retaining existing snags is only short-term Northwest Forest Plan (LSRA at 1). The guidelines which were incorporated into the 40 DH mitigation, but it’s worthwhile to try to retain as many as possible, especially in LSRs and design criteria for this project suggest where safety considerations are met, retain all snags riparian reserves. equal or greater than 20’ dbh and ten percent of snags between nine and 20 inches in dbh (snag use will be greater in the size classes closer to 20 than to nine). Retain any snags knocked over during management activities as down wood. The only snags which will be intentionally felled as part of this project will be as a result of safety mitigation (LSRA at 92). This language clarifies that it is desirable if possible to give preference to retaining the larger snags over the smaller snags. In wet environments like the Oregon Coast range, carpenter ants tend to favor standing snags rather than down logs, because the standing snags have moisture conditions more The EA discuss effects to pileated woodpeckers. Pileated woodpeckers are associated with favorable for the ants. Therefore, the provisions for pileated woodpecker habitat should be mature snags and down low which are currently lacking in the stands proposed for thinning. 41 DH adjusted to emphasize more retention of standing snags (recognizing it will eventually fall Thinning to accelerate late successional characteristics including large snags and down and become down wood too). And, since snags do not persist as long as down wood, all wood should benefit pileated woodpeckers in the long term. For a discussion on the things being equal, in order to support a similar number of ants and woodpeckers, more management and effects to MIS species and to pileated woodpeckers. snags need to be recruited and retained. The 110 acres at risk for heavier blowdown are not proposed for treatments and have Rethinning stands that have been previously thinned should be carefully considered because considerable amounts of down wood and snags. Of the remaining 418 acres, slightly less it exacerbates and perpetuates the problem of captured mortality. If this activity is than half are proposed for treatment in this analysis. Stands proposed for treatment are 42 DH contemplated (the EA is not entirely clear on this), it should be done on only a small subset those with the highest densities of live treess (farthest from achieving the desired of the previously thinned stands. condition). These stands are also proposed for the highest levels of down wood and snag creation. The Siuslaw NF project website says that this project includes potential treatment of “338 acres of alder dominated upper slopes” but the EA does not include that in the proposed action so we are a little confused whether that is included in this project. If the FS has Alder dominated stands are no longer proposed for treatment in the analysis, see 43 DH deferred these areas, we are fine with that. We feel that the over-mature alder and shrub Alternatives Considered But Eliminated From Detailed Analysis. stands represent a beneficial feature of landscape diversity, so we are unconvinced there is a need for treatment. If the FS thinks that these stands should be managed in the future, we urge the FS to do some test treatments and monitoring. The EA includes several references to the “Niagara-Boulder” project. Maybe this was These are copy and paste errors due to carrying over material from previous EA’s, they will 44 DH intentional and is used as a comparison or example but maybe this is a cut-and-paste be corrected. problem. Project design criteria and best management practices implemented on similar thinning 45 DH We discourage wet season logging and hauling in order to protect soil, and water quality. projects on the Forest have proven to be very effective at protecting soil and water quality

North Nestucca Environmental Assessment Page 7

Appendix E in the wet season. The EA refers to “(Mellen-McLean 2011)” but we did not find the complete reference Cited in both the Wildlife report and the EA, but not in either reference list.. This reference 46 DH anywhere in the EA. will be added to Appendix F. The EA has some good descriptions of the need for thinning but it lacks a balanced description of the trade-offs. The EA (p 17) says “With one known exception, all current The sentence, “With one known exception, . . . increasing habitat diversity.” is confusing. scientific evidence points to the need for thinning young, dense managed stands to achieve It is being changed to, “With one known exception, all current scientific evidence indicates conditions favorable for developing old growth upland and riparian forest characteristics that the large old trees in old growth stands developed at low stocking levels, far different and increasing habitat diversity. … Therefore, the District Ranger feels the preponderance from the dense, young managed stands that are proposed for treatment in this analysis area.” 47 DH of the evidence suggests that an early reduction of stand density is the most prudent These large old trees are the cornerstone of old growth stands as they provide many approach “… thinning captures mortality which is an essential feature of late successional essential habitat components and develop into the large snags and down wood that are also habitat, so with thinning there are trade-offs between large trees and diverse understories so important to many species. Thus, the rest of that paragraph on page 17 of the analysis versus long-term dead wood recruitment. This issue is not adequately addressed in the EA, will remain the same. including the “needs” analysis.” The EA analysis of the need for thinning characterizes Linda Winter’s study of the yellow jacket stand in Washington as some kind of aberration that conflicts with other evidence. We would characterize her results differently. Instead of asking whether thinning is universally good or bad, or whether old growth develops exclusively from more dense or less dense stands, it would be better to view Winters’ study as an example of the fact that 48 DH Comment noted. late-successional old-growth conditions can develop from a variety of different initial conditions via a diversity of developmental pathways. A framework like this that emphasizes diversity leads to a different set of conclusions about the efficacy of for thinning as many acres as possible versus an approach that seeks to find the optimal mix of thinned and unthinned stands across the landscape. Stands that are too dense, will thin themselves. Consider for instance the findings of Lutz. J.A. 2005. The Contribution of Mortality to Early Coniferous Forest Development. MS Thesis. University of Washington. http://faculty.washington.edu/chalpern/Lutz_2005.pdf and Lutz & Halpern 2006. Tree Mortality During Early Forest Development: A Long-Term Study Of Rates, Causes, And Consequences. Ecological Monographs, 76(2), 2006, pp. 257– See page 40 of the analysis. Lutz study confirms that natural disturbance events such as 49 DH 275. http://cfr501.jamesalutz.com/Lutz_Halpern_Mortality_EM_2006.pdf. These papers windthrow and root disease are important process for creating diversity in the young show that non-competitive mortality (including small-scale contagious disturbances such as managed stands, as we identified on that page. tree fall events) remains a strong driver of stand development in dense young stands and it can produce desired results such as canopy gaps, dead wood recruitment, heterogeneity, density reduction, etc. These finding deserve to be a part of the description of the no action alternative. The consultation elevation process being conducted by the Siuslaw NF and NMFS is This issue has been elevated to higher level teams in the consultation process, as there is confirming that heavy thinning does not leave enough green trees to adequately provide for clear disagreement between National Marine Fisheries and Forest Service scientists 50 DH long-term recruitment of dead wood, so heavy thinning, if applied to broadly, cannot restore regarding the best science available. If it was easy for scientists to agree that heavy “reference” conditions of dead wood. thinning does not leave enough green trees to adequately provide for long term dead wood

North Nestucca Environmental Assessment Page 8

Appendix E recruitment as would be expected in natural stand development, this issue would have been resolved long ago. It has not been resolved. Heavy thinning reduces the amount of small dead wood created in the short term to encourage the development of large trees that can provide large dead wood in the long term – see deadwood analysis in Appendix G. It is difficult to comment on this figure based on the information provided without knowing how the data was derived, what models were used to project growth and mortality, whether This project proposes to thin to 50-100 tpa. In the figure below, {figure contained in the models used accurately projected in-growth of an understory, etc. Dead wood comment letter} please carefully consider the dead wood recruitment pattern for that recruitment is a serious consideration in this analysis because it is such an important 51 DH thinning intensity compared to the reference stand average and standard deviation. Heavy component of late successional stands for many species, see the analysis and Appendix G. thinning clearly misses the mark. Our analysis indicates that the proposed thinnings are the best way to encourage development of many late successional forest habitat characteristics, including the development of large dead wood, especially large snags. Thinning to 100 trees per acre focuses on maximizing stand growth, rather than individual The unavoidable conclusion is that thinning to less than 100 tpa should be limited to tree growth. Individual trees would still be growing so close together that they would be patches, and that significant patches within treated stands should be retained unthinned, or unlikely to achieve the desired condition of accelerating the development of old growth 52 DH thinned very lightly in order to mitigate for the effect of “captured mortality” in areas that characteristics. Prescriptions include leaving at least 10% of stands in unthinned patches. are commercially thinned. Recent experience indicates that in reality; due to fish and wildlife buffers and logging system limitations, we end up leaving more in the range of 30-35% in unthinned patches. The EA (p 64) erroneously states that Alt 2 “will not contribute to a loss of mature conifer As described in the response to comments above, it is difficult to comment on the figure habitat or snags ≥ 20” dbh…” The figure above clearly shows that large dead trees are that is referenced in this comment, or draw a similar conclusion. Based on the analysis that 53 DH significantly diminished by thinning to 50-100 tpa, and since dead wood is an important was done for this project, which was conducted using the best available science available, component of “mature conifer habitat,” that habitat will suffer as well. This needs to be the EA is accurately depicts the effects of the action. acknowledged and mitigated. Figures 1-6 display DecAID cumulative species curves. It would be useful to show the 54 DH Comment noted. effects of the action and no action alternatives (over time) on those charts. As shown in Appendix G, current growth and yield models do not accurately reflect The DecAID dead wood analysis is focused on the coastal lowland, small-medium, conifer mortality that we are experiencing in study plots, so it is difficult to project (with any hardwood forest type because that accurately describes the stands’ current condition. accuracy) mortality into the distant future. This limited knowledge led to the development However, the goal is future late successional habitat with optimal levels of dead wood. The of the four strategies identified in the Late Successional Reserve Assessment and discussed REO says that the agencies should help mitigate for the landscape deficit of dead wood by in Appendix G, Conclusions. Using the model that appears to be most accurate, Appendix 55 DH managing LSRs for ecologically optimal levels of dead wood even if that is more than G displays the projected mortality at stand age 101 in unthinned stands. Snag sizes are typical. The EA should therefore project the future effects of thinning into the future to clearly smaller than reference conditions at that age, so we reason that reducing live tree determine if thinning does in fact prevent or allow recruitment of optimal levels of dead densities now to levels similar to those that would be found in natural stands at this age, wood when these stands reach late successional age classes. would more likely yield future snag levels and sizes that mimic those natural “reference condition” stands. One important caveat in DecAID is that the “reference” conditions do not include recently This is not an accurate statement. It appears that this comment is referring the caveats page 56 DH disturbed sites, so the reference conditions lack areas of abundant snags that would have in DecAID in the Under-representation of post-fire conditions section where it states that been an important part of the historic landscape condition that wildlife evolved with. This “The inventory data in most cases do not represent recent post-fire conditions very well

North Nestucca Environmental Assessment Page 9

Appendix E needs to be reflected in the analysis and description of reference conditions. because the plots sample conditions arising from a variety of disturbances, including but not limited to fire. The sample plots of older forests might represent at least some post-fire conditions; however, young stands originating after recent wildfire are not well represented because they are an extremely small proportion of the current landscape and often have been salvaged or otherwise treated”. Post disturbance plots are scattered throughout the pre-existing structure stages and are represented by the high snag density classes at the right hand of the histograms (personal communication with Kim Mellem McLean). The effects analysis for snags and down wood do not clearly show the adverse effects of Comment noted. We are currently working on modeling mortality based on current studies captured mortality. The analysis could really benefit from a graphic display of modeling and hope to have this capability in the near future. Based on our observations in natural and 57 DH results like that shown above and/or below {figures in comment letter} from the Umpqua young managed stands it is clear that Figures 19 and 20 from the Umpqua NF example are NF, Cottage Grove District’s, Holland-Moonsalt EA. not accurate for the Siuslaw National Forest. The EA focuses on the short-term (<16 years) effects of thinning on dead wood recruitment when much longer term effects appear more significant and more relevant. The graphic See response above 58 DH from NMFS above {figure in comment letter}shows effects starting at 40 years and

extending out to 140 years. The figure above from the Umpqua NF shows that the effects are subtle at 15 years but become more significant over time. Recent experience indicates that in reality; due to fish and wildlife buffers, and logging 10% untreated “skips” (including stream buffers) may not be enough to recruit natural system limitations; we end up leaving more in the range of 30-35% in unthinned patches in levels of dead wood across the landscape and over time. At a minimum, the 10% should be the treated stands. In this analysis area many of the “stream buffers” extend all the way to 59 DH counted outside of the riparian buffers so that some pockets of dense forest and abundant the ridgetop. Additionally, 57% of the analysis area is in natural stands that are not dead wood recruitment are well distributed across the watershed and not all concentrated proposed for treatment and more than half of the remaining area is in young managed stands near the stream. that are not proposed for treatment. Thus, dead wood recruitment is well distributed across the watershed Oregon Wild supports thinning of young planted stands when such projects are well planned and designed to accomplish comprehensive restoration objectives and carefully implemented to avoid unintended consequences. One of the key considerations is to find the optimal mix of treated and untreated patches within and between stands. This is because thinning benefits some aspects of late successional forest conditions such as large trees and vegetation diversity, but thinning also has adverse effects on other aspects of late successional forests such as dead wood recruitment, biomass accumulation, wildlife cover, The interdisciplinary team carefully analyzed the placement and amount of thinned and 60 DH soil quality, and microclimate conditions. In order to achieve all the objectives for optimal unthinned areas. late successional forest conditions, restoration projects must contain both thinned and unthinned patches. Finding the right mix should not be an accident based mostly on operational feasibility, but should be a conscious decision based on quantitative analysis showing how best to achieve optimal late successional conditions. Since thinning has a long-term negative effect on reducing recruitment of dead wood, it should be treated as a limiting factor and used to drive the search for an alternative with the most appropriate mix of treated and untreated stands.

North Nestucca Environmental Assessment Page 10

Appendix E It is useful to apply the concept of “habitat complementation” based on proximity of different life stages and life needs. Recognize that the thoughtful juxtaposition of thinned The projects purpose and need recognizes the need for habitat diversity. The current and unthinned areas can provide habitat benefits greater than large homogeneous areas of condition of the stands proposed for treatment lack structure and variability to develop either thinned or unthinned. There is a synergy to creation of a mosaic of thinned and rapidly into late successional habitat, so the Interdisciplinary Team carefully considered a unthinned sands that is greater than the sum of its parts. With this recognition, an important range of treatments or non-treatment for each stand. Due to windthrow concerns, currently 61 DH purpose of the NEPA document and the ultimate decision is to seek and find the most proposed treatments are only a step towards reducing stand densities to their optimal levels, optimal mix of treated and untreated areas. Instead of an 80/20 mix of treated/untreated so many stands will still have 80 to 100 trees per acre after thinning (see Appendix B). areas, consider a variety of combinations such as 60/40, 50/50, 40/60, and 20/80. Note that Additionally, treated and untreated portions of stands will vary widely, similar to the both the absolute proportion and the spatial pattern of treated and untreated must be variations proposed in your comments. considered. Consider the ecological costs and benefits of both thinned areas and unthinned areas. Thinned areas grow big trees (but fewer of them), while unthinned areas recruit more dead The interdisciplinary team carefully analyzed the placement and amount of thinned and 62 DH wood habitat structure in the short and long-term. In order to accomplish real ecological unthinned areas. restoration in young stands we need to plan for and implement both thinned areas and unthinned areas. Determining the appropriate scale of thinned and unthinned areas is a critical decision The deadwood analysis was completed utilizing information in DecAID, which is useful for which requires clear objectives and quantitative analysis. One necessary component of such planning for deadwood at a landscape level rather than a project level. There is no specific 63 DH an analysis is to determine how many green trees are needed at what density in order to tolerance level that is required as an objective. Note also the response to comments 59 & recruit sufficient snags over time (both short and long-term) to achieve 50-80% DecAID 60.# tolerance levels across the project area. The EA (p 43) is logically inconsistent about the future fate of the trees in these stands. It says: “Thinning would be expected to increase diameter in residual trees (Marshall et al., 1992). These residual trees would be expected to eventually die and produce large- diameter snags and downwood characteristic of late-successional stands. It is likely that the proposed vegetation treatments will be finished by 2030. It is likely that all The silviculture report covers this subject in more detail and is available upon request. 64 DH proposed thinning stands would need additional thinning treatments to further reduce the overstory tree density to densities found in the mature natural stands.” The first part of this statement says that retained trees in thinned stands will eventually die and contribute to dead wood habitat. The second part of this statement says that many of those trees will be removed in the future which means they cannot contribute to dead wood habitat. The FS should not pre-judge the need for future thinning. The FS should recognize that - . forests are subject to a variety of disturbance mechanisms and other natural processes that lead to self-organized development toward late successional forest Forest Service NEPA and silvicuture direction requires us to consider future treatments that 65 DH conditions (See Lutz. J.A. 2005. The Contribution of Mortality to Early Coniferous may occur.` Forest Development. MS Thesis. University of Washington. http://faculty.washington.edu/chalpern/Lutz_2005.pdf); and

North Nestucca Environmental Assessment Page 11

Appendix E . repeated thinning entries will perpetuate and exacerbate the adverse effects of “captured mortality” and ultimately reduce and delay recruitment of desired levels of dead wood in LSRs and riparian reserves. (See Heiken, D. 2012. Thinking About Dead Wood in Managed Landscapes (powerpoint) https://dl.dropbox.com/u/47741/dead%20wood%20slides%202012.ppt).

The EA emphasizes that density-dependent mortality is not a significant contributor to instream wood recruitment, implying that the effect of thinning on density-dependent mortality may not be a big deal. However, the EA fails to recognize that thinning in potential wood source areas significantly reduces the total amount of wood available for 66 DH Note response to comment #30. natural processes to act upon. Natural disturbance occurs in both thinned and unthinned stands. The proper comparison is not between density-dependent versus density- independent causes of dead wood recruitment, but the total recruitment of dead wood from all sources in thinned versus unthinned areas. The EA really contains only a half of a complete analysis of effects on riparian reserves. The EA focuses virtually its entire analysis of aquatic effects of logging on coho habitat which get large buffers, but the EA does not disclose the effects of logging on recruitment This passage has been changed in the EA to clarify that these other fish species will not be 67 DH of functional wood in riparian reserves that are not coho habitat – areas that get much significantly affected by Alternative 2. smaller buffers. The effects of logging in these two situations will be different and this should be disclosed. Coho were chosen as a management indicator species under the Siuslaw LRMP, and the EA (p 119) concludes that logging won’t adversely affect coho, and therefore logging won’t affect the other species either. The EA says “The documentation concluded that the Project will have “No Effect” on coho salmon or their critical habitat. Considering this, the Project will have No Effect on This passage has been changed in the EA to clarify that these other fish species will not be 68 DH the Forest-wide viability of coho salmon on the Siuslaw National Forest. Other fish significantly affected by Alternative 2. species, including resident and Coastal Cutthroat trout, Pacific and Brook lamprey, and sculpin reside in Project area streams and will not be affected by Alternative 2 due to the aforementioned design criteria.” This is flawed logic. The effects analysis for coho cannot be used to represent the effects on other fish unless the habitat of the other fish are buffered the same as the coho streams. There is of course a need to address effects to Threatened coho, but the Northwest Forest Plan Aquatic Conservation Strategy is an ecosystem plan that requires consideration of effects throughout the stream network and across the watershed. The narrow ESA/coho The EA differentiates coho habitat from aquatic habitat further upstream and includes a 69 DH analysis cannot be used as a replacement for the more comprehensive scope of the ACS separate ACS assessment in Appendix D. analysis, especially when different parts of the stream network will be treated very differently.

North Nestucca Environmental Assessment Page 12

Appendix E The scenario depicted in the figure reflects the inherent trade-off between dead tree density Outside of coho habitat, 15-30 foot riparian buffers may not be adequate to ensure long- and diameter. The proposed riparian buffers are designed to achieve a balance between the term recruitment of wood in non-fish bearing streams and riparian reserves. See the figure number and size of dead wood pieces, while supporting Late Successional Reserve 70 DH {figure in comment letter} above showing the effects of thinning on dead wood which is development objectives. It is also important to consider the significant contribution of important aspect of habitat development in both fish-bearing and non-fish bearing streams hardwood along Oregon Coast Range stream corridors toward maintenance of dead wood in and both riparian areas and uplands. the diameter classes smaller than this figure’s reference stand average. Outside of coho habitat, we recommend a mix of thinned and unthinned areas within young planted stands along streams. The thinned areas would produce larger trees but fewer of This strategy of a combination of thinned and unthinned areas within young planted stands them, while the unthinned areas would provide more abundant total wood volume, but is recognized as sound and is effectively being achieved by the Hebo Ranger District smaller piece sizes. An appropriate mix of both wood quantity and wood quality along each considering the combination of thinned and unthinned stream miles across the Project Area. 71 DH stream reach might be optimal. Please study the option. As described in the EA the proposed stand thinning represents approximately one-third of the Riparian Reserve acreage in the Project Area. Therefore, there are considerable The ACS analysis in Appendix D does not address the deficiencies described above. It also unthinned riparian areas from which to recruit a diversity of wood. contains misleading assertions about dead wood. We are concerned about application of a cookie-cutter approach to riparian thinning, either where wide no-touch buffers are established in dense young stands, or where thinning is The importance of adaptive riparian ecosystem management is recognized and the best 72 DH prescribed near a significant fraction of the stream network. It is important to resolve the available science was reviewed to inform the preparation of this EA. Future evolutions of underlying scientific questions and start doing what’s best for aquatic and terrestrial scientific inquiry are anticipated to further the pursuit of dynamic land management. ecosystems. We offer as a testable hypothesis that young plantations near streams should be managed for a combination of long-term wood quality (i.e., delayed recruitment of large, though less numerous, trees from thinned areas) and total wood quantity (i.e., more abundant, though 73 DH See response for comment #70. slightly smaller, wood from unthinned areas), which will also provide a combination of overstory shade (from unthinned areas) and understory diversity (from carefully thinned areas). These objectives might be best harmonized in dense young stands with an optimal mix of thinned and unthinned areas near streams. The optimal mix should be identified based not 74 DH See response for comment #71. on guesswork but on quantitative methods grounded in the needs of ecosystems and the real effects of commercial and non-commercial logging over time. We are opposed to road construction because the adverse impacts on soil, water, weeds, and All proposed road construction and reopening is for the purpose of achieving optimal wildlife are almost never justified by ecological benefits. This is especially true when it is landscape variation by thinning on a minority proportion of the streamside and overall recognized that some areas need to be left unthinned in order to provide an optimal Project Area acreage. Newly constructed and reopened roads are all located on ridge tops 75 DH landscape variation, including some dense forest and dead wood recruitment. Areas and are not near perennial drainages, making the likelihood of water quality impacts low. inaccessible from roads can be used to meet that need. There is a harmony to be realized Soil impacts are also limited given that the new and re-opened roads are temporary and will when the impacts of road construction can be avoided while the benefits of untreated stands be rehabilitated following use. can be also realized. Young stands do not exist in isolation, so be sure to consider the effects of thinning on This project has undergone consultation with USFWS for effects to spotted owls and 76 DH adjacent mature & old-growth habitat which may provide habitat for spotted owls, marbled murrelets, which included an analysis of effects to habitat including stands proposed for

North Nestucca Environmental Assessment Page 13

Appendix E murrelets, and other species. treatment and within the project area outside of the area planned for treatment (Appendix H and Appendix A). Effects to sensitive, MIS and landbirds are described in the EA in the Wildlife section, and in Appendix H. Spotted owls may use young stands for dispersal, foraging, and security from predators. It may be helpful to create a spotted owl “risk map” that identifies areas that are more or less 77 DH suitable for thinning based on criteria such as: existing habitat characteristics, proximity to Comment noted. activity centers, proximity to NRF habitat, and proximity to recently thinned areas, non- habitat, and roads. This project has undergone consultation with USFWS for effects to spotted owls and Thinning to increase habitat breadth in young stands has many benefits but it may also murrelets, and the resulting project design criteria include measures to protect suitable 78 DH invite additional predators into the forest that depredate nests of marbled murrelets and habitat and nest sites from disturbance and disruption as described in Appendix A and in northern spotted owls. Maybe there are ways of buffering nest sites and suitable habitat. Appendix E The agency should also consider adjusting both the location and timing of thinning to 79 DH See response above minimize the cumulative effects of widespread thinning on the sensitive and listed species.

North Nestucca Environmental Assessment Page 14

Appendix E – Attachment #1

Opposing Views Attachment #1

Scientists Reveal the Natural Resources in the Forest are Harmed (and some destroyed) by Timber Harvest Activities

Note to the Responsible Official who reads these opposing views: There are negative effects caused by nearly all actions … this includes the actions necessary to harvest trees. The public deserves to consider projects proposed to occur on their land with the knowledge of the pros and cons of the project.

The Responsible Official will find that none of the literature sources for the opposing views is specific to this project. Information contained in books and/or scientific prediction literature is never specific to individual projects. They describe cause and effects relationships that exist when certain criteria are met … at any location under the vast majority of landscape characteristics.

Indeed, the literature in the References section of the draft NEPA document for this project is not specific to the project yet its used to help design this project.

The opposing views presented below are not always right or wrong. When responding to opposing views that the Responsible Official believes are “reasonable” please discuss them in the context of this project. In other words, could the resource damage occur as a result of this project.

Once again, this gives the public complete project understanding. This allows them to submit meaningful comments.

Introduction The following scientific statements describe the natural resources that most likely will sustain damage as a result of timber harvest activities. ------

North Nestucca Environmental Assessment Page 1

Appendix E – Attachment #1

Timber Harvest Opposing View #1 - The following document contains pertinent color pictures showing logging damage, thus the article text is not shown here. Please use the link below to access the article.

Al-jabber, Jabber M. “Habitat Fragmentation:: Effects and Implications” Clearcuts and forest fragmentation, Willamette NF, Oregon. From: Cascadia Wildland Project, Spring 2003 http://faculty.ksu.edu.sa/a/Documents/Habitat%20Fragmentation%20Effects%20and%2 0Implication.pdf

------Timber Harvest Opposing View #2 - “Timber harvest operations have been shown to have many effects on adjacent watercourses and on the aquatic ecosystems they support. This may occur from introductions or loss of woody debris, loss of riparian vegetation, accelerated stream bank and bed erosion, the alteration of natural channel form and process, and the reduction of stream habitat diversity. However, the existing literature indicates one of the most insidious effects of logging is the elevation of sediment loads and increased sedimentation within the drainage basin.

Sediment generation from various forestry practices has been studied extensively in the past. Forestry practices which generate suspended sediments include all operations that disturb soil surfaces such as site preparations, clear-cutting, log skidding, yarding, slash burns, heavy equipment operation and road construction and maintenance.”

Anderson, P.G. 1996. “Sediment generation from forestry operations and associated effects on aquatic ecosystems” Proceedings of the Forest-Fish Conference: Land Management Practices Affecting Aquatic Ecosystems, May 1-4, 1996, Calgary, Alberta. http://www.alliance-pipeline.com/contentfiles/45____Sediment_generation.pdf

North Nestucca Environmental Assessment Page 2

Appendix E – Attachment #1

Response: Potential sediment sources mentioned in this paper include stream bank disturbance, instream activities, clear cutting and road building. This project does not include any clear cutting no temporary roads are allowed to cross streams. There are streamside buffers to protect stream banks from disturbance. Road maintenance is proposed, but that will reduce the potential to mobilize any sediment that might reach streams.

------Timber Harvest Opposing View #3 - “Timber harvest will remove dead and dying material from the site and inhibit the recruitment of downed woody material as time progresses. Timber harvest and associated reduced structural complexity and reduced age and size class diversity are all known to reduce population abundance and diversity of ants and a number of birds. For instance, ants are documented to require downed woody material in a variety of sizes and in all stages of decomposition (Torgersen and Bull, 1995). This is an attribute that is negatively correlated with harvest of the dead and dying trees and positively correlated with natural succession, especially after disturbance. Ants and birds are known to predate on insect species which cause mortality to trees, serving as a potentially important population control in the case of epidemics or before they occur (Campbell, Torgersen and Srivastava, 1983). Structural and functional characteristics associated with unlogged forests are also important for canopy arthropods, which play an important role in regulating pest outbreaks (Schowalter, 1989).

Response: The EA contains an extensive analysis of the effects of the action on existing and potential coarse woody debris. The action excludes the harvest of existing dead or dying trees. The project does propose the creation of snags and CWD. Thinning of dense stands will also allow the underplanting of conifers to create a greater structural diversity within the treated stands.

Structural complexity, functional diversity, diversity of ecological process and diversity of structure in roadless areas are all expected to be less susceptible to the outbreak of pests and regulate insect activity in North Nestucca Environmental Assessment Page 3

Appendix E – Attachment #1

surrounding homogenized forests (Schowalter and Means, 1989; Franklin, Perry, Schowalter, Harmon, McKee and Spies, 1989).

Response: This project does not propose to treat any stands in roadless areas.

A large body of scientific evidence also indicates that increased edge effect and increased sunlight into stands, resulting from reduced canopy cover associated with timber harvest, can directly promote the population abundance, productivity and persistence of insects which cause mortality to trees of (Roland, 1993; Rothman and Roland, 1998; Kouki, McCullough and Marshall, 1997; Bellinger, Ravlin and McManus, 1989).”

“Applying Ecological Principles to Management of the U.S. National Forests” Issues in Ecology Number 6 Spring 2000 http://www.esa.org/science_resources/issues/FileEnglish/issue6.pdf

Response: The focus of this paper was on primarily on the impacts of clear cuts, no clear cuts are proposed in this project. canopy cover will be reduced in the short term, but a minimum of 40% canopy cover will be maintained.

------Timber Harvest Opposing View #4 - “The biggest ecological con job in years is being waged by the U.S. Republican party and their timber industry cronies. They are blaming the recent Western wildfires on environmentalists, and assuring the public that commercial logging will reduce the risk of catastrophic wildfires.”

Barry, Glen, Ph.D. “Commercial Logging Caused Wildfires” Published by the Portland Independent Media Center, August 2002. http://portland.indymedia.org/en/2002/08/17464.shtml

Response: Reduction of wildfire risk is not part of the purpose and need for this project. In addition, this project is not located in a fire prone area.

North Nestucca Environmental Assessment Page 4

Appendix E – Attachment #1

------Timber Harvest Opposing View #5 - “According to a 1998 poll by a firm that has worked for several Republican House members and two presidents, 69 percent of Americans oppose commercial logging on federally owned land. The Forests Service's own poll showed that 59 percent of Americans who expressed an opinion oppose timber sales and other commodity production in national forests.”

“Many Americans are surprised to learn that logging is even allowed on public lands. Alas, it has been since the Organic Act of 1897 first authorized logging in America's new forest reserves. That legislation called for watershed protection and a steady supply of timber - what the Forest Service calls ‘multiple use.’ "

“But the agency has been unable to balance those goals. More often than not, the integrity of the forest ecosystem has been sacrificed to maximize timber and other commodities. And at taxpayer expense, notes Bernie Zaleha, chair of the End Commercial Logging on Federal Lands (ECL) campaign. The Forest Service lost $2 billion on its logging program from 1992 to 1997, according to the General Accounting Office. It spends more on building roads and preparing sales than it gets back in timber receipts.”

Barry, John Byrne. “Stop the Logging, Start the Restoration” from The Planet newsletter June 1999, Volume 6, Number 5 http://www.sierraclub.org/planet/199905/ecl1.asp

Response: This is a 13 year old opinion piece that was focused on clear cutting activities. The current thinning program on the Siuslaw is focused on encouraging the development of late successional forest characteristics, and maximizing economic

North Nestucca Environmental Assessment Page 5

Appendix E – Attachment #1

return is not part of the purpose and need. The article also focused on increasing fragmentation caused by clear cutting, thinning does not contribute to increased fragmentation.

------Timber Harvest Opposing View #6 - “Federal auditors have found that the Forest Service frequently fails to assess, prevent or correct environmental damage from logging on the national forests.

After inspecting 12 timber projects in the field from 1995 to 1998, the Agriculture Department's inspector general found that all were deficient and that ’immediate corrective action is needed.’

A new report on the audits found that the environmental studies required before logging was approved were poorly done, the rules to protect streams and wildlife habitat from undue damage during logging were not followed, and the steps planned to repair some of the harm after logging were not carried out.

The inspector general, Roger C. Viadero, reported on Jan. 15 to Mike Dombeck, chief of the Forest Service, that the review had found '’numerous serious deficiencies.'’ Agency officials generally agreed with the report's conclusions and recommendations.”

Cushman, John H. Jr. “Audit Faults Forest Service on Logging Damage in U.S. Forests” New York Times, February 5, 1999 http://query.nytimes.com/gst/fullpage.html?res=9B00E2DF163BF936A35751C0A96F95 8260&sec=&spon=&pagewanted=print

Response: The report comments focuses on poorly done environmental documents and inadequate monitoring of projects. The Hebo Ranger District performs an extensive analysis before each project, and welcomes input from the public and other agencies to improve the analysis. In addition, the presence of Endangered and/or Threatened species means that the federal regulatory agencies are also involved in reviewing the

North Nestucca Environmental Assessment Page 6

Appendix E – Attachment #1

documents. Monitoring requirements are built into each project and we encourage public and agency review of the project activities.

------Timber Harvest Opposing View #7 - "The timber harvest shouldn't be dominant. It should be on an equal plane with recreation concerns, with wildlife concerns, hunting, fishing, protecting our cultural heritage. That's what the American public is asking us to do.”

Dombeck, Mike Ph.D. "Through the Woods" The News Hour with Jim Lehrer. 19 June 1998. http://www.pbs.org/newshour/bb/fedagencies/jan-june98/road_6-19.html

Response: The Northwest Forest Plan has designated all of the lands in this project into a combination of Late Successional Reserve, Riparian Reserve and Adaptive Management Area. Timber harvest is only allowed as a restoration tool to encourage the development of late successional forest conditions. All resources are evaluated so that the actions can be determined to have No Significant Impact.

------Timber Harvest Opposing View #8 - “I recently read a letter from a line officer who chided local managers for being behind schedule relative to meeting the region’s ‘timber targets.’ My expectation is that line officers will demand similar accountability for meeting watershed restoration, fish and wildlife habitat, riparian, recreation, cultural resource, and wilderness management goals.”

“We need to do a better job talking about, and managing for, the values that are so important to so many people. Values such as wilderness and roadless areas, clean water, protection of rare species, old growth forests, naturalness -- these are the reasons most Americans cherish their public lands.”

North Nestucca Environmental Assessment Page 7

Appendix E – Attachment #1

"Fifty years ago, Aldo Leopold wrote his seminal work, A Sand County Almanac. In it, Leopold spoke of his personal land ethic and the need for land managers to extend their own ecological conscience to resource decisions. The Forest Service natural resource agenda is an expression of our agency's land ethic. If we are to redeem our role as conservation leaders, it is not enough to be loyal to the Forest Service organization. First and foremost, we must be loyal to our land ethic. In fifty years, we will not be remembered for the resources we developed; we will be thanked for those we maintained and restored for future generations."

Dombeck, Mike Ph.D. a message on "Conservation Leadership” sent to all USFS employees on July 1, 1998 http://www.wvhighlands.org/VoicePast/VoiceAug98/Dombeck.Aug98.html

Response: Watershed restoration objectives are the primary focus for this project, timber harvest is only a tool to obtain those objectives.

------Timber Harvest Opposing View #9 - “For much of the past century the Forest Service, entrusted as the institutional steward of our National Forests, focused its management on an industrial-scale logging program. The result of the massive logging and road construction program was to damage watersheds, destroy wildlife habitat and imperil plant and animal species.”

“The continued logging of our National Forests also wastes American tax dollars and diminishes the possibilities of future economic benefits. The Forest Service lost $2 billion dollars on the commercial logging program between 1992-1997. Annually, timber produces roughly $4 billion while recreation, fish and wildlife, clean water, and unroaded areas provide a combined total of $224 billion to the American economy. Forests purify our drinking water - 60 million Americans get their drinking water from National Forests. When the dramatic values of ecological goods and services are

North Nestucca Environmental Assessment Page 8

Appendix E – Attachment #1

taken into account, it is clear that protecting National Forests creates more economic benefits than continued logging.”

Ehrlich, Anne Ph.D., David Foster Ph.D. and Peter Raven Ph.D. 2002 “Call to End Logging Based on Conservation Biology.” Native Forest Network. http://www.nativeforest.org/campaigns/public_lands/stb_5_30_02.htm

Response: Projects focused on commercial timber production are not allowed under the Northwest Forest Plan for the types of land covered in this project.

------Timber Harvest Opposing View #10 - “The Bush administration has announced plans to greatly increase logging on federal lands in order to reduce the risk of wildfires. The Forest Service is using the fear of wildfires to allow logging companies to remove medium-and large-diameter trees that they can sell, rather than just the small trees and brush that can make fires more severe. There is little evidence to show that such logging will prevent catastrophic fires; on the contrary, logging roads and industrial logging cause wildfires. Bush is a well known supporter of the timber industry and has accepted huge sums of money from wealthy timber company leaders. He is promoting misinformation about forest fires in order to benefit timber industry campaign contributors.”

“Bush Fire Policy: Clearing Forests So They Do Not Burn” FOREST CONSERVATION NEWS TODAY, August 27, 2002 http://forests.org/archived_site/today/recent/2002/tiporefl.htm

Response: Reduction of fire risk is not a part of the purpose and need for this project.

------Timber Harvest Opposing View #11 - "The proposition that forest values are protected with more, rather than less logging, and that forest reserves North Nestucca Environmental Assessment Page 9

Appendix E – Attachment #1

are not only unnecessary, but undesirable, has great appeal to many with a vested interest in maximizing timber harvest. These ideas are particularly attractive to institutions and individuals whose incomes depend upon a forest land base. (page 2)"

"On the other hand, approaches that involve reserving of a portion of the land base, or harvest practices that leave commercially valuable trees uncut to achieve ecological goals, are often considered much less desirable as they reduce traditional sources of timber income. (page 2)"

Franklin, Jerry Ph.D., David Perry Ph.D., Reed Noss Ph.D., David Montgomery Ph.D. and Christopher Frissell Ph.D. 2000. "Simplified Forest Management to Achieve Watershed and Forest Health: A Critique." http://www.coastrange.org/documents/forestreport.pdf

Response: This project involves thinning of sub-dominant trees to encourage the growth of larger trees. It is also only impacting a very small portion of the watershed. The total project area is 38, 204 acres. The project proposes to thin 538 acres which is only 1.5% of the project area. The total Nestucca basin consists of 163,000 acres, we are only thinning 0.3% of the whole basin.

------Timber Harvest Opposing View #12 - “Consequently, we specifically criticize the “simplified structure-based management” approaches derived from simple structural models and traditional silvicultural systems such as clearcutting. In our view, the assumptions underpinning simplified structure-based management (SSBM) are not supported by the published scientific literature on structural development of natural forests, disturbance ecology, landscape ecology and conservation biology, or by the relationships between ecosystem structures and processes. In this report, we review scientific findings associated with each of these areas with particular attention to the over-simplified structural models associated with SSBM and the importance and viability of forest reserves to achieve various ecological goals. (page 2)

North Nestucca Environmental Assessment Page 10

Appendix E – Attachment #1

“We do not believe, however, that scientific literature or forestry experience supports the notions that intensively managed forests can duplicate the role of natural forests, or that sufficient knowledge and ability exist to create even an approximation of a natural old-growth forest stand.” (page 3)

Franklin, Jerry F. Ph.D. and James K. Agee Ph.D. 2007. “Forging a Science-Based National Forest Fire Policy.” Issues in Science and Technology. A National Wildlife Federation publication sponsored by the Bullitt Foundation http://www.coastrange.org/documents/forestreport.pdf

Response: The Northwest Forest Plan defines our management objectives and even provides some guidance on obtaining them. But, we constantly review the literature to refine our approaches and techniques.

------Timber Harvest Opposing View #13 - “But the majority of the protesters were angry about Bush’s plans to implement rules that would thin our national forests to reduce fire risk. Cascadia Forest Alliance volunteer Carrie Taylor said Bush’s plan to log mature and old forests “will only increase fire risks while providing taxpayer subsidized logs to the timber industry.”

“According to the Cascadia Forest Alliance, under the Bush proposal, ‘environmental laws and citizen involvement will be undermined or suspended so that federal land management agencies can increase logging and roadbuilding on public lands, one of the timber industry's highest priorities.’”

Giuliano, Jackie Alan, Ph.D. “Fire Suppression Bush Style: Cut Down the Trees!” Environmental News Service, 2008. http://www.ens-newswire.com/ens/aug2002/2002-08-23g.asp

North Nestucca Environmental Assessment Page 11

Appendix E – Attachment #1

Response: Reduction of fire risk is not a part of the purpose and need for this project.

------Timber Harvest Opposing View #14 - "Most of the trees that need to be removed to reduce accumulated fuels are small in diameter and have little or no commercial value."

"Mechanically removing fuels (through commercial timber harvesting and other means) can also have adverse effects on wildlife habitat and water quality in many areas. Officials told GAO that, because of these effects, a large-scale expansion of commercial timber harvesting alone for removing materials would not be feasible. However, because the Forest Service relies on the timber program for funding many of its activities, including reducing fuels, it has often used this program to address the wildfire problem. The difficulty with such an approach, however, is that the lands with commercially valuable timber are often not those with the greatest wildfire hazards."

Government Accounting Office “Western National Forests: A Cohesive Strategy is Needed to Address Catastrophic Wildfire Threats” GAO/RCED-99-65 http://www.gao.gov/archive/1999/rc99065.pdf

Response: Reduction of fire risk is not a part of the purpose and need for this project.

------Timber Harvest Opposing View #15 - “The recent concern over the poor health of western pine ecosystems has been attributed at least partly to inappropriate silvicultural practices, both before and since the national forests were established. (4) Because of the timber industry's needs,

North Nestucca Environmental Assessment Page 12

Appendix E – Attachment #1

logging in mixed conifer stands has emphasized cutting the large pines and leaving the true firs and Douglas-fir to dominate the remaining stands. (5) However, true firs and Douglas-fir are more susceptible to the damage (including insect and disease attacks as well as direct damage) that has occurred during the decade-long drought in the interior West, and thus may contribute to the risk of catastrophic wildfires. Salvage sales are one tool that can be used to improve forest health, (6) but critics object to granting the agency the discretion to use timber sales to correct problems partially created by past timber sales.”

“A more general concern in some quarters is over Forest Service "bias" toward timber outputs, at the expense of ecosystem conditions and other resource values. While timber harvests are important, other important values are not measured, and managers are not rewarded for achieving these other values. (7) Some have attributed this "bias" to inappropriate incentives, particularly related to the agency's numerous trust funds and special accounts. (8) The Forest Service has several trust funds and special accounts that are either funded by timber revenues or provide funds for timber management (or both). (9)”

“One trust fund often cited by critics is the Knutson-Vandenberg (K-V) Fund. This account receives an unlimited portion of timber sale receipts, to be used for reforestation, timber stand improvements, and other resource mitigation and enhancement activities in timber sale areas. Forest Service managers can, therefore, fund their programs from timber sales; in the words of one critic, wildlife managers have an incentive to support timber sales that damage wildlife habitat, because they can use the revenues to mitigate that damage and to keep themselves and their staffs employed. (10)”

Gorte, Ross W. Ph.D. “Forest Service Timber Sale Practices and Procedures: Analysis of Alternative Systems.” A Congressional Research Service (CRS) report, October 30, 1995. http://www.ncseonline.org/NLE/CRS/abstract.cfm?NLEid=215

Response: Reduction of fire risk is not a part of the purpose and need for this project, and there are no Assigned Sale Quantities for this area.

North Nestucca Environmental Assessment Page 13

Appendix E – Attachment #1

------Timber Harvest Opposing View #16 - “In April 1999, the General Accounting Office issued a report that raised serious questions about the use of timber sales as a tool of fire management. It noted that "most of the trees that need to be removed to reduce accumulated fuels are small in diameter" -- the very trees that have ‘little or no commercial value.’ “

“As it offers timber for sale to loggers, the Forest Service tends to ‘focus on areas with high-value commercial timber rather than on areas with high fire hazards,’ the report said. Its sales include ‘more large, commercially valuable trees’ than are necessary to reduce the so-called accumulated fuels (in other words, the trees that are most likely to burn in a forest fire).”

“The truth is that timber sales are causing catastrophic wildfires on national forests, not alleviating them. The Sierra Nevada Ecosystem Project Report, issued in 1996 by the federal government, found that ‘timber harvest, through its effects on forest structure, local microclimate and fuel accumulation, has increased fire severity more than any other recent human activity.’ The reason goes back to the same conflict that the G.A.O. found: loggers want the big trees, not the little ones that act as fuel in forest fires.”

“After a ‘thinning’ timber sale, a forest has far fewer of the large trees, which are naturally fire-resistant because of their thick bark; indeed, many of these trees are centuries old and have already survived many fires. Without them, there is less shade. The forest is drier and hotter, making the remaining, smaller trees more susceptible to burning. After logging, forests also have accumulations of flammable debris known as "slash piles" -- unsalable branches and limbs left by logging crews.”

Hanson, Chad Ph.D., “Commercial Logging Doesn't Prevent Catastrophic Fires, It Causes Them.” Published in the New York Times, May 19, 2000 http://www.commondreams.org/views/051900-101.htm

North Nestucca Environmental Assessment Page 14

Appendix E – Attachment #1

Response: Reduction of fire risk is not a part of the purpose and need for this project.

------Timber Harvest Opposing View #17 - "The Forest Service keeps the vast majority of timber sale revenues, which gives it a perverse incentive to do more cutting. It has developed a huge bureaucracy around the selling of timber from national forest land."

Hanson, Chad, Ph.D. “Logging for Dollars in National Forests” Special to The Sacramento Bee - November 14, 2001 http://www.johnmuirproject.org/news-logging-for-dollars.html

Response: The stands proposed for treatment are not part of the suitable timber base, and thus are not part of the Allowable Sale Quantity (ASQ). All silvicultural activities, including thinning, are designed to encourage the attainment of late-successional forest characteristics.

------Timber Harvest Opposing View #18 - “Recent editorials by timber industry spokespersons are a wildly misleading attempt to promote increased logging of western U.S. forests under the guise of reducing wildland fires …”

Hanson, Chad Ph.D., “Logging Industry Misleads on Climate and Forest Fires.” Guest Commentary in New West, July 11, 2008 http://www.newwest.net/topic/article/logging_industry_misleads_on_climate_and_forest _fires/C41/L41/

Response: Reduction of fire risk is not a part of the purpose and need for this project.

North Nestucca Environmental Assessment Page 15

Appendix E – Attachment #1

------Timber Harvest Opposing View #19 - "Logging reduces the organic parent material (duff and woody residues) available for soil-formation processes."

Harvey, A. E., M. J. Larsen, and M. F. Jurgensen “Distribution of Ectomycorrhizae in a Mature Douglas-fir/larch Forest Soil in Western Montana” Forest Science, Volume 22, Number 4, 1 December 1976 , pp. 393-398(6) http://www.ingentaconnect.com/content/saf/fs/1976/00000022/00000004/art00007;jsess ionid=l2sdf2hphia2.alexandra

Response: Only selected sub-dominant trees will be removed, and many of the branches and tops will be left on site. No under burning is planned. Cable logging is planned for most of the area to reduce impacts. The soils analysis in the EA documents potential effects to the substrate.

------Timber Harvest Opposing View #20 - "For too long, we foresters took the public for granted, assuming unwavering support for those who grow the nation’s wood fiber. Few noticed when the public’s mood changed, and those who did were often ridiculed by disbelieving colleagues. Now we come to a day of reckoning: the public believes forests are too important to be entrusted to foresters. To restore lost confidence, foresters must first come out of hiding. We have a lot of explaining to do because, where forests are concerned, the public will no longer support what it cannot see and understand. Regaining the public’s trust will take time. We must be prepared to answer hard questions about what we are doing and how our actions are impacting the environment. We must also help the public think through its forest management options. When we lay out these options, we must speak of much more than trees. Only then will our critics know we love forests as much as they do."

North Nestucca Environmental Assessment Page 16

Appendix E – Attachment #1

Houston, Alan Ph.D., "Why Forestry is in Trouble with the Public." Evergreen magazine, October 1997. http://evergreenmagazine.com/web/Why_forestry_is_in_trouble_with_the_public- v2.html

Response: The public was involved through the scoping process and had opportunities to comment. The project was described in the SOPA, a public notice was placed in the local paper and letters were sent to interested parties on the forest mailing list.

------Timber Harvest Opposing View #21 - "SEC. 3. FINDINGS.

Congress finds the following:

Commercial logging has many indirect costs which are very significant, but not easily measured, such as flooding damage and relief of flooding damage through Federal funds, damage to the salmon fishing industry; and harm to the recreation and tourism industries."

H. R. 1494 text. April 4, 2001 http://www.agriculturelaw.com/legis/bills107/hr1494.htm

Response: The EA addresses these issues in Chapter 3. The hydrology, soils and fisheries sections particularly focus on these issues.

------Timber Harvest Opposing View #22 - "Human tampering with nature has not been without costs. Human manipulation of existing ecosystems has also sometimes had unfortunate consequences."

North Nestucca Environmental Assessment Page 17

Appendix E – Attachment #1

Hudak, Mike Ph.D. “From Prairie Dogs to Oysters: How Biodiversity Sustains Us” from his book review of The Work of Nature: How the Diversity of Life Sustains Us by Yvonne Baskin, 1997 Newsletter of Earth Day Southern Tier, February/March 1999, p. 2 http://www.mikehudak.com/Articles/FromPrairieDogs9902.html

Response: The EA provides a detailed analysis of the potential effects of the action in order to allow the deciding official to make an informed decision. The analysis is deemed adequate to determine that there are no significant effects from the action.

------Timber Harvest Opposing View #23 - “In general, rate of spread and flame length were positively correlated with the proportion of area logged (hereafter, area logged) for the sample watersheds. Correlation coefficients of area logged with rate of spread were > 0.57 for five of the six river basins (table 5). Rate of spread for the Pend Oreille and Wenatchee River basins was strongly associated (r-0.89) with area logged. Correlation of area logged with flame length were > 0.42 for four of six river basins (table 5). The Deschutes and Methow River basins showed the strongest relations. All harvest techniques were associated with increasing rate of spread and flame length, but strength of the associations differed greatly among river basins and harvesting methods.” (pg.9)

“As a by-product of clearcutting, thinning, and other tree-removal activities, activity fuels create both short- and long-term fire hazards to ecosystems. The potential rate of spread and intensity of fires associated with recently cut logging residues is high, especially the first year or two as the material decays. High fire-behavior hazards associated with the residues can extend, however, for many years depending on the tree. Even though these hazards diminish, their influence on fire behavior can linger for up to 30 years in the dry forest ecosystems of eastern Washington and Oregon.”

Huff, Mark H. Ph.D.; Ottmar, Roger D.; Alvarado, Ernesto Ph.D. Vihnanek, Robert E.; Lehmkuhl, John F.; Hessburg, Paul F. Ph.D. Everett, Richard L. Ph.D. 1995. “Historical and current forest North Nestucca Environmental Assessment Page 18

Appendix E – Attachment #1

landscapes in eastern Oregon and Washington. Part II: Linking vegetation characteristics to potential fire behavior and related smoke production” Gen. Tech. Rep. PNW-GTR-355. USDA Forest Service, Pacific Northwest Research Station. https://ir.library.oregonstate.edu/xmlui/bitstream/handle/1957/4706/PB96155213.pdf;jse ssionid=C8DDB611DB29D3716BBF313AADBA2E70?sequence=1

Response: Reduction of fire risk is not a part of the purpose and need for this project.

------Timber Harvest Opposing View #24 - "The Quincy Library Group's (QLG's) fuelbreak strategy represents a giant step backwards from the progressive development of rational fire policies established by the 1995 Federal Wildland Fire Management Policy and Program Review."

"The fact that the QLG admits that its Plan is inconsistent with these new policies (indeed, is almost gleefully defiant of them) says a lot about the credibility of the QLG's self-purported fire management expertise."

"In spite of (or more likely because of) the intensive 'fuels reduction' activities associated with commercial logging, the Fountain Fire was truly catastrophic in its effects."

"Even 'kinder, gentler' commercial logging still inflicts environmental impacts such as eroded topsoil, degraded water quality, destroyed wildlife habitat, and extirpated species that are every bit as much symptoms of forest health problems as large-scale, severe wildfires."

"And after spending millions of dollars creating the SNEP Report, it seems wise to use its information, not ignore it or opportunistically select out statements clearly worded as assumptions, values, or goals which run contrary to factual research findings. The QLG Plan has much more to do with timber extraction than with genuine fire protection, and in that respect, it constitutes more of a forest health threat than a real solution."

North Nestucca Environmental Assessment Page 19

Appendix E – Attachment #1

"The QLG Bill resembles similar 'panic legislation' that was passed during the early 1970s in which, following some large-scale wildfires in California, Congress allowed the Forest Service to access emergency firefighting funds to conduct 'presuppression' timber sales. Many fuelbreaks were cut in the Sierras during this period, and while costs rapidly rose into tens of millions of dollars, most of these fuelbreaks failed to perform adequately during wildfire suppression incidents. Congress quickly had to take away this funding source from the Forest Service. What has become of these old fuelbreaks? Almost without exception, the agency failed to monitor or maintain them, and in a modern-day version of 'cut and run' logging, many of these old fuelbreaks have converted to chaparral brush and 'dog-hair' thickets … a much more flammable vegetation type than the original forest cover. The QLG Bill appears to be 'deja vu' without evidence of Congress or the QLG being aware of this history of previous fuelbreak programs."

Ingalsbee, Timothy Ph.D. "Logging for Firefighting: A Critical Analysis of the Quincy Library Group Fire Protection Plan." Unpublished research paper. 1997. http://www.fire-ecology.org/research/logging-for-firefighting_2.htm

Response: Reduction of fire risk is not a part of the purpose and need for this project.

------Timber Harvest Opposing View #25 - “The notion that commercial logging can prevent wildfires has its believers and loud proponents, but this belief does not match up with the scientific evidence or history of federal management practices. In fact, it is widely recognized that past commercial logging, road-building, livestock grazing and aggressive firefighting are the sources for "forest health" problems such as increased insect infestations, disease outbreaks, and severe wildfires.”

“How can the sources of these problems also be their solution? This internal contradiction needs more than propaganda to be resolved. It is time for the timber industry and their supporters to heed the facts, not

North Nestucca Environmental Assessment Page 20

Appendix E – Attachment #1

fantasies, and develop forest management policies based on science, not politics.”

Ingalsbee, Timothy Ph.D. 2000. “Commercial Logging for Wildfire Prevention: Facts Vs Fantasies” http://www.fire-ecology.org/citizen/logging_and_wildfires.htm

Response: Reduction of fire risk is not a part of the purpose and need for this project.

------Timber Harvest Opposing View #26 - "Since the 'New Perspectives' program of the early 1990s, the agency has tried to dodge public opposition to commercial logging by using various euphemisms, such as this gem from the Siskiyou National Forest: Clearcuts are called 'minimum green tree retention units.' Accordingly, Forest Service managers have believed that if they simply refer to logging as 'thinning,' or add the phrases 'fuels reduction' or 'forest restoration' to the title of their timber sale plans, then the public will accept these projects at face value, and business-as-usual commercial logging can proceed. In the face of multiple scandals and widespread public skepticism of the Forest Service's credibility, it seems that only Congress is buying the agency's labeling scheme."

Ingalsbee, Timothy Ph.D. “Logging without Limits isn't a Solution to Wildfires” published in the Portland Oregonian, August 6, 2002 http://www.klamathforestalliance.org/Documents/loggingwithoutlimits.html

Response: Reduction of fire risk is not a part of the purpose and need for this project, and no clear cutting is.proposed.

------Timber Harvest Opposing View #27 - “Thus, the use of commercial logging for fire hazard reduction poses yet another paradox: Logging North Nestucca Environmental Assessment Page 21

Appendix E – Attachment #1

removes the trees that normally survive fires, leaves behind the trees that are most often killed by fire, increases flammable fuel loads, and worsens fire weather conditions.” (pg. 5)

Ingalsbee, Timothy Ph.D. “The wildland fires of 2002 illuminate fundamental questions about our relationship to fire.” The Oregon Quarterly, Winter 2002 http://fireecology.org/research/wildfire_paradox.pdf

Response: Reduction of fire risk is not a part of the purpose and need for this project.

------Timber Harvest Opposing View #28 - "In the face of growing public scrutiny and criticism of the agency's logging policies and practices, the Forest Service and their enablers in Congress have learned to mask timber sales as so-called 'fuels reduction' and 'forest restoration' projects. Yet, the net effect of these logging projects is to actually increase fire risks and fuel hazards."

"Decades of encouraging private logging companies to take the biggest, oldest, most fire-resistant trees from public lands, while leaving behind a volatile fuel load of small trees, brush, weeds, stumps and slash has vastly increased the flammability of forestlands."

"In addition to post-fire salvage logging, the Forest Service and timber industry advocates in Congress have been pushing pre-fire timber sales, often falsely billed as hazardous fuels reduction or 'thinning' projects, to lower the risk or hazard of future wildfires. In too many cases, these so- called thinning projects are logging thick-diameter fire-resistant overstory trees instead of or in addition to cutting thin-sized fire-susceptible understory trees. The resulting logging slash and the increased solar and wind exposure can paradoxically increase the fuel hazards and fire risks."

Ingalsbee, Timothy Ph.D. "Fanning the Flames! The U.S. Forest Service: A Fire-Dependent Bureaucracy."

North Nestucca Environmental Assessment Page 22

Appendix E – Attachment #1

Missoula Independent. Vol. 14 No. 24, June 2003 http://www.fire-ecology.org/research/USFS_fire_dependent.html

Response: Reduction of fire risk is not a part of the purpose and need for this project.

------Timber Harvest Opposing View #29 - “More than any other recent human activity, the legacy of commercial timber extraction has made public forests more flammable and less resilient to fire. Firstly, clearcut and high-grade logging have historically taken the largest, most fire-resilient, most commercially-valuable trees, and left behind dead needles and limbs (logging debris called "slash"), along with smaller trees and brush that are less commercially valuable but more flammable than mature and old- growth trees. The net effect is to increase the amount of available hazardous fuel.”

“Secondly, the removal of large overstory trees also changes the microclimate of logged sites, making them hotter, drier, and windier, which increases the intensity and rate of spread of wildfires. Third, the creation of densely-stocked even-aged plantations of young conifers made sites even more flammable since this produced a solid mass of highly combustible conifer needles within easy reach of surface flames. These changes in the fuel load, fuel profile, and microclimate make logged sites more prone to high-intensity and high-severity wildfires.”

Ingalsbee, Timothy Ph.D. 2005. “A Reporter's Guide to Wildland Fire.” Published by the Firefighters United for Safety, Ethics, and Ecology (FUSE), January 2005 http://www.commondreams.org/news2005/0111-14.htm

Response: Reduction of fire risk is not a part of the purpose and need for this project.

North Nestucca Environmental Assessment Page 23

Appendix E – Attachment #1

------Timber Harvest Opposing View #30 - “Linear developments may result in habitat avoidance for grizzly bears. Logging-truck traffic in the Kimsquit Valley in British Columbia resulted in a 78% reduction in use of the “Zone of Hauling Activity” by radio collared bears compared to non-hauling periods (16). For 14 hours/day, 3%-23% of each bear's home range was unavailable to them because of disturbance.”

“The impacts of land-use activities on wolverines are likely similar to those on grizzly bears. Wolverines seem to have been most affected by activities that fragment and supplant habitat, such as human settlement, extensive logging, oil and gas development, mining, recreational developments, and the accompanying access. Wolverine populations that are now at the edge of extirpation have been relegated to the last available habitat that has not been developed, extensively modified, or accessed by humans.”

Jalkotzy, M.G., P.I. Ross, and M.D. Nasserden. 1997. “The Effects of Linear Developments on Wildlife: A Review of Selected Scientific Literature.” Prepared for Canadian Association of Petroleum Producers. Arc Wildlife Services Ltd., Calgary. 115pp. http://www.capp.ca/getdoc.aspx?DocId=24902&DT=PDF

Response: The wildlife section in the EA addresses these issues and a more detailed response is found in the Wildlife Biological Evaluation (Appendix I).

------Timber Harvest Opposing View #31 - “History, not science, refutes the claim that logging helps to prevent forest fires.

The forests of the West are far more vulnerable to fire due to a century of industrial logging and fire suppression. Logging has removed most of the older, fire-resistant trees from the forests.

North Nestucca Environmental Assessment Page 24

Appendix E – Attachment #1

Fire suppression has encouraged many smaller and more flammable trees, brush and dense plantations to fill the holes. Logging has set the forests of the West up to burn big and hot.

More logging will not fix this.”

Keene, Roy “Logging does not prevent wildfires” Guest Viewpoint, the Eugene Register Guard January 11, 2009 http://www.highbeam.com/doc/1G1-192070397.html

Response: Reduction of fire risk is not a part of the purpose and need for this project.

------Timber Harvest Opposing View #32 - “Fear of wildfire is heavily used to sell these forest “restoration” schemes. Logging has not been proven, in practice, to reduce fire frequency or intensity. Historically, the largest, most destructive blazes, like the Tillamook conflagration, were caused from logging or fueled by slash. Unlogged forests, cool and shaded, are typically more fire resistant than cut over, dried-up stands choked with slash and weeds.

Large-scale logging (by any name) has devalued our forests, degraded our waters, damaged soils, and endangered a wide variety of plants and animals. How will the current round of politically and environmentally propelled ‘restorative’ logging proposals differ, in practice, from past logging regimes?”

Keene, Roy Restorative Logging? “More rarity than reality” Guest Viewpoint, the Eugene Register Guard March 10, 2011 http://eugeneweekly.com/2011/03/03/views3.html

Response: Reduction of fire risk is not a part of the purpose and need for this project. North Nestucca Environmental Assessment Page 25

Appendix E – Attachment #1

------Timber Harvest Opposing View #33 - "Timber harvesting operations affect hydrologic processes by reducing canopy interception and evapotranspiration. Many studies have documented changes in soil properties following tractor yarding (Stone, 1977; Cafferata, l983), and low- ground-pressure skidding (Sidle and Drlica, 1981). More recently, researchers have evaluated cable yarding (Miller and Sirois, 1986; Purser and Cundy, 1992). In general, these studies report decreased hydraulic conductivity and increased bulk density in forest soils after harvest."

Keppeler, Elizabeth T. Robert R. Ziemer Ph.D., and Peter H. Cafferata "Effects of Human-Induced Changes on Hydrologic Systems." An American Water Resources Association publication, June 1994 http://www.fs.fed.us/psw/publications/ziemer/Ziemer94a.PDF

Response: The hydrologic effects of the action are analyzed in the Hydrology section of the EA. The soils and stability effects are analyzed in the Soils section of the EA. Both of these analyses are supported by appropriate literature citations. Appendix A-PDC’s contains specific design criteria to minimize the effects of the action.

------Timber Harvest Opposing View #34 - "Among these four species of amphibians, the spotted salamander is most likely to be affected adversely by the logging as this species of salamander relies on dense forests with full canopies (Harding, 1997)."

"Looking at the study on a larger scale, the potential for changes caused by logging is great. Absence of trees could influence water temperature by altering available sunlight, conductivity by changing the amount of organic matter that collects in the vernal ponds, or pH if the logging process deposits foreign residues to the area. Also heavy equipment used to harvest the timber has the potential to alter the terrain."

North Nestucca Environmental Assessment Page 26

Appendix E – Attachment #1

"Modifications to the landscape could change how water flows and collects at the surface and change the size, shape, and location of the vernal ponds. Loss or alteration to small temporary water sources less than four hectares can be extremely detrimental to amphibians water (Semlitsch, 2000). Without vernal ponds amphibians would have difficulty inhabiting forested areas because they rely on the ponds as breeding grounds. If logging disturbs the ponds, amphibian populations could diminish in the areas that surround these vernal pools."

Klein, Al 2004. Logging Effects on Amphibian Larvae Populations in Ottawa National Forest. http://www.nd.edu/~underc/east/education/documents/AKlein2004Pre- loggingsurveyofamphibianlarvaeinvernalpools.pdf

Response: The hydrologic effects of the action are analyzed in pages 61 through 67 in the EA. The wildlife section (pg. 37) in the EA addresses amphibians and a more detailed response is found in the Wildlife Biological Evaluation (Appendix I).

------Timber Harvest Opposing View #35 - “The Congressional Research Service (CRS) recently addressed the effect of logging on wildfires in an August 2000 report and found that the current wave of forest fires is not related to a decline in timber harvest on Federal lands. From a quantitative perspective, the CRS study indicates a very weak relationship between acres logged and the extent and severity of forest fires. To the contrary, in the most recent period (1980 through 1999) the data indicate that fewer acres burned in areas where logging activity was limited.”

“Qualitative analysis by CRS supports the same conclusion. The CRS stated: "[T]imber harvesting removes the relatively large diameter wood that can be converted into wood products, but leaves behind the small material, especially twigs and needles. The concentration of these fine fuels on the forest floor increases the rate of spread of wildfires." Similarly, the National Research Council found that logging and clearcutting can

North Nestucca Environmental Assessment Page 27

Appendix E – Attachment #1

cause rapid regeneration of shrubs and trees that can create highly flammable fuel conditions within a few years of cutting.”

Laverty, Lyle, USDA Forest Service and Tim Hartzell U.S. Department of the Interior “A Report to the President in Response to the Wildfires of 2000”, September 8, 2000. http://frames.nacse.org/6000/6269.html

Response: Reduction of fire risk is not a part of the purpose and need for this project.

------Timber Harvest Opposing View #36 - “I will turn first to forest thinning aimed at reducing fire risks. There is surprisingly little scientific information about how thinning actually affects overall fire risk in national forests.”

“How can it be that thinning could increase fire risks? First, thinning lets in sunlight and wind, both of which dry out the forest interior and increase flammability. Second, the most flammable material - brush, limbs, twigs, needles, and saplings - is difficult to remove and often left behind. Third, opening up forests promotes brushy, flammable undergrowth. Fourth, logging equipment compacts soil so that water runs off instead of filtering in to keep soils moist and trees healthy. Fifth, thinning introduces diseases and pests, wounds the trees left behind, and generally disrupts natural processes, including some that regulate forest health, all the more so if road construction is involved.”

Lawrence, Nathaniel, NRDC senior attorney “Gridlock on the National Forests” Testimony before the U.S. House of Representatives Subcommittee on Forests and Forest Health (Committee on Resources) December 4, 2001. http://www.nrdc.org/land/forests/tnl1201.asp

Response: Reduction of fire risk is not a part of the purpose and need for this project. The hydrologic effects of the action are analyzed in pages 61 through 67 in the EA. The soils and stability effects are analyzed Soils & Hydrology sections of the EA. Both of

North Nestucca Environmental Assessment Page 28

Appendix E – Attachment #1

these analyses are supported by appropriate literature citations. Appendix A-PDC’s contains specific design criteria to minimize the effects of the action.

------Timber Harvest Opposing View #37 - “Those who would argue that this form of logging has any positive effects on an ecosystem are clearly misinformed. This type of logging has side effects related to wildfires, first and foremost being that the lumber companies aren't interested in hauling out all the smaller trees, branches, leaves, pine needles, sawdust, and other debris generated by cutting all these trees. All this debris is left on site, quickly dries out, and is far more flammable sitting dead on the ground than it was living in the trees. Smaller, non-commercially viable trees are left behind (dead) as well - creating even more highly flammable fuel on the ground.

Leitner, Brian. “Logging Companies are Responsible for the California Wildfires.” the Democratic Underground, October 30, 2003. http://www.democraticunderground.com/articles/03/10/30_logging.html

Response: Reduction of fire risk is not a part of the purpose and need for this project.

------Timber Harvest Opposing View #38 - "We concluded that commercial timber sales do not meet the criteria for forest restoration." (Pg. 11)

Long, Richard D., U.S. Department of Agriculture Office of Inspector General "Western Region Audit Report: Forest Service National Fire Plan Implementation" Report No. 08601-26-SF, November 2001. http://maps.wildrockies.org/ecosystem_defense/Resources_Species_Topics/Fire/Misus e%20of%20Fire%20Plan%20funds.pdf

North Nestucca Environmental Assessment Page 29

Appendix E – Attachment #1

Response: This report is focused on timber sales with an avowed purpose of reducing fire risks, reduction of fire risk is not a part of the purpose and need for this project. The stands proposed for treatment are not part of the suitable timber base, and thus are not part of the Allowable Sale Quantity (ASQ). All silvicultural activities, including thinning, are designed to encourage the attainment of late-successional forest characteristics.

------Timber Harvest Opposing View #39 - “In hopes of ending conflicts over "multiple use," an independent scientific committee has proposed that "ecological sustainability" should become the principal goal in managing the U.S. national forests and grasslands, which since 1960 have been under a congressional mandate to serve industry, recreation, and conservation all at once.”

Mann, Charles C. Ph.D. and Mark L. Plummer Ph.D. “Call for 'Sustainability' in Forests Sparks a Fire” Science 26 March 1999: Vol. 283. no. 5410, pp. 1996 – 1998 http://www.sciencemag.org/content/283/5410/1996.summary

------Timber Harvest Opposing View #40 - "Logging removes a mass that harbor a myriad of organisms, from bacteria and actinomycetes to higher fungi. The smaller organisms, not visible to the unaided eye, are still important components of the system."

Maser, C. Ph.D., and J. M. Trappe Ph.D.

North Nestucca Environmental Assessment Page 30

Appendix E – Attachment #1

“The Seen and Unseen World of the Fallen Tree”, 1984 USDA Forest Service, GTR-PNW-164 http://www.fs.fed.us/pnw/publications/pnw_gtr164/

------Timber Harvest Opposing View #41 - "Logging removes mature and maturing trees which conserve essential elements, whereas the area containing new very young planted trees following logging are susceptible to erosion and essential element loss." (pg.5)

"Logging removes tree parts that would have created and maintained diversity in forest communities." (pg. 44)

Maser, C. Ph.D., R. F. Tarrant, J. M. Trappe Ph.D., and J. F. Franklin Ph.D. 1988 “The Forest to the Sea: A Story of Fallen Trees” USDA Forest Service, GTR-PNW-GTR-229 http://www.fs.fed.us/pnw/publications/pnw_gtr229/

------Timber Harvest Opposing View #42 - "In addition to the direct effects of habitat loss and fragmentation, logging typically reduces ecosystem health by: North Nestucca Environmental Assessment Page 31

Appendix E – Attachment #1

a) damaging aquatic habitats through siltation, reduction in stream complexity and increased water temperatures.”

McIntosh, B.A., J.R. Sedell, J.E. Smith, R.C. Wissmar S.E. Clarke, G.H. Reeves, and L.A. Brown “Management history of eastside ecosystems: changes in fish habitat over 50 years, 1935-1992.” 1994 GTR-321 93-181 http://www.fs.fed.us/pnw/publications/pnw_gtr321/

Response: The current thinning program on the Siuslaw is focused on encouraging the development of late successional forest characteristics, and maximizing economic return is not part of the purpose and need. The article also focused on increasing fragmentation caused by clear cutting, thinning does not contribute to increased fragmentation. The Hydrology, Soils and fisheries sections of the EA contain additional information on the effects of the action on streams.

------Timber Harvest Opposing View #43 - “Logging practices can indirectly result in changes in the biological components of a stream, and can have direct and indirect on the physical environment in streams.

The primary environmental changes of concern are the effects of siltation, logging debris, gravel scouring, destruction of developing embryos and alevins, blockage of streamflow, decrease in surface and intragravel dissolved oxygen, increase in maximum and diel water temperatures, changes in pool/riffle ratios and cover, redistribution of fishes, reduction in fish numbers, and reduction in total biomass.”

Moring, John R. Ph.D. 1975. “The Alsea Watershed Study: Effects of Logging on the Aquatic Resources of Three Headwater Streams of the Alsea River, Oregon – Part III.” Fishery Report Number 9 Oregon Department of Fish and Wildlife. http://www.for.gov.bc.ca/hfd/library/ffip/Moring_JR1975b.pdf

North Nestucca Environmental Assessment Page 32

Appendix E – Attachment #1

Response: The Hydrology, Soils and fisheries sections of the EA contain additional information on the effects of the action on streams.

------Timber Harvest Opposing View #44 - "Biodiversity in managed ecosystems is poor. Less biodiverse communities and ecosystems are more susceptible to adverse weather (such as drought) and exotic invaders, and have greatly reduced rates of biomass production and nutrient cycling."

"All of these studies show that ecosystem functioning is decreased as the number of species in a community decreases. Declines in functioning can be particularly acute when the number of species is low, such as in most managed ecosystems including croplands or timber plantations."

"Recent evidence demonstrates that both the magnitude and stability of ecosystem functioning are likely to be significantly altered by declines in local diversity, especially when diversity reaches the low levels typical of managed ecosystems."

Naeem, Shahid Ph.D., F.S. Chapin III Ph.D., Robert Costanza Ph.D., Paul R. Ehrlich Ph.D., Frank B. Golley Ph.D., David U. Hooper Ph.D. J.H. Lawton Ph.D., Robert V. O’Neill Ph.D., Harold A. Mooney Ph.D. Osvaldo E. Sala Ph.D., Amy J. Symstad Ph.D., and David Tilman Ph.D. "Biodiversity and Ecosystem Functioning: Maintaining Natural Life Support Processes." Issues in Ecology No. 4. Fall 1999. http://www.esa.org/science_resources/issues/TextIssues/issue4.php

Response: The project design is specifically directed at creating late successional forest characteristics. The existing stands tend to be monocultures of even aged conifers. This includes underplanting, gap creation, CWD creation and the encouragement of natural re-vegetation by allowing light to hit the forest floor.

North Nestucca Environmental Assessment Page 33

Appendix E – Attachment #1

------Timber Harvest Opposing View #45 - "As a result of the Forest Service's well-documented mismanagement over many years of the timber sale program, taxpayers also have been stuck with the tab for hundreds of millions of dollars worth of subsidies to a profitable timber industry."

Nappier, Sharon. Lost in the Forest: How the Forest Service's Misdirection, Mismanagement, and Mischief Squanders Your Tax Dollars. Taxpayers for Common Sense, 2002. http://www.ourforests.org/fact/lostintheforest.pdf

Response: This 2002 report focused on the poor condition of the existing road systems and the use of FS funds to build logging roads. The condition of the existing road network is outside the scope of this project. However, the timber purchaser will be responsible to build and remove any temporary roads needed for the project. As part of the project the timber buyer will perform much needed maintenance on existing Forest Service roads. Separate projects, such as the Legacy Roads Project are beginning to address the backlog in road maintenance and to reduce the existing road network.

------Timber Harvest Opposing View #46 - "Agroforestry does reduce biodiversity. In forests used for logging, whole-landscape management is crucial. Here, emphasis is placed on areas of intensive use interspersed with areas for conservation and catchment purposes. Management strategies for sustainable forestry are being developed, but there is a need for further interaction among foresters, ecologists, community representatives, social scientists, and economists."

Noble, Ian R. and Rodolfo Dirzo Ph.D. "Forests as Human-Dominated Ecosystems." Science Vol. 277. No. 5325, pp. 522 - 525. 25 July 1997. http://www.sciencemag.org/content/277/5325/522.abstract?maxtoshow=&HITS=10&hits =10&RESULTFORMAT=&fulltext=logging&searchid=1136659907310_5043&FIRSTIND EX=0&journalcode=sci

North Nestucca Environmental Assessment Page 34

Appendix E – Attachment #1

Response: This project involves thinning of sub-dominant trees to encourage the growth of larger trees. It is also only impacting a very small portion of the watershed. The total project area is 75,112 acres. The project proposes to thin 5,229 acres which is only 6.9% of the project area. The total Nestucca basin consists of 163,000 acres, we are only thinning 3.2% of the whole basin. The Watershed Analysis for the Nestucca Watershed (1994) is a guiding document for this restoration and was the product of a diverse group of stakeholders.

------Timber Harvest Opposing View #47 - "The U.S. Forest Service has been sitting on a public opinion survey it commissioned, not knowing what to do with the results. The problem is that most people surveyed want more wilderness and less logging on the Green Mountain National Forest (GMNF), while the federal agency seems to want to build more roads and cut more trees."

"The survey conducted by Dr. Robert Manning of the School of Natural Resources at the University of Vermont, polled 1,500 Vermont households in the spring of 1995. A survey with similar results was completed last fall for the White Mountain National Forest in New Hampshire. 'It is clear that New England residents value the national forest for many reasons, but non- material values, such as aesthetics and ecological protection, are more important than material values, such as economic development,' said Dr. Manning."

"The responses to several survey questions indicate a strong public desire for more areas of wild, untouched nature on the GMNF and less roadbuilding and logging. Very few people supported clearcutting and other types of industrial logging, especially if natural beauty or wildlife habitat were harmed."

"For example:

• 82 percent wanted to ban clearcutting,

North Nestucca Environmental Assessment Page 35

Appendix E – Attachment #1

• 82 percent said logging should not hurt scenic beauty, • 80 percent of the respondents wanted to protect remaining undisturbed forest; and • 72 percent urged prohibition of logging if bear or other wildlife habitat would be harmed."

"Only 36 percent felt that management of the GMNF should emphasize timber and lumber products; and only 15 percent felt that jobs are more important than protection of endangered species."

"'The results of this survey and a similar one on the White Mountain National Forest in Vermont should serve as loud wake-up calls to the U.S. Forest Service,' said Northup. 'Forest Service officials have two choices: either begin a major overhaul of the agency's management programs or ignore the wishes of the people they are supposed to serve'."

Northup, Jim. 1999. "Public Wants More Wilderness, Less Logging on Green Mountain NF". Press Release by Forest Watch, a Vermont-based environmental organization. http://www.forestwatch.org/content.php?id=10

Response: Timber is not emphasized as a product of this action. There is no clear cutting occurring, only thinning of overstocked managed conifer stands. Large sections of the project area, and watershed basin, are being protected from any disturbance.

------Timber Harvest Opposing View #48 - “Still, forestry experts warned in the 2000 plan that logging should be used carefully and rarely; in fact, the original draft states plainly that the "removal of large merchantable trees from forests does not reduce fire risk and may, in fact, increase such risk."

“Now, critics charge that the Bush administration is ignoring that warning. Neil Lawrence, a policy analyst with the Natural Resource Defense Council, claims that Washington has taken a far more aggressive approach to incorporating commercial logging in its wildfire prevention plans. As a

North Nestucca Environmental Assessment Page 36

Appendix E – Attachment #1

result, Lawrence and other critics say, the National Fire Plan is becoming a feeding ground for logging companies. Moreover, critics claim the administration's strategy, far from protecting the lives and homes of those most at risk, could actually increase the likelihood of wildfires.”

Okoand Ilan Kayatsky, Dan. “Fight Fire with Logging?” Mother Jones, August 1, 2002 http://motherjones.com/politics/2002/08/fight-fire-logging

Response: Reduction of fire risk is not a part of the purpose and need for this project. This project involves thinning of sub-dominant trees to encourage the growth of larger trees. It is also only impacting a very small portion of the watershed. The total project area is 75,112 acres. The project proposes to thin 5,229 acres which is only 6.9% of the project area. The total Nestucca basin consists of 163,000 acres, we are only thinning 3.2% of the whole basin.

------Timber Harvest Opposing View #49 - “In response to catastrophic wildfires, wide-reaching forest management policies have been enacted in recent years, most notably the Healthy Forests Restoration Act of 2003. A key premise underlying these policies is that fire suppression has resulted in denser forests than were present historically in some western forest types. Therefore, although reducing the threat of wildfire is the primary goal, forest managers commonly view fuel treatments as a means to restore historic forest structure in those forest types that are outside of their historic range of variation. This study evaluates where both wildfire mitigation and restoration of historic forest structure are potentially needed in the ponderosa pine–dominated montane forest zone of Boulder County, Colorado. Two spatial models were overlain: a model of potential fireline intensity and a model of historic fire frequency. The overlay was then aggregated by land management classes.

Contrary to current assumptions, results of this study indicate that both wildfire mitigation and restoration of historic forest structure are needed in only a small part of the study area, primarily at low elevations.

North Nestucca Environmental Assessment Page 37

Appendix E – Attachment #1

Furthermore, little of this land is located on Forest Service land where most of the current thinning projects are taking place. We question the validity of thinning as a means both to reduce the threat of wildfire and to restore historic forest structure in the absence of site-specific data collection on past and present landscape conditions.”

Platt, Rutherford V. Ph.D., Thomas T. Veblen Ph.D., and Rosemary L. Sherriff “Are Wildfire Mitigation and Restoration of Historic Forest Structure Compatible? A Spatial Modeling Assessment” Published Online: by the by Association of American Geographers. Sep. 8, 2006 http://www.ingentaconnect.com/content/routledg/anna/2006/00000096/00000003/art000 01

Response: Reduction of fire risk is not a part of the purpose and need for this project.

------Timber Harvest Opposing View #50 - "Private lands are more suitable for timber production. National Forest land is on average of lower productivity and on steeper, higher elevation terrain than are private forestlands."

Powell, Douglas S. Ph.D, Joanne L. Faulkner, David R. Darr, Zhiliang Zhu Ph.D. and Douglas W. MacCleery. 1992. "Forest Resources of the United States." USDA Forest Service. Rocky Mt. Forest and Range Experiment Station. Gen. Tech. Rep. RM-234. http://www.fs.fed.us/rm/pubs_rm/rm_gtr234.html

North Nestucca Environmental Assessment Page 38

Appendix E – Attachment #1

------Timber Harvest Opposing View #51 - "Fire severity has generally increased and fire frequency has generally decreased over the last 200 years. The primary causative factors behind fire regime changes are effective fire prevention and suppression strategies, selection and regeneration cutting, domestic livestock grazing, and the introduction of exotic plants."

Quigley, Thomas M. Ph.D., Richard W. Haynes and Russell Graham Tech. editors. 1996. “Integrated Scientific Assessment for Ecosystem Management in the Interior Columbia Basin and Portions of the Klamath and Great Basins.” USDA Forest Service, PNW-GTR-382, 303 p. http://www.fs.fed.us/pnw/publications/icbemp.shtml

Response: Reduction of fire risk is not a part of the purpose and need for this project.

------Timber Harvest Opposing View #52 - “Less than 5% of America's original forests remain, and these forests are found primarily on federal lands. Logging in the last core areas of biodiversity is destroying the remaining intact forest ecosystems in the United States. At the current rate of logging, these forests and their priceless biological assets will be destroyed within a few decades.

We urge Congress to pass the Act to Save America's Forests. It is the first nationwide legislation that would halt and reverse deforestation on all our federal lands. By implementing protective measures based on principles of conservation biology, the bill provides a scientifically sound legislative solution for halting the rapid decline of our nation's forest ecosystems.

The Act to Save America's Forests will:

North Nestucca Environmental Assessment Page 39

Appendix E – Attachment #1

• Make the preservation and restoration of native biodiversity the central mission of Federal forest management agencies.

• Ban extractive logging in core areas of biodiversity and the last remnant original forest ecosystems: roadless areas, ancient forests and special areas of outstanding biological value.

• Protect sensitive riparian areas and watershed values by banning extractive logging in streamside buffer zones.

• End clearcutting and other even age logging practices on federal land.

• Establish a panel of scientists to provide guidance to federal forest management.

We believe it is our professional responsibility to ask Congress to align Federal forest management with modern scientific understandings of forest ecosystems. Passage of the Act to Save America's Forests will give our nation's precious forest ecosystems the best chance or survival and recovery into the 21st century and beyond.”

Raven, Peter, Ph.D., Jane Goodall, C.B.E., Ph.D., Edward O. Wilson, Ph. D. and over 600 other leading biologists, ecologists, foresters, and scientists from other forest specialties. From a 1998 letter to congress. http://www.saveamericasforests.org/resources/Scientists.htm

Response: This project involves no clear cutting and no impacts on any roadless or proposed roadless areas. Riparian areas are protected by extensive no harvest buffers. The Northwest Forest Plan which provides management direction for this area was developed by panel of scientists.

------

North Nestucca Environmental Assessment Page 40

Appendix E – Attachment #1

Timber Harvest Opposing View #53 - “The Act to Save America’s Forests is based on the principles of conservation biology. It would make the protection native biodiversity the primary goal of federal forest management agencies. The bill would protect over 20 million acres of core forest areas throughout the nation, including ancient forests, roadless areas, key watershed, and other special areas. It is a comprehensive, sustainable, and ecologically-sound plan for protecting and restoring the entire federal forest system.

If the current pace of logging planned by the Forest Service continues, nearly all of America’s ancient and roadless wild forests will soon be lost forever. According to a recent report by the World Resources Institute, only one percent of the original forest cover remains in large blocks within the lower 48 states. The Act to Save America’s Forests incorporates the solution recommended by the report, namely to protect core forest areas from any logging and to allow sustainable forest practices around these protected forests. Endorsed by over 600 leading scientists, this bill may be the last hope for America’s forests.”

Raven, Peter, Ph.D., from his February 9, 2001 letter to Senator Jean Carnahan http://www.saveamericasforests.org/Raven.htm

Response: Activities are proposed to occur only in existing managed stands. No “Ancient Forests” or roadless areas will be impacted by this project.

------Timber Harvest Opposing View #54 - “It is well established that logging and roadbuilding often increase both fuel loading and fire risk. For example, the Sierra Nevada Ecosystem Project (SNEP) Science Team (1996) concluded that “timber harvest…. has increased fire severity more than any other recent human activity” in the Sierra Nevada. Timber harvest may increase fire hazard by drying of microclimate associated with canopy opening and with roads, by increases in fuel loading by generation of activity fuels, by increases in ignition sources associated with machinery North Nestucca Environmental Assessment Page 41

Appendix E – Attachment #1

and roads, by changes in species composition due to opening of stands, by the spread of highly flammable non native weeds, insects and disease, and by decreases in forest health associated with damage to soil and residual trees (DellaSala and Frost, 2001; Graham et al., 2001; Weatherspoon et al., 1992; SNEP Science Team, 1996). Indeed a recent literature review reported that some studies have found a positive correlation between the occurrence of past logging and present fire hazard in some forest types in the Interior Columbia Basin (DellaSala and Frost, 2001).”

Roberson, Emily B. Ph.D., Senior Policy Analyst, California Native Plant Society Excerpt from a letter to Chief Dale Bosworth and 5 members of congress http://www.plantsocieties.org/PDFs/Fire%20letter%20CNPS%208.02%20letterhead.pdf

Response: Reduction of fire risk is not a part of the purpose and need for this project. This paper focuses on eastern fire prone forests and does not have any direct application to the project area.

------Timber Harvest Opposing View #55 - “I will discuss my views on how activities related to timber harvest adversely affect coastal salmonids in California by destroying, altering, or otherwise disturbing the freshwater habitats upon which these fish depend during crucial phases of their life cycle. I base these opinions on my research and observations in the field, as well as my review of and familiarity with the scientific literature and publications of government agencies, commissions, and scientific review panels. Below I discuss in some detail the life history and habitat needs of coho salmon to illustrate how timber harvest and related roads affect this threatened species. Although Chinook salmon and steelhead trout have similar life histories and habitat needs, and also are negatively affected by timber harvest, I will use coho salmon in my discussion.”

“Loss or degradation of stream habitat has been and remains the single most significant cause of the decline of anadromous salmonids in general in the Pacific Northwest. In my experience the most pervasive and severe

North Nestucca Environmental Assessment Page 42

Appendix E – Attachment #1

impacts to coastal watersheds in California inhabited by coho salmon result from logging and associated activities. These activities cause significant alteration and degradation to coho salmon habitat by 1) increasing sediment input to salmon bearing streams and their tributaries: 2) by decreasing input of LWD into waterways; 3) by altering streamflow regimes, increasing the likelihood of scouring flows and flooding; and 4) by increasing water temperatures. These pervasive changes due to timber harvest decrease the complexity and suitability of coho salmon habitat, including adversely affecting insects and other organisms that provide food for fish.”

Roelofs, Terry D. Ph.D. Testimony for the California State Water Board and Regional Water Quality Control Boards Regarding Waivers of Waste Discharge Requirements on Timber Harvest Plans. August 2003. http://webcache.googleusercontent.com/search?q=cache:QNy_aih1RxEJ:edennapa.org /thp/roelofstestimony.doc+%22timber+harvest%22+ph.d.+adverse&hl=en&ct=clnk&cd= 5&gl=us

Response: The EA provides an analysis of the effects of the project on aquatic species in the Fisheries section of the EA, and a more detailed response is available in Appendix H. The hydrology analysis also clarifies potential impacts to aquatic species.

------Timber Harvest Opposing View #56 - “People moving to the region may do so for reasons related to the social environment and the physical landscape but not care about specific Federal land management practices. We found this not to be true, since 92 percent were concerned with how Federal lands were managed. The most frequent preferences for managing Federal lands were water/watershed and ecosystem protection (table 3). Timber harvesting was cited by 16 percent, grazing and ranching by 6 percent, and mineral exploration/mining by less than 1 percent. Overall, protective strategies made up 76 percent of the preferred management strategies and commodity-based strategies 23 percent. This same trend is evident for the second and third most stated preferences. These findings also contradict the longstanding view of the Federal lands

North Nestucca Environmental Assessment Page 43

Appendix E – Attachment #1

as a public warehouse of commodities to be harvested and jobs to be filled. For newcomers in the rural West, the value of these public lands is related to protecting and preserving them.”

Rudzitis, Gundars. 1999 “Amenities Increasingly Draw People to the Rural West” Rural Development Perspectives, vol. 14, no. 2 http://www.ers.usda.gov/publications/rdp/rdpsept99/rdpsept99b.pdf

------Timber Harvest Opposing View #57 - “Once clear-cutting has occurred, regulation and human silvicultural practices become responsible for the revegetation that follows. The creation of new forest succession patterns are the result of human control over the growing environment. Rather than proceeding at a natural pace, humans attempt to speed up the forest succession process to quickly return to a situation where harvesting is again possible. Reforestation of the disturbed area after clear-cutting also emphasizes maintaining control over the distribution and quality of forest species.

Simplification is a state that results from the forest being harvested before it reaches maturity. Logging simplifies forest ecosystems (Dudley et al 1995) by narrowing the age range of the stand and suppressing diversification through repeated harvesting, burning to remove slash, and replanting with hybrid seedlings. Simplification affects the health and productivity of the forest because simplified forests lack the variety found in older stands, including species diversity, vertical structure, and microhabitat. From an ecological standpoint, a simplified forest of a particular age has less overall bio-mass per acre than a natural forest of the same age, but a simplified forest produces a higher volume of merchantable timber.

North Nestucca Environmental Assessment Page 44

Appendix E – Attachment #1

Scott, Mark G. “Forest Clearing in the Gray’s River Watershed 1905-1996” A research paper submitted in partial fulfillment of the requirements for the degree of MASTER OF SCIENCE in GEOGRAPHY Portland State University, 2001 http://www.markscott.biz/papers/grays/chapter1.htm

------Timber Harvest Opposing View #58 - “Within this volatile atmosphere the Bush Administration presented a new proposal for fire prevention called the "Healthy Forest Initiative." The plan received wide coverage in the national media in August and September 2002 and continues to be at the center of an attempt to significantly shift public land management in the United States. At the core of the plan is an effort to create private sector incentives to promote logging/thinning projects in the national forests.”

Short, Brant, Ph.D. and Dayle C. Hardy-Short Ph.D. "Physicians of the Forest": A Rhetorical Critique of the Bush Healthy Forest Initiative” Electronic Green Journal, Issue #19, December 2003 http://escholarship.org/uc/item/4288f8j5

Response: Reduction of fire risk is not a part of the purpose and need for this project. The stands proposed for treatment are not part of the suitable timber base, and thus are not part of the Allowable Sale Quantity (ASQ). All silvicultural activities, including thinning, are designed to encourage the attainment of late-successional forest characteristics.

------

North Nestucca Environmental Assessment Page 45

Appendix E – Attachment #1

Timber Harvest Opposing View #59 - “Logging on the National Forests provides less than 5% of the nation's timber supply, but costs the taxpayers more than 1 billion dollars in subsidies every year. Nor is logging a good job provider compared to recreation, which by Forest Service estimates provides over 30 times the economic benefits of logging. These forests are the last remnants of the virgin forests that covered the country, and now have far more value as forest ecosystems, watershed/water supply protection, and recreational assets than for logging. In fact, the justification for the Weeks Act in 1911 which established national forests in the east, was watershed protection.

(A major barrier to the Forest Service changing its ways is that these increased recreational economic benefits flow into the local economy, not to the Forest Service itself, whereas extractive uses of the national forests contribute directly to Forest Service budgets.)

“Our nation is engaged in a great debate over the real purpose of our national forests, with the weight of public opinion swinging more and more strongly toward preservation. Certainly this nation should not be subsidizing logging when it is clear that we understand so little about the functioning of these enormously complex and ancient forest ecosystems that provide millions of people with clean air and water, as well as homes for a myriad of plants and wildlife that can live nowhere else.”

Sierra Club. 2005 “Ending Commercial Logging on Public Lands” http://northcarolina.sierraclub.org/pisgah/conservation/ecl.html

------Timber Harvest Opposing View #60 - “Timber harvesting in British Columbia influences (a) forest hydrology; (b) fluvial geomorphology; (c) North Nestucca Environmental Assessment Page 46

Appendix E – Attachment #1

terrain stability; and (d) integrated watershed behavior. Impacts on forest hydrology are well understood and include increased average runoff, total water yield, increased storm runoff and advances in timing of floods. Stream channels and valley floors are impacted differently by fine sediment, coarse sediment and large woody debris transport. Terrain stability is influenced through gully and mass movement processes that are accelerated by timber harvesting. Impacts on integrated watershed behavior are assessed through disturbed sediment budgets and lake sediments.”

Slaymaker, Olav Ph.D. “Assessment of the Geomorphic Impacts of Forestry in British Columbia” AMBIO: A Journal of the Human Environment 29(7):381-387. 2000 http://www.bioone.org/doi/abs/10.1579/0044-7447-29.7.381

Response: The hydrologic effects of the action are analyzed in the Soils &Hydrology section on the EA. The soils and stability effects are analyzed in the Soils &Hydrology section of the EA. Both of these analyses are supported by appropriate literature citations. Appendix A-PDC’s contains specific design criteria to minimize the effects of the action.

------Timber Harvest Opposing View #61 - “In sum, 100 years of fire suppression and logging have created conditions that threaten central Oregon’s natural resources and communities.”

“Thus it is inexplicable that the solution proposed by President Bush and some members of Congress emphasizes fire suppression and commercial logging, the very practices that created today’s crisis. The federal government continues to attempt to suppress over 99% of all wildland fires. The Forest Service continues to measure its success not in terms of ecosystems restored, but in fires put out. The President’s Healthy Forest Initiative, as embodied in H.R. 1904, promotes commercial logging at the expense of citizen participation and oversight of the forests we own.”

Stahl, Andy. “Reducing the Threat of Catastrophic Wildfire to

North Nestucca Environmental Assessment Page 47

Appendix E – Attachment #1

Central Oregon Communities and the Surrounding Environment.” Testimony before the House Committee on Resources, August 25, 2003 http://www.propertyrightsresearch.org/2004/articles6/testimony_of_andy_stahl.htm

Response: Reduction of fire risk is not a part of the purpose and need for this project.

------Timber Harvest Opposing View #62 - “Fire, just like insects and disease, are a natural and beneficial part of forest ecosystems and watersheds. Without these natural processes the forest ecosystems quickly degrade. Excessive logging removes and reduces cooling shade adding to the hotter, drier forests along with logging debris creating a more flammable forest. Current "forest management" practices, road building and development cause forest fires to rage for hundreds of miles.

The Sierra Nevada Ecosystem Project said in a report to the U.S. Congress that timber harvests have increased fire severity more than any other recent human activity. Logging, especially clear cutting, can change the fire climate so that fires start more easily, spread faster, further, and burn hotter causing much more devastation than a fire ignited and burned under natural conditions. If we stop the logging and stop building fire prone developments, we minimize the loss of lives and property suffered by people in fires.

As long as the people of America let politicians, timber executives, and the Forest Service get away with it - it will not stop. Those corporations that profit will continue to lie, cheat and steal to continue to make more money from our losses. Just like big tobacco.”

Strickler, Karyn and Timothy G. Hermach, “Liar, Liar, Forests on Fire: Why Forest Management Exacerbates Loss of Lives and Property” Published by CommonDreams.org, October 31, 2003 http://www.commondreams.org/scriptfiles/views03/1031-10.htm

North Nestucca Environmental Assessment Page 48

Appendix E – Attachment #1

Response: Reduction of fire risk is not a part of the purpose and need for this project.

------Timber Harvest Opposing View #63 - “The agency’s commercial timber program can contribute to the risk and severity of wildfire in the National Forests, yet Congress devotes nearly one-third of the Forest Service’s entire budget to this wasteful program.” (pg. 1)

“Do not utilize the commercial timber program to reduce the risk of fire. Commercial incentives undercut forest health objectives and can actually increase the risk of fire.” (pg. 9)

“Commercial logging, especially of larger, fire-resistant trees, in the National Forests is one of several factors contributing to the risk and severity of wildfire.” (pg. 19)

“Commercial logging and logging roads open the forest canopy, which can have two effects. First, it allows direct sunlight to reach the forest floor, leading to increased evaporation and drier forests.5 As a consequence, ground fuels (grass, leaves, needles, twigs, etc.) dry out more quickly and become susceptible to fire. Second, an open canopy allows more sunlight to reach the understory trees, increasing their growth.6 This can lead to weaker, more densely-packed forests.” (pgs. 19-20)

“Congress and the Forest Service continue to rely on the commercial logging program to do something it will never accomplish – reduce fire risk. The commercial logging program is designed to provide trees to private timber companies, not to reduce the risk of fire.” (pg. 20)

Taxpayers for Common Sense. “From the Ashes: Reducing the Harmful Effects and Rising Costs of Western Wildfires” Washington DC , Dec. 2000 http://www.ourforests.org/fact/ashes.pdf

North Nestucca Environmental Assessment Page 49

Appendix E – Attachment #1

Response: Reduction of fire risk is not a part of the purpose and need for this project.

------Timber Harvest Opposing View #64 - “Indiscriminate logging is not a viable solution to reducing wildfire risk. Logging can actually increase fire danger by leaving flammable debris on the forest floor. Loss of tree canopy lets the sun in, encouraging the growth of brush, increases wind speed and air temperature, and decreases the humidity in the forest, making fire conditions even worse.”

Thomas, Craig. “Living with risk: Homeowners face the responsibility and challenge of developing defenses against wildfires.” Sacramento Bee newspaper, July 1, 2007. http://www.sierraforestlegacy.org/NR_InTheNews/SFLIP_2007-07- 01_SacramentoBee.php

Response: Reduction of fire risk is not a part of the purpose and need for this project.

------Timber Harvest Opposing View #65 - "Timber harvest, through its effects on forest structure, local microclimate, and fuels accumulation, has increased fire severity more than any other recent human activity."(pg.62)

University of California; SNEP Science Team and Special Consultants 1996 “Sierra Nevada Ecosystem Project: Final Report to Congress” Volume 1, Chapter 4 – Fire and Fuels. http://ceres.ca.gov/snep/pubs/web/PDF/v1_ch04.pdf

Response: Reduction of fire risk is not a part of the purpose and need for this project.

North Nestucca Environmental Assessment Page 50

Appendix E – Attachment #1

------Timber Harvest Opposing View #66 - "During the post-World War II housing boom, national forests were viewed as a ready supply of building material. The increased demand for timber from national forests led to more widespread use of commodity-oriented harvesting techniques such clearcutting. Along with the increased logging that followed, concern over the environment increased. In the 1960's and 1970's, several laws were enacted to protect forests. Additional laws formalized the concept of "multiple-use," whereby the uses of timber, forage, and water shared equal footing with wildlife conservation and recreation opportunities."

USDA Forest Service. "Forest Management: A Historical Perspective." http://www.fs.fed.us/forestmanagement/aboutus/histperspective.shtml

------Timber Harvest Opposing View #67 - "The development of sound forestmanagement policies requires that consideration be given to the economic benefits associated with competing uses of forest resources. The benefits that may be provided under different management regimes include both use values (such as those provided by timber harvesting and recreation) and passive-use (or nonuse) values, including existence value, option value and quasi-option value. Many of these benefits are not revealed in market transactions, and thus cannot be inferred from conventional data on prices and costs."

Vincent, James W. Ph.D., Daniel A. Hagen, Ph.D., Patrick G. Welle

North Nestucca Environmental Assessment Page 51

Appendix E – Attachment #1

Ph.D. and Kole Swanser. 1995. Passive-Use Values of Public Forestlands: A Survey of the Literature. A study conducted on behalf of the U.S. Forest Service. http://www.icbemp.gov/science/vincent.pdf

------Timber Harvest Opposing View #68 - “Unfortunately, there are number of massive logging proposals, disguised as hazardous fuels treatments, that have put environmentalists at odds with the Forest Service. Nearly all of these proposals focus primarily on the removal of mature and old-growth trees. These proposals continue even with overwhelming evidence that commercial logging is more of a problem than a solution. There's simply a cognitive disconnect between the Forest Service's scientists and its timber sale planners, whose budgets are dependent upon selling valuable mature trees.

Ironically, this very type of logging, experts inform us, is likely to increase, not decrease, the frequency and severity of wildland fires.

In the Forest Service's own National Fire Plan, agency scientists warned against the use of commercial logging to address fire management. The report found that ‘the removal of large, merchantable trees from forests does not reduce fire risk and may, in fact, increase such risk.’ “

Voss, René “Getting Burned by Logging,” July 2002 The Baltimore Chronicle http://www.baltimorechronicle.com/firelies_jul02.shtml

North Nestucca Environmental Assessment Page 52

Appendix E – Attachment #1

Response: Reduction of fire risk is not a part of the purpose and need for this project. The Northwest Forest Plan has designated all of the lands in this project into a combination of Late Successional Reserve, Riparian Reserve and Adaptive Management Area. Timber harvest is only allowed as a restoration tool to encourage the development of late successional forest conditions. All resources are evaluated so that the actions can be determined to have No Significant Impact.

------Timber Harvest Opposing View #69 - “Another surprising finding is that mechanical fuels treatment, commonly known as logging and thinning, typically has little effect on the spread of wildfires. In fact, in some cases, it can increase wildfires’ spread and severity by increasing the fine fuels on the ground (slash) and by opening the forest to greater wind and solar penetration, drying fuels faster than in unlogged forests.”

Wuerthner, George. “Logging, thinning would not curtail wildfires” The Eugene Register-Guard, December 26, 2008 http://wuerthner.blogspot.com/2008/12/logging-thinning-would-not-curtail.html

Response: Reduction of fire risk is not a part of the purpose and need for this project.

------Timber Harvest Opposing View #70 - “Logging equipment compacts soils. Logging removes biomass critical to future soil productivity of the forest. Logging disturbs sensitive wildlife. Logging typically requires roads and skid trails which create chronic sources of sedimentation that degrades water quality and aquatic organism habitat. Logging roads and skid trails are also a major vector for the spread of weeds. Logging disrupts nutrient cycling and flows. Logging can alter species composition and age structure (i.e. loss of old growth). Logging can alter fire regimes. Logging can change water cycling and water balance in a drainage. The litany of negative impacts is much longer, but suffice it to say that anyone who North Nestucca Environmental Assessment Page 53

Appendix E – Attachment #1

suggests that logging is a benefit or benign is not doing a full accounting of costs.”

Those who suggest that logging “benefits” the forest ecosystem are using very narrow definitions of “benefit.” Much as some might claim that smoking helps people to lose weight and is a “benefit” of smoking.”

Wuerthner, George “Who Will Speak For the Forests?” NewWest, January 27, 2009 http://www.newwest.net/topic/article/who_will_speak_for_the_forests/C564/L564/

------Timber Harvest Opposing View #71 - "After logging, peak pipeflow was about 3.7 times greater than before logging."

"The use of heavy logging equipment was expected to compact the soil, reduce infiltration rates, and increase surface runoff. In addition, heavy equipment might collapse some of the subsurface pipes, increasing local pore water pressure and the chance of landslides (Sidle, 1986)."

Ziemer, Robert R. Ph.D., "Effect of logging on subsurface pipeflow and erosion: coastal northern California, USA." Proceedings of the Chengdu Symposium, July 1992. IAHS Publication. No. 209, 1992 http://www.fs.fed.us/psw/publications/ziemer/Ziemer92.PDF

Response: The hydrologic effects of the action are analyzed in the Soils & Hydrology section of the EA. The soils and stability effects are analyzed in the Soils & hydrology section of the EA. Both of these analyses are supported by appropriate literature citations. Appendix A-PDC’s contains specific design criteria to minimize the effects of the action.

North Nestucca Environmental Assessment Page 54

Appendix E – Attachment #1

------Timber Harvest Opposing View #72 - “As conservation-minded scientists with many years of experience in biological sciences and ecology, we are writing to bring your attention to the need to protect our National Forests. Logging our National Forests has not only degraded increasingly rare and valuable habitat, but also numerous other services such as recreation and clean water.”

“Unfortunately, the past emphasis of management has been on logging and the original vision for our National Forests has failed to be fully realized. During the past several decades, our National Forests have suffered from intense commercial logging. Today almost all of our old growth forests are gone and the timber industry has turned our National Forests into a patchwork of clearcuts, logging roads, and devastated habitat.”

“It is now widely recognized that commercial logging has damaged ecosystem health, clean water, and recreational opportunities-- values that are highly appreciated by the American public. The continued logging of our National Forests also wastes American tax dollars and diminishes the possibilities of future economic benefits. The Forest Service and independent economists have estimated that timber accounts for only 2.7 percent of the total values of goods and services derived from the National Forests, while recreation and fish and wildlife produce 84.6 percent.”

From an April 16, 2002 letter to President Bush asking him to stop all logging in the national forests. http://www.forestwatch.org/content.php?id=108 Note: After the link has been opened, scroll to the bottom and follow the link to “Scientist's No Logging Letter.pdf 64KB” This will show the complete letter and the signatories.

The names of the 221 Ph.D. level scientists that signed the letter are:

Dr. E.O. Wilson, Ph.D. Harvard University, Department of Biology, ------Professor Dr. Anne Ehrlich, Ph.D.

North Nestucca Environmental Assessment Page 55

Appendix E – Attachment #1

Stanford University, Organismal Biology, Department of Biological ------Professor Emeritus Sciences, Sr. Research Dr. David R. Atkinson, Ph.D. Associate, Center for Cornell University, Professor ------Conservation Biology of Ecology & Evolutionary Dr. Benjamin Blount, Ph.D. Biology University of Georgia, ------Department of Anthropology, Dr. Peter Raven, Ph.D. ------Professor Missouri Botanical Garden, Michelle A. Baker, Ph.D. Director, 2000 National Utah State University, ------Medal of Science winner Department of Biology, Dr. Dee Boersma, Ph.D. Assistant Professor University of Washington, ------Department of Zoology, Dr. David R. Foster, Ph.D. ------Professor Harvard University, Director Dr. Henry L. Bart, Jr., Ph.D Harvard Forest Tulane University, Museum ------of Natural History, Director Dr. Eric Bolen, Ph.D. ------and Curator of Fishes University of North Carolina- Dr. Kenneth P. Able, Ph.D. Wilmington, Department of University at Albany, SUNY ------Biology, Professor of Wildlife Department of Biological Dr. Fakhri Bazzaz, Ph.D. Ecology Sciences, Professor Harvard University, Department of Biology, ------Mallinckrodt Professor of Dr. Herb Boschung, Ph.D. Dr. Kraig Adler, Ph.D. Biology University of Alabama- Cornell University, Vice Tuscaloosa, Department of Provost for Life Sciences, ------Biological Sciences, Professor of Biology Dr. Donald L. Beaver, Ph.D. Professor Emeritus Michigan State University, ------Department of Zoology/The ------Dr. Steven C. Anderson, Michigan State University Dr. Richard Bradley, Ph.D. Ph.D. Museum, Professor Emeritus Ohio State University, University of the Pacific, Department of Evolution, Department of Biological ------Ecology, and Organismal Sciences, Professor Emeritus Dr. David L. Bechler, Ph.D. Biology, Professor Valdosta State University, ------Department of Biology, ------Dr. William D. Anderson, Jr., Department Head Dr. Greg Brown, Ph.D. Ph.D. Alaska Pacific University, Grice Marine Biological ------Department of Environmental Laboratory Dr. Chris Benkman, Ph.D. Science, Associate Professor New Mexico State University, ------Department of Biology, ------Dr. Robert Angus, Ph.D. Associate Professor Dr. David M. Bryant , Ph.D. University of Alabama- Harvard University, Birmingham, Department of ------Department of Earth and Biology, Professor Dr. Brad Bergstrom, Ph.D. Planetary Science, Member, Valdosta State University, Zi Sigma Pi, the Honorary ------Department of Biology, Fraternity of Foresters Professor Dr. Jonathan W. Armbruster, ------Ph.D. ------Dr. Deborah Buitron, Ph.D. Auburn University, North Dakota State Department of Biology, Dr. Tim M. Berra, Ph.D. University, Department of Assistant Professor of Ohio State University, Biological Sciences, Adjunct Biology, Curator of Fishes Evolution, Ecology & Professor

North Nestucca Environmental Assessment Page 56

Appendix E – Attachment #1

Dr. Rabel J. Burdge, Ph.D. Cape Cod National Dr. Thomas W. Culliney, Western Washington Seashore, Biological Ph.D. University, Department of Technician Hawaii Department of Sociology, and Agriculture, population Environmental Studies, ------ecologist Professor Emeritus, Dr. Jeff Connor, Ph.D. Michigan State University, ------Department of Botany and Dr. Gretchen C. Daily, Ph.D. Dr. Nancy M. Butler, Ph.D. Plant Pathology, Associate Stanford University, Gustavus Adolphus College, Professor, Kellogg Biological Department of Biological Department of Biology, Station, Associate Editor Sciences, Bing Assistant Professor Evolution Interdisciplinary Research Scientist, Editor, Nature's ------Services: Societal Dr. William Calder, Ph.D. Carol Conway, Ph.D. Dependence on Natural University of Arizona, University of California-Davis, Ecosystems Professor of Ecology and Department of Ecology Evolutionary Biology ------Dr. James Danoff-Burg, ------Dr. Joseph Cook, Ph.D. Ph.D. Kevin Caldwell, Ph.D University of Alaska, Curator Columbia University, Center Appalachian Ecological of Mammals and Professor of for Environmental Research Consultants, Botanist Biology and Conservation, Associate ------Research Scientist Dr. Todd Campbell, Ph.D. Dr. Jeffery D. Corbin, Ph.D. ------University of Tennessee, University of California- Dr. Margaret B. Davis, Ph.D. Department of Ecology and Berkeley, Department of University of Minnesota, Evolutionary Biology, Post- Integrative Biology, Post- Department of Ecology, Doctoral Research Associate Doctoral Fellow/ Lecturer Evolution and Behavior, The Institute for Biological Regents Professor of Invasions ------Dr. Richard G. Coss, Ph.D. Ecology, retired ------University of California------Kai Chan, Ph.D. Davis, Graduate Groups in Dr. Larry Dew, Ph.D. Princeton University, Psychology, Ecology, and University of California-Davis, Department of Ecology and Animal Behavior Professor Department of Anthropology Evolutionary Biology ------Dr. Tom Cottrell, Ph.D. Dr. Calvin B. DeWitt, Ph.D. Dr. Jiquan Chen, Ph.D. Central Washington University of Wisconsin- Michigan Tech University, University, Department of Madison Professor of School of Forestry and Wood Biology, Plant Ecologist Environmental Studies Products, Associate ------Director, Au Sable Institute of Professor, Landscape Environmental Studies Ecology & Ecosystem Dr. Tom Cottrell, Ph.D. Science Central Washington ------University, Department of Dr. Janis L. Dickinson, Ph.D. ------Biology, Plant Ecologist University of California- Dr. Joel E. Cohen, Ph.D. ------Berkeley Museum of Rockefeller University, Vertebrate Zoology, Assistant Professor of Populations Dr. Brian I. Crother, Ph.D. Southeastern Louisiana Research Zoologist Hastings ------University, Department of Natural History Reservation Cormac Collier, Ph.D. Biology, Associate Professor ------North Nestucca Environmental Assessment Page 57

Appendix E – Attachment #1

Dr. C. Kenneth Dodd, Jr., Elizabeth Fensin, Ph.D. Umatilla Chemical Agent Ph.D. N.C. Division of Water Disposal Facility, Principal University of Florida Quality, Environmental Investigator Department of Wildlife Biologist Ecology and Conservation, ------Courtesy Associate ------Dr. Jay Greenberg, Ph.D. Professor, President, The Dr. G. Edgar Folk, Ph.D. University of Rochester Herpetologists' League Iowa State University, Medical Center, Department Department of Physiology, of Biochemistry and ------Professor of Environmental Biophysics Dr. David Edds, Ph.D. Physiology Emporia State University, ------Department of Biological ------Sciences, Professor Dr. Johannes Foufopoulos, Ph.D. Dr. Correigh Greene, Ph.D. ------Princeton University, University of California- Dr. Joan Edwards, Ph.D. Department of Ecology and Davis, Section of Evolution Williams University, Evolutionary Biology, Visiting and Ecology Department of Biology, Assistant Professor Professor of Biology ------Dr. Ed Grumbine, Ph.D. ------Dr. ElizaBeth A. Fox, Ph.D. University of California- Dr. Timothy J. Ehlinger, Ph.D Princeton University, Santa Cruz, Extension Sierra University of Wisconsin- Department of Ecology and Institute Milwaukee, Department of Evolutionary Biology, Biological Sciences, Lecturer ------Assistant Professor Dr. David G. Hankin, Ph.D. ------Humboldt State University, ------Patricia Gensel, Ph.D. Telonicher Marine Lab Dr. Paul Ehrlich, Ph.D. University of North Carolina, Professor of Fisheries Stanford University, Professor of Biology, Biology Department of Biological President Botanical Society Sciences, Professor of of America ------Biological Sciences Dr. Robert B. Hastings, Ph.D. ------Southeastern Louisiana ------Dr. Cameron Ghalambor, University, Department of Dr. W. Hardy Eshbaugh, Ph.D. Biology, Professor of Ph.D. University of California- Biological Sciences Miami University, Department Riverside, Department of of Botany, Professor Biology ------Emeritus Dr. Dean A. Hendrickson, ------Ph.D ------Dr. Barrie K. Gilbert, Ph.D. University of Texas- Austin, Dr. William J. Etges, Ph.D. Utah State University, Texas Natural History University of Arkansas, Department of Fisheries and Collections, Texas Museum Department of Biological Wildlife-- Ecology Center, of Science and History, Sciences Senior Scientist Curator of Ichthyology ------Dr. Joseph E. Faber, Ph.D. Dr. Douglas S. Glazier, Ph.D. Dr. Andrew Hendry , Ph.D. West Virginia University- Juniata College, Department University of Massachusetts- Parkersburg, Division of of Biology, Professor of Amherst, Organismic and Natural Sciences, Assistant Biology Evolutionary Biology Program Professor ------Dr. Robert H. Gray , Ph.D.

North Nestucca Environmental Assessment Page 58

Appendix E – Attachment #1

Dr. James D. Hengeveld, Sciences, Postdoctoral Ph.D. ------Research Associate Indiana University, Dr. Charles Jackson, Ph.D. Department of Biology, ------Dr. Keith T. Killingbeck, Ph.D. Assistant Professor & Lab Dr. Dan Janzen, Ph.D Coordinator Univeristy of Rhode Island, University of Pennsylvania, Department of Biological ------Professor Sciences Dr. Frank H. Heppner, Ph.D. ------University of Rhode Island, Dr. Robert L. Jeanne, Ph.D. Department of Biological Dr. David R. Klein, Ph.D. University of Wisconsin- University of Alaska- Sciences, Professor of Madison, Department of biological sciences Fairbanks, Institute of Arctic Entomology, Professor of Biology, Professor Emeritus Entomology and Zoology Dr. David M. Hillis, Ph.D. ------University of Texas- Austin, ------Director, School of Biological Sciences Dr. Paul A. Johnsgard, Ph.D. University of Nebraska------Lincoln, Department of Dr. Mark Hixon, Ph.D. Dr. Walter Koenig, Ph.D Biological Sciences, University of California- Oregon State University, Foundation Professor of Department of Zoology Berkeley, Museum of Biological Sciences Vertebrate Zoology ------Dr. Karen Holl, Ph.D. Dr. Erik S. Jules, Ph.D. University of California- Dr. Alan Kohn, Ph.D. Humboldt State University, University of Washington, Santa Cruz, Department of Department of Biological Environmental Studies Department of Zoology, Sciences, Assistant Professor Emeritus, Formerly ------Professor President of Society for Dr. Robert W Howarth, Ph.D. ------Integrative and Comparative Environmental Defense Dr. James R. Karr, Ph.D. Biology Oceans Program, Senior University of Washington, ------Scientist and Program Department of Environmental Manager Dr. Arthur H. Kopelman, Health, Professor of Aquatic Ph.D. ------Sciences and Zoology, State University of New York, Dr. Bruce Hungate, Ph.D. Adjunct Professor of Civil Department of Science and Northern Arizona University, Engineering Mathematics, Professor of Department of Biological ------Science, President Coastal Sciences, Assistant Dr. Sylvan R. Kaufman, Research and Education Professor Ph.D. Society of Long Island ------Harvard University, Biological ------Dr. Alan Hutchcroft, Ph.D. Labs, Postdoctoral Fellow Dr. Don Kroodsma, Ph.D. Rockford College, Bartels ------University of Massachusetts, Professor of Chemistry Dr. Sterling Keeley, Ph.D. Department of Biology, ------University of Hawaii- Manoa, Professor Dr. David W. Inouye, Ph.D. Department of Botany, ------University of Maryland, Professor and Chair Dr. Kenneth Krysko, Ph.D. Professor & Director, ------University of Florida, Florida Graduate Program in Dr. Melody J. Kemp, Ph.D. Museum of Natural History, Sustainable Development University of Notre Dame, Collections Manager, Division and Conservation Biology Department of Biological of Herpetology North Nestucca Environmental Assessment Page 59

Appendix E – Attachment #1

California Institute for Rural ------Studies, Executive Director ------Bernard Kuhajda, Ph.D. Dr. John McLaughlin, Ph.D. University of Alabama------Western Washington Tuscaloosa, Department of Dr. John T. Lill, Ph.D. University, Huxley College of Biological Sciences University of Missouri- Environmental Studies,- St.Louis Department of Environmental ------Sciences, Assistant Stephen P. Kunz , Ph.D. ------Professor Certified Senior Dr. Randy Linder, Ph.D. Ecologist,Certified Wetland University of Texas- Austin, ------Scientist School of Biology Dr. David McNeely, Ph.D Sciences/Section of Langston University, ------Integrative Biology Department of Biology, Dr. Doug LaFollette, Ph.D. Professor Wisconsin Secretary of State ------Dr. Robin A. Matthews, Ph.D. ------Western Washington Dr. Geoff Meaden, Ph.D. Dr. Robert O. Lawton, Ph.D. University, Huxley College of Canterbury Christ Church University of Alabama- Environmental Studies, University College, Huntsville, Department of Professor, Director, Institute Department of Biological Sciences for Watershed Studies GeographyMarine Fisheries Estella Leopold, Ph.D. GIS Unit University of Washington, ------Department of Botany, Dr. Thomas P. Maxwell, ------Professor Ph.D. University of Maryland, ------Institute for Ecological Dr. Bruce Means, Ph.D. Dr. John J. Lepri, Ph.D. Economics, Professor Florida State University, University of North Carolina, Department of Biological Department of Biology, ------Sciences, Adjunct Professor Associate Professor of Dr. Audrey Mayer, Ph.D. of Biological Science, Biology University of Cincinnati, Executive Director Coastal Department of Biological Plains Institute ------Sciences Dr. Malcolm P. Levin, Ph.D. ------University of Illinois at ------Dr. Robert J. Meese, Ph.D. Springfield, Department of Dr. Terrence P. McGlynn, University of California, Environmental Studies, Ph.D. Department of Environmental Department Chair University of San Diego, Science and Policy Assistant Professor of ------Biology ------Dr. John Lichter, Ph.D. Dr. Gary K. Meffe, Ph.D. Bowdoin College, Biology ------University of Florida, Department and Dr. James B. McGraw, Ph.D. Department of Wildlife Environmental Studies West Virginia University, Ecology and Conservation, Program, Assistant Professor Department of Biology, Adjunct Professor, Editor, Eberly Professor of Biology & Conservation Biology ------Aldo Leopold Leadership Dr. William Z. Lidicker, Ph.D. Program Fellow ------University of California, Dr. DeForest Mellon, Ph.D. Berkeley, Professor of ------University of Virginia, Integrative Biology, Emeritus Don McKenzie, Ph.D. Department of Biology, University of Washington, Professor of Biology ------College of Forest Resources, Dr. David R. Lighthall, Ph.D. Research Ecologist ------

North Nestucca Environmental Assessment Page 60

Appendix E – Attachment #1

Dr. John Miles, Ph.D. Dr. Steven Mullin, Ph.D. University of Washington, Western Washington Eastern Illinois University, Professor Emeritus of University, Huxley College of Department of Biological Zoology Environmental Studies, Sciences, Professor Professor, Director Center for ------Geography and ------Dr. Michael Ort, Ph.D. Environmental Social Dave Neely, Ph.D. University of Northern Sciences University of Alabama, Arizona, Department of Biodiversity and Systematics Geology, Associate ------ProfessorCenter for Dr. Arlee M. Montalvo, Ph.D. ------Environmental Sciences and University of California- Dr. Richard Niesenbaum, Education Riverside, Department of Ph.D. Botany and Plant Sciences, Muhlenberg College, ------Asst. Res. Plant Population Department of Dr. Richard S. Ostfeld, Ph.D. Biologist & Lecturer BiologyAssociate Professor Institute of Ecosystem of Biology, Donald and Anne Studies ------Shire Distinguished Teaching Dr. Harold Mooney , Ph.D. Professor ------Stanford University, Dr. Ken Parejko, Ph.D. Department of Biological ------University of Wisconsin, Sciences, Paul S. Achilles Dr. Elliott A. Norse, Ph.D. Department of Biology, Professor of Environmental President, Marine Associate Professor Biology Conservation Biology Institute, Author: Ancient ------Forests of the Pacific Dr. Dennis Paulson, Ph.D. Dr. Cliff Morden, Ph.D. Northwest University of Puget Sound, University of Hawaii- Manoa, Slater Museum of Natural Department of Botany, ------History, Director ProfessorCenter for Dr. M. Philip Nott, Ph.D. Conservation Research and The Institute for Bird Training Populations Dr. Ann Phillippi, Ph.D. ------Dr. Timothy C. Morton, Ph.D. Dr. Gary Nuechterlein, Ph.D. ------University of Chicago, North Dakota State Dr. Stuart Pimm, Ph.D. Department of Biology, University, Department of Columbia University, Center visiting Assistant Professor, Biological Sciences, for Environmental Research Ecological Society of America Professor and Conservation, Professor of Conservation Biology ------Dr. Peter B. Moyle, Ph.D. Dr. Philip Nyhus, Ph.D. ------University of California- Franklin & Marshall College, Dr. Mary V. Price, Ph.D. Davis, Department of Wildlife, Department of Geosciences, University of California- Fish, and Conservation Assistant Professor Riverside, Department of Biology, Professor of Fish ------Biology, Professor of Biology Biology Dr. Dennis Ojima, Ph.D. ------Natural Resource Ecology Dr. Mark Pyron, Ph.D. Dr. Helmut C. Mueller, Ph.D. Laboratory, Colorado State Ball State University, University of North Carolina, University, Senior Research Department of Biology, Department of Biology & Scientist, Aldo Leopold Assistant Professor Curriculum in Ecology, Leadership Fellow ------Professor Emeritus ------Dr. Peter A. Quinby , Ph.D. ------Dr. Gordon H. Orians, Ph.D. North Nestucca Environmental Assessment Page 61

Appendix E – Attachment #1

Paul Smith's College, Natural Resources, Science and ------Liberal Arts, Assistant Dean Dr. Scott D. Russell, Ph.D. Dr. Peter Schulze, Ph.D. and Associate Professor University of Oklahoma, Austin College, Associate George Lynn Cross Professor of Biology, ------Research Professor of Director, Center for Dr. John T. Ratti, Ph.D. Botany, Director, Samuel Environmental Studies University of Idaho- Moscow, Roberts Noble Electron Department of Fish and Microscopy Laboratory ------Wildlife Burton Shank, Ph.D. ------Florida Fish and Wildlife ------Dr. John M. Rybczyk, Ph.D. Conservation, Dr. Stuart Reichler, Ph.D. Western Washington AssociationResearch University of Texas- Austin, University, Huxley College of Biologist School of Biology Sciences Environmental Studies, Assistant Professor ------Dr. Sharron K. Sherrod, Dr. Janita Rice, Ph.D. ------Ph.D. California State University Dr. Karin Sable, Ph.D. University of Denver, University of Puget Sound, Department of Biology, ------Department of Economics Professor Dr. Carol Riley, Ph.D. ------Dr. Edward Saiff, Ph.D. Dr. Fraser Shilling, Ph.D. Dr. Caroljane B. Robertson, Ramapo College of New University of California- Ph.D. Jersey, Department of Davis, Section of Microbial ------Biology, Professor of Biology, and Cellular Biology, Chair Dr. George Robinson, Ph.D. Fellow, American Association Committee on Conservation, State University of New York for the Advancement of Society for Integrative at Albany, Department of Science andComparative Biology Biological Sciences, ------Associate Professor Dr. Alan H. Savitzky, Ph.D. Erin A. Shope, Ph.D. Old Dominion University, Brevard University, Associate Professor of Environmental Educator Joe Rocchio, Ph.D. Biological Sciences Colorado Natural Heritage Dr. John O. Sawyer, Ph.D. ------Program, Wetland Ecologist Humboldt State University, Dr. Clifford Slayman, Ph.D. Emeritus Professor of Botany Yale School of Medicine ------Cellular and Molecular Dr. Charles Romesburg, ------Physiology, Professor of Ph.D. Dr. William H. Schlesinger, Physiology Utah State University, Ph.D. Department of Forest Duke University, Dean, ------Resources, Professor Nicholas School of the Dr. Christoper C. Smith, ------Environment and Earth Ph.D. Sciences, James B. Duke Kansas State University, Dr. Thomas Rooney, Ph.D. Division of Biology University of Wisconsin- Professor of Biogeochemistry Madison, Department of ------Botany Dr. Stephen H. Schneider, Dr. Bradley F. Smith, Ph.D. Ph.D Western Washington ------University, Huxley College of Dr. Barry Rosenbaum, Ph.D. Stanford University, Department of Biological Environmental Studies, University of Colorado, Dean Research Associate, Institute Sciences of Arctic and Alpine Research ------North Nestucca Environmental Assessment Page 62

Appendix E – Attachment #1

Dr. Youngsinn Sohn, Ph.D. University of Massachusetts- Dr. Eric J. Taylor, Ph.D University of Maryland- Boston, Department of Fish and Wildlife Biologist Baltimore, Geography & Biology, Associate Professor Environmental Systems, of Biology ------Assistant Professor Dr. John Terborgh, Ph.D. ------Duke University, Center for ------Dr. Glen R. Stewart, Ph.D. Tropical Conservation, Dr. John Soluri, Ph.D. California State Polytechnic James B Duke Professor Carnegie Mellon University, University- Pomona, Department of History, Department of Biological ------Assistant Professor of History Sciences, Professor of Dr. Andrea S. Thorpe, Ph.D. and Policy Zoology University of Montana, Division of Biological ------Sciences Dr. Stefan Sommer, Ph.D. Dr. Craig Stockwell, Ph.D. Idaho State University, North Dakota State ------Department of Biological University, Department of Dr. Harry M. Tiebout, Ph.D. Sciences, Research Zoology, Assistant Professor West Chester University, Assistant, Professor, Director Department of Biology Natural Heritage Center ------Dr. Phillip K. Stoddard, Ph.D. ------Florida International Dr. Gordon Ultsch, Ph.D. Dr. Lisa G. Sorenson, Ph.D. University, Department of University of Alabama- Union of Concerned Biological Sciences Tuscaloosa, Department of Scientists, Global Biological Sciences Environment Program, ------Dr. Philip C. Stouffer, Ph.D. ------Adjunct Research Assistant Dr. Loraine Utter Kohorn, Professor- Biology Southeastern Louisiana University, Department of Ph.D. Department, Duke University, Department BostonUniversity Biological Sciences, Associate Professor of Biology/Nicholas School of the Environment, Visiting Dr. Michael Soule, Ph.D. ------Assistant Professor Wildlands Project ------Dr. Larry T. Spencer, Ph.D. Dr. Boyd R. Strain, Ph.D. Duke University, Department Plymouth State College, Professor of Biology of Biological Sciences, Professor Emeritus Dr. Daniel M Vernon, Ph.D. ------Whitman University, Dr. Timothy P. Spira, Ph.D. ------Department of Biology Clemson University, Dr. Michael C. Swift, Ph.D. ------Department of Biological St. Olaf College, Department of Biology, Department of Dr. Richard A. Wahle, Ph.D. Sciences, Associate Bigelow Laboratory for Professor Biology- University of Virginia, sabbatical Ocean Sciences, Research Scientist ------Dr. Alan Springer, Ph.D. ------University of Alaska- Dr. Douglas W. Tallamy, Ph.D. Dr. David B. Wake, Ph.D. Fairbanks, Institute of Marine University of California, Science, Professor University of Delaware, Department of Entomology Professor of Integrative ------and Applied Ecology, Biology, Curator, Museum of Dr. Robert D. Stevenson, Professor Vertebrate Zoology Ph.D. ------Dr. Skip Walker, Ph.D. North Nestucca Environmental Assessment Page 63

Appendix E – Attachment #1

University of Alaska- Fairbanks, Institute of Arctic ------Biology Dr. John F. Weishampel, Dr. Helen Young, Ph.D. Ph.D. Middlebury College, ------University of Central Florida, Department of Biology Dr. Lawernce R. Walker, Department of Biology Professor Ph.D. University of Nevada- Las ------Vegas, Department of Dr. Gregory Welch, Ph.D. Dr. Joy B. Zedler, Ph.D. Biology, Professor of Biology University of Maine, University of Wisconsin- Professor Darling Marine Madison, Department of ------Center Botany and Arboretum, Aldo Dr. Diana H. Wall, Ph.D. Leopold Professor of Colorado State University, ------Restoration Ecology College of natural Resources, Dr. Robert G. Wetzel, Ph.D. Professor, Director, Natural University of Alabama------Resources Ecological Tuscaloosa, Department of Dr. Marion Klaus, Ph.D. Laboratory Biological Sciences, Bishop Sheridan College Professor of Biology ------Dr. Donald M. Waller, Ph.D. ------University of Wisconsin- Dr. Peter S. White, Ph.D. Madison, Department of University of North Carolina- Botany, Editor, Evolution Chapel Hill, Department of Biology, Professor, Director ------North Carolina Botanical Dr. David O. Wallin, Ph.D. Garden Western Washington University, Huxley College of ------Environmental Studies- Dr. Bill Willers, Ph.D. Department of Environmental University of Wisconsin- Sciences, Associate Oshkosh, Department of Professor Biology, Emeritus Professor of Biology ------Dr. Glen Walsberg, Ph.D. ------Arizona State University Dr. Joe Williams, Ph.D. Professor of Biology Colorado State University, President, Cooper Department of EPO Biology Ornithological Society ------Dr. Nickolas M. Waser, Ph.D. Dr. Ernest J. Willoughby, University of California- Ph.D. Riverside, Department of St. Mary's College of Biology, Professor of Biology, Maryland, Department of President, Rocky Mountain Biology, Professor of Biology Biological Laboratory ------Dr. Michael Windelspecht, Dr. Judith S. Weis, Ph.D. Ph.D. Rutgers University, Appalachian State University, Department of Biological Department of Biology, Sciences, Professor of Assistant Professor of Biology, Past President Biology American Institute of Biological Sciences ------Dr. Marti Witter, Ph.D. North Nestucca Environmental Assessment Page 64

Appendix E – Attachment #1

Comment: The Responsible Official ignores the statements of 221 unbiased, highly educated biological scientists who point out the common natural resource degradation resulting from commercial timber sales based on the word of a handful of foresters and silviculturists who will gain personally when the timber sale is sold. Clearly, the Responsible Official prefers to let representatives from resource extraction corporations choose the projects on the forest.

------Timber Harvest Opposing View #73 - “Recently, so called "salvage" logging has increased on national forests in response to a timber industry invented "forest health crisis" which points the finger at normal forest processes of fire, fungi, bacteria, insects and other diseases. In fact the crisis in the national forests is habitat destruction caused by too much clearcutting.

My long-term studies of forest diseases in Idaho show the loss by disease and insect activity in all age classes of forests to be less than or slightly more than 1 percent per year over the past thirty-eight years. These findings are consistent with Forest Service national level data.

Forests are structured systems of many life forms interacting in intricate ways and disturbances are essential to their functioning. It’s not fire disease fungi bacteria and insects that are threatening the well being of forests. Disease, fire, windthrow, and other disturbances are a natural part of the forest ecosystem and assist in dynamic processes such as succession that are essential to long term ecosystem maintenance. The real threat facing forests are excessive logging, clearcutting and

North Nestucca Environmental Assessment Page 65

Appendix E – Attachment #1

roadbuilding that homogenize and destroy soil, watersheds and biodiversity of native forests.”

Partridge, Arthur Ph.D., Statement at a Press Conference with Senator Robert Torricelli about S. 977 and HR 1376), the Act to Save America’s Forests April 28, 1998, U.S. Capitol http://www.saveamericasforests.org/news/ScientistsStatement.htm

------

Timber Harvest Opposing View #74 - “CONCLUSIONS In our overview of the impacts of forest management activities on soil erosion and productivity, we show that erosion alone is seldom the cause of greatly reduced site productivity. However, erosion, in combination with other site factors, works to degrade productivity on the scale of decades and centuries. Extreme disturbances, such as wildfire or tractor logging, cause the loss of nutrients, mycorrhizae, and organic matter. These combined losses reduce long-term site productivity and may lead to sustained periods of extended erosion that could exacerbate degradation.

Managers should be concerned with harvesting impacts, site preparation disturbances, amount of tree that is removed, and the accumulation of fuel from fire suppression. On erosion-sensitive sites, we need to carefully evaluate such management factors.”

Elliot, W.J.; Page-Dumroese, D.; Robichaud, P.R. 1999. The effects of forest management on erosion and soil productivity. Proceedings of the Symposium on Soil Quality and Erosion Interaction, Keystone, CO, July 7, 1996. Ankeney, IA: Soil and Water Conservation Society. 16 p. http://forest.moscowfsl.wsu.edu/smp/docs/docs/Elliot_1-57444-100-0.html North Nestucca Environmental Assessment Page 66

Appendix E – Attachment #1

North Nestucca Environmental Assessment Page 67

Appendix E – Attachment 4

Opposing Views Attachment #4

Roads Damage the Proper Ecological Functioning of the Natural Resources in a Forest

Note to the Responsible Official who reads these opposing views: There are negative effects caused by nearly all actions … this includes forest road construction. The public deserves to consider projects proposed to occur on their land with the knowledge of the pros and cons of the project. None of the sources for the opposing views is specific to this project. Information contained in books and/or scientific prediction literature are not specific to individual projects. They describe cause and effects relationships that exist when certain criteria are met.

Indeed, the literature in the References section of the draft NEPA document is not specific to the project yet its used to help design this project.

Once again, this gives the public complete project understanding.

Response: The Forest Service acknowledges that there will be effects from this project. The production of this Environmental Assessment documents that there are effects. This EA documents the expected effects and include any actions designed to limit or mitigate these effects. The EA also describes the analysis that took place to support the finding that this project would have no significant impact on the environment. The reference section of the EA only includes this references cited in the document. The references for the opposing views are available in Appendix E and thus are part of the public record.

Response: The 57 views expressed in this attachment all deal with the potential impacts of roads. The following response applies to all of the views expressed in the attachment. Comments relevant to the specific comment are attached to the specific views.

Response: The North Nestucca Project will utilize existing system roads, reopened temporary roads and some new temporary road construction. The following table summarizes the road activity.

Road Type Miles Disposition Key System 50.0 Will receive maintenance Non-Key System 43.0 Will receive maintenance

North Nestucca Environmental Assessment Page 1

Appendix E – Attachment 4

Re-opened System 4.8 Will have storm damage risk reduction and closed Re-opened old road templates 17.2 Decommissioned after project New Temporary 3.2 Decommissioned after project All Season Haul 72.0 Miles available for all season haul Dry Season Haul 21.0 Restricted to dry season haul

The Siuslaw National Forest recognizes that roads have the potential for the greatest environmental impact in this project. Considerable effort was invested in the planning and analysis of this project to ensure that roads will not have a deleterious effect on the environment. There are 93 miles of open system roads planned for use in this project. The timber purchaser will be required to perform any necessary maintenance on these roads prior to their use. At the end of the project they will be required to leave the roads in a safe and stable condition. Forest Service engineers will monitor the maintenance and use of the roads throughout the length of the project. The maintenance of these roads will exceed what the Forest Service could accomplish under present budget constraints. The re-opened system roads will have storm damage risk reduction and closed damage risk reduction and closed damage risk reduction and closed proofed and closed at the end of the project. Storm damage risk reduction will involve installing water bars and either removing culverts or reducing the potential for plugging or failing. This maintenance for project use, and subsequent storm damage risk reduction, will leave these previously closed roads in a more stable and less environmentally risky condition than many of them currently are. The re-opened old road templates will be decommissioned at the end of the project. This will leave these features in a more stable condition than many of them currently are. Project Design Criteria will ensure that the new temporary roads will be built only in stable areas and will not cross streams. These roads will also be decommissioned at the end of the project. The road system was also evaluated to determine what roads could stand up to all season haul and which ones should be limited to the dry season only. Project design criteria will insure that those roads designated for all season haul will be inspected on a regular basis. If there are any concerns about toad stability or environmental impacts all hauling will be terminated.

Road Construction Opposing View #1 - “Fragmentation has been considered as one of the most major factors that lead to the decline of many wildlife species (Brittingham and Temple 1983, Yahner 1988, Winslow et al. 2000) because fragmentation tends to decrease population productivity (Robinson et al. 1995). Therefore, Meffe states that “fragmentation has become a major subject of research and debate in conservation biology” (Meffe et al. 1997, p. 272). Forest fragmentation usually occurs when large and continuous forests are divided into smaller patches as a result of road establishment, clearing for agriculture, and human development (Robinson et al. 1995, Meffe et al. 1997).” (Pg. 1)

North Nestucca Environmental Assessment Page 2

Appendix E – Attachment 4

“Generally, habitat fragmentation is an ecological process in which a large patch of habitat is divided into smaller patches of habitats. Usually, this process is caused by human activities (roads, agriculture, and logging). It also reduces the value of the landscape as habitat for many species (plants and animals). Fragmentation alters natural habitat in many ways, including reduction of patches’ sizes, increment of distances between similar patches, and increment of edges and predation (Brittingham and Temple 1983, Robinson et al. 1995).” (Pp. 2 and 3)

Al-jabber, Jabber M. 2003 “Habitat Fragmentation: Effects and Implications” http://faculty.ksu.edu.sa/a/Documents/Habitat%20Fragmentation%20Effects%20and%2 0Implication.pdf

------Road Construction Opposing View #2 - "Debris slides over a 20-year period were inventoried on 137,500 acres of forested land in the Klamath Mountains of southwest Oregon. Frequency during the study period was about one slide every 4.3 years on each 1,000 acres-an erosion rate of about 1/2 yd3 per acre per year. Erosion rates on roads and landings were 100 times those on undisturbed areas, while erosion on harvested areas was seven times that of undisturbed areas. Three-quarters of the slides were found on slopes steeper than 70 percent and half were on the lower third of slopes."

"Soil erosion rates due to debris slides were many times higher on forests with roads, landings, and logging activity than on undisturbed forests."

Amaranthus, Mike P. Ph.D., Raymond M. Rice Ph.D., N. R. Barr North Nestucca Environmental Assessment Page 3

Appendix E – Attachment 4 and R. R. Ziemer Ph.D. "Logging and forest roads related to increased debris slides in southwestern Oregon." Journal of Forestry Vol. 83, No. 4. 1985. http://www.humboldt.edu/~rrz7001/pubs/Ziemer85.PDF

Response: The soils/hydrology section of the EA (pg. 87) contains an analysis of ground stability in the project area. A geologist examined the project area to identify any unstable areas. All unstable areas were identified and excluded from treatment.

------Road Construction Opposing View #3 - " ‘Roads may have unavoidable effects on streams, no matter how well they are located, designed or maintained. The sediment contribution to streams from roads is often much greater than that from all other land management activities combined, including log skidding and yarding.’ (Gibbons and Salo 1973). Research by Megahan and Kidd in 1972 found that roads built in areas with highly erosive soils can contribute up to 220 times as much sediment to streams as intact forests.”

“Applying Ecological Principles to Management of the U.S. National Forests” Issues in Ecology Number 6 Spring 2000 http://www.watertalk.org/wawa/ecosci.html

Response: This project does not include any clear cutting no temporary roads are allowed to cross streams. There are streamside buffers to protect stream banks from disturbance. Road maintenance is proposed, but that will reduce the potential to mobilize any sediment that might reach streams. The hydrology/soils (pg. 87) section in the EA contains detailed analysis of potential soil impacts. Appendix A contains the PDC’s designed to minimize or eliminate impacts to aquatic systems.

------Road Construction Opposing View #4 - “Plot-level studies have demonstrated the ability of forest roads to intercept and route both subsurface and surface overland flow more efficiently to the stream network. Significant amount of subsurface throughflow can be intercepted by the road, as a function of the road cut depth and the current saturation North Nestucca Environmental Assessment Page 4

Appendix E – Attachment 4 deficit, and then redirected, concentrating the flow in particular areas below the road. Road drainage concentration increases the effective length of the channel network and strongly influences the distribution of erosional processes. The concept of wetness index has been used in the study as a surrogate for subsurface throughflow, and the effect of forest roads on subsurface throghflow rerouting has been assessed by evaluating the changes in terms of draining upslope areas. A threshold model for shallow slope instability has been used to analyse erosional impacts of drainage modifications. In the model, the occurrence of shallow landsliding is evaluated in terms of drainage areas, ground slope and soil properties (i.e., hydraulic conductivity, bulk density, and friction angle). The model has been used to generate hypotheses about the broader geomorphic effect of roads. Modelling results have been compared with available field data collected in north-eastern Italy.”

Borga, M., F. Tonelli, G. Dalla Fontana and F. Cazorzi “Evaluating the Effects of Forest Roads on Shallow Landsliding” Geophysical Research Abstracts, Vol. 5, 13312, 2003 http://www.cosis.net/abstracts/EAE03/13312/EAE03-J-13312.pdf

Response: The hydrologic effects of the action are analyzed in the hydrology/soils section (pg. 87) of the EA. This section also contains an analysis of unstable soils in the project area, these areas were excluded from the action.

------Road Construction Opposing View #5 - “A large scale land use experiment has taken place over the last 40 years in the mountainous areas of the northwestern U.S. through timber harvesting. This land use change effects the hydrology of an area through two mechanisms:

• Clear-cut logging which causes changes in the dynamics of Rain-On- Snow (ROS) events due to changes in the accumulation and ablation of snow caused by vegetation effects on snow interception and melt; and

• Construction and maintenance of forest roads which channel intercepted subsurface flow and infiltration excess runoff to the stream network more quickly.” North Nestucca Environmental Assessment Page 5

Appendix E – Attachment 4

Bowling, L.C., D. P. Lettenmaier, M. S. Wigmosta and W. A. Perkins “Predicting the Effects of Forest Roads on Streamflow using a Distributed Hydrological Model” from a poster presented at the fall meeting of the American Geophysica Union, San Francisco, CA, December 1996. http://www.ce.washington.edu/~lxb/poster.html

Response: This project does not include any clear cutting. Only 3.2 miles of temporary roads will be constructed and closed and re-vegetated after use. The Hydrology/Soils section (page 87) in the EA contains a thorough analysis of the hydrologic effects of these proposed temporary roads plus any impacts from road maintenance related to the project. The Hydrology/Soils section (page 87) of the EA contains an analysis of ground stability in the project area. Unstable areas were identified and excluded from treatment.

------Road Construction Opposing View #6 - "Many of the conclusions and assumptions contained in the Roads Report are based on analysis of the positive contributions of roads. Negative socio-economic effects of roads have been, in large part, glossed over. The general view expressed in the Roads Report is that overall, roads make a positive socio-economic contribution."

"The Socio-Economic Effects section has been constructed to overwhelmingly support the contention that the benefits of roads outweigh the costs. In order to arrive at such a conclusion, however, certain important economic costs and concepts have been omitted."

"A serious problem with the Roads Report is its lack of discussion concerning the economic costs arising from the negative ecological effects of roads. Despite overwhelming scientific data linking roads and sedimentation (Bennett 1991; Grayson et al. 1993; Lyon 1984; Megahan 1980; McCashion and Rice 1983; Wade 1998; Williams 1998), the socio- economic costs of mitigating the effects of this sedimentation receive no mention in the Roads Report. Such costs are central to and should be included in any socio-economic assessment of forest roads."

Response:

North Nestucca Environmental Assessment Page 6

Appendix E – Attachment 4

See response at beginning of document.

Road Construction Opposing View #7 - "The present road system constitutes a legacy of current and potential sources of damage to aquatic and riparian habitats, mostly through sedimentation, and to terrestrial habitats through fragmentation and increased access" (Amaranthus et all 1985)."

"The failure of the Report to properly address mitigation costs associated with the ecological effects is a serious problem that needs to be addressed in future drafts. Similarly, passive-use values need to be taken seriously and considered throughout the Roads Report. In order to rectify these problems, most of the Socio-Economic Effects subsections will have to be reworked. Failing to do so, the Roads Report will paint an incomplete picture of the costs and benefits associated with the Forest Service's road program."

Brister, Daniel. "A Review and Comment on: Forest Service Roads: A Synthesis of Scientific Information, 2nd Draft, USDA Forest Service." December 1998. http://www.wildlandscpr.org/forest-service-roads-synthesis-scientific-information-socio- economic-impacts

Response: See response at beginning of document. ------Road Construction Opposing View #8 - "Sediment input to freshwater is due to either the slower, large-scale process of soil erosion, or to rapid, localized “mass movements,” such as landslides. Forest practices can increase the rate at which both processes occur. Most sediment from forestry arises from landslides from roads and clearcuts on steep slopes, stream bank collapse after riparian harvesting, and soil erosion from logging roads and harvested areas. Roads, particularly those that are active for long periods of time, are likely the largest contributor of forestry- induced sediment (Furniss et al. 1991)."

"Sediment can increase even when roads comprise just 3% of a basin (Cederholm et al. 1981)."

North Nestucca Environmental Assessment Page 7

Appendix E – Attachment 4

"More than half the species present in the study area will likely be negatively impacted by sedimentation from logging roads."

"In areas made highly turbid (cloudy) from sedimentation, the foraging ability of adults and juveniles may be inhibited through decreased algal production and subsequent declines in insect abundance, or, for visual- feeding taxa dependent on good light, through their inability to find and capture food. Highly silted water may damage gill tissue and cause mortality or physiological stress of adults and juveniles."

Bunnell, Fred L. Ph.D., Kelly A. Squires and Isabelle Houde. 2004 "Evaluating effects of large-scale salvage logging for mountain pine beetle on terrestrial and aquatic vertebrates." Mountain Pine Beetle Initiative Working Paper 1. Canadian Forest Service. http://warehouse.pfc.forestry.ca/pfc/25154.pdf

Response: See response at beginning of document. ------Road Construction Opposing View #9 - "The road construction and right- of-way logging were immediately detrimental to most aquatic invertebrates in South Fork Caspar Creek"

"Salmonid populations decreased immediately after the road construction."

"Sustained logging and associated road construction over a period of many years do not afford either the stream or the 'fish population a chance to recover."

Burns, James W., "Some Effects of Logging and Associated Road Construction on Northern California Streams." Transactions of the American Fisheries Society, Volume 1, Number 1, January 1972. http://www.fs.fed.us/psw/publications/4351/Burns72.pdf

Response: The EA provides an analysis of the effects of the project on aquatic species in the Fisheries section (pg. 94) section of the EA, and a more detailed response is available in Appendix H.

North Nestucca Environmental Assessment Page 8

Appendix E – Attachment 4 ------Road Construction Opposing View #10 has been deleted. ------Road Construction Opposing View #11 - “Forest roads apparently can serve as a partial filter to the movements of some amphibian species”

deMaynadier, Phillip G. and Malcolm L. Hunter, Jr. “Road Effects on Amphibian Movements in a Forested Landscape” From Natural Areas Journal (2000) Volume: 20, Issue: 1, Pages: 56-65 http://www.mendeley.com/research/road-effects-on-amphibian-movements-in-a- forested-landscape/

Response: No new permanent roads are proposed for construction in this project. The total project area is75,112 acres. The project proposes to construct 3 acres of temporary roads which is only .004% of the project area. The total Nestucca basin consists of 163,000 acres, temporary roads only impact 0.002% of the whole basin. ------Road Construction Opposing View #12 - "Roads often cause serious ecological impacts. There are few more irreparable marks we can leave on the land than to build a road."

Dombeck, Mike Ph.D., US Forest Service Chief, 1997-2001 Remarks made to Forest Service employees and retirees at the University of Montana. February 1998. https://www.uwsp.edu/cnr/gem/Dombeck/MDSpeeches/CD%20COPY/Chief%20Mike% 20Dombeck%27s%20Remarks%20to%20Forest%20Service%20Employees%20and%2 0.htm

Response: See response at beginning of document.

North Nestucca Environmental Assessment Page 9

Appendix E – Attachment 4 ------Road Construction Opposing View #13 - "Few marks on the land are more lasting than roads."

"The negative effects on the landscape of constructing new roads, deferring maintenance, and decommissioning old roads are well documented. Unwanted or non-native plant species can be transported on vehicles and clothing by users of roads, ultimately displacing native species. Roads may fragment and degrade habitat for wildlife species and eliminate travel corridors of other species. Poorly designed or maintained roads promote erosion and landslides, degrading riparian and wetland habitat through sedimentation and changes in streamflow and water temperature, with associated reductions in fish habitat and productivity. Also, roads allow people to travel into previously difficult or impossible to access areas, resulting in indirect impacts such as ground and habitat disturbance, increased pressure on wildlife species, increased litter, sanitation needs and vandalism, and increased frequency of human- caused fires."

EPA entry into the Federal Register: March 3, 2000 (Volume 65, Number 43) Page 11675, "National Forest System Road Management." http://www.epa.gov/fedrgstr/EPA-GENERAL/2000/March/Day-03/g5002.htm

Response: No new permanent roads are proposed for construction in this project. The new temporary roads will only impact about 3 acres, however this ground will be stabilized, closed and seeded upon completion of the project.

------Road Construction Opposing View #14 - “Fragmentation caused by roads is of special interest because the effects of roads extend tens to hundreds of yards from the roads themselves, altering habitats and water drainage patterns, disrupting wildlife movement, introducing exotic plant species, and increasing noise levels. The land development that follows roads out into rural areas usually leads to more roads, an expansion process that only ends at natural or legislated barriers.”

North Nestucca Environmental Assessment Page 10

Appendix E – Attachment 4

“Forest Fragmentation and Roads” Eastern Forest Environmental Threat Assessment Center U.S. Forest Service - Southern Research Station http://www.forestthreats.org/publications/su-srs-018/fragmentation

Response: No new permanent roads are proposed for construction in this project. The new temporary roads will only impact about 3 acres, however this ground stabilized, closed and seeded upon completion of the project. This project includes only commercial thinning, no clear cuts are proposed. The intent is to encourage the development of late successional forest characteristics. By thinning the scattered units the intent is to create larger blocks of late successional habitat. This will reduce fragmentation that resulted from previous harvest activities.

------Road Construction Opposing View #15 - “A huge road network with vehicles ramifies across the land, representing a surprising frontier of ecology. Species-rich roadsides are conduits for few species. Roadkills are a premier mortality source, yet except for local spots, rates rarely limit population size. Road avoidance, especially due to traffic noise, has a greater ecological impact. The still-more-important barrier effect subdivides populations, with demographic and probably genetic consequences. Road networks crossing landscapes cause local hydrologic and erosion effects, whereas stream networks and distant valleys receive major peak-flow and sediment impacts. Chemical effects mainly occur near roads. Road networks interrupt horizontal ecological flows, alter landscape spatial pattern, and therefore inhibit important interior species. Thus, road density and network structure are informative landscape ecology assays. Australia has huge road-reserve networks of native vegetation, whereas the Dutch have tunnels and overpasses perforating road barriers to enhance ecological flows. Based on road-effect zones, an estimated 15–20% of the United States is ecologically impacted by roads.”

Forman, Richard T. and Lauren E. Alexander “Roads and their Major Ecological Effects” Annual Review of Ecology and Systematics, Vol. 29: 207-231, November 1998 http://arjournals.annualreviews.org/doi/abs/10.1146/annurev.ecolsys.29.1.207?cookieSet=1&j ournalCode=ecolsys.1

North Nestucca Environmental Assessment Page 11

Appendix E – Attachment 4

Response: See response at beginning of document. The new temporary roads will only impact about 3 acres, however this ground will be r stabilized, closed and seeded upon completion of the project.

------Road Construction Opposing View #16 - “Questions to consider: Roads dramatically alter forest ecosystems

1. Does the management prescription account for the ecological effects of the road construction and maintenance activities associated with carrying out such activities?

2. Have alternatives to road building been considered? How does the plan attempt to address the effects of roads?” (page 37)

Franklin, Jerry Ph.D., David Perry Ph.D., Reed Noss Ph.D., David Montgomery Ph.D. and Christopher Frissell Ph.D. 2000. "Simplified Forest Management to Achieve Watershed and Forest Health: A Critique." A National Wildlife Federation publication sponsored by the Bullitt Foundation http://www.coastrange.org/documents/forestreport.pdf

Response: The proposed use of temporary roads was thoroughly analyzed in the EA. Discussions of the need for, and impact of, construction of new temporary can be found in each section of the EA.

------Road Construction Opposing View #17 - “The authors warned that cutting roads into current roadless areas could bring much more harm to wildlife, soil and fisheries than the beetle-killed trees pose to the forest.”

Frey, David “Logging Won’t Halt Beetles, Fire, Report Says” NewWest.net, 3-03-10 http://www.newwest.net/topic/article/logging_wont_halt_beetles_fire_report_says/C41/L41/

North Nestucca Environmental Assessment Page 12

Appendix E – Attachment 4

Response: There are no roads proposed for construction in roadless areas.

------Road Construction Opposing View #18 - "Rarely can roads be designed and built that have no negative impacts on streams. Roads modify natural drainage patterns and can increase hillslope erosion and downstream sedimentation. Sediments from road failures at stream crossings are deposited directly into stream habitats and can have both on-site and offsite effects. These include alterations of the channel pattern or morphology, increased bank erosion and changes in channel width, substrate composition, and stability of slopes adjacent to the channels."

"All of these changes result in important biological consequences that can affect the entire stream ecosystem. One specific example involves anadromous salmonids, such as salmon and steelhead, that have complex life histories and require suitable stream habitat to support both juvenile and adult life stages."

"A healthy fishery requires access to suitable habitat that provides food, shelter, spawning gravel, suitable water quality, and access for upstream and downstream migration. Road-stream crossing failures have direct impacts on all of these components."

Furniss, Michael J., Michael Love Ph.D. and Sam A. Flanagan "Diversion Potential at Road-Stream Crossings." USDA Forest Service. 9777 1814—SDTDC. December 1997. http://www.stream.fs.fed.us/water-road/w-r-pdf/diversionpntl.pdf

Response: The proposed use of temporary roads was thoroughly analyzed in the EA. Discussions of the need for, and impact of, construction of new temporary can be found in each section of the EA. See response at beginning of document for additional clarification.

------

North Nestucca Environmental Assessment Page 13

Appendix E – Attachment 4

Road Construction Opposing View #19 - “Barry Noon, a professor of wildlife ecology at Colorado State University, noted that scientific research has consistently shown the adverse effects of roads on hydrologic processes and fish and wildlife populations.

“ “One of the key things to recognize is the effects of the roads extend far beyond their immediate footprint,” Noon said. For example, “in terms of hydrology, the roads are leading to faster runoff of water, often with great increases in sedimentation, particularly following storm events, and roads in watersheds often lead to increases in the intensity of floods.” “

These changes degrade fish habitat because of the increased sedimentation that leads to decreases in water quality, Noon said. And roads fragment wildlife habitat and create areas that animals avoid, often as result of increased hunting, he said.”

Gable, Eryn “Battling beetles may not reduce fore risks – report” Land Letter, March 4, 2010 http://www.xerces.org/2010/03/04/battling-beetles-may-not-reduce-fire-risks-report/

Response: See response at beginning of document. ------Road Construction Opposing View #20 - "Roads and skid trails have been identified as a major contributor to increased turbidity of water draining logging areas resulting in increases from 4 to 93 parts per million (Hoover, 1952). Forest roads have been found to have erosion rates from one to three orders of magnitude greater than similar undisturbed areas (Megahan, 1974) and perhaps account for as much as 90 percent of all forest erosion (Megahan, 1972). Forest roads can also cause soil erosion and stream sedimentation, which adversely impact on the nation’s water quality (Authur et al., 1998).

Grace, Johnny M. III Ph.D. 2003. "Minimizing the impacts of the forest road system." In: Proceedings of the conference 34 international erosion control association; ISSN 1092-2806. [Place of publication unknown]: International Erosion Control Association: 301-310. http://www.srs.fs.usda.gov/pubs/ja/ja_grace011.pdf

North Nestucca Environmental Assessment Page 14

Appendix E – Attachment 4

Response: See response at beginning of document. ------Road Construction Opposing View #21 - "Roads have well-documented, short- and long-term effects on the environment that have become highly controversial, because of the value society now places on unroaded wildlands and because of wilderness conflicts with resource extraction."

"(Road) consequences include adverse effects on hydrology and geomorphic features (such as debris slides and sedimentation), habitat fragmentation, predation, road kill, invasion by exotic species, dispersal of pathogens, degraded water quality and chemical contamination, degraded aquatic habitat, use conflicts, destructive human actions (for example, trash dumping, illegal hunting, fires), lost solitude, depressed local economies, loss of soil productivity, and decline in biodiversity."

Gucinski, Hermann Ph.D., Michael J. Furniss, Robert R. Ziemer Ph.D. and Martha H. Brookes, Editors. 2001. "Forest Roads: A Synthesis of Scientific Information." USDA Forest Service, General Technical Report PNW-GTR-509. http://www.fs.fed.us/pnw/pubs/gtr509.pdf

Response: See response at beginning of document.

------Road Construction Opposing View #22 - "Fires in the roaded areas are more intense, due to drier conditions, wind zones on the foothill/valley interface, high surface-fuel loading, and dense stands."

Hann, W.J. et al. 1997 Landscape dynamics of the Basin. Pp. 337-1,055 in: Quigley, T.M. and S.J. Arbelbide (eds.) An Assessment of Ecosystem Components in the Interior Columbia Basin and Portions of the Klamath and Great Basins: Volume II. USDA Forest Service, PNW-GTR-405 http://www.fs.fed.us/pnw/pubs/gtr405/pnw_gtr405aa.pdf

North Nestucca Environmental Assessment Page 15

Appendix E – Attachment 4

Response: See response at beginning of document. The project proposes no broadcast burning or underburning. The only potential burning would be slash piles located on landings or along major roads.

------Road Construction Opposing View #23 - “Many forested landscapes are fragmented by roads, but our understanding of the effects of these roads on the function and diversity of the surrounding forest is in its infancy. I investigated the effect of roads in otherwise continuous forests on the macroinvertebrate fauna of the soil. I took soil samples along transects leading away from the edges of unpaved roads in the Cherokee National Forest in the Southern Appalachian mountains of the United States. Roads significantly depressed both the abundance and the richness of the macroinvertebrate soil fauna. Roads also significantly reduced the depth of the leaf-litter layer. These effects persisted up to 100 m into the forest. Wider roads and roads with more open canopies tended to produce steeper declines in abundance, richness, and leaf-litter depth, but these effects were significant only for canopy cover and litter depth. The macroinvertebrate fauna of the leaf litter plays a pivotal role in the ability of the soil to process energy and nutrients. These macroinvertebrates also provide prey for vertebrate species such as salamanders and ground- foraging birds. The effect of roads on the surrounding forest is compounded by the sprawling nature of the road system in this and many other forests. My data suggest that even relatively narrow roads through forests can produce marked edge effects that may have negative consequences for the function and diversity of the forest ecosystem.”

Haskell, David G. Ph.D. 1999 “Effects of Forest Roads on Macroinvertebrate Soil Fauna of the Southern Appalachian Mountains” http://www.jstor.org/stable/2641904

Response: See response at beginning of document. The new temporary roads will only impact about 3 acres, however this ground will be stabilized, closed and seeded upon completion of the project.

North Nestucca Environmental Assessment Page 16

Appendix E – Attachment 4 ------Road Construction Opposing View #24 - “Roads remove habitat, alter adjacent areas, and interrupt and redirect ecological flows. They subdivide wildlife populations, foster invasive species spread, change the hydrologic network, and increase human use of adjacent areas. At broad scales, these impacts cumulate and define landscape patterns.”

Hawbaker, Todd J. Ph.D., Volker C. Radeloff Ph.D., Murray K. Clayton Ph.D., Roger B. Hammer Ph.D., and Charlotte E. Gonzalez-Abraham Ph.D. “Road Development, Housing Growth, and Landscape Fragmentation In Northern Wisconsin: 1937–1999” Ecological Applications: Vol. 16, No. 3, pp. 1222-1237. http://www.esajournals.org/doi/abs/10.1890/1051- 0761%282006%29016%5B1222%3ARDHGAL%5D2.0.CO%3B2?journalCode=ecap

Response: See response at beginning of document. The new temporary roads will only impact about 3 acres, however this ground will be stabilized, closed and seeded upon completion of the project.

------Road Construction Opposing View #25 - “Last winter was unusually wet in the Pacific Northwest. The result was landslides all over caused by logging roads; five people died, spawning streams were ruined, water supplies were contaminated and the flooding was tremendously aggravated. According to David Bayles, conservation director of the Pacific Rivers Council, aerial surveys documented more than 650 landslides in February in Washington and Oregon alone. The stupidest and most dangerous practice is allowing logging roads on steep slopes — that's really asking for it.

You may ask yourself why the taxpayers are expected to pony up to build roads for profitable logging companies. Build roads for the timber companies in order to stimulate the U.S. logging, paper and building industries. There's just one problem. A lot of U.S. logs get shipped overseas, mostly to Japan. We're actually subsidizing Japanese

North Nestucca Environmental Assessment Page 17

Appendix E – Attachment 4 companies while doing terrible damage to our environment and not helping the U.S. job scene much except when it comes to cutting

Start with the assumption that the U.S. Forest Service a component of the Department of Agriculture, is simply an auxiliary branch of the timber industry and you'll pretty much have the picture of what's going on. Last winter, the Forest Service refused a bid at a timber auction from an environmentalist who wanted to save, not harvest, a stand of evergreens in the Okanogan National Forest in Washington. Instead, the Forest Service accepted a bid of $15,000 from a logging company that cut 3.5 million board-feet of lumber in that stand. Try to find a price like that at Home Depot.”

Ivins, Molly Creators Syndicate, August 3 1997 08 03 http://www.creators.com/opinion/molly-ivins/molly-ivins-august-3-1997-08-03.html

------Road Construction Opposing View #26 - "Although disturbance patches are created by peak flow and debris flow disturbances in mountain landscapes without roads, roads can alter the landscape distributions of the starting and stopping points of debris flows, and they can alter the balance between the intensity of flood peaks and the stream network's resistance to change."

Jones, Julia A. Ph.D., Frederick J. Swanson Ph.D. Beverley C. Wemple Ph.D., and Kai U. Snyder. "Effects of roads on hydrology, geomorphology, and disturbance patches in stream networks." Conservation Biology 14, No. 1. 2000. http://www.jstor.org/stable/2641906

North Nestucca Environmental Assessment Page 18

Appendix E – Attachment 4

Response: See response at beginning of document. The proposed use of temporary roads was thoroughly analyzed in the EA. Discussions of the need for, and impact of, construction of new temporary can be found in each section of the EA.

------Road Construction Opposing View #27 - "In the Pacific Northwest, the two main processes that contribute to sediment production are mass failure and surface erosion from forest roads (Fredriksen 1970, Reid and Dunne 1984). In the Clearwater River basin in the State of Washington, as much as 40 percent of the sediment produced in the watershed was attributed to logging roads (Reid 1980)."

Kahklen, Keith. "A Method for Measuring Sediment Production from Forest Roads." Pacific Northwest Research Station, USDA Forest Service. Research note PNW-RN-529, April 2001. http://www.fs.fed.us/pnw/pubs/rn529.pdf

Response: See response at beginning of document. The new temporary roads will only impact about 3 acres, however this ground will be stabilized, closed and seeded upon completion of the project. The proposed use of temporary roads was thoroughly analyzed in the EA. Discussions of the need for, and impact of, construction of new temporary can be found in each section of the EA. The hydrology/soils section (page 87) of the EA contains an analysis of ground stability in the project area. Unstable areas were identified and excluded from treatment.

------Road Construction Opposing View #28 - "It is indisputable that roads are one of the greatest threats to the ecological integrity of forested systems and associated river, wetland, lake, and coastal ecosystems. Yet, the USFS has failed to adopt a policy that mandates reversing the worst ecological effects of roads, or that precludes incursion of roads into roadless areas. Despite widespread recognition of these facts, the USFS diverts staff and money to extraordinarily costly salvage logging projects at

North Nestucca Environmental Assessment Page 19

Appendix E – Attachment 4 the expense of reducing the extent of the road network or undertaking needed fine-fuels reductions in unburned forests."

Karr, James R. Ph.D., Christopher A. Frissell Ph.D., Jonathan J. Rhodes, David L. Perry Ph.D. and G. Wayne Minshall Ph.D. Excerpt from a letter to the Subcommittee on Forests & Forest Health U.S. House of Representatives. 3 July, 2002. http://www.nativeforest.org/campaigns/wildfire_info_center/letter_from_beschta.htm

------Road Construction Opposing View #29 - “Forest fragmentation, as scientists call the intentional felling of woodland, is actually two processes. In populated areas such as the Atlantic seaboard, it means reduction in the size of forest tracts, usually due to suburbanization and development. In less inhabited areas--northern New England, for example--forest fragmentation refers to isolation of one patch of forest from another by logging, or by the building of roads or power lines.”

Lawren, Bill 1992 “Singing the Blues for Songbirds: Bird lovers lament as experts ponder the decline of dozens of forest species” National Wildlife http://www.nwf.org/News-and-Magazines/National-Wildlife/Birds/Archives/1992/Singing- the-Blues-for-Songbirds.aspx

North Nestucca Environmental Assessment Page 20

Appendix E – Attachment 4

The proposed use of temporary roads was thoroughly analyzed in the EA. Discussions of the need for, and impact of, construction of new temporary can be found in each section of the EA. ------Road Construction Opposing View #30 - "The compaction of forest road soils is known to reduce aeration, porosity, infiltration rates, water movement, and biological activity in soils. Research indicates that soil bulk density, organic matter, moisture, and litter depths are much lower on roads than on nearby forest lands. Macropores, which provide soil drainage and infiltration, have been shown to significantly decrease in size as a result of road construction and use. Reduced infiltration and increased compaction promote soil erosion, especially during the seasonal southwestern monsoon rains (Elseroad 2001)."

"Physical disturbances caused by road construction and vehicle use create ideal conditions for colonization by invasive exotic plant species. The use of roads by vehicles, machinery, or humans often aids the spread of exotic plant seeds. Once established, they can have long-term impacts on surrounding ecosystems and can be difficult to remove."

"Roads are known to cause habitat fragmentation. Many create ecological 'edges' with different plant species, light levels, and hiding cover, all of which may alter animal survival, reproductive success, and movement patterns. The introduction of exotic plants can disrupt the availability of native vegetation used by wildlife for food and shelter (Trombulak and Frissell 1999)."

"Forest roads often develop a water-repellent soil layer caused by lack of vegetative cover and changes in soil composition. This can substantially influence how runoff is processed. Erosion, the formation of water channels beside the road, and increased sediment loads in nearby streams are common results of this process (Baker 2003)."

"Because they provide easier access to many forest tracts, forest roads often allow more human-caused fires to be ignited."

Lowe, Kimberly Ph.D.,"Restoring Forest Roads." A Northern Arizona University Ecological Restoration Institute publication

North Nestucca Environmental Assessment Page 21

Appendix E – Attachment 4

Working Paper 12. June, 2005. http://www.eri.nau.edu/en/information-for-practitioners/restoring-forest-roads

Response: Information on soil compaction can be found in the Hydrology/Soils section (pg. 87) of the EA. The project area was surveyed for invasive weeds in the EA (pg. 120) and a management plan was developed. No new permanent roads are proposed for construction in this project. The new temporary roads will only impact about 3 acres, however this ground will be stabilized, closed and seeded upon completion of the project. This project includes only commercial thinning, no clear cuts are proposed. The intent is to encourage the development of late successional forest characteristics. By thinning the scattered units the intent is to create larger blocks of late successional habitat. This will reduce fragmentation that resulted from previous harvest activities See response at beginning of document. The new temporary roads will only impact about 3 acres, however this ground will be stabilized, closed and seeded upon completion of the project. The proposed use of temporary roads was thoroughly analyzed in the EA. Discussions of the need for, and impact of, construction of new temporary can be found in each section of the EA.

------Road Construction Opposing View #31 - "Almost everywhere people live and work they build and use unimproved roads, and wherever the roads go, a range of environmental issues follows."

"Among the environmental effects of unimproved roads, those on water quality and aquatic ecology are some of the most critical. Increased chronic sedimentation, in particular, can dramatically change the food web in affected streams and lakes."

"The nearly impervious nature of road surfaces (or treads) makes them unique within forested environments and causes runoff generation even in mild rainfall events, leading to chronic fine sediment contributions."

"If we look at the issue of what we need to learn or the research priorities for forest road hydrology, I would argue that the areas of cutslope hydrology and effectiveness of restoration efforts are perhaps most critical."

North Nestucca Environmental Assessment Page 22

Appendix E – Attachment 4

"At a few sites in the mountains of Idaho and Oregon a substantial portion of the road runoff (80–95%) came from subsurface flow intercepted by the cutslope (Burroughs et al., 1972; Megahan, 1972; Wemple, 1998)."

Luce, Charles H. Ph.D., 2002. "Hydrological processes and pathways affected by forest roads: what do we still need to learn?" Hydrologic Processes: 16, 2901–2904. http://www.fs.fed.us/rm/boise/teams/soils/Publications/Luce%202002%20HP.pdf

------Road Construction Opposing View #32 - "Roads in the watershed contribute to sediment production by concentrating runoff, thereby increasing sediment load to the stream network. Most unimproved (dirt) roads connect either directly or indirectly with streams and, therefore, act as extensions of stream networks by effectively increasing watershed drainage density and subsequently sediment loads to streams. In the South Fork subwatershed of Squaw Creek, road connectivity has resulted in an increase in effective drainage density of approximately 250%. Throughout the Squaw Creek watershed, it is estimated that dirt roads potentially contribute as much as 7,793 metric tons/year to the watershed sediment budget."

Maholland, Becky and Thomas F. Bullard Ph.D., "Sediment-Related Road Effects on Stream Channel Networks in an Eastern Sierra Nevada Watershed." Journal of the Nevada Water Resources Association, Volume 2, Number 2, Fall 2005. http://www.nvwra.org/docs/journal/vol_2_no_2/NWRAjournal_fall2005_article4.pdf

Response: See response at beginning of document. The new temporary roads will only impact about 3 acres, however this ground will be stabilized, closed and seeded upon completion of the project.

North Nestucca Environmental Assessment Page 23

Appendix E – Attachment 4 ------Road Construction Opposing View #33 - “One of the greatest impacts of roads and (especially motorized) trails is their effect on the hydrology of natural landscapes, including the flow of surface and ground water and nutrients. These hydrologic effects are responsible for changes to geomorphic processes and sediment loads in roaded areas (Luce and Wemple 2001).” (pg. 12)

Malecki, Ron W. “A New Way to Look at Forest Roads: the Road Hydrologic Impact Rating System (RHIR)” The Road-RIPorter, Autumn Equinox, 2006 http://www.wildlandscpr.org/files/uploads/RIPorter/rr_v11-3.pdf

Response: See response at beginning of document. The new temporary roads will only impact about 3 acres, however this ground will be stabilized, closed and seeded upon completion of the project. The proposed use of temporary roads was thoroughly analyzed in the EA. Discussions of the need for, and impact of, construction of new temporary can be found in each section of the EA. Appendix A contains a list of Project Design Criteria designed to limit or exclude sediment from reaching streams.

------Road Construction Opposing View #34 - "A study was made on 344 miles of logging roads in northwestern California to assess sources of erosion and the extent to which road-related erosion is avoidable. At most, about 24 percent of the erosion measured on the logging roads could have been prevented by conventional engineering methods. The remaining 76 percent was caused by site conditions and choice of alignment. On 30,300 acres of commercial timberland, an estimated 40 percent of the total erosion associated with management of the area was found to have been derived from the road system."

McCashion, J. D. and R. M. Rice Ph.D. 1983. "Erosion on logging roads in northwestern California: How much is avoidable?" Journal of Forestry 8(1): 23-26.

North Nestucca Environmental Assessment Page 24

Appendix E – Attachment 4 http://www.fs.fed.us/psw/rsl/projects/water/McCashion.pdf

Response: See response at beginning of document. The new temporary roads will only impact about 3 acres, however this ground will be stabilized, closed and seeded upon completion of the project. The proposed use of temporary roads was thoroughly analyzed in the EA. Discussions of the need for, and impact of, construction of new temporary can be found in each section of the EA. Appendix A contains a list of Project Design Criteria designed to limit or exclude sediment from reaching streams.

------Road Construction Opposing View #35 - "Research has shown that roads can have adverse impacts on the water quality on the forest landscape (Authur et al. 1998; Binkley and Brown 1993; Megahan et al. 1991). The forest road system has been identified by previous research as the major source of soil erosion on forestlands (Anderson et. al 1976; Patric 1976; Swift 1984; Van Lear et al. 1997). Furthermore, roads are cited as the dominant source of sediment that reaches stream channels (Packer 1967; Trimble and Sartz 1957; Haupt 1959)."

McFero III, Grace, J. "Sediment Plume Development from Forest Roads: How are they related to Filter Strip Recommendations?" An ASAE/CSAE Meeting Presentation, Paper Number: 045015, August 1-4, 2004. http://www.srs.fs.usda.gov/pubs/ja/ja_grace017.pdf

------Road Construction Opposing View #36 - “Overall, roads had a greater impact on landscape structure than logging in our study area. Indeed, the 3-fold increase in road density between 1950–1993 accounted for most of

North Nestucca Environmental Assessment Page 25

Appendix E – Attachment 4 the changes in landscape configuration associated with mean patch size, edge density, and core area.”

McGarigal, Kevin Ph.D., William H. Romme Ph.D. Michele Crist Ph.D.and Ed Roworth Ph.D. “Cumulative effects of roads and logging on landscape structure in the San Juan Mountains, Colorado (USA)” Landscape Ecology, Volume 16, Number 4 / May, 2001 http://www.springerlink.com/content/w12557624742tv77/

Response: See response at beginning of document. The new temporary roads will only impact about 3 acres, however this ground will be stabilized, closed and seeded upon completion of the project. The proposed use of temporary roads was thoroughly analyzed in the EA. Discussions of the need for, and impact of, construction of new temporary can be found in each section of the EA. Appendix A contains a list of Project Design Criteria designed to minimize impacts from roads.

------Road Construction Opposing View #37 - “Road construction in remote areas appears to be the major long term impact of resource extraction industries and the most significant problem facing grizzly bears in most locations. Open roads are an influence in all 5 ways that people affect bears. Vehicles on roads can harass bears, displace them from quality habitats, and cause reduced bear use of altered habitats, such as cutting units. Bears that are displaced from roads may cause social disruption in areas away from roads. Finally, roads permit access for many people and some of these will shoot bears.” (Pg. 62)

McLellan, Bruce N. “Relationships between Human Industrial Activity and Grizzly Bears” Bears: Their Biology and Management, Vol. 8 International Conference on Bear Research and Management February 1989 (1990), pp. 57-64 http://www.bearbiology.com/fileadmin/tpl/Downloads/URSUS/Vol_8/McClellan_8.pdf

North Nestucca Environmental Assessment Page 26

Appendix E – Attachment 4

Response: See response at beginning of document. The new temporary roads will only impact about 3 acres, however this ground will be stabilized, closed and seeded upon completion of the project. The proposed use of temporary roads was thoroughly analyzed in the EA. Discussions of the need for, and impact of, construction of new temporary can be found in each section of the EA. Appendix A contains a list of Project Design Criteria designed to minimize impacts from roads.

------Road Construction Opposing View #38 - “Erosion from forest roads can be a large source of sediment in watersheds managed for timber production.”

Megahan, Walter F. Ph.D. “Predicting Road Surface Erosion from Forest Roads in Washington State” from a presentation presented at the 2003 Geological Society of America meeting. http://gsa.confex.com/gsa/2003AM/finalprogram/abstract_67686.htm

Response: See response at beginning of document. The new temporary roads will only impact about 3 acres, however this ground will be stabilized, closed and seeded upon completion of the project. The proposed use of temporary roads was thoroughly analyzed in the EA. Discussions of the need for, and impact of, construction of new temporary can be found in each section of the EA. Appendix A contains a list of Project Design Criteria designed to limit or exclude sediment from reaching streams.

------Road Construction Opposing View #39 - “Today, addressing the adverse impacts of forest roads is consistently identified as one of the highest watershed restoration priorities in U.S. forests—in many forested watersheds in the western United States there is a greater road density than stream density. It is simply irrational to spend millions of dollars subsidizing further forest road construction when we are simultaneously

North Nestucca Environmental Assessment Page 27

Appendix E – Attachment 4 spending millions of dollars to offset detrimental effects associated with similar actions in the past.”

Montgomery, David Ph.D., Statement at a Press Conference with Senator Robert Torricelli about S. 977 and HR 1376), the Act to Save America’s Forests April 28, 1998, U.S. Capitol http://www.saveamericasforests.org/news/ScientistsStatement.htm

Response: See response at beginning of document. The new temporary roads will only impact about 3 acres, however this ground will be stabilized, closed and seeded upon completion of the project. The proposed use of temporary roads was thoroughly analyzed in the EA. Discussions of the need for, and impact of, construction of new temporary can be found in each section of the EA. Appendix A contains a list of Project Design Criteria designed to minimize impacts from roads.

------Road Construction Opposing View #40 - “Nothing is worse for sensitive wildlife than a road. Over the last few decades, studies in a variety of terrestrial and aquatic ecosystems have demonstrated that many of the most pervasive threats to biological diversity - habitat destruction and fragmentation, edge effects, exotic species invasions, pollution, and overhunting - are aggravated by roads. Roads have been implicated as mortality sinks for animals ranging from snakes to wolves; as displacement factors affecting animal distribution and movement patterns; as population fragmenting factors; as sources of sediments that clog streams and destroy fisheries; as sources of deleterious edge effects; and as access corridors that encourage development, logging and poaching of rare plants and animals.”

"Most public agencies disregard the ecological impacts of roads, and attempt to justify timber roads as benefiting recreation and wildlife management. Even when a land manager recognizes the desirability of closing roads, he or she usually contends that such closures would be unacceptable to the public."

North Nestucca Environmental Assessment Page 28

Appendix E – Attachment 4

“The Forest Service and other public agencies will claim that road closures, revegetation, and other restorative measures are too expensive to be implemented on a broad scale. But much of the approximately $400 million of taxpayers' money squandered annually by the Forest Service on below- cost timber sales goes to road-building. Road maintenance is also expensive. Virtually all of this money could be channeled into road closures and associated habitat restoration. This work would be labor- intensive, and providing income to the many laid off loggers, timber sale planners, and road engineers -- for noble jobs, rather than jobs of destruction!”

Noss, Reed F., Ph.D. 1995. “The Ecological Effects of Roads or the Road to Destruction” Wildlands CPR http://www.wildlandscpr.org/ecological-effects-roads

Response: See response at beginning of document. The new temporary roads will only impact about 3 acres, however this ground will be stabilized, closed and seeded upon completion of the project. Appendix A contains a list of Project Design Criteria designed to minimize impacts from roads. The proposed use of temporary roads was thoroughly analyzed in the EA. Discussions of the need for, and impact of, construction of new temporary can be found in each section of the EA.

------Road Construction Opposing View #41 - “Numerous studies have reported lower densities of breeding Ovenbirds (Seiurus aurocapillus) adjacent to forest edges. However, none of these studies has considered habitat use and reproductive success to address mechanisms underlying the observed pattern, and most were conducted in fragmented landscapes and ignored juxtapositions of forest with narrow openings such as roads. We studied the influence of forest roads on Ovenbird density in an extensively forested region of Vermont, evaluating habitat use and reproductive success relative to mechanisms proposed to explain the density-edge relationship. Territory densities on seven study plots were 40% lower within edge areas (0 to 150 m from unpaved roads) than within interior areas (150 to 300 m from roads). We simulated the distribution of Ovenbird territories and concluded that passive displacement, where birds

North Nestucca Environmental Assessment Page 29

Appendix E – Attachment 4 perceive habitat interfaces as boundaries and limit their territories entirely to forest habitat, did not account for the observed density-edge pattern. Territory size was inversely related to distance from roads, providing an alternative explanation for reduced densities near edges and suggesting that habitat quality was higher away from roads. Pairing success was lower within edge areas than within interior zones, but the difference was not statistically significant. The proportion of males that produced fledglings did not differ between edge and interior areas. We conclude that habitat quality for Ovenbirds may be lower within 150 m of unpaved roads in extensive forested landscapes, affecting territory density and possibly reproductive success.”

Ortega, Yvette K.; Capen, David E. 1999. “Effects of forest roads on habitat quality for Ovenbirds in a forested landscape” Auk. 116(4): 937-946. http://www.fs.fed.us/rm/pubs_other/rmrs_1999_ortega_y001.html

Response: Ovenbirds are not native to the Pacific Northwest, however there are numerous other species of passerine birds present. The condition of the existing road network is outside the scope of this project. However, the timber purchaser will be responsible to build and remove any temporary roads needed for the project. As part of the project the timber buyer will perform much needed maintenance on existing Forest Service roads. Separate projects, such as the Legacy Roads Project are beginning to address the backlog in road maintenance and to reduce the existing road network. The new temporary roads will only impact about 3 acres, however this ground will be stabilized, closed and seeded upon completion of the project. The proposed use of temporary roads was thoroughly analyzed in the EA. Discussions of the need for, and impact of, construction of new temporary can be found in each section of the EA.

------Road Construction Opposing View #42 - “Increasingly, previously extensive, continuous tracts of forest are being reduced to widely dispersed patches of remnant forest vegetation by logging and road-building, but few measures of the effects of roads on forest fragmentation are available. Fragmentation affects animal populations in a variety of ways, including decreased species diversity and lower densities of some animal species in the resulting smaller patches. This study seeks to quantify the effects of roads and logging activities on forest habitat.”

North Nestucca Environmental Assessment Page 30

Appendix E – Attachment 4

“Roads precipitate fragmentation by dissecting previously large patches into smaller ones, and in so doing they create edge habitat in patches along both sides of the road, potentially at the expense of interior habitat. As the density of roads in landscapes increases, these effects increase as well. McGurk and Fong (1995) considered the additive effects of clearcuts and roads, but did not measure the amount of associated edge habitat. Thus a more direct measurement of the impacts of roads on landscapes is needed.”

Reed, R.A., Johnson-Barnard, J., and Baker, W.A. 1996. "Contribution of Roads to Forest Fragmentation in the Rocky Mountains." Conservation Biology 10: 1098-1106. http://cpluhna.nau.edu/Research/contribution_of_roads_to_forest_.htm

Response: This project includes only commercial thinning, no clear cuts are proposed. The intent is to encourage the development of late successional forest characteristics. By thinning the scattered units the intent is to create larger blocks of late successional habitat. This will reduce fragmentation that resulted from previous harvest activities. See response at beginning of document. The new temporary roads will only impact about 3 acres, however this ground will be stabilized, closed and seeded upon completion of the project. The proposed use of temporary roads was thoroughly analyzed in the EA. Discussions of the need for, and impact of, construction of new temporary can be found in each section of the EA. No clear cuts or new permanent roads are proposed in this project. Appendix A contains a list of Project Design Criteria designed to minimize impacts from roads. ------Road Construction Opposing View #43 - “Erosion on roads is an important source of fine-grained sediment in streams draining logged basins of the Pacific Northwest. Runoff rates and sediment concentrations from 10 road segments subject to a variety of traffic levels were monitored to produce sediment rating curves and unit hydrographs for different use levels and types of surfaces. These relationships are combined with a continuous rainfall record to calculate mean annual sediment yields from road segments of each use level. A heavily used road segment in the field area contributes 130 times as much sediment as an abandoned road. A paved road segment, along which cut slopes and ditches are the only

North Nestucca Environmental Assessment Page 31

Appendix E – Attachment 4 sources of sediment, yields less than 1% as much sediment as a heavily used road with a gravel surface.”

Reid, L. M. Ph.D. and T. Dunne (1984), “Sediment Production from Forest Road Surfaces,” Water Resour. Res., 20(11), 1753–1761. http://www.agu.org/pubs/crossref/1984/WR020i011p01753.shtml

Response: See response at beginning of document. The new temporary roads will only impact about 3 acres, however this ground will be stabilized, closed and seeded upon completion of the project. The proposed use of temporary roads was thoroughly analyzed in the EA. Discussions of the need for, and impact of, construction of new temporary can be found in each section of the EA. Appendix A contains Project Design Criteria to limit or eliminate sediment from reaching streams.

------Road Construction Opposing View #44 - "Roads are associated with high sediment inputs and altered hydrology, both of which can strongly influence downstream channel habitats. Roads are also important as a source of indirect human impacts and as an agent of vegetation change and wildlife disturbance."

"Any ground disturbance increases the potential for erosion and hydrologic change, and roads are a major source of ground disturbance in wildlands. Compacted road surfaces generate overland flow, and much of this flow often enters the channel system, locally increasing peak flows. Localized peak flows are also increased where roads divert flow from one swale into another, and where roadcuts intercept subsurface flows."

"Overland flow from the road surface is a very effective transport medium for the abundant fine sediments that usually are generated on road surfaces. Road drainage also can excavate gullies and cause landslides downslope in swales. Cut and fill slopes are often susceptible to landsliding, and road-related landsliding is the most visible forestry-related erosional impact in many areas."

Reid, Leslie M. Ph.D., Robert R. Ziemer Ph.D., and Michael J. Furniss

North Nestucca Environmental Assessment Page 32

Appendix E – Attachment 4

1994. "What do we know about Roads?" USDA Forest Service. http://www.fs.fed.us/psw/publications/reid/4Roads.htm

Response: See response at beginning of document. The new temporary roads will only impact about 3 acres, however this ground will be stabilized, closed and seeded upon completion of the project. The proposed use of temporary roads was thoroughly analyzed in the EA. Discussions of the need for, and impact of, construction of new temporary can be found in each section of the EA. Appendix A contains Project Design Criteria to limit or eliminate sediment from reaching streams.

------Road Construction Opposing View #45 - "Disturbances from roadbuilding and logging changed the sediment/discharge relationship of the South Fork from one which was supply dependent to one which was stream power dependent, resulting in substantial increases in suspended sediment discharges."

"Road construction and logging appear to have resulted in increases in average turbidity levels (as inferred from suspended sediment increases) above those permitted by Regional Water Quality Regulations."

Rice, Raymond M. Ph.D., Forest B. Tilley and Patricia A. Datzman. 1979. "Watershed's Response to Logging and Roads: South Fork of Caspar Creek, California, 1967-1976." USDA Forest Service, Research Paper PSW-146. http://www.fs.fed.us/psw/publications/rice/Rice79.pdf

Response: See response at beginning of document. The new temporary roads will only impact about 3 acres, however this ground will be stabilized, closed and seeded upon completion of the project. The proposed use of temporary roads was thoroughly analyzed in the EA. Discussions of the need for, and impact of, construction of new temporary can be found in each section of the EA. Appendix A contains Project Design Criteria to limit or eliminate sediment from reaching streams.

North Nestucca Environmental Assessment Page 33

Appendix E – Attachment 4 ------Road Construction Opposing View #46 - "Sediment eroded from gravel roads can be a major component of the sediment budget in streams in this region (Van Lear, et al, 1995)."

Riedel, Mark S. Ph.D. and James M. Vose Ph.D., "Forest Road Erosion, Sediment Transport and Model Validation in the Southern Appalachians." Presented at the Second Federal Interagency Hydrologic Modeling Conference, July 28 – August 1, 2002. http://www.srs.fs.usda.gov/pubs/ja/ja_riedel002.pdf

Response: See response at beginning of document. The new temporary roads will only impact about 3 acres, however this ground will be stabilized, closed and seeded upon completion of the project. The proposed use of temporary roads was thoroughly analyzed in the EA. Discussions of the need for, and impact of, construction of new temporary can be found in each section of the EA. Appendix A contains Project Design Criteria to limit or eliminate sediment from reaching streams.

------Road Construction Opposing View #47 - “Early studies of elk were among the first to address effects of roads on wildlife, establishing a precedent for subsequent research on a wide range of terrestrial and aquatic species. These early elk-roads studies included those reported in a symposium on the topic in 1975 (Hieb 1976), the seminal studies of Jack Lyon in Montana and northern Idaho (Lyon 1979, 1983, 1984), the Montana Cooperative Elk-Logging Study (Lyon et al. 1985), and work by Perry and Overly (1977) in Washington and Rost and Bailey (1979) in Colorado.

As research and analysis techniques have become more sophisticated, particularly with the advent of geographic information systems (GIS) and high-resolution remote imagery, the study of effects of roads on terrestrial and aquatic communities has evolved into a unique discipline of “road ecology” (Forman et al. 2003). Road effects are far more pervasive than originally believed and include such disparate consequences as population

North Nestucca Environmental Assessment Page 34

Appendix E – Attachment 4 and habitat fragmentation, accelerated rates of soil erosion, and invasion of exotic plants along roadways. Indeed, “in public wildlands management, road systems are the largest human investment and the feature most damaging to the environment” (Gucinski et al. 2001:7). Summaries of the effects of roads on wildlife habitats and biological systems in general have been compiled by Forman and Alexander (1998), Trombulak and Frissell (2000), Gucinski et al. (2001), Forman et al. (2003) and Gaines et al. (2003).”

Rowland, M. M., M. J. Wisdom, B. K. Johnson, and M. A. Penninger 2005. “Effects of Roads on Elk: Implications for Management in Forested Ecosystems.” Pages 42-52 in Wisdom, M. J., technical editor, The Starkey Project: a synthesis of long-term studies of elk and mule deer Reprinted from the 2004 Transactions of the North American Wildlife and Natural Resources Conference, Alliance Communications Group. http://www.fs.fed.us/pnw/pubs/journals/pnw_2004_rowland001.pdf

Response: See response at beginning of document. The new temporary roads will only impact about 3 acres, however this ground will be stabilized, closed and seeded upon completion of the project. The proposed use of temporary roads was thoroughly analyzed in the EA. Discussions of the need for, and impact of, construction of new temporary can be found in each section of the EA. Appendix A contains Project Design Criteria to limit or eliminate sediment from reaching streams.

------Road Construction Opposing View #48 - “The consequences of road construction to wildlife are generally negative. Roads result in increased human access, habitat fragmentation, disturbance, and in some cases direct mortality due to vehicle collisions.”

“Research has documented an 80% decline in grizzly bear habitat use within 1 km of open roads used by motorized vehicles in Montana9. This has been ascribed either to bears avoiding humans or to the selective over- harvest of bears habituated to humans that would otherwise more fully use areas heavily influenced by people.”

Schwartz, Chuck Ph.D. - March 1998 “Wildlife and Roads”

North Nestucca Environmental Assessment Page 35

Appendix E – Attachment 4

The Interagency Forest Ecology Study Team (INFEST) newsletter http://www.sf.adfg.state.ak.us/sarr/forestecology/fsroads.cfm

Response: See response at beginning of document. The new temporary roads will only impact about 3 acres, however this ground will be stabilized, closed and seeded upon completion of the project. The proposed use of temporary roads was thoroughly analyzed in the EA. Discussions of the need for, and impact of, construction of new temporary can be found in each section of the EA. Appendix A contains Project Design Criteria to limit or eliminate sediment from reaching streams.

------Road Construction Opposing View #49 - “The effects of forest roads on hydrology are related to the effects of forest clearing. Most logging requires road access, and the roads often remain after the logging, so there are both short and long-term effects.94 Forest road surfaces are relatively impermeable. Water readily runs over the road surface and associated roadside ditches, often directly to a stream channel, with the net effect of extending channel networks and increasing drainage density.95 In addition to providing conduits for overland flow, forest roads involve slope-cuts and ditching that may intersect the water table and interrupt natural subsurface water movement.96 This diversion of subsurface water may be quantitatively more important than the overland flow of storm water in some watersheds.97 The importance of roads in altering basin hydrology has been underscored in paired-watershed studies and recent modeling studies.98 “ (Pgs. 730 and 731)

Shanley, James B. and BeverleyWemple Ph.D. “Water Quantity and Quality in the Mountain Environment” Vermont Law Review, Vol. 26:717, 2002 http://www.uvm.edu/~bwemple/pubs/shanley_wemple_law.pdf

Appendix E – Attachment 4

Appendix A contains Project Design Criteria to limit or eliminate sediment from reaching streams.

------Road Construction Opposing View #50 - "Roads are often the major source of soil erosion from forested lands (Patric 1976)."

"Generally, soil loss is greatest during and immediately after construction."

Swift Jr., L. W. "Soil losses from roadbeds and cut and fill slopes in the Southern Appalachian Mountains." Southern Journal of Applied Forestry 8: 209-216. 1984. http://cwt33.ecology.uga.edu/publications/403.pdf

Response: See response at beginning of document. The new temporary roads will only impact about 3 acres, however this ground will be stabilized, closed and seeded upon completion of the project. The proposed use of temporary roads was thoroughly analyzed in the EA. Discussions of the need for, and impact of, construction of new temporary can be found in each section of the EA. Appendix A contains Project Design Criteria to limit or eliminate sediment from reaching streams.

------Road Construction Opposing View #51 - “More subtle causes of habitat loss include the construction of roads and power lines. These linear barriers also have been correlated with a decline in neotropical migrant songbirds (Berkey 1993; Boren et al. 1999; Ortega and Capen 2002). Whether by forest conversion or the construction of roads and power lines, fragmentation subdivides habitat into smaller and smaller parcels. The result is an increase of edge habitat, or the boundary between intact forest and surrounding impacted areas. Small forests with large amounts of edge habitat are a hostile landscape for nesting neotropical migratory songbirds. In these areas, songbirds face two great threats: 1) the loss of eggs and nestlings to predators and, 2) parasitism by cowbirds.”

North Nestucca Environmental Assessment Page 37

Appendix E – Attachment 4

Switalski, Adam “Where Have All the Songbirds Gone? Roads, Fragmentation, and the Decline of Neotropical Migratory Songbirds” Wildlands CPR, September 8, 2003 http://www.wildlandscpr.org/node/213

Response: See response at beginning of document. The new temporary roads will only impact about 3 acres, however this ground will be stabilized, closed and seeded upon completion of the project.

------Road Construction Opposing View #52 - “Roads are a widespread and increasing feature of most landscapes. We reviewed the scientific literature on the ecological effects of roads and found support for the general conclusion that they are associated with negative effects on biotic integrity in both terrestrial and aquatic ecosystems. Roads of all kinds have seven general effects: mortality from road construction, mortality from collision with vehicles, modification of animal behavior, alteration of the physical environment, alteration of the chemical environment, spread of exotics, and increased use of areas by humans. Road construction kills sessile and slow-moving organisms, injures organisms adjacent to a road, and alters physical conditions beneath a road. Vehicle collisions affect the demography of many species, both vertebrates and invertebrates; mitigation measures to reduce roadkill have been only partly successful. Roads alter animal behavior by causing changes in home ranges, movement, reproductive success, escape response, and physiological state. Roads change soil density, temperature, soil water content, light levels, dust, surface waters, patterns of runoff, and sedimentation, as well as adding heavy metals (especially lead), salts, organic molecules, ozone, and nutrients to roadside environments. Roads promote the dispersal of exotic species by altering habitats, stressing native species, and providing movement corridors. Roads also promote increased hunting, fishing, passive harassment of animals, and landscape modifications. Not all species and ecosystems are equally affected by roads, but overall the presence of roads is highly correlated with changes in species composition, population sizes, and hydrologic and geomorphic processes that shape aquatic and riparian systems. More experimental research is needed to complement post-hoc correlative studies. Our review underscores the importance to conservation of avoiding construction of new roads in North Nestucca Environmental Assessment Page 38

Appendix E – Attachment 4 roadless or sparsely roaded areas and of removal or restoration of existing roads to benefit both terrestrial and aquatic biota.”

Trombulak, Stephen C. Ph.D. and Christopher A. Frissell Ph.D. “Review of Ecological Effects of Roads on Terrestrial and Aquatic Communities” Conservation Biology, Volume 14, No. 1, Pages 18–30, February 2000 http://www.transwildalliance.org/resources/200922144524.pdf

Response: See response at beginning of document. The new temporary roads will only impact about 3 acres, however this ground will be stabilized, closed and seeded upon completion of the project. The proposed use of temporary roads was thoroughly analyzed in the EA. Discussions of the need for, and impact of, construction of new temporary can be found in each section of the EA. Appendix A contains Project Design Criteria to limit or eliminate sediment from reaching streams.

------Road Construction Opposing View #53 - "Roads are a major contributor to habitat fragmentation because they divide large landscapes into smaller patches and convert interior habitat into edge habitat. As additional road construction and timber harvest activities increase habitat fragmentation across large areas, the populations of some species may become isolated, increasing the risk of local extirpations or extinctions (Noss and Cooperrider 1994)."

"Habitat fragmentation creates landscapes made of altered habitats or developed areas fundamentally different from those shaped by natural disturbances that species have adapted to over evolutionary time (Noss and Cooperrider 1994 in Meffe et al. 1997). Adverse effects of habitat fragmentation to both wildlife populations and species include:

"Increased isolation of populations or species, which leads to:

• Adverse genetic effects; i.e. inbreeding depression (depressed fertility and fecundity, increased natal mortality) and decreased genetic diversity from genetic drift and bottlenecks,

North Nestucca Environmental Assessment Page 39

Appendix E – Attachment 4

• Increased potential for extirpation of localized populations or extinction of narrowly distributed species from catastrophic events such as hurricanes, wildfires or disease outbreaks,

• Changes in habitat vegetative composition, often to weedy and invasive species,

• Changes in the type and quality of the food base,

• Changes in microclimates by altering temperature and moisture regimes,

• Changes in flows of energy and nutrients,

• Changes in the availability of cover and increases edge effect, bringing together species that might otherwise not interact, potentially increasing rates of predation, competition and nest parasitism, and

• Increased opportunities for exploitation by humans, such as poaching or illegal collection for the pet trade."

Watson, Mark L. "Habitat Fragmentation and the Effects of Roads on Wildlife and Habitats." Background and Literature Review 2005. http://www.wildlife.state.nm.us/conservation/habitat_handbook/documents/2004Effectso fRoadsonWil dlifeandHabitats.pdf

North Nestucca Environmental Assessment Page 40

Appendix E – Attachment 4 ------Road Construction Opposing View #54 - "Our analysis also indicated that >70 percent of the 91 species are affected negatively by one or more factors associated with roads."

"Roads in forested areas increase trapping pressures for martens and fishers, resulting in significantly higher captures in roaded versus unroaded areas (Hodgman and others 1994) and in logged versus unlogged areas, in which the difference was again attributed to higher road densities in logged stands (Thompson 1994). Secondary roads also might increase the likelihood that snags and logs will be removed for fuel wood. This could impact fishers, martens and flammulated owls, and also could have a negative effect on the prey base for goshawks (Reynolds and others 1992)."

"An additional, indirect effect of roads is that road avoidance leads to underutilization of habitats that are otherwise high quality."

Wisdom, Michael J., Richard S. Holthausen Ph.D. Barbara C. Wales Ph.D., Christina D. Hargis Ph.D. Victoria A. Saab Ph.D., Danny C. Lee Ph.D. Wendel J. Hann Ph.D. Terrell D. Rich, Mary M. Rowland, Wally J. Murphy, and Michelle R. Eames "Source Habitats for Terrestrial Vertebrates of Focus in the Interior Columbia Basin: Broad-Scale Trends and Management Implications Volume 2 – Group Level Results." USDA Forest Service, PNW-GTR-485, May 2000. http://maps.wildrockies.org/ecosystem_defense/Science_Documents/Wisdom_et_al_20 00/Vol_2a.pdf

Response: See response at beginning of document. The new temporary roads will only impact about 3 acres, however this ground will be stabilized, closed and seeded upon completion of the project. The proposed use of temporary roads was thoroughly analyzed in the EA. Discussions of the need for, and impact of, construction of new temporary can be found in each section of the EA. Appendix A contains Project Design Criteria to limit or eliminate sediment from reaching streams.

North Nestucca Environmental Assessment Page 41

Appendix E – Attachment 4 ------Road Construction Opposing View #55 - “According to the DEIS, the Forest now manages a total of 5,914 miles of roads across the Forest. Scientific literature has established that roads have numerous widespread, pervasive and, if left untreated, long-lasting biological and physical impacts on aquatic ecosystems that continue long after completion of construction. (Angermeier et al. 2004). Roads increase surface water flow, alter runoff patterns, alter streamflow patterns and hydrology, and increase sedimentation and turbidity. Roads are the main source of sediment to water bodies from forestry operations in the United States. (US EPA 2002). Road construction can lead to slope failures, mass wasting and gully erosion. Road crossings can act as barriers to movement for fish and other aquatic organisms, disrupting migration and reducing population viability. (Schlosser and Angermeier 1995). Chemical pollutants that enter streams via runoff, such as salt and lead from road use and management, compound these impacts. Most of these adverse effects are persistent and will not recover or reverse without human intervention. The techniques for road remediation are well established, agreed upon and readily available. (Weaver et al. 2006).” (Pg. 2)

Wright, Bronwen, Policy Analyst and Attorney Pacific Rivers Council Excerpt from a May 11, 2009 letter to the Rogue River-Siskiyou National Forest Travel Management Team http://www.pacificrivers.org/protection-defense/comment- letters/Rogue%20River%20Siskiyou%20TMP%20DEIS.pdf

Response: See response at beginning of document. The new temporary roads will only impact about 3 acres, however this ground will be stabilized, closed and seeded upon completion of the project. The proposed use of temporary roads was thoroughly analyzed in the EA. Discussions of the need for, and impact of, construction of new temporary can be found in each section of the EA. Appendix A contains Project Design Criteria to limit or eliminate sediment from reaching streams.

------

North Nestucca Environmental Assessment Page 42

Appendix E – Attachment 4

Road Construction Opposing View #56 - “Fires do not leave a large road network in place (assuming the blaze was not suppressed otherwise there may be dozer lines, etc.). Logging creates roads that fragment habitat and generally increase human access, both of which affect the use of the land by wildlife. Moreover, roads and logging equipment can become vectors for the dispersal of weeds.”

Wuerthner, George 2008 “Ecological Differences between Logging and Wildfire” http://wuerthner.blogspot.com/2008/12/ecological-differences-between-logging.html

Response: See response at beginning of document. The new temporary roads will only impact about 3 acres, however this ground will be stabilized, closed and seeded upon completion of the project. The proposed use of temporary roads was thoroughly analyzed in the EA. Discussions of the need for, and impact of, construction of new temporary can be found in each section of the EA. Appendix A contains Project Design Criteria to limit or eliminate sediment from reaching streams. The only burning activities potentially associated with this project would be the burning of slash piles at the landings or along major roads.

------Road Construction Opposing View #57 - “Forest fragmentation occurs when large, contiguous blocks of forest are broken up into isolated islands by development, roads, or clearing for agriculture. Just as inbreeding among the royal families of Europe spread hemophilia, forest fragmentation negatively impacts the long term sustainability of both plant and animal communities. Geographic isolation results in inbreeding and diminishes biodiversity.”

Zimmerman, E.A. and P.F. Wilbur “A Forest Divided” New Roxbury Land Trust newsletter, 2004 http://www.ourbetternature.org/forestfrag.htm

Appendix E – Attachment 4

See response at beginning of document. The new temporary roads will only impact about 3 acres, however this ground will be stabilized, closed and seeded upon completion of the project. The proposed use of temporary roads was thoroughly analyzed in the EA. Discussions of the need for, and impact of, construction of new temporary can be found in each section of the EA. Appendix A contains Project Design Criteria to limit or eliminate sediment from reaching streams.

North Nestucca Environmental Assessment Page 44

Appendix E – Attachment #9

Opposing Views Attachment #9

Herbicides Containing Glyphosate should Never be Applied to Areas where Mammals (including humans), Fish, or Birds Might be Present

Background Information Chemical Formula for Glyphosate: N-(phosphonomethyl) glycine

Trade Names for herbicides containing glyphosate: Monsanto discovered and held the patent for glyphosate, and was for many years, the only company that manufactured and sold this herbicide. The patent expired in 2000, however, and already several other companies are making and selling glyphosate formulations.

Some of the current trade names for glyphosate-containing herbicides include:

Roundup Ultra®, Roundup Pro®, Accord®, Honcho®, Pondmaster®, Protocol®, Rascal®, Expedite®, Ranger®, Bronco®, Campain®, Landmaster®, and Fallow Master® manufactured by Monsanto;

Glyphomax® and Glypro® manufactured by Dow AgroSciences;

Glyphosate herbicide manufactured by Du Pont;

Silhouette® manufactured by Cenex/Land O’Lakes;

Rattler® manufactured by Helena;

MirageR® manufactured by Platte;

North Nestucca Environmental Assessment Page 1

Appendix E – Attachment #9

JuryR® manufactured by Riverside/Terra; and

Touchdown® manufactured by Zeneca.

As of November 2001, Rodeo® (previously manufactured by Monsanto) is now being manufactured by Dow AgroSciences and Monsanto is now producing Aquamaster®. ------Recent Toxicity Determinations Conducted by Independent, Unbiased Scientists with nothing to Gain or Loose from Disclosing Accurate Information about Glyphosate-Containing Herbicides

North Nestucca Environmental Assessment Page 2

Appendix E – Attachment #9

Glyphosate safety opposing view #1 - “Chronic Effects of Glyphosate versus Formulations: Throughout this study glyphosate itself showed no chronic effects on developing tadpoles. The tadpoles reared in the formulations Roundup Original® and Transorb® did show significant physical abnormalities. Abnormalities were also found upon exposure to the surfactant POEA. For all endpoints POEA showed practically identical results to the Roundup Original® formulation whereas the same cannot be said for the Transorb® formulation. The surfactant used in the Transorb formulation is not known (being protected as “Trade Secret”), but has been described as a “surfactant blend”. This “surfactant blend” may be responsible for inhibition of metamorphosis, as well as the skewed sex ratio towards female seen in the present study.

Developmental abnormalities induced by Roundup are likely a result of endocrine disruption. The thyroid axis can be greatly affected by corticoids and sex steroids which influence hypothalamic and pituitary control (See Dodd and Dodd, 1976, and Hayes, 1997 for review). Corticoids, sex steroids and prolactin have caused delayed metamorphosis and decreased size by both antagonizing and inhibiting thyroid action (Hayes, 1997). Sex steroid can induced sex reversal and intersex in amphibians and mammals, while low thyroid levels interfere with vitellogenesis. A concentration at which the animals were not effected (NOEC) by The Roundup formulations was not determined by this study.

Howe, Christina Ph.D., Michael Berrill Ph.D., and Bruce D. Pauli 2001 “The Acute and Chronic Toxicity of Glyphosate-Based Pesticides in Northern Leopard Frogs” http://www.trentu.ca/biology/berrill/Research/Roundup_Poster.htm

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

North Nestucca Environmental Assessment Page 3

Appendix E – Attachment #9

Glyphosate safety opposing view #2 - “After spraying, glyphosate herbicides can remain in soils for long periods. The herbicide can drift onto neighbouring fields, streams or hedges. Roundup kills beneficial insects. It wipes out habitat for birds and animals. Glyphosate causes genetic damage to fish. It is "extremely lethal to amphibians", according to assistant professor of biology Rick Relyea at the University of Pittsburgh. It is hazardous to earthworms. Glyphosate reduces nitrogen fixation. Roundup reduces the growth of mycorrhizal fungi. Roundup can increase the spread and severity of plant diseases (see WRM Bulletin no. 18).”

“Glyphosate herbicides can have a range of impacts on human health, including genetic damage, skin tumours, thyroid damage, anaemia, headaches, nose bleeds, dizziness, tiredness, nausea, eye and skin irritation, asthma and breathing difficulties. Several studies have indicated a link between glyphosate herbicides and non-Hodgkin's lymphoma, a type of cancer.”

Lang, Chris “Glyphosate herbicide, the poison from the skies” WRM's bulletin Nº 97, August 2005 http://www.wrm.org.uy/bulletin/97/Glyphosate.html

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #3 - “In California, where there is a mandatory system of reporting pesticide poisoning, Glyphosate is the third most common cause of pesticide illness in farm workers. It is the most common form of reported pesticide poisoning in landscape gardeners.”

“Two separate studies in Sweden have linked exposure to Glyphosate to Hairy Cell Leukemia and Non Hodgkins Lymphoma. These types of cancers were extremely rare, however non-Hodgkins lymphoma is the most rapidly increasing cancer in the Western world. It has risen by 73% in the

North Nestucca Environmental Assessment Page 4

Appendix E – Attachment #9

USA since 1973. Another study has found a higher incidence of Parkinson disease amongst farmers who used herbicides, including glyphosate.”

“Other studies show that Glyphosate and commercial herbicides containing Glyphosate cause a range of cell mutations and damage to cell DNA. These types of changes are usually regarded as precursors to cancer and birth defects.”

“Studies show that exposure to Glyphosate is associated with a range of reproductive effects in humans and other species. Research from Ontario, Canada found that a father's exposure to Glyphosate was linked to an increase in miscarriages and premature births in farm families.”

“Glyphosate caused a decrease in the sperm count of rats and an increase in abnormal and dead sperms in rabbits. Pregnant rabbits exposed to Glyphosate had a decrease in the weight of their babies.”

Leu, Andre “Monsanto's Toxic Herbicide Glyphosate: A Review of its Health and Environmental Effects” Organic Producers Association of Queensland, May 15, 2007 http://www.organicconsumers.org/articles/article_5229.cfm

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #4 - “Symptoms of exposure to glyphosate include eye irritation, blurred vision, skin rashes, burning or itchy skin, nausea, sore throat and difficulty breathing, headache, lethargy, nose bleeds and dizziness.

In lab tests, glyphosate and herbicides containing glyphosate caused genetic damage to human and animal cells.

North Nestucca Environmental Assessment Page 5

Appendix E – Attachment #9

Studies of farmers and other people exposed to glyphosate herbicides link this exposure to increased risks of cancer, miscarriages and attention deficit disorder. Additional laboratory tests have confirmed the results of these studies.

Laboratory evidence indicates that glyphosate herbicides can reduce production of sex hormones.

Studies of glyphosate contamination of water are limited, but new results indicate that it can easily contaminate streams in both agricultural and urban areas.

Glyphosate herbicides cause more off-target damage incidents than all but one other herbicide — 2, 4-D.

Glyphosate herbicides cause genetic damage and harm to the immune system in fish. In frogs, glyphosate herbicides cause genetic damage and abnormal development.”

Long, Cheryl. “Hazards of the World’s Most Common Herbicide” Mother Earth News, October/November 2005 http://www.motherearthnews.com/Organic-Gardening/2005-10-01/Hazards-of-the- Worlds-Most-Common-Herbicide.aspx

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #5 - “Very low doses of some types of the herbicide Roundup can endocrine disruptor the formulations' toxicity may be tied to their "inactive" ingredients rather than the active weed-killing ingredient glyphosate.

North Nestucca Environmental Assessment Page 6

Appendix E – Attachment #9

French scientists report that a number of Roundup formulations tested at very dilute concentrations can alter hormone actions and cause human liver cells to die within 24 hours of treatment.

The toxicity of some of the formulations was independent of how much glyphosate - the active herbicide in Roundup - they contained, suggesting it is other "inert" ingredients that may alone - or in combination with each other and/or the weed killer - assault the cells. This study's results are similar to prior studies - as reported in a recent Environmental Health News article - that find human embryo cells are affected more by the Roundup formulations and an inert ingredient than by the active ingredient.

The levels of Roundup used in this study are similar to what is typically found in food crops or animal feed treated with Roundup. Because of this, it is possible that people, livestock and wildlife may be exposed to levels of the herbicide mix that can damage cells.”

Martin, Negin P. Ph. D. “Monsanto's Roundup More Deadly to Liver Cells than Glyphosate Alone” Organic Consumers Assn., August 18, 2009 http://www.organicconsumers.org/articles/article_18842.cfm

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #6 - “A recent study by eminent oncologists Dr. Lennart Hardell and Dr. Mikael Eriksson of Sweden [1], has revealed clear links between one of the world's biggest selling herbicide, glyphosate, to non-Hodgkin's lymphoma, a form of cancer [2].

In the study published in the 15 March 1999 Journal of American Cancer Society, the researchers also maintain that exposure to glyphosate 'yielded increased risks for NHL.' They stress that with the rapidly increasing use of

North Nestucca Environmental Assessment Page 7

Appendix E – Attachment #9

glyphosate since the time the study was carried out, 'glyphosate deserves further epidemiologic studies.' “

“New Study Links Monsanto's Roundup to Cancer” Organic Consumers Association PRESS RELEASE, June 22, 2009 http://www.organicconsumers.org/Monsanto/glyphocancer.cfm

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #7 - “Safe, effective management and control of established exotic-weeds requires input from and the joint effort of scientists from several distinct disciplines, including biological control specialists, chemical control specialists, wildlife ecologists, animal science specialists, economists, and the public. The basic premise of IPM centers on employing first biological and other non-chemical pest controls, with the use of chemical pesticides only as a last resort. Since pesticide effects on public health and the environment cost the United States a conservatively estimated $9 billion per year, this should be a much welcome change.”

Pimentel, David Ph.D., “True lntegrated Weed Management: Pesticides as a last resort” from a Beyond Pesticides publication, 2004 http://www.beyondpesticides.org/infoservices/pesticidesandyou/Fall%2004/Montanas% 20War%20On%20Weeds.pdf

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

North Nestucca Environmental Assessment Page 8

Appendix E – Attachment #9

------

Glyphosate safety opposing view #8 - “Glyphosate was ranked third worst among all pesticides causing severe health problems among those working in agriculture in the State of California.”

“The application of glyphosate causes the production of phyto-oestrogens in legumes. These phyto-oestrogens mimic the role of hormones in the bodies of mammals who ingest them. Hence, they may cause severe reproductive system disruptions. The data on estrogen-content of the plants submitted by Monsanto does not reflect the real scope of this problem, because the tested plants were grown in a glyphosate-free environment.”

“Possible human health impacts of Monsanto's transgenic glyphosate-resistant soybeans” Third World Network http://www.twnside.org.sg/title/weiz-cn.htm

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #9 - “Glyphosate (N- (phosphonomethyl) glycine, C3H8NO5P), a herbicide, used to control unwanted annual and perennial plants all over the world. Nevertheless, occupational and environmental exposure to pesticides can pose a threat to nontarget species including human beings. Therefore, in the present study, genotoxic effects of the herbicide glyphosate were analyzed by measuring chromosomal aberrations (CAs) and micronuclei (MN) in bone marrow cells of Swiss albino mice. A single dose of glyphosate was given intraperitoneally (i.p) to the animals at a concentration of 25 and North Nestucca Environmental Assessment Page 9

Appendix E – Attachment #9

50 mg/kg b.wt. Animals of positive control group were injected i.p. benzo(a)pyrene (100 mg/kg b.wt., once only), whereas, animals of control (vehicle) group were injected i.p. dimethyl sulfoxide (0.2 mL). Animals from all the groups were sacrificed at sampling times of 24, 48, and 72 hours and their bone marrow was analyzed for cytogenetic and chromosomal damage. Glyphosate treatment significantly increases CAs and MN induction at both treatments and time compared with the vehicle control (P<.05). The cytotoxic effects of glyphosate were also evident, as observed by significant decrease in mitotic index (MI). The present results indicate that glyphosate is clastogenic and cytotoxic to mouse bone marrow.”

Prasad, Sahdeo, Ph.D., Smita Srivastava Ph.D., Madhulika Singh Ph.D., and Yogeshwer Shukla Ph.D. “Clastogenic Effects of Glyphosate in Bone Marrow Cells of Swiss Albino Mice” Journal of Toxicology Volume 2009 (2009), Article ID 308985, 6 pages http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2809416/

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #10 - “PITTSBURGH--The herbicide Roundup® is widely used to eradicate weeds. But a study published today by a University of Pittsburgh researcher finds that the chemical may be eradicating much more than that.

Pitt assistant professor of biology Rick Relyea found that Roundup®, the second most commonly applied herbicide in the United States, is "extremely lethal" to amphibians. This field experiment is one of the most extensive studies on the effects of pesticides on nontarget organisms in a natural setting, and the results may provide a key link to global amphibian declines.

North Nestucca Environmental Assessment Page 10

Appendix E – Attachment #9

In a paper titled "The Impact of Insecticides and Herbicides on the Biodiversity and Productivity of Aquatic Communities," published in the journal Ecological Applications, Relyea examined how a pond's entire community--25 species, including crustaceans, insects, snails, and tadpoles--responded to the addition of the manufacturers' recommended doses of two insecticides--Sevin® (carbaryl) and malathion--and two herbicides--Roundup® (glyphosate) and 2,4-D.

Relyea found that Roundup® caused a 70 percent decline in amphibian biodiversity and an 86 percent decline in the total mass of tadpoles. Leopard frog tadpoles and gray tree frog tadpoles were completely eliminated and wood frog tadpoles and toad tadpoles were nearly eliminated. One species of frog, spring peepers, was unaffected.”

Reeves, Walter. “Roundup®highly lethal to amphibians, finds University of Pittsburgh researcher” The Georgia Gardener, 2009 http://www.walterreeves.com/tools_chemicals/article.phtml?cat=22&id=889

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #11 - “For all nine species of larval anurans, the Kruskal-Wallis analyses detected significant effects of pesticide concentration on mortality (p # 0.002; Fig. 1). The subsequent mean comparisons, using Dunnett’s tests, indicated the lowest concentrations that caused significantly greater mortality than the control (p , 0.05). For two species (bullfrogs and spring peepers), 1 mg a.e./L of glyphosate caused significantly greater mortality than the control. For the remaining seven species (green frogs, leopard frogs, wood frogs, Cascades frogs, American toads, western toads, and gray tree frogs), 2 mg a.e./L of glyphosate was the lowest concentration to cause significantly greater mortality than the control. Based on the probit analyses, the

North Nestucca Environmental Assessment Page 11

Appendix E – Attachment #9

estimated LC5096-h values for the nine species of larval anurans ranged from 0.8 to 2.0 mg a.e./L (Table 2).”

Relyea, Rick A. Ph.D. and Devin K. Jones “The Toxicity of Roundup Original Max to 13 Species of Larval Amphibians” Environmental Toxicology and Chemistry, Vol. 28, No. 9, pp. 2004–2008, 2009 http://www.pitt.edu/news2009/Roundup.pdf

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #12 - “A recent study of Roundup presents new evidence that the glyphosate-based herbicide is far more toxic than the active ingredient alone. The study, published in the June 2005 issue of Environmental Health Perspectives, reports glyphosate toxicity to human placental cells within hours of exposure, at levels ten times lower than those found in agricultural use. The researchers also tested glyphosate and Roundup at lower concentrations for effects on sexual hormones, reporting effects at very low levels. This suggests that dilution with other ingredients in Roundup may, in fact, facilitate glyphosate's hormonal impacts.”

“The evidence presented in the recent study is supported by earlier laboratory studies connecting glyphosate with reproductive harm, including damaged DNA in mice and abnormal chromosomes in human blood. Evidence from epidemiological studies has also linked exposure to the herbicide with increased risk of non-Hodgkin's lymphoma, and laboratory studies have now begun to hone in on the mechanism by which the chemical acts on cell division to cause cancer. A Canadian study has linked glyphosate exposure in the three months before conception with increased risk for miscarriage and a 2002 study in Minnesota connected glyphosate exposure in farm families with increased incidence of attention deficit disorder.”

North Nestucca Environmental Assessment Page 12

Appendix E – Attachment #9

“Rethinking Roundup” Pesticide Action Network North America (PANNA) Update, August 5, 2005 http://www.panna.org/node/466

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #13 - “Our studies show that glyphosate acts as a disruptor of mammalian cytochrome P450 aromatase activity from concentrations 100 times lower than the recommended use in agriculture, and this is noticeable on human placental cells after only 18 hr, and it can also affect aromatase gene expression. It also partially disrupts the ubiquitous reductase activity but at higher concentrations. Its effects are allowed and amplified by at least 0.02% of the adjuvants present in Roundup, known to facilitate cell penetration, and this should be carefully taken into account in pesticide evaluation. The dilution of glyphosate in Roundup formulation may multiply its endocrine effect. Roundup may be thus considered as a potential endocrine disruptor. Moreover, at higher doses still below the classical agricultural dilutions, its toxicity on placental cells could favor some reproduction problems.”

Richard, Sophie Ph.D., Safa Moslemi Ph.D., Herbert Sipahutar, Nora Benachour and Gilles-Eric Seralini Ph.D., 2005 “Differential effects of glyphosate and Roundup on human placental cells and aromatase” Mindfully.org http://www.mindfully.org/Pesticide/2005/Glyphosate-Roundup-Placental24feb05.htm

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

North Nestucca Environmental Assessment Page 13

Appendix E – Attachment #9

------

Glyphosate safety opposing view #14 - “There are serious health implications from the use of this pesticide. There is a long list of reported toxic effects from glyphosate exposure and this Swedish study provides compelling evidence of the links between glyphosate and cancer.”

“Swedish study shows links between glyphosate and cancer” The European NGO Network on Genetic Engineering, 1999 http://www.gene.ch/genet/1999/Jun/msg00018.html

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #15 - “This review suggests that the silvicultural use of glyphosate needs to be re-evaluated with respect to nontarget impacts on amphibians in B.C. In addition, knowledge gaps hinder effective and realistic assessment of these impacts. Glyphosate impacts can be species-specific in amphibians, but acute toxicity values are known for only two native B.C. amphibians (the Wood Frog, Rana sylvatica, and the Leopard Frog, R. pipiens). The impact of glyphosate herbicides on salamander species and on terrestrial stages of amphibians is not well understood. There is insufficient information on the levels of glyphosate contamination in small ephemeral wetlands, which are favoured habitats of amphibians, and which may be exposed to direct overspraying with herbicide under current use guidelines. Although the surfactant in glyphosate herbicides, POEA, has been identified as potentially the primary ingredient causing toxicity to amphibians, the option of using surfactants of lower toxicity has not been assessed. These knowledge gaps need to be addressed so that best management practices can be developed to

North Nestucca Environmental Assessment Page 14

Appendix E – Attachment #9

minimize non-target impacts on amphibians from the use of glyphosate herbicides in forestry.” (Pg. iii)

Govindarajulu, Purnima P. Ph.D. “Literature review of impacts of glyphosate herbicide on amphibians: What risks can the silvicultural use of this herbicide pose for amphibians in B.C.?” British Columbia Ministry of Environment, Wildlife Report No. R-28, June 2008 http://www.llbc.leg.bc.ca/public/pubdocs/bcdocs/442206/finishdownloaddocument.pdf

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #16 - “E. Wider ecological concerns of the genetically engineered soya beans

1. Glyphosate is a broad-spectrum herbicide which will have major impacts on biodiversity (see Greenpeace Report, 1998, and references therein). It kills all plants indiscriminately. This will destroy wild plants as well as insects, birds, mammals and other animals that depend on the plants for food and shelter. In addition, Roundup (Monsanto's formulation of glyphosate) can be highly toxic to fish. Glyphosate also harms earthworms and many beneficial mycorrhizal fungi and other microorganisms that are involved in nutrient recycling in the soil. It is so generally toxic that researchers are even investigating its potential as an antimicrobial (Roberts et al, 1998).”

Affidavit submitted by Mae-Wan Ho Ph.D. , August 12, 1998 http://www.i-sis.org.uk/greenpeace.php?printing=yes

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

North Nestucca Environmental Assessment Page 15

Appendix E – Attachment #9

------

Glyphosate safety opposing view #17 - “Glyphosate was formerly considered relatively non-toxic however there is now a considerable body of evidence for deleterious effects of Roundup, glyphosate and its adjuvants on a wide range of non-target species, including humans.

In 2003 the Danish Government announced unprecedented restrictions on glyphosate following analyses which demonstrated that it had been percolating through the soil and polluting the ground water at a rate 5-times that allowable for drinking water. Subsequently, another study confirmed that both glyphosate and its degradation product amino-methylphosphonic acid (AMPA) can leach through structured soils thereby posing a potential risk to the aquatic environment (5). More recently, an analytical method for glyphosate and AMPA based on liquid chromatography coupled to electrospray tandem mass spectrometry has been applied to water samples previously found to contain glyphosate (6). The glyphosate concentrations in the re-anaylzed samples were found to be 2 – 14 –fold higher than previously (6) suggesting that contamination of groundwater and other aquatic systems by glyphosate may be even greater than previously thought.”

Brennan-Rieder, Denise Ph.D. June, 2008 “PROPOSED COSMETIC PESTICIDE BAN IN PROVINCE OF ONTARIO SCIENTIFIC BASIS FOR BANNING BOTH SALE AND USE OF SYNTHETIC PESTICIDES” http://www.pesticidereform.ca/RoundupDrBrennan-Rieder.PDF

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

North Nestucca Environmental Assessment Page 16

Appendix E – Attachment #9

Glyphosate safety opposing view #18 - “1. Glyphosate was ranked third worst among all pesticides causing severe health problems among those working in agriculture in the State of California.

2. The application of glyphosate causes the production of phyto-oestrogens in legumes. These phyto-oestrogens mimic the role of hormones in the bodies of mammals who ingest them. Hence, they may cause severe reproductive system disruptions. The data on estrogen-content of the plants submitted by Monsanto does not reflect the real scope of this problem, because the tested plants were grown in a glyphosate-free environment (see above).”

Tappeser, Beatrix Ph.D. and Christine von Weizsacker “Possible human health impacts of Monsanto's transgenic glyphosate-resistant soybeans” Third World Network http://www.twnside.org.sg/title/weiz-cn.htm

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #19 - “A recently published study by Italian researchers [3] examined the toxicity of four popular glyphosate based herbicide formulations on human placental cells, kidney cells, embryonic cells and neonate umbilical cord cells and surprisingly found total cell death of each of these cells within 24 hours. The researchers reported several mechanisms by which the herbicides caused the cells to die including: cell membrane rupture and damage, mitochondrial damage and cell asphyxia. Following these findings, the researchers tested G, AMPA and POEA by themselves and concluded that, ‘It is very clear that if G, POEA, or AMPA has a small toxic effect on embryonic cells alone at low levels, the combination of two of them at the same final concentration is significantly ’deleterious’.

North Nestucca Environmental Assessment Page 17

Appendix E – Attachment #9

Although previous researchers have proposed that the supposed ‘inert ingredients’ alter the role of cell membrane disruptors in fish, amphibians, microorganisms [4] and plants [5], independent of G, this study is the first of its kind to report similar findings in human cells. The researchers concluded that, “the proprietary mixtures available on the market could cause cell damage and even death around residual levels to be expected, especially in food and feed derived from R [Roundup] formulation-treated crops” which are pervasive in GM-soya.”

“Toxicity of Glyphosate” Natural Communities magazine, July 16th, 2009 http://naturalcommunitiesmag.com/2009/07/16/gm-soy-destroy-the-earth-and-humans- for-profit/

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010). ------

Glyphosate safety opposing view #20 - “A study released by an Argentine scientist earlier this year reports that glyphosate, patented by Monsanto under the name "Round Up," causes birth defects when applied in doses much lower than what is commonly used in soy fields.

The study was directed by a leading embryologist, Dr. Andres Carrasco, a professor and researcher at the University of Buenos Aires. In his office in the nation's top medical school, Dr. Carrasco shows me the results of the study, pulling out photos of birth defects in the embryos of frog amphibians exposed to glyphosate. The frog embryos grown in petri dishes in the photos looked like something from a futuristic horror film, creatures with visible defects—one eye the size of the head, spinal cord deformations, and kidneys that are not fully developed.”

Trigona, Marie “Study Released in Argentina Puts Glyphosate Under Fire” Znet, July 28, 2009 http://www.zcommunications.org/study-released-in-argentina-puts-glyphosate-under- fire-by-marie-trigona North Nestucca Environmental Assessment Page 18

Appendix E – Attachment #9

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #21 - “Controversy exists around the use of herbicides more commonly used by home gardeners, such as, 2, 4- D and Roundup. A manufacturer supported review of studies found Roundup safe for use around humans while anti-herbicide groups cite studies that find it affecting human embryonic, placental, and umbilical cells in vitro as well as testosterone development in mice.”

Vinje, Eric, “Chemical Quandary: The Problem with Pesticides, Herbicides and Chemical Fertilizer” Planet Natural http://www.planetnatural.com/site/garden-chemicals.html

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #22 - “According to Mr. Carrasco’s research, even tiny quantities of glyphosate could cause embryonic malformations in frogs and thus, by extrapolation, may have implications for humans.

“I suspect the toxicity classification of glyphosate is too low ... in some cases this can be a powerful poison,” Mr Carrasco told the Financial Times in an interview. He says residents near soya-producing areas began reporting problems from 2002, a couple of years after the first big harvests

North Nestucca Environmental Assessment Page 19

Appendix E – Attachment #9

using genetically modified seeds, which were approved for use in Argentina in 1996.

Research by other Argentine scientists and evidence from local campaigners has indicated a high incidence of birth defects and cancers in people living near crop-spraying areas. One study conducted by a doctor, Rodolfo Páramo, in the northern farming province of Santa Fé reported 12 malformations per 250 births, well above the normal rate.”

Weber, Jude and Hal Weitzman “Argentina Pressed to Ban Crop Chemical” The Financial Times, UK, May 29, 2009 http://www.gene.ch/genet/2009/Jun/msg00006.html

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #23 - “Fish and aquatic invertebrates are more sensitive to Roundup than terrestrial organisms.[24] Glyphosate is generally less persistent in water than in soil, with 12 to 60 day persistence observed in Canadian pond water, yet persistence of over a year have been observed in the sediments of ponds in Michigan and Oregon.”[9]

“The EU classifies Roundup as R51/53 Toxic to aquatic organisms, may cause long-term adverse effects in the aquatic environment.”[25]

“Although Roundup is not registered for aquatic uses[26] and studies of its effects on amphibians indicate it is toxic to them,[27] scientists have found that it may wind up in small wetlands where tadpoles live, due to inadvertent spraying during its application. A recent study found that even at concentrations one-third of the maximum concentrations expected in nature, Roundup still killed up to 71 percent of tadpoles raised in outdoor tanks.”[28]

North Nestucca Environmental Assessment Page 20

Appendix E – Attachment #9

“In 1996, Monsanto was accused of false and misleading advertising of glyphosate products, prompting a law suit by the New York State attorney general.[42] Monsanto had made claims that its spray-on glyphosate based herbicides, including Roundup, were safer than table salt and "practically non-toxic" to mammals, birds, and fish.”[43]

“Environmental and consumer rights campaigners brought a case in France in 2001 for presenting Roundup as biodegradable and claiming that it left the soil clean after use; glyphosate, Roundup's main ingredient, is classed by the European Union as "dangerous for the environment" and "toxic for aquatic organisms". In January 2007, Monsanto was convicted of false advertising.[44] The result was confirmed in 2009.”[45]

“On two occasions, the United States Environmental Protection Agency has caught scientists deliberately falsifying test results at research laboratories hired by Monsanto to study glyphosate.[46][47][48] In the first incident involving Industrial Biotest Laboratories, an EPA reviewer stated after finding "routine falsification of data" that it was "hard to believe the scientific integrity of the studies when they said they took specimens of the uterus from male rabbits".[49][50][51] In the second incident of falsifying test results in 1991, the owner of the lab (Craven Labs), and three employees were indicted on 20 felony counts, the owner was sentenced to 5 years in prison and fined 50,000 dollars, the lab was fined 15.5 million dollars and ordered to pay 3.7 million dollars in restitution.[32][52][53] Craven laboratories performed studies for 262 pesticide companies including Monsanto.”

“Monsanto has stated that the studies have been repeated, and that Roundup's EPA certification does not now use any studies from Craven Labs or IBT. Monsanto also said that the Craven Labs investigation was started by the EPA after a pesticide industry task force discovered irregularities.”[54]

Wikipedia, the free encyclopedia, April 10, 2010 http://en.wikipedia.org/wiki/Roundup#Toxicity_2

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

North Nestucca Environmental Assessment Page 21

Appendix E – Attachment #9

------

Glyphosate safety opposing view #24 - “In the study published in the 15 March 1999 Journal of American Cancer Society, the researchers also maintain that exposure to glyphosate ‘yielded increased risks for NHL.’ They stress that with the rapidly increasing use of glyphosate since the time the study was carried out, ‘glyphosate deserves further epidemiologic studies.’ “

DaSilva, Guy MD, “New Study Links Monsanto's Roundup to Cancer” daSilva Institute - Antiaging & Functional Medicine http://www.dasilvainstitute.com/article.asp?artid=18&areacode=ITN

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #25 - “These latest studies confirm a wealth of evidence on the toxicities of glyphosate and Roundup formulations [2] ( Glyphosate Toxic & Roundup Worse , SiS 26), and pinpoint the different sites of action, all of which result in cell death. Epidemiological studies have previously linked glyphosate to spontaneous abortions, non-Hodgkin lymphoma, and multiple myeloma. Laboratory studies showed that glyphosate inhibits transcription in sea urchin eggs and delays development. Brief exposures to glyphosate in rats caused liver damage, and adding the surfactant in Roundup had a synergistic effect, causing greater liver damage. Roundup was also found to be much more lethal to frogs than to weeds, and could have contributed to the global demise of amphibians within the past decades,” [3]

Ho Mae-Win Ph.D. and Brett Cherry “Death by North Nestucca Environmental Assessment Page 22

Appendix E – Attachment #9

Multiple Poisoning, Glyphosate and Roundup” an Institute of Science in Society news release submitted to the USDA November 2, 2009 http://current.com/146im4c

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #26 - “Terrestrial toxicity: A number of species of birds, mammals and beneficial insects suffer population loses through habitat and/or food supply destruction resulting from the use of glyphosate. There are also direct lethal and sublethal effects.

- Birds LD50 (mg/kg body weight) >3851 - Beneficial Insects oral LD50 >100ug/bee. (Cox 1995b; IPCS 1994)

Exposure to freshly applied Roundup killed more than half of three species - a parasitoid wasp, a lacewing, and a ladybug - and more than 80 percent of a predatory beetle. Carabid beetle populations have shown significant decline and slow recovery after glyphosate application (Asterarki et al., 1992; Brust, 1990; Hassan 1988)

Glyphosate adversely affects a number of soil and plant fauna, such as the beneficial predatory mites. However, it prolonged larval survival of the foliar-feeding nematode Nothanguinea by 50% thus increasing the damage done by this pest. (Carlisle & Trevore, 1987; Eijsackers 1985)

Glyphosate may inhibit a number of fungi that decompose dead plant material. Roundup applied to the soil in repeated doses had a substantial adverse effect on the growth rate of earthworms. The reproductive capacity and the total population in the soil could be expected to fall following repeated low doses of biocides. IPCS, however, classifies

North Nestucca Environmental Assessment Page 23

Appendix E – Attachment #9

glyphosate as having low toxicity to earthworms with a No Observed Effects Concentration of 158mg/kg. (Grossbard 1985; IPCS, 1994; Springett and Gray, 1992)

Laboratory studies show significant effects on nitrogen fixation, denitrification and nitrification. (IPCS 1994)

Watts, Meriel and Ronald Macfarlane, “Glyphosate” A Pesticide Action Network - Asia and the Pacific publication, 1999 http://www.poptel.org.uk/panap/pest/pe-gly.htm

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #27 - Regarding your article, Mystery of Disappearing Honeybees (SiS 34), I am a Dutch beekeeper in the east of the Netherlands near Germany, and we see the same problem with bees, as in Belgium, Germany, France and the whole of Europe. In the Netherlands the government is set to give permission for growing GMOs, even in such a very small country. It will cause a lot of damage: bad for biodiversity, the earth, water, air, drinking water and food.

I just lost 68 percent of my bees, and I blame the city workers who sprayed glyphosate twice at the end of October last year. My beehives were 4 metres from the spray, whereas the legal distance is 200 metres. By the beginning of January 2008, the bees started to die. The municipal authorities in villages and small cities spray glyphosate on weeds in public places, gardens and footpaths. In big cities, they would use steam instead of weed killers.

I did a ‘test’ in September 2007 with a bit of glyphosate, and within three or five minutes, the bees were dead. It is very important for the city workers to give people warning when they spray, but they never do.

North Nestucca Environmental Assessment Page 24

Appendix E – Attachment #9

We must study the toxic effects of GMOs and glyphosate, for the sake of the next generation, our children, as well as the sick and old people.

Broek, Hans van den, “Glyphosate kills bees” The Institute of Science in Society Science in Society #38, summer 2008 http://www.i-sis.org.uk/SIS38lettersToTheEditor.php

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #28 - “Glyphosate herbicides can have a range of impacts on human health, including genetic damage, skin tumours, thyroid damage, anaemia, headaches, nose bleeds, dizziness, tiredness, nausea, eye and skin irritation, asthma and breathing difficulties. Several studies have indicated a link between glyphosate herbicides and non-Hodgkin's lymphoma, a type of cancer.

Not surprisingly, considering the amount of money that Monsanto makes from sales of glyphosate products, the company plays down the health risks of glyphosate. Monsanto claims that glyphosate herbicides pose only a "low risk to human health" as long as glyphosate is used "according to label directions". “

Lang, Chris, “Glyphosate herbicide, the poison from the skies” WRM's bulletin Nº 97, August 2005 http://www.wrm.org.uy/bulletin/97/Glyphosate.html

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

North Nestucca Environmental Assessment Page 25

Appendix E – Attachment #9

------

Glyphosate safety opposing view #29 - “A 1999 study, A Case-Control Study of Non-Hodgkin Lymphoma and Exposure to Pesticides, (American Cancer Society, 1999), found that people exposed to glyphosate are 2.7 times more likely to contract non-Hodgkin Lymphoma.

A Finnish study shows that glyphostate decreases the defenses of enzymes of the liver and intestines.18 RoundUp, as a mixture of all its ingredients, has been shown to shut down a powerful antioxidant in the liver that detoxifies harmful compounds so they can be excreted through bile. A paper published in August 2000 shows that RoundUp alters gene expression and inhibits necessary steroid production by disrupting a particular protein expression. In 2002, a paper shows that RoundUp can also affect early cell division processes in embryos.19”

“chemicalWATCH Factsheet” Published by Beyond Pesticides, August 2009 http://www.beyondpesticides.org/pesticides/factsheets/Glyphosate.pdf

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #30 - “The USDA first deregulated Roundup Ready alfalfa in 2005. Internal emails recently obtained by Truthout show that Monsanto worked closely with regulators to edit its original petition to deregulate the alfalfa. One regulator accepted Monsanto's help in conducting the USDA's original environmental assessment of the alfalfa.

North Nestucca Environmental Assessment Page 26

Appendix E – Attachment #9

Farmers and biotech opponents soon filed a lawsuit against the USDA to challenge the initial deregulation. In 2007, a federal court ruled that the USDA did not consider the full environmental impacts of Roundup Ready alfalfa and vacated the agency's decision to deregulate the alfalfa. Monsanto and its allies appealed the decision, and last year, the Supreme Court reversed the lower court's ruling, but ordered the USDA to produce an Environmental Impact Statement (EIS) on the alfalfa before allowing it back into America's fields.

The USDA released a final EIS on Roundup Ready alfalfa in late 2010, and the GE alfalfa was fully deregulated on January 27. The USDA went on to approve two more GE seeds within weeks of the alfalfa decision.

Roundup Ready alfalfa was deregulated just weeks after USDA Secretary Tom Vilsack was pressed by Republican Congressmen, some of whom recently received campaign contributions from Monsanto and the biotech industry, to dump a proposal to geographically isolate Roundup Ready alfalfa from organic and conventional alfalfa and, instead, legalize the GE seed without any government oversight.

The latest lawsuit filed by CFS and its allies argues that the final EIS ignores or downplays the threats Roundup Ready alfalfa poses to conventional alfalfa farms and the environment.”

Ludwig, Mike “Farmers Sue USDA Over Monsanto Alfalfa – Again” Truthout, March 25, 2011 http://www.truth-out.org/farmers-sue-usda-over-monsanto-alfalfa-again68656

Response: Th This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

North Nestucca Environmental Assessment Page 27

Appendix E – Attachment #9

Glyphosate safety opposing view #31 - “JH: You said you had found that very low doses of glyphosate had caused these effects on aromatase. Are they the kind of doses that would be used in practical agriculture in the European Union?”

“GE-S: They are about ten to 100 times less than the doses used by agricultural workers. One has to be cautious because these are in vitro results but we do not want to wait for death when the precautionary principle suggests a need for measures to avoid any harmful effects on foetuses and children.”

“Glyphosate disrupts of human hormones” An interview with Professor Gilles-Eric Seralini Ph.D. Published by ecochem http://www.ecochem.com/ENN_glyphosate(2).html

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #32 - “The December/January 2010 issue of The Organic & Non-GMO Report featured an interview with Robert Kremer, an adjunct professor in the Division of Plant Sciences at the University of Missouri, whose research showed negative environmental impacts caused by glyphosate, the main ingredient in Monsanto's Roundup herbicide, which is used extensively with Roundup Ready genetically modified crops.”

“The widespread use of glyphosate is causing negative impacts on soil and plants as well as possibly animal and human health. These are key findings of Don Huber, emeritus professor of plant pathology, Purdue University.”

North Nestucca Environmental Assessment Page 28

Appendix E – Attachment #9

Roseboro, Ken “Monsanto's Glyphosate Problems: Scientist Warns of Dire Consequences with Widespread Use” The Organic and Non-GMO Report, Posted June 14, 2010 http://www.organicconsumers.org/articles/article_21039.cfm

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #33 - “There is, indeed, direct evidence that glyphosate inhibits RNA transcription in animals at a concentration well below the level that is recommended for commercial spray application. Transcription was inhibited and embryonic development delayed in sea urchins following exposure to low levels of the herbicide and/or the surfactant polyoxyethyleneamine. The pesticide should be considered a health concern by inhalation during spraying [4].”

“New research shows that a brief exposure to commercial glyphosate caused liver damage in rats, as indicated by the leakage of intracellular liver enzymes. In this study, glyphosate and its surfactant in Roundup were also found to act in synergy to increase damage to the liver [5].”

Ho, Mae-Wan Ph.D. and Prof. Joe Cummins Ph.D. “Glyphosate Toxic & Roundup Worse” An Institute of Science in Society publication, 07/03/05 http://www.i-sis.org.uk/GTARW.php

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

North Nestucca Environmental Assessment Page 29

Appendix E – Attachment #9

Glyphosate safety opposing view #34 - “In contrast to malathion, Roundup had strong direct effects on the tadpoles. Roundup caused a 40% reduction in total tadpole survival and biomass. The impact of Roundup (with POEA [polyethoxylated tallow-amine] surfactant) is consistent with previous laboratory studies in a variety of species. Mann and Bidwell (1999) estimated LC5048h at 3.9 to 15.5 mg active ingredient (AI)/L in four species of Australian tadpoles while Perkins et al. (2000) estimated LC5096h values of 12.4 mg AI/L in the African clawed frog (Xenopus laevis). In both studies, it was clear that the high toxicity of Roundup was caused by the POEA surfactant and not from the active ingredient (glyphosate). Lajmanovich et al. (2003) examined the impact of Kleeraway (another formulation of glyphosate that contains the POEA surfactant) on a South American tadpole (Scinax nasicus) and found an LC5048h of 1.74 mg AI/L. In North American tadpoles (Bufo americanus, Rana pipiens, and R. clamitans), Edginton et al. (2004) found LC5096h of 1.5–4.7 mg AI/l using Vision (a formulation that also includes the POEA surfactant). For the three species used in our mesocosm experiment, Relyea (2005b) found LC5016d values of 1.4 mg AI/L for gray tree frogs, 2.5 mg AI/L for American toads, and 2.5 mg AI/L for leopard frogs. All of this suggests that Roundup with the POEA surfactant can cause substantial mortality in larval amphibians.”

Relya, Rick A. Ph.D., Nancy Schoeppner and Jason T. Hoverman, “Pesticides and Amphibians: The Importance of Community Context” Ecological Applications, 15(4), July 1, 2005, pp. 1125–1134 http://www.mindfully.org/Pesticide/2005/Roundup-Amphibians-Community1jul05.htm

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #34 - “The decline in amphibians across the globe has sparked a search for the causes, and recent evidence suggests a connection with pesticides. However, for most pesticides, tests

North Nestucca Environmental Assessment Page 30

Appendix E – Attachment #9

on amphibians are rare and conducted only for short durations (1 to 4 days) and without natural stressors. Recent studies have discovered that the stress of predator cues in the water can make insecticides much more lethal to larval amphibians, but it is unknown whether this phenomenon can be generalized to other types of pesticides. Using six species of North American amphibian larvae (Rana sylvatica, R. pipiens, R. clamitans, R. catesbeiana, Bufo americanus, and Hyla versicolor), I examined the impact of a globally common herbicide (Roundup) on the survival of tadpoles for 16 days with and without the chemical cues emitted by predatory newts (Notophthalmus viridescens). LC5016-d estimates varied from 0.55 to 2.52 mg of active ingredient (AI)/L, which was considerably lower than the few previous studies using Roundup (1.5 to 15.5 mg AI/L). Moreover, in one of the six species tested (R. sylvatica), the addition of predatory stress made Roundup twice as lethal. This discovery suggests that synergistic interactions between predatory stress and pesticides may indeed be a generalizable phenomenon in amphibians that occurs with a wide variety of pesticides.”

Relyea, R.A. Ph.D. “The Lethal Impacts of Roundup and Predatory Stress on Six Species of North American Tadpoles” Archives of Environmental Contamination and Toxicology v 48, n. 3, April 1, 2005 http://www.mindfully.org/Pesticide/2005/Roundup-Tadpoles-Relyea1apr05.htm

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #35 - “Species richness was reduced by 15% with Sevin, 30% with malathion, and 22% with Roundup, whereas 2,4-D had no effect. Both insecticides reduced zooplankton diversity by eliminating cladocerans but not copepods (the latter increased in abundance). The insecticides also reduced the diversity and biomass of predatory insects and had an apparent indirect positive effect on several species of tadpoles, but had no effect on snails. The two herbicides had no

North Nestucca Environmental Assessment Page 31

Appendix E – Attachment #9

effects on zooplankton, insect predators, or snails. Moreover, the herbicide 2,4-D had no effect on tadpoles. However, Roundup completely eliminated two species of tadpoles and nearly exterminated a third species, resulting in a 70% decline in the species richness of tadpoles. This study represents one of the most extensive experimental investigations of pesticide effects on aquatic communities and offers a comprehensive perspective on the impacts of pesticides when nontarget organisms are examined under ecologically relevant conditions.”

Relyea, R.A. Ph.D. “The Impact of Insecticides and Herbicides on the Biodiversity and Productivity of Aquatic Communities” Ecological Applications v 15, n. 2, April 1, 2005 http://www.mindfully.org/Pesticide/2005/Roundup-Aquatic- Communities1apr05.htm

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #36 - “He is joined in his conclusions by Robert Bellé, from the National Center for Scientific Research (CNRS) biological station in Roscoff (Finistere), whose team has been studying the impact of glyphosate formulations on sea-urchin cells for several years. This recognized model for the study of early stages of cancer genesis earned Tim Hunt the 2001 Nobel Prize in medicine. In 2002, the Finisterian team had shown that Roundup acted on one of the key stages of cellular division.

The Breton team has recently demonstrated (Toxicological Science, December 2004) that a "control point" for DNA damage was affected by Roundup, while glyphosate alone had no effect. "We have shown that it's a definite risk factor, but we have not evaluated the number of cancers potentially induced, nor the time frame within which they would declare themselves," the researcher acknowledges. A sprayed droplet could affect North Nestucca Environmental Assessment Page 32

Appendix E – Attachment #9

thousands of cells. On the other hand, "the concentration in water and fruits is lower, which is rather reassuring."

Morin, Herve “Roundup Doesn’t Poison Only Weeds” Le Monde (France) March 12, 2005 http://www.mindfully.org/GE/2005/Roundup-Poison12mar05.htm

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #37 - “We have evaluated the toxicity of four glyphosate (G)-based herbicides in Roundup (R) formulations, from 105 times dilutions, on three different human cell types. This dilution level is far below agricultural recommendations and corresponds to low levels of residues in food or feed. The formulations have been compared to G alone and with its main metabolite AMPA or with one known adjuvant of R formulations, POEA. HUVEC primary neonate umbilical cord vein cells have been tested with 293 embryonic kidney and JEG3 placental cell lines. All R formulations cause total cell death within 24 h, through an inhibition of the mitochondrial succinate dehydrogenase activity, and necrosis, by release of cytosolic adenylate kinase measuring membrane damage. They also induce apoptosis via activation of enzymatic caspases 3/7 activity. This is confirmed by characteristic DNA fragmentation, nuclear shrinkage (pyknosis), and nuclear fragmentation (karyorrhexis), which is demonstrated by DAPI in apoptotic round cells. G provokes only apoptosis, and HUVEC are 100 times more sensitive overall at this level. The deleterious effects are not proportional to G concentrations but rather depend on the nature of the adjuvants. AMPA and POEA separately and synergistically damage cell membranes like R but at different concentrations. Their mixtures are generally even more harmful with G. In conclusion, the R adjuvants like POEA change human cell permeability and amplify toxicity induced already by G, through apoptosis and necrosis. The real threshold of G toxicity must take into account the presence of

North Nestucca Environmental Assessment Page 33

Appendix E – Attachment #9

adjuvants but also G metabolism and time-amplified effects or bioaccumulation. This should be discussed when analyzing the in vivo toxic actions of R. This work clearly confirms that the adjuvants in Roundup formulations are not inert. Moreover, the proprietary mixtures available on the market could cause cell damage and even death around residual levels to be expected, especially in food and feed derived from R formulation-treated crops.”

Benachour, Nora and Gilles-Eric S ralini “Glyphosate Formulations Induce Apoptosis and Necrosis in Human Umbilical, Embryonic, and Placental Cells” Chem. Res. Toxicol., 2009, 22 (1), pp 97–105 DOI: 10.1021/tx800218n Publication Date (Web): December 23, 2008 http://pubs.acs.org/doi/abs/10.1021/tx800218n

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #38 - “We exposed human liver HepG2 cells, a well-known model to study xenobiotic toxicity, to four different formulations and to glyphosate, which is usually tested alone in chronic in vivo regulatory studies. We measured cytotoxicity with three assays (Alamar Blue®, MTT, ToxiLight®), plus genotoxicity (comet assay), anti-estrogenic (on ERα, ERβ) and anti-androgenic effects (on AR) using gene reporter tests. We also checked androgen to estrogen conversion by aromatase activity and mRNA. All parameters were disrupted at sub- agricultural doses with all formulations within 24 h. These effects were more dependent on the formulation than on the glyphosate concentration. First, we observed a human cell endocrine disruption from 0.5 ppm on the androgen receptor in MDA-MB453-kb2 cells for the most active formulation (R400), then from 2 ppm the transcriptional activities on both estrogen receptors were also inhibited on HepG2. Aromatase transcription and activity were disrupted from 10 ppm. Cytotoxic effects started at 10 ppm with Alamar Blue assay (the most sensitive), and DNA damages at 5 ppm.

North Nestucca Environmental Assessment Page 34

Appendix E – Attachment #9

A real cell impact of glyphosate-based herbicides residues in food, feed or in the environment has thus to be considered, and their classifications as carcinogens/mutagens/reprotoxics is discussed.”

Gasnier, Céline Ph.D., Coralie Dumont Ph.D., Nora Benachour Ph.D., Emilie Clair Ph.D., Marie-Christine Chagnon Ph.D. and Gilles-Eric Séralini Ph.D. “Glyphosate- based herbicides are toxic and endocrine disruptors in human cell lines” Available online 17 June 2009 http://www.sciencedirect.com/science?_ob=ArticleURL&_udi=B6TCN-4WJBC0R- 1&_user=10&_coverDate=08%2F21%2F2009&_rdoc=1&_fmt=high&_orig=search&_ori gin=search&_sort=d&_docanchor=&view=c&_searchStrId=1591140451&_rerunOrigin=s cholar.google&_acct=C000050221&_version=1&_urlVersion=0&_userid=10&md5=2adf d01803a911a1ff1eda15564d337e&searchtype=a

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #39 - “In the study published in the 15 March 1999 Journal of American Cancer Society, the researchers also maintain that exposure to glyphosate ‘yielded increased risks for NHL.’ They stress that with the rapidly increasing use of glyphosate since the time the study was carried out, ‘glyphosate deserves further epidemiologic studies.’ “

"New Study Links World's Biggest Selling Pesticides to Cancer Swedish Study Finds Exposure to Glyphosate and MCPA Increases Risk for Non-Hodgkin's Lymphoma" Press Release PAN AP, June 21, 1999 http://www.mindfully.org/Pesticide/Monsanto-Roundup-Glyphosate.htm

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

North Nestucca Environmental Assessment Page 35

Appendix E – Attachment #9

------

Glyphosate safety opposing view #40 - “There is, indeed, direct evidence that glyphosate inhibits RNA transcription in animals at a concentration well below the level that is recommended for commercial spray application. Transcription was inhibited and embryonic development delayed in sea urchins following exposure to low levels of the herbicide and/or the surfactant polyoxyethyleneamine. The pesticide should be considered a health concern by inhalation during spraying [4].”

New research shows that a brief exposure to commercial glyphosate caused liver damage in rats, as indicated by the leakage of intracellular liver enzymes. In this study, glyphosate and its surfactant in Roundup were also found to act in synergy to increase damage to the liver [5].

Three recent case-control studies suggested an association between glyphosate use and the risk of non-Hodgkin lymphoma [6-8]; while a prospective cohort study in Iowa and North Carolina that includes more than 54 315 private and commercial licensed pesticide applicators suggested a link between glyphosate use and multiple myoeloma [9]. Myeloma has been associated with agents that cause either DNA damage or immune suppression.”

Ho, Mae-Wan Ph.D. and Prof. Joe Cummins “Glyphosate Toxic & Roundup Worse” Institute of Science in Society report 07/03/05 http://www.i-sis.org.uk/GTARW.php

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

North Nestucca Environmental Assessment Page 36

Appendix E – Attachment #9

Glyphosate safety opposing view #41 - “New scientific studies link Roundup (glyphosphate), the most widely used herbicide in the world, to a host of health risks, such as cancer, miscarriages and disruption of human sex hormones.”

Long, Cheryl “Hazards of the World’s Most Common Herbicide” Mother Earth News, October/November 2005 http://www.motherearthnews.com/Organic-Gardening/2005-10-01/Hazards-of-the- Worlds-Most-Common-Herbicide.aspx

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #42 - “A series of studies has found that farmers develop non-Hodgkin's lymphoma more often than other people do, but until now it has been difficult for scientists to explain why this increase occurs. New research, however, shows that exposure to the herbicide glyphosate, commonly sold as Roundup, is one explanation. The study was published in 2003 by researchers at the National Cancer Institute, the University of Nebraska Medical Center, Kansas University Medical Center, and the University of Iowa College of Medicine.”

Study Links Herbicide use and Cancer A Northwest Coalition for Alternatives to Pesticides publication, 2010 http://www.pesticide.org/the-buzz/study-links-herbicide-use-and-cancer

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

North Nestucca Environmental Assessment Page 37

Appendix E – Attachment #9

Glyphosate safety opposing view #43 - “5. SUMMARY OF GLYPHOSATE IMPACTS ON AMPHIBIANS This summary is derived almost entirely from toxicological studies on tadpoles and late-stage anuran embryos. The impact of glyphosate herbicides on other amphibians and other life stages is virtually unknown.

• Recent studies have shown that tadpoles are one of the vertebrate groups most sensitive to the toxicity effects of most commercial formulations of glyphosate herbicides, including Vision.

• The estimated LC50 values for some species of amphibians are at or below the expected environmental concentration (EEC) of 1.43 mg a.e./L of Vision (Table 1). Most LC50 values are calculated from experimental durations of 24 to 96 hours, but at low concentrations death may not occur until after 96 hours. This suggests that amphibians may be even more sensitive than the published LC50 values suggest.

• Although LC50 values have traditionally been used to set hazard quotients, recent risk analysis methodology suggests that LC10 values are better for judging population-level impacts of environmental contaminants (Solomon and Thompson 2003). In at least one published study, all North American amphibian larvae tested to date had LC10 values estimated at or below the EEC for Vision, especially at pH higher than 7.0.

• In addition to direct mortality effects, glyphosate herbicides also cause sublethal effects, including reduced growth and development rates, behavioural impairment, and genomic effects. The population- level consequences of these sublethal effects have not been tested under field conditions. For example, reduced growth and development rates, which have been documented under laboratory conditions, could translate into increased mortality if amphibian larvae are unable to metamorphose before the end of the season. Similarly, impaired behavioural response to prodding under laboratory conditions could translate to increased susceptibility to predators under field conditions.

North Nestucca Environmental Assessment Page 38

Appendix E – Attachment #9

• Impacts have been shown to be synergistically enhanced by interaction with some environmental factors. Of particular concern is that the effects of glyphosate herbicide may be greater when pond pH is 7 or higher (Edginton et al. 2004a). Amphibians in general avoid acidic conditions, preferring to breed in ponds with higher pH, which could increase their vulnerability to glyphosate herbicide impacts.

• More detailed toxicological studies indicate that the toxicity of glyphosate herbicides arises not from the active ingredient, glyphosate, but from the surfactant, POEA.

• POEA is thought to interfere with the synthesis of collagen and to reduce the branchial cartilage in the gills of tadpoles and to cause lysis of gill epithelial cells in fish. This could result in loss of osmotic stability and asphyxiation. The toxic mode of action in terrestrial, postmetamorphic amphibians is not known at formulations without POEA surfactants, such as Rodeo, and formulations with other surfactants, such as Roundup Biactive, have reduced toxicity to amphibians. (pg. 31)

Govindarajulu, Purnima P. Ph.D., “Literature review of impacts of glyphosate herbicide on amphibians: What risks can the silvicultural use of this herbicide pose for amphibians in B.C.?” British Columbia Ministery of the Environment, Wildlife Report No. R-28, June 2008 http://www.llbc.leg.bc.ca/public/pubdocs/bcdocs/442206/finishdownloaddocument.pdf

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #44 - “Chronic Effects of Glyphosate versus Formulations: Throughout this study glyphosate itself showed no chronic effects on developing tadpoles. The tadpoles reared in the formulations Roundup Original® and Transorb® did show significant

North Nestucca Environmental Assessment Page 39

Appendix E – Attachment #9

physical abnormalities. Abnormalities were also found upon exposure to the surfactant POEA. For all endpoints POEA showed practically identical results to the Roundup Original® formulation whereas the same cannot be said for the Transorb® formulation. The surfactant used in the Transorb formulation is not known (being protected as “Trade Secret”), but has been described as a “surfactant blend”. This “surfactant blend” may be responsible for inhibition of metamorphosis, as well as the skewed sex ratio towards female seen in the present study. Developmental abnormalities induced by Roundup are likely a result of endocrine disruption. The thyroid axis can be greatly affected by corticoids and sex steroids which influence hypothalamic and pituitary control (See Dodd and Dodd, 1976, and Hayes, 1997 for review). Corticoids, sex steroids and prolactin have caused delayed metamorphosis and decreased size by both antagonizing and inhibiting thyroid action (Hayes, 1997). Sex steroid can induced sex reversal and intersex in amphibians and mammals, while low thyroid levels interfere with vitellogenesis. A concentration at which the animals were not effected (NOEC) by The Roundup formulations was not determined by this study.”

Christina Howe, Ph.D., Michael Berrill Ph.D., and Bruce D. Pauli “The Acute and Chronic Toxicity of Glyphosate-Based Pesticides in Northern Leopard Frogs” Amphibian Ecology and Pathobiology, August 14, 2002 http://www.trentu.ca/biology/berrill/Research/Roundup_Poster.htm

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #45 - “Concern #1: Roundup is only intended for terrestrial use, not aquatic use While it may be intended for terrestrial use, there is overwhelming evidence that Roundup gets into aquatic habitats, typically through inadvertent (or unavoidable) aerial overspray (Newton et al. 1984, Goldsborough and Brown 1989, Feng et al. 1990, Thompson et al. 2004). To determine the

North Nestucca Environmental Assessment Page 40

Appendix E – Attachment #9

effect on amphibians, Relyea (2005a) simulated a direct overspray of a small wetland using pond mesocosms (1000-liter tanks). The result was widespread death for many species and the death rate was much higher than expected based on previous studies of Roundup. It is relatively common knowledge that Roundup should not be applied to large ponds and lakes, but it seems to be much less commonly appreciated that many amphibians are not produced in large ponds and lakes due to predation by fish. Instead, small temporary wetlands that may appear to be unimportant and only have 6" of water can, in fact, produce thousands of tadpoles. These small, temporary pools are either not avoided or not avoidable by aerial pesticide applications.

Moreover, Roundup is not only lethal to amphibian larvae. New studies have found that Roundup can be highly lethal to terrestrial amphibians as well (Relyea 2005c).”

“Concern #2: The application rate of Roundup was 7 times too high The application rate of 6 ounces per 300 square feet came directly from the label of Monsanto's "Roundup Weed and Grass Killer". What Monsanto is claiming is that the application rate for this Roundup is higher than their listed application rate for other forms of Roundup. However, both application rates come from Monsanto. Moreover, it is well accepted by Monsanto and the applicators of Roundup that some types of weeds require up to four times the recommended application rate to be effective.”

“Concern #4: A past risk assessment has shown that Roundup poses minimal risk to amphibians The risk assessment was conducted by Giesy et al. (2000), in cooperation with Monsanto, and the assessment was based on the available data at that time. For amphibians, data only existed for four species of Australian tadpoles and one species of African frog. From these studies, the LC50 estimates (the amount of pesticide needed to kill 50% of the animals) were 4 to 16 mg a.i./L (Mann and Bidwell 1999, Perkins et al. 2000).

More recent LC50 laboratory data for North American amphibians demonstrate that North American amphibians are much more sensitive; LC50 values range from 0.5 to 4.7 mg a.i./L (Edginton et al. 2004, Relyea 2005b). According to U.S. Fish and Wildlife classifications, this means that North Nestucca Environmental Assessment Page 41

Appendix E – Attachment #9

Roundup can no longer be considered slightly to moderately toxic, but rather moderately to highly toxic to North American amphibians.”

Relya, Rick Ph.D. “Roundup is Highly Lethal” Dr. Relya Responds to Monsanto’s Concerns Regarding Recent Published Study Mindfully.org, April 1, 2005 http://www.mindfully.org/GE/2005/Relyea-Monsanto-Roundup1apr05.htm

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #46 - “Based on the best available information, the Agency makes a Likely to Adversely Affect determination for the CRLF from the use of glyphosate. Additionally, the Agency has determined that there is the potential for modification of CRLF designated critical habitat from the use of the chemical.

This assessment indicates that direct effects to the terrestrial-phase CRLF eating broadleaf plants, small insects and small herbivorous mammals on a dietary-basis may be at risk following chronic exposure to glyphosate at application rates of 7.5 lb a.e./A and above (forestry, areas with impervious surfaces and rights of way). In addition, for one particular formulation (Registration No. 524-424), medium and large-sized CRLF’s eating small herbivorous mammals on a dose-basis may be at risk following acute exposure at an application rate of 5.5 lb formulation/A (industrial outdoor uses). At the lowest application rate of 1.1 lb formulation/A, there is potential risk to medium-sized CRLF’s eating small herbivorous mammals on a dose-basis (ornamental lawns and turf).” (Pg. 173)

Carey, Stephen, Tanja Crk, Colleen Flaherty, Pamela Hurley, James Hetrick, Keara Moore, and Silvia C. Termes “Risks of Glyphosate Use to Federally Threatened California Red-legged Frog (Rana aurora draytonii) -- Pesticide Effects Determination”

North Nestucca Environmental Assessment Page 42

Appendix E – Attachment #9

A Report by the Environmental Fate and Effects Division Office of Pesticide Programs Washington, D.C. 20460, October 17, 2008 http://www.epa.gov/espp/litstatus/effects/redleg-frog/glyphosate/determination.pdf

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #47 - “Glyphosate is the poster child for the global pesticide controversy due to its place in the ongoing debate over mega-farming and genetically engineered crops. Industry scientists say it's one of the safest herbicides in the world, while independent scientists have discovered potential links among the widespread use of glyphosate-based herbicides and non-Hodgkin's lymphoma, birth defects and even attention deficit disorder. Research also shows that additives like surfactants in glyphosate in herbicides like Roundup are more toxic than glyphosate itself and can increase the toxicity of glyphosate.”

“The war on invasive species is a war on a fact of life. Humans have caused or exacerbated these species "invasions" by changing habitats and introducing species to new areas, and now we are trying to turn back the clock in an attempt to prevent nature from taking its new course. As long as people attempt to dominate the land, extract its resources and shape it to their liking, there will be money to be made and dramatic consequences for other livings things. The search for a balance between supporting our collective desire to prosper and a healthy natural world is sure to spark more heated debates for years to come.”

Ludwig, Mike “Special Investigation: The Pesticides and Politics of America's Eco- War” Published by Truthout, June 9, 2011 http://www.truth-out.org/pesticides-and-politics-americas-eco-war/1307539754

North Nestucca Environmental Assessment Page 43

Appendix E – Attachment #9

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #48 - “We also observed a gradual loss of the r3 and r5domains in embryos treated with GBH (compare Figure 5E,Fwith D), which resembles the results observed in frog embryosin the krox-20 domains (Figures 1B and 2E). Hybridization withthe c-shh probe showed that, as in Xenopus, the prechordalmesoderm domain is preferentially lost in GBH-treated chickembryos (compare Figure 5G with H,I). As the GBH concentra-tion increases, the expression along the embryonic dorsal midlinealso gradually disappears (Figure 5H,I).Therefore, our experiments with chick embryos further extendconclusions from studies about the teratogenic effects of GBHin amphibians to other vertebrate species.DiscussionThe results presented above argue that both GBH andglyphosate itself interfere with key molecular mechanismsregulating early development in both Xenopus and chickenembryos, leading to congenital malformations. Sublethal dosesof the herbicide (430 µM of glyphosate in 1/5000 dilutions ofGBH) and injections leading to a final concentration of 8 to 12µM of glyphosate in the injected side of the embryo weresufficient to induce serious disturbances in the expression ofslug, otx2, and shh. These molecular phenotypes were correlatedwith a disruption of developmental mechanisms involving theneural crest, embryonic dorsal midline formation, and cephalicpatterning. Because glyphosate penetration through the cellmembrane requires facilitation by adjuvants present in commercial formulations (5, 6), we tested the effects of glyphosatealone by directly microinjecting it into Xenopus embryos. Thesimilarity of the phenotypes obtained in both situations suggeststhat they are attributable to the active principle of GBH andnot to the adjuvants.We will discuss our results in the following context: (1) thecorrelation of our phenotypes with those observed in animalmodels with an impairment of RA signaling or deficits in theexpression of critical genes that control embryonic development;(2) the probable mechanisms underlying the phenotypes inducedby GBH and glyphosate; (3) possible correlations with clinicalcases North Nestucca Environmental Assessment Page 44

Appendix E – Attachment #9

of human offspring exhibiting malformations in zonesexposed to GBH.Misregulation of RA, shh, and otx2 Are Involved inCephalic Malformations and Neural Crest-Derived Pheno-types Reminiscent of the Effects of GBH and Glyphosate.The phenotypes obtained after GBH treatments or injections ofglyphosate alone are strikingly reminiscent of those observedas a consequence of an excess of RA signaling in vertebratesand humans. Acute or chronic increase of RA levels leads toteratogenic effects during human pregnancy and in experimentalFigure 4. Phenotype induced by GBH is mediated by an increase ofRA signaling (A). Analysis of RA activity with the reporter plasmidRAREZ. All embryos were injected with the reporter plasmid RAREZ,except for uninjected controls, and left untreated or were treated asindicated in the figure until stage 14- 15, when they were processed.Results are expressed as arbitrary luminiscence units per µg of protein.A two-tailed t test was employed to analyze the significance in thedifference of the means. ** p < 0.01; *** p < 0.0001. (B-G) WMISHfor shh and otx2 at tailbud stages. (B) Control embryo. Notochord (n);floor plate (fp); brain (space between bars), eye (arrowhead). (C)Embryo treated with 1/5000 GBH manifesting microcephaly (spacebetween bars), reduced eyes (arrowhead), diminished Shh signalingfrom the prechordal mesoderm (arrow), and shortened A-P axis (78%,n)9).” (Pg. 6)

Alejandra Paganelli, Victoria Gnazzo, Helena Acosta, Silvia L. López, and Andrés E. Carrasco “Glyphosate-Based Herbicides Produce Teratogenic Effects on Vertebrates by Impairing Retinoic Acid Signaling” Publicado por NOGAL DE VIDA, May 20, 2010 http://nogaldevida.blogspot.com/2010/08/glyphosate-based-herbicides-produce.html

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #49 - “Although there is only a handful of studies on the safety of GM soybeans, there is considerable evidence

North Nestucca Environmental Assessment Page 45

Appendix E – Attachment #9

that glyphosate—especially in conjunction with the other ingredients in Roundup—wreaks havoc with the endocrine and reproductive systems. ‘I think the concentration of glyphosate in the soybeans is the likely cause of the problem,’ says Ewen.

Glyphosate throws off the delicate hormonal balance that governs the whole reproductive cycle. ‘It’s an endocrine buster,’ says Ewen, ‘that interferes with aromatase, which produces estrogen.’ Aromatase is required by luteal cells to produce hormones for the normal menstrual cycle, but it’s those luteal cells that have shown considerable alterations in the rats fed GM soybeans.

Glyphosate is also toxic to the placenta, the organ which connects the mother to the fetus, providing nutrients and oxygen, and emptying waste products. In a 2009 French study at the University of Caen, scientists discovered that glyphosate can kill the cells in the outer layer of the human placenta (the trophoblast membrane), which in turn can kill the placenta. The placenta cells are, in Ewen’s words, ‘exquisitely sensitive to glyphosate.’ Only 1/500th the amount needed to kill weeds was able to kill the cells. The amount is so small, according to the study authors the ‘residual levels to be expected, especially in food and feed derived from R[oundup] formulation-treated crops’ could be enough to ‘cause cell damage and even [cell] death.’ Furthermore, the effect of the toxin may bioaccumulate, growing worse with repeated consumption from Roundup laden foods.

Smith, Jeffery “Genitically Modified Soy Diets Lead and Uterus Changes in Rats” foodconsumer.org, September 22, 2010 http://www.foodconsumer.org/newsite/Safety/gmo/genetically_modified_soy_diets_0910 100128.html

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

North Nestucca Environmental Assessment Page 46

Appendix E – Attachment #9

Glyphosate safety opposing view #50 - “Such reports gained further traction after an Argentine government scientist, Andres Carrasco conducted a study, "Glyphosate-Based Herbicides Produce Teratogenic Effects on Vertebrates by Impairing Retinoic Acid Signaling" in 2009.

The study, published in the journal Chemical Research in Toxicology in 2010, found that glyphosate causes malformations in frog and chicken embryos at doses far lower than those used in agricultural spraying. It also found that malformations caused in frog and chicken embryos by Roundup and its active ingredient glyphosate were similar to human birth defects found in genetically modified soy-producing regions.

"The findings in the lab are compatible with malformations observed in humans exposed to glyphosate during pregnancy," wrote Carrasco, director of the Laboratory of Molecular Embryology at the University of Buenos Aires. "I suspect the toxicity classification of glyphosate is too low.” “

“Fagan told HuffPost that among developmental biologists who are not beholden to the chemical industry or the biotechnology industry, there is strong recognition that Carrasco’s research is credible.”

"For me as a scientist, one of the reasons I made the effort to do this research into the literature was to really satisfy the question myself as to where the reality of the situation lies,” he added. “Having thoroughly reviewed the literature on this, I feel very comfortable in standing behind the conclusions Professor Carrasco came to and the broader conclusions that we come to in our paper.”

“We can’t figure out how regulators could have come to the conclusions that they did if they were taking a balanced took at the science, even the science that was done by the chemical industry itself.”

Graves, Lucia. “Roundup: Birth Defects Caused By World's Top-Selling Weedkiller, Scientists Say” by Lucia Graves Published on Friday, June 24, 2011 by Huffington Post http://www.commondreams.org/headline/2011/06/24-4

North Nestucca Environmental Assessment Page 47

Appendix E – Attachment #9

Response: Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #51 - "This study was just routine," said Russian biologist Alexey V. Surov, in what could end up as the understatement of this century. Surov and his colleagues set out to discover if Monsanto's genetically modified (GM) soy, grown on 91% of US soybean fields, leads to problems in growth or reproduction. What he discovered may uproot a multi-billion dollar industry.

After feeding hamsters for two years over three generations, those on the GM diet, and especially the group on the maximum GM soy diet, showed devastating results. By the third generation, most GM soy-fed hamsters lost the ability to have babies. They also suffered slower growth, and a high mortality rate among the pups.

And if this isn't shocking enough, some in the third generation even had hair growing inside their mouths—a phenomenon rarely seen, but apparently more prevalent among hamsters eating GM soy.”

“In addition to the GMOs, it could be contaminants, he said, or higher herbicide residues, such as Roundup. There is in fact much higher levels of Roundup on these beans; they're called "Roundup Ready." Bacterial genes are forced into their DNA so that the plants can tolerate Monsanto's Roundup herbicide. Therefore, GM soy always carries the double threat of higher herbicide content, couple with any side effects of genetic engineering.

Without detailed tests, no one can pinpoint exactly what is causing the reproductive travesties in Russian hamsters and rats, Italian and Austrian mice, and livestock in India and America. And we can only North Nestucca Environmental Assessment Page 48

Appendix E – Attachment #9

speculate about the relationship between the introduction of genetically modified foods in 1996, and the corresponding upsurge in low birth weight babies, infertility, and other problems among the US population. But many scientists, physicians, and concerned citizens don't think that the public should remain the lab animals for the biotech industry's massive uncontrolled experiment.

Alexey Surov says, "We have no right to use GMOs until we understand the possible adverse effects, not only to ourselves but to future generations as well. We definitely need fully detailed studies to clarify this. Any type of contamination has to be tested before we consume it, and GMO is just one of them."

Smith, Jeffery “Genetically Modified Soy Linked to Sterility, Infant Mortality” foodconsumer.org, September 22, 2010 http://www.foodconsumer.org/newsite/Watch- List/genetically_modified_soy_linked_to_sterility_infant_mortality_22.html

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #52 - “A study released by an Argentine scientist earlier this year reports that glyphosate, patented by Monsanto under the name "Round Up," causes birth defects when applied in doses much lower than what is commonly used in soy fields.

North Nestucca Environmental Assessment Page 49

Appendix E – Attachment #9

visible defects—one eye the size of the head, spinal cord deformations, and kidneys that are not fully developed.

"We injected the amphibian embryo cells with glyphosate diluted to a concentration 1,500 times than what is used commercially and we allowed the amphibians to grow in strictly controlled conditions." Dr. Carrasco reports that the embryos survived from a fertilized egg state until the tadpole stage, but developed obvious defects which would compromise their ability to live in their normal habitats.

Trigona, Marie “GMO – Monsanto Soy Herbicide could Pose Health Risks” Americas Program, Center for International Policy (CIP), July 13, 2009 http://www.internationalnews.fr/article-36061426.html

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #53 - “A study released by an Argentine scientist earlier this year reports that glyphosate, patented by Monsanto under the name “Round Up,” causes birth defects when applied in doses much lower than what is commonly used in soy fields.

The study was directed by a leading embryologist, Dr. Andres Carrasco, a professor and researcher at the University of Buenos Aires. In his office in the nation’s top medical school, Dr. Carrasco shows me the results of the study, pulling out photos of birth defects in the embryos of frog amphibians exposed to glyphosate. The frog embryos grown in petri dishes in the photos looked like something from a futuristic horror film, creatures with visible defects-one eye the size of the head, spinal cord deformations, and kidneys that are not fully developed.”

Trigona, Marie “Study released in Argentina puts glyphosate under fire” SOURCE Americas Program, Center for International Policy, USA, July 13, 2009 Published by Prism Webcast News North Nestucca Environmental Assessment Page 50

Appendix E – Attachment #9

http://prismwebcastnews.com/2009/08/06/study-released-in-argentina-puts-glyphosate- under-fire/

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #54 - “Relyea found that Roundup caused a 70 percent decline in amphibian biodiversity and an 86 percent decline in the total mass of tadpoles. Leopard Frog tadpoles and Gray Treefrog tadpoles were completely eliminated and Wood Frog tadpoles and toad (Bufo) tadpoles were nearly eliminated. One species of frog, Spring Peepers, was unaffected. "The most shocking insight coming out of this was that Roundup, something designed to kill plants, was extremely lethal to amphibians," said Relyea, who conducted the research at Pitt’s Pymatuning Laboratory of Ecology. "We added Roundup, and the next day we looked in the tanks and there were dead tadpoles all over the bottom." “

Roundup Ravages Riparian Residents” The Center for North American Herpetology. NEWS RELEASE 18 April 2005 http://www.csupomona.edu/~cmbrady/courses/bio304/Roundup.htm

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #55 - “False Research The EPA has twice caught scientists deliberately falsifying results at research laboratories hired by Monsanto to study glyphosate.

North Nestucca Environmental Assessment Page 51

Appendix E – Attachment #9

In 1983, the EPA revealed that Industrial Biotest Laboratories (IBL) routinely falsified results of their 1971 research performed on glyphosate. Tests performed at IBL included eleven out of nineteen total chronic toxicology studies on glyphosate; studies instrumental in its retaining registration in 1974.

In 1991, the EPA alleged that Craven Laboratories, another lab hired by Monsanto to study the effects of glyphosate, had falsified test results. Several methods were used, including manipulation of equipment and notebook entries.”

“Alaska has an economic and cultural dependence on the welfare of salmon and other fish species, so it is particularly vital for Alaskans to know that glyphosate, and even more so glyphosate herbicides, are acutely toxic to fish.

The toxicity of glyphosate, which is most potently dangerous to younger fish, increases as water temperature rises. Ironically, the use of glyphosate causes water temperatures to increase for several years following treatment, as the herbicide kills shading vegetation. This is significant in more than one way for salmon, as juvenile salmon require cold water to thrive under even normal environmental circumstances.

The effects of glyphosate on fish have been documented using rainbow trout, which exhibited erratic swimming and labored breathing, effects which can increase the risk that fish will be eaten, as well as affecting ability to feed, migrate, and reproduce.”

James, Carrie “Aerial Herbicide Spraying” SitNews (Ketchikan, Alaska) June 19, 2004 http://www.sitnews.us/0604Viewpoints/061904_carrie_james.html

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

North Nestucca Environmental Assessment Page 52

Appendix E – Attachment #9

------

Glyphosate safety opposing view #56 - “Worldwide, amphibian populations are reported to be in a state of decline. Causative factors are incompletely understood. In ecosystems of northeastern North America, multiple stressors of pesticide contamination and acidification may be involved. As an initial component of a multi-tier investigation, the effects of forest-use herbicides Vision® (glyphosate) andRelease® (triclopyr) are being studied using Xenopus laevis, Rana pipiens and Rana clamitans. Two different life stages of amphibians, embryos (blastula stage) and larvae (Gosner stage 25), are being used. Interactive effects of various herbicide concentrations and pH (5.5 and 7.5) are being studied using the organisms exposed in 96hr static renewal tests. The Frog Embryo Teratogenesis Assay - Xenopus (FETAX) protocol is used for the embryo stage for the determination of mortality, malformation and growth data. The larval exposures are being developed and refined to compare sensitivities to the FETAX assay. The larval 96hr static renewal exposure is followed by a 10-day water-only recovery period. Sensitivities are being compared to determine the appropriateness of the exotic amphibian Xenopus laevis for toxicity testing. Results on toxicity to date indicate that Vision® is more toxic to all species at pH 7.5 than at pH 5.5. The reverse has been shown for Release®. In addition, the larval stage has consistently been shown to be more sensitive than the blastula stage. Understanding species sensitivities and herbicide/pH interactions will aid in altering forestry herbicide use patterns to minimize effects on amphibians and other nontarget organisms.”

Edginton, Andrea N.Ph.D. “Multiple stressor effects in amphibians: herbicide/pH interaction” A presentation at the 5th Annual of the Canadian Amphibian and Reptile Conservation Network, September 22-25, 2000 http://www.carcnet.ca/past_meetings/2000/pastmeeting2000.php

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

North Nestucca Environmental Assessment Page 53

Appendix E – Attachment #9

------

Glyphosate safety opposing view #57 - “We have evaluated the toxicity of four glyphosate (G)-based herbicides in Roundup (R) formulations, from 105 times dilutions, on three different human cell types. This dilution level is far below agricultural recommendations and corresponds to low levels of residues in food or feed. The formulations have been compared to G alone and with its main metabolite AMPA or with one known adjuvant of R formulations, POEA. HUVEC primary neonate umbilical cord vein cells have been tested with 293 embryonic kidney and JEG3 placental cell lines. All R formulations cause total cell death within 24 h, through an inhibition of the mitochondrial succinate dehydrogenase activity, and necrosis, by release of cytosolic adenylate kinase measuring membrane damage. They also induce apoptosis via activation of enzymatic caspases 3/7 activity. This is confirmed by characteristic DNA fragmentation, nuclear shrinkage (pyknosis), and nuclear fragmentation (karyorrhexis), which is demonstrated by DAPI in apoptotic round cells. G provokes only apoptosis, and HUVEC are 100 times more sensitive overall at this level. The deleterious effects are not proportional to G concentrations but rather depend on the nature of the adjuvants. AMPA and POEA separately and synergistically damage cell membranes like R but at different concentrations.

Benachour, Nora and Gilles-Eric Seralini “Glyphosate Formulations Induce Apoptosis and Necrosis in Human Umbilical, Embryonic, and Placental Cells” Chemical Research in Toxicology, 2009, 22 (1), pp 97–105 http://pubs.acs.org/doi/abs/10.1021/tx800218n

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

North Nestucca Environmental Assessment Page 54

Appendix E – Attachment #9

------

Glyphosate safety opposing view #58 - “Case example: Okanogan NF Integrated Weed Management Environmental Assessment (EA) (1997, 1999) The Okanogan NF Integrated Weed Management EA for 1997 received many comments from the public asking for documentation and analysis of the risks of herbicides to human health and safety, yet all of these concerns for safety were lumped into a single issue on p. 15-16:

Noxious weed populations can degrade recreational experiences by decreasing the desirability of campsites, replacing native plant populations in developed and dispersed areas and changing the scenery. Herbicide contact could pose risks to human health through skin exposure, inhalation, or ingestion. Some noxious weeds also pose risks to human health.

The marginalization of human health as mere “issues” rather than actual hazards suggests that there was never any intention of questioning the safety or use of herbicides, except in a very limited fashion, and this is borne out in the analysis section.

Two years later the Okanogan NF prepared a second EA (1999) and through another public comment process, the issues identified through public comments were exactly the same.

Why are the issues of public health ignored? According to the rationalization given in the EA (Okanogan NF, 1997, p. 17), public comments were addressed in a “higher level document”. In other words, concerns about human health and safety were not considered in the EA. By its limited scope, the agency effectively avoids having to consider issues that it doesn't want to.

The purpose of an EA is to assess a problem, propose and evaluate alternatives and select the most effective remedy, which should be the

North Nestucca Environmental Assessment Page 55

Appendix E – Attachment #9

least harmful to the environment. In this case, the alternative to use herbicides had been selected prior to doing an analysis. The EA was only used to justify a predetermined decision rather than truly explore alternatives.”

From Chapter 3. Adverse impacts in the report: “Risky Business: Invasive species management on National Forests - A review and summary of needed changes in current plans, policies and programs” A publication of the Kettle Range Conservation Group, February, 2001 http://kettlerange.org/weeds/Chapter-3.html

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #59 - “In one study, for instance, we exposed neural stage embryos and newly hatched tadpoles of green frogs to low levels of the herbicide glyphosate. Following 96 hours of exposure to the herbicide, surviving animals were moved to fresh water. Nominal glyphosate concentrations of 1.2 to 4.0 ppm initially caused tadpoles paralysis from which they eventually recovered. During the first 24 hours of exposure to 8.0 ppm, all tadpoles either died or were completely paralysed. Furthermore, almost all of the survivors from the first 24 hours of exposure died before the completion of the 96-hour exposure period. Follow-up tests indicated that much of the toxicity could be attributed to the surfactant used in the RoundUp® formulation of glyphosate.”

Pauli, Bruce and M. Berrill Ph.D. “Pesticides and Behaviour in Tadpoles” In Environmental Contaminants and Amphibians in Canada http://www.open.ac.uk/daptf/froglog/FROGLOG-16-5.html

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

North Nestucca Environmental Assessment Page 56

Appendix E – Attachment #9

------

Glyphosate safety opposing view #60 - “BUENOS AIRES – The herbicide used on genetically modified soy – Argentina’s main crop – could cause brain, intestinal and heart defects in fetuses, according to the results of a scientific investigation released Monday.

Although the study “used amphibian embryos,” the results “are completely comparable to what would happen in the development of a human embryo,” embryology professor Andres Carrasco, one of the study’s authors, told Efe.”

“Carrasco said that the research found that “pure glyphosate, in doses lower than those used in fumigation, causes defects ... (and) could be interfering in some normal embryonic development mechanism having to do with the way in which cells divide and die.”

“ “The companies say that drinking a glass of glyphosate is healthier than drinking a glass of milk, but the fact is that they’ve used us as guinea pigs,” he said.”

“Herbicide Used in Argentina Could Cause Birth Defects” Latin American Herald Tribune, April 30, 2009 http://www.progressiveconvergence.com/roundup-report-Argentina.htm

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #61 - “DENVER, Colo.— Recognizing the threat posed by expanding use of dangerous pesticides across 18 western states, competition from invading bullfrogs, nonnative diseases, North Nestucca Environmental Assessment Page 57

Appendix E – Attachment #9

and loss of wetlands, the U.S. Fish and Wildlife Service will announce tomorrow their conclusion that western populations of the northern leopard frog may warrant protection under the Endangered Species Act.”

“The use of Roundup (a proprietary herbicide containing glyphosate), which is lethal to amphibians even at recommended levels according to recent studies, also threatens the western leopard frog. Roundup Ready crops (resistant to Roundup so the herbicide can be broadly applied to kill weeds) comprise a significant portion of crop acreage in the midwestern United States. In 2004, Roundup Ready soybean crops comprised 89 percent of all soybean crops in Iowa, 82 percent in Minnesota, 92 percent in Nebraska, 82 percent in North Dakota, and 95 percent in South Dakota.”

Western Leopard Frogs Move a Step Closer to Protection -- U.S. Fish and Wildlife Service: Pesticides, Disease, Invasive Species, and Habitat Loss May Threaten Native Frogs with Extinction Center for Biological Diversity news release, June 30, 2009 http://www.biologicaldiversity.org/news/press_releases/2009/western-leopard-frog-06- 30-2009.html

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #62 - “Eduardo Neaves, a 12-year-old, went swimming in a canal in Coral Gables, Florida that was contaminated with four times the recommended amount of RoundUp herbicide. The child became completely paralyzed, and five years after the incident suffers residual nervous system damage.

The EPA, according to this article, in 1985 reported on the case of a 59- year-old woman in Tennessee who has suffered central nervous system damage after exposure to RoundUp.

North Nestucca Environmental Assessment Page 58

Appendix E – Attachment #9

Monsanto's original neurotoxicity studies on RoundUp were ruled invalid by the EPA due to "extensive gaps in the raw data supporting study findings and conclusions. There has been no requirement for a new study on the neurotoxicity of RoundUp.”

“Anecdotal Evidence of RoundUp's Toxicity” Natures Country Store From July 1987 edition of The Progressive, and article entitled 'Weed Killer' http://www.naturescountrystore.com/roundup/page7.html

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #63 - “A group of international scientists has released a report detailing health and environmental hazards from the cultivation of genetically modified (GM) Roundup Ready soy and the use of glyphosate (Roundup®) herbicide.

The report, GM Soy: Sustainable? Responsible?,[1] highlights new research by Argentine government scientist, Professor Andrés Carrasco,[2] which found that glyphosate causes malformations in frog and chicken embryos at doses far lower than those used in agricultural spraying.

“The findings in the lab are compatible with malformations observed in humans exposed to glyphosate during pregnancy,” said Carrasco.”

Antoniou, Michael, Paulo Brack Ph.D., Andrés Carrasco Ph.D., John Fagan, Mohamed Ezz El-Din Mostafa Habib Ph.D., Paulo Yoshio Kageyama Ph.D., Carlo Leifert Ph.D, Rubens Onofre Nodari Ph.D., Walter A. Pengue Ph.D. “GM Soy: Sustainable? Responsible?” GM Watch, 13 September 2010 http://www.globalresearch.ca/index.php?context=viewArticle&code=ANA20101010&arti cleId=21382

North Nestucca Environmental Assessment Page 59

Appendix E – Attachment #9

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #64 - “Three recent studies show that Roundup, which is used by farmers and home gardeners, is not the safe product we have been led to trust.

A group of scientists led by biochemist Professor Gilles-Eric Seralini from the University of Caen in France found that human placental cells are very sensitive to Roundup at concentrations lower than those currently used in agricultural application.

An epidemiological study of Ontario farming populations showed that exposure to glyphosate, the key ingredient in Roundup, nearly doubled the risk of late miscarriages. Seralini and his team decided to research the effects of the herbicide on human placenta cells. Their study confirmed the toxicity of glyphosate, as after eighteen hours of exposure at low concentrations, large proportions of human placenta began to die. Seralini suggests that this may explain the high levels of premature births and miscarriages observed among female farmers using glyphosate.”

Heong, Chee Yoke “New Evidence Establishes Dangers of Roundup” Third World Resurgence, No. 176, April 2005 Re-published by Project Censored http://www.projectcensored.org/top-stories/articles/13-new-evidence-establishes- dangers-of-roundup/

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

North Nestucca Environmental Assessment Page 60

Appendix E – Attachment #9

------

Glyphosate safety opposing view #65 - “Colombia - A Colombian court on Friday ordered the government to suspend immediately aerial spraying of drug crops with the herbicide glyphosate, a potential blow to President Andres Pastrana's anti-cocaine offensive.

Bogota Judge Gilberto Reyes Delgado, ruling in favor of indigenous groups that had protested the spraying program, said he had asked the government to provide studies on glyphosate's effects on the environment and human health.”

“Ecuador recently asked Colombia to stop aerial crop spraying near the border the two nations share over fears glyphosate could harm Ecuadoreans' health and damage subsistence crops in the region's jungle towns.”

“Columbian Court Suspends Aerial Spraying of Roundup on Drug Crops” Reuters, July 27, 2001 Republished by Mindfilly.org http://www.mindfully.org/Pesticide/Roundup-Drug-Spray-Colombia.htm

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #66 - “In short, Monsanto's Roundup Ready technology is emerging as an environmental disaster. The question isn't why a judge demanded an environmental impact study of Roundup Ready sugar beets in 2010; it's that no one did so in 1996 before the

North Nestucca Environmental Assessment Page 61

Appendix E – Attachment #9

technology was rolled out. After all, the Union of Concerned Scientists was already quite, well, concerned back then.”

“As I wrote in June, rather than spark a reassessment of the wisdom of relying on toxic chemicals, the failure of Roundup Ready has the U.S. agricultural establishment scrambling to intensify chemical use. Companies like Dow Agriscience are dusting off old, highly toxic poisons like 2, 4-D and promoting them as the "answer" to Roundup's problems.”

Philpott, Tom. “Why Monsanto is paying farmers to spray its rivals’ herbicides” Grist, October 20, 2010 http://www.grist.org/article/food-2010-10-20-why-monsanto-paying-farmers-to-spray- rival-herbicides/

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #67 - “Glyphosate is no more than slightly toxic to fish, and practically non-toxic to amphibians (McComb 1990) and aquatic invertebrate animals.” (page 4)

“For glyphosate and its formulations, findings are from studies conducted by the manufacturer. These studies have been presented to EPA to support product registration, but may not be available to the public. (page 5)

“Since the 1988 rating, EPA has concluded that glyphosate should be classified as having evidence of noncarcinogenicity for humans. There was no convincing evidence of carcinogenicity in new studies in two animal species (Dykstra and Ghali 1991). (page 7)

“Glyphosate Herbicide Information Profile” Forest Service Pacific Northwest Region, February, 1997

North Nestucca Environmental Assessment Page 62

Appendix E – Attachment #9

http://www.fs.fed.us/r6/nr/fid/pubsweb/gly.pdf

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Glyphosate safety opposing view #68 - “Two new studies indicate that Monsanto's herbicide, Roundup, is a hormone-disruptor and is associated with birth defects in humans.

Farm families that applied pesticides to their crops in Minnesota were studied to see if their elevated exposure to pesticides caused birth defects in their children. The study found that two kinds of pesticides -- fungicides and the herbicide Roundup -- were linked to statistically significant increases in birth defects. Roundup was linked to a 3-fold increase in neurodevelopmental (attention deficit) disorders. [EHP Supplement 3, Vol. 110 (June 2002), pgs. 441-449.]

“A recent test tube study reveals that Roundup can severely reduce the ability of mouse cells to produce hormones. Roundup interferes with a fundamental protein called StAR (steroidogenic acute regulatory protein). The StAR protein is key to the production of testosterone in men (thus controlling male characteristics, including sperm production) but also the production of adrenal hormone (essential for brain development), carbohydrate metabolism (leading to loss or gain of weight), and immune system function. The authors point out that "a disruption of the StAR protein may underlie many of the toxic effects of environmental pollutants." [EHP Vol. 108, No. 8 (August 2000), pgs. 769-776.]”

“Monsanto’s Roundup Herbicide Threatens Public Health” Rachel's Environment and Health News, issue 751, Sept. 5, 2002. Reprinted by Organic Consumers Association http://www.organicconsumers.org/Monsanto/roundup92502.cfm

North Nestucca Environmental Assessment Page 63

Appendix E – Attachment #9

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------Following the Label Directions on “Approved” Herbicide Containers does not Assure Safety

Herbicide Safety Testing Opposing View #69 - “Tests done on glyphosate to meet registration requirements have been associated with fraudulent practices.

Laboratory fraud first made headlines in 1983 when EPA publicly announced that a 1976 audit had discovered "serious deficiencies and improprieties" in toxicology studies conducted by Industrial Biotest Laboratories (IBT).44 Problems included "countless deaths of rats and mice that were not reported," "fabricated data tables," and "routine falsification of data."44

IBT was one of the largest laboratories performing tests in support of pesticide registrations.44 About 30 tests on glyphosate and glyphosate- containing products were performed by IBT, including 11 of the 19 chronic toxicology studies.45 A compelling example of the poor quality of IBT data comes from an EPA toxicologist who wrote, "It is also somewhat difficult not

North Nestucca Environmental Assessment Page 64

Appendix E – Attachment #9

to doubt the scientific integrity of a study when the IBT stated that it took specimens from the uteri (of male rabbits) for histopathological examination."46 (Emphasis added.)

In 1991, laboratory fraud returned to the headlines when EPA alleged that Craven Laboratories, a company that performed contract studies for 262 pesticide companies including Monsanto, had falsified test results.47 "Tricks" employed by Craven Labs included "falsifying laboratory notebook entries" and "manually manipulating scientific equipment to produce false reports."48 Roundup residue studies on plums, potatoes, grapes, and sugarbeets were among the tests in question.49

The following year, the owner/president of Craven Laboratories and three employees were indicted on 20 felony counts. A number of other employees agreed to plead guilty on a number of related charges.50 The owner was sentenced to five years in prison and fined $50,000; Craven Labs was fined 15.5 million dollars, and ordered to pay 3.7 million dollars in restitution.48

Although the tests of glyphosate identified as fraudulent have been replaced, these practices cast shadows on the entire pesticide registration process.”

Cox, Caroline, “Quality of Toxicology Testing” Journal of Pesticide Reform, Volume 15, Number 3, Fall 1995. Northwest Coalition for Alternatives to Pesticides, Eugene, OR. Glyphosate, Part 1: Toxicology http://www.inspiringlandscapes.com/hope/glyphos8.htm

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Herbicide Safety Testing Opposing View #70 - “In 2004 the “Counterpart Regulations,” strongly supported by industry, were proposed to streamline

North Nestucca Environmental Assessment Page 65

Appendix E – Attachment #9

EPA’s pesticide review process at the expense of the most vulnerable life forms in our country, Endangered and Threatened Species aka Listed Species (1,265 species are “Listed”). The critical change these regulations bring about is elimination of the requirement for consultations with wildlife experts at the U.S. Fish and Wildlife Service (FWS) and the National Marine Fisheries Service (NMFS) by EPA reviewers evaluating adverse impacts of pesticides on Listed Species and their habitats. RCC opposed the Counterpart Regulations with comments, but, sadly, the Regulations were issued in final form on July 29, 2004, despite our objections. Over 125,000 public comments were received by the Fish and Wildlife Service, and they ran 2 to 1 against the Counterpart Regulations.

RCC Insight: Apparently, the public’s concerns did not make a difference to the people at FWS and NMFS, or did they? We wonder whether the scientists involved with protecting wildlife at both “Services” would want to be bringing their experience and knowledge to bear on decisions made by EPA with respect to pesticides, if it were up to them. Perhaps they would prefer to be part of the evaluation process and they do not concur with finalizing the Counterpart Regulations. However, the fact is that decision-makers, by finalizing these changes, support an action that will weaken Endangered Species’ protection from poisoning and habitat degradation due to pesticides. This latest environmental rollback can mean increasingly hazardous conditions in rivers, lakes and wetlands. A further risk is weakening of the Endangered Species Act itself. (Text of our “Comments” is available through our website -- rachelcarsoncouncil.com)”

“Species from Pesticides – Weakened” Rachel Carson Council Inc., Issues & Insights October, 2004 http://www.rachelcarsoncouncil.org/index.php?page=issues-insights-october-2004

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------North Nestucca Environmental Assessment Page 66

Appendix E – Attachment #9

Herbicide Safety Testing Opposing View #71 - “Used in yards, farms and parks throughout the world, Roundup has long been a top-selling weed killer. But now researchers have found that one of Roundup’s inert ingredients can kill human cells, particularly embryonic, placental and umbilical cord cells.

Until now, most health studies have focused on the safety of glyphosate, rather than the mixture of ingredients found in Roundup. But in the new study, scientists found that Roundup’s inert ingredients amplified the toxic effect on human cells—even at concentrations much more diluted than those used on farms and lawns.

One specific inert ingredient, polyethoxylated tallowamine, or POEA, was more deadly to human embryonic, placental and umbilical cord cells than the herbicide itself – a finding the researchers call “astonishing.”

“The research team suspects that Roundup might cause pregnancy problems by interfering with hormone production, possibly leading to abnormal fetal development, low birth weights or miscarriages.

Monsanto, Roundup’s manufacturer, contends that the methods used in the study don’t reflect realistic conditions and that their product, which has been sold since the 1970s, is safe when used as directed. Hundreds of studies over the past 35 years have addressed the safety of glyphosate.

“Roundup has one of the most extensive human health safety and environmental data packages of any pesticide that's out there,” said Monsanto spokesman John Combest. “It's used in public parks, it's used to protect schools. There's been a great deal of study on Roundup, and we're very proud of its performance.”

The EPA considers glyphosate to have low toxicity when used at the recommended doses.

“Risk estimates for glyphosate were well below the level of concern,” said EPA spokesman Dale Kemery. The EPA classifies glyphosate as a Group E chemical, which means there is strong evidence that it does not cause cancer in humans.” North Nestucca Environmental Assessment Page 67

Appendix E – Attachment #9

Weed-Whacking Herbicide Proves Deadly to Human Cells By Crystal Gammon and Environmental Health News June 23, 2009 http://www.scientificamerican.com/article.cfm?id=weed-whacking-herbicide-p

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Herbicide Safety Testing Opposing View #72 - “However, the U.S. government regulatory agencies seem to have given Monsanto a long rope. The clout Monsanto enjoys in the U.S. government is by no means incidental. According to the Organic Consumers Association, Clarence Thomas, before being the Supreme Court Judge who put George W. Bush in office (in his first term), was a Monsanto lawyer; Anne Veneman, the U.S. Secretary of Agriculture, was on the board of directors of Monsanto's Calgene Corporation; Donald Rumsfeld, the Secretary of Defence, was on the board of directors of Monsanto's Searle Pharmaceuticals; Secretary of Health Tommy Thompson received $50,000 in donations from Monsanto during his winning campaign for Wisconsin's governorship; and the two Congressmen who received the most donations from Monsanto during the last election were Larry Combest (Chairman of the House Agricultural Committee) and John Ashcroft (the Attorney-General).”

“A multinational Exposed” Frontline, Volume 22 - Issue 05, Feb. 26 - Mar. 11, 2005 http://www.hinduonnet.com/fline/fl2205/stories/20050311003312500.htm

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------North Nestucca Environmental Assessment Page 68

Appendix E – Attachment #9

Herbicide Safety Testing Opposing View #73 - “A recent study which shows clear links between exposure to the herbicide glyphosate and non- Hodgkin's lymphoma (NHL), a form of cancer that afflicts the lymphatic system, has caused worldwide concern over the safety of the herbicide on humans.

The study was conducted by eminent oncologists Dr Lennart Hardell and Dr Mikael Eriksson of Sweden and published in the journal Cancer by the American Cancer Society on March 15.”

“Monsanto's Argument: Previous evaluations conducted by the US Environmental Protection Agency (EPA) and the World Health Organization (WHO) suggest that glyphosate is not a mutagenic or carcinogenic.

WHO and the Food and Agriculture Organization (FAO) have approved the safety of glyphosate residues in genetically-engineered Roundup Ready soyabeans.

PAN's Counter Argument: The EPA and WHO evaluations were done more than five years ago and based mainly on data submitted to them by Monsanto.

These evaluations did conclude that "there is no evidence of mutagenicity or carcinogenicity" based on the available data, but they do not support definitive assertions that glyphosate "is not mutagenic or carcinogenic".

Previous EPA and WHO evaluations which made similar claims for other chemicals had to be revised as new evidence came to light.

The establishment of the WHO's Acceptable Daily Intake (ADI) is based on limited studies using limited parameters which do not account for vulnerable groups such as children, the elderly, the sick and other groups that might have increased susceptibility to glyphosate exposure.”

“Concerns Over Glyphosate Use” The Sun (Malaysia), Friday August 20, 1999 http://www.poptel.org.uk/panap/archives/glywb.htm

North Nestucca Environmental Assessment Page 69

Appendix E – Attachment #9

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Herbicide Safety Testing Opposing View #74 - “To protect our health, the U.S. Environmental Protection Agency (EPA) sets maximum legal residue levels for every pesticide, for dozens of crops. But a new study in the respected journal Toxicology has shown that, at low levels that are currently legal on our food, Roundup could cause DNA damage, endocrine disruption and cell death. The study, conducted by French researchers, shows glyphosate-based herbicides are toxic to human reproductive cells.”

“Solvents and surfactants, legally considered ‘inert ingredients,’ are mixed with glyphosate in products such as Roundup weed killer to create chemical formulations that increase mobility and more direct access to the cells. ‘Those same factors that aid penetration into a plant, also aid penetration into the skin,’ says Vincent Garry, professor emeritus of pathology at the University of Minnesota. ‘These chemicals are designed to kill cells.’ ”

“Herbicide manufacturers are subject to fewer rules in the testing of inert ingredients than they are for active ingredients, explains Caroline Cox, research director at the Center for Environmental Health in Oakland, Calif. ‘The tests the EPA requires for inert ingredients cover only a small range of potential health problems,’ Cox says. ‘Testing for birth defects, cancer and genetic damage are required only on the active ingredients. But we’re exposed to both.’ ”

“ ‘Our bodies are gigantic spider webs of chemical communications that work in the parts-per-trillion range,’ says Warren Porter, professor of zoology and environmental toxicology at the University of Wisconsin. ‘When you put so-called ‘insignificant’ amounts of toxic chemicals into the

North Nestucca Environmental Assessment Page 70

Appendix E – Attachment #9

mix, you have a molecular bull in a china shop. The possibilities for impact are endless.’ ”

Kimble-Evans, Amanda “Roundup Kills more than Weeds” Mother Earth News, December 2009/January 2010 http://www.motherearthnews.com/Sustainable-Farming/Roundup-Weed-Killer- Toxicity.aspx?page=2

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Herbicide Safety Testing Opposing View #75 - “Glyphosate is of relatively low oral and dermal acute toxicity. It has been placed in Toxicity Category III for these effects (Toxicity Category I indicates the highest degree of acute toxicity, and Category IV the lowest). The acute inhalation toxicity study was waived because glyphosate is nonvolatile and because adequate inhalation studies with end-use products exist showing low toxicity.” (Pg. 2)

“Glyphosate does not cause mutations.” (Pg. 2)

“EPA conducted a dietary risk assessment for glyphosate based on a worst-case risk scenario, that is, assuming that 100 percent of all possible commodities/acreage were treated, and assuming that tolerance-level residues remained in/on all treated commodities. The Agency concluded that the chronic dietary risk posed by glyphosate food uses is minimal.” (Pg. 3)

“Occupational and residential exposure to glyphosate can be expected based on its currently registered uses. However, due to glyphosate's low acute toxicity and the absence of other toxicological concerns (especially

North Nestucca Environmental Assessment Page 71

Appendix E – Attachment #9

carcinogenicity), occupational and residential exposure data are not required for reregistration.” (Pg. 3)

“Glyphosate is no more than slightly toxic to birds and is practically nontoxic to fish, aquatic invertebrates and honeybees. Due to the presence of a toxic inert ingredient, some glyphosate end-use products must be labeled, ‘Toxic to fish,’ if they may be applied directly to aquatic environments. Product labeling does not preclude off-target movement of glyphosate by drift. EPA therefore is requiring three additional terrestrial plant studies to assess potential risks to nontarget plants.

EPA does not expect that most endangered terrestrial or aquatic organisms will be affected by the registered uses of glyphosate.” (Pg. 4)

“Based on current data, EPA has determined that the effects of glyphosate on birds, mammals, fish and invertebrates are minimal.” (Pg. 5)

“Regulatory Conclusion The use of currently registered pesticide products containing the isopropylamine and sodium salts of glyphosate in accordance with the labeling specified in this RED will not pose unreasonable risks or adverse effects to humans or the environment. Therefore, all uses of these products are eligible for reregistration.” (Pg. 6)

“R.E.D. FACTS Glyphosate” EPA publication - EPA-738-F-93-011, September 1993 http://www.epa.gov/oppsrrd1/REDs/factsheets/0178fact.pdf

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Herbicide Safety Testing Opposing View #76 - “The findings of Richard et al. (2005) are an important addition to our understanding that the health

North Nestucca Environmental Assessment Page 72

Appendix E – Attachment #9

and environmental effects of formulated pesticide products are not fully reflected in tests conducted on the active ingredient(s) alone. It has been long known that the adjuvants (commonly and misleadingly called "inert" ingredients) may be toxic and may enhance or supplement the toxic effects of the active pesticidal ingredient.

In the case of glyphosate-containing products, this phenomenon was well demonstrated in the data submitted to the (EPA) by the registrant (Monsanto), and summarized by the U.S. EPA in the Reregistration Eligibility Document (RED) for glyphosate (U.S. EPA 1993). For example, based on the registrant's own tests of acute toxicity to freshwater fish, the U.S. EPA classified technical grade glyphosate as "slightly toxic" to "practically non-toxic" and formulated products ranged from "moderately toxic" to "practically non-toxic." Tested alone, the surfactant adjuvant (identified as "inert") was "highly toxic" to "slightly toxic." Similar differences were reported in tests of acute toxicity to freshwater invertebrates.

Based in part on the data in the glyphosate RED (U.S. EPA 1993), the New York State Attorney General's office successfully pursued an action against Monsanto in 1996 (Attorney General of the State of New York 1996). At that time, Monsanto was making advertising claims about the toxicity of the Roundup products based on data from tests on the active ingredient alone. Such claims are scientifically unfounded and inherently deceptive. The Attorney General's action was facilitated by the availability of at least some limited information about the inert ingredients and their toxicity. That same sort of information enabled Richard et al. (2005) to conduct their study.

Unfortunately, that is not always the case, and for many pesticide products, little or no information about the identity of inert ingredients is publicly available. Registrants are generally required to conduct acute toxicity tests on formulated products, but they traditionally conduct chronic toxicity tests on the active ingredient alone. Even when formulated products are tested, the identity of inert ingredients is rarely revealed in the open literature, publicly available regulatory documents, or product labels. Therefore, independent research is stymied, and the public is ill-informed in the marketplace.”

North Nestucca Environmental Assessment Page 73

Appendix E – Attachment #9

Séralini, Gilles-Eric “Issue: Cumulative Impacts to Amphibians Species” A Laboratoire de Biochimie et Biologie Moleculaire publication, Université de Caen, February 2006 http://www.signaloflove.org/clearcutting/reports/cumulativeimpactstoamphibian

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Herbicide Safety Testing Opposing View #77 - “FACT: The EPA (Environmental Protection Agency) does not test pesticides for safety. It relies on the manufacturers’ test data to make judgments. Recent probes have found that the experiments on which these data have been based, have been designed to show only what the manufacturer would like them to show. This criticism of self-serving misrepresentation can be aimed equally validly at irresponsible experimenters bent on demonstrating toxicity of a given pesticide.

It seems that however this problem is approached, the EPA needs to take more affirmative action and responsibility. This is not likely to happen, as the EPA’s research program increasingly relies on corporate joint venture, according to agency documents obtained by Public Employees for Environmental Responsibility (PEER). Indeed, a study by the Government Accountability Office (the investigative arm of Congress – the same people who first told us of the $640 toilet seats and $1,000 hammers purchased with Department of Defense money), in April 2005, concluded that the EPA lacks safeguards to “evaluate or manage potential conflicts of interest” in corporate research agreements, as they are taking money from corporations that they are supposed to be regulating.”

“MYTH: The Government tests pesticides for safety before they are sold” Wild Ones Journal, Nov 17, 2006 http://www.for-wild.org/download/roundupmyth/roundupmyth.html

North Nestucca Environmental Assessment Page 74

Appendix E – Attachment #9

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Herbicide Safety Testing Opposing View #78 - “FACT: The primary focus of the Federal Insecticide, Fungicide, and Rodenticide Act, originally enacted in 1947, was to provide federal control of pesticide distribution, sale, and use. The act has been amended many times over the years. One of these amendments permitted manufacturers protection of trade secrets. It is under these provisions that manufacturers circumvent a law that originally intended all information to be known – at least by the EPA. The fact that today, with mass spectrometers, chemistry can determine the makeup of the inert ingredients, leaves only the end consumer in the dark.

In 1990 the Office of the Attorney General of New York filed a request that all inert ingredients in pesticides be made public. The request was repeated a number of times through the decade, to no avail. Sixteen years later, in August of 2006, the attorneys general of 14 states have filed a similar petition to the EPA. This time the EPA is obliged to respond within a given time period.”

“MYTH: There are laws…” Wild Ones Journal, Nov 17, 2006 http://www.for-wild.org/download/roundupmyth/roundupmyth.html

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

North Nestucca Environmental Assessment Page 75

Appendix E – Attachment #9

Herbicide Safety Testing Opposing View #79 - “A recent study by eminent oncologists Dr. Lennart Hardell and Dr. Mikael Eriksson of Sweden [1], has revealed clear links between one of the world's biggest selling herbicide, glyphosate, to non-Hodgkin's lymphoma, a form of cancer [2].”

“In the study published in the 15 March 1999 Journal of American Cancer Society, the researchers also maintain that exposure to glyphosate 'yielded increased risks for NHL.' They stress that with the rapidly increasing use of glyphosate since the time the study was carried out, 'glyphosate deserves further epidemiologic studies.' “

“O' Neill concluded: 'The EPA when authorising Monsanto's field trials for Roundup-ready sugar beet did not consider the issue of glyphosate. They considered this to be the remit of the Pesticides Control Service of the Department of Agriculture. Thus nobody has included the effects of increasing the use of glyphosate in the risk/benefit analysis carried out. It is yet another example of how regulatory authorities supposedly protecting public health have failed to implement the 'precautionary principle' with respect to GMOs.' “

O' Neill, Sadhbh “RoundUp—Lymphoma Connection” Genetic Concern, June 22, 1999 http://www.hancock.forests.org.au/docs/herbicidesUpdate0602.htm

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Herbicide Safety Testing Opposing View #80 - “Glyphosate-containing products are acutely toxic to animals, including humans. Symptoms include eye and skin irritation, cardiac depression, gastrointestinal pain, vomiting, and accumulation of excess fluid in the lungs. The surfactant used in a common glyphosate product (Roundup) is more acutely toxic than glyphosate itself; the combination of the two is yet more toxic.”

North Nestucca Environmental Assessment Page 76

Appendix E – Attachment #9

“Tests done on glyphosate to meet registration requirements have been associated with fraudulent practices.”

“Laboratory fraud first made headlines in 1983 when EPA publicly announced that a 1976 audit had discovered "serious deficiencies and improprieties" in toxicology studies conducted by Industrial Biotest Laboratories (IBT).44 Problems included "countless deaths of rats and mice that were not reported," "fabricated data tables," and "routine falsification of data." “44

“IBT was one of the largest laboratories performing tests in support of pesticide registrations.44 About 30 tests on glyphosate and glyphosate- containing products were performed by IBT, including 11 of the 19 chronic toxicology studies.45 A compelling example of the poor quality of IBT data comes from an EPA toxicologist who wrote, "It is also somewhat difficult not to doubt the scientific integrity of a study when the IBT stated that it took specimens from the uteri (of male rabbits) for histopathological examination." “46 (Emphasis added.)

“In 1991, laboratory fraud returned to the headlines when EPA alleged that Craven Laboratories, a company that performed contract studies for 262 pesticide companies including Monsanto, had falsified test results.47 "Tricks" employed by Craven Labs included "falsifying laboratory notebook entries" and "manually manipulating scientific equipment to produce false reports."48 Roundup residue studies on plums, potatoes, grapes, and sugarbeets were among the tests in question.” “49

“The following year, the owner/president of Craven Laboratories and three employees were indicted on 20 felony counts. A number of other employees agreed to plead guilty on a number of related charges.50 The owner was sentenced to five years in prison and fined $50,000; Craven Labs was fined 15.5 million dollars, and ordered to pay 3.7 million dollars in restitution.”48

Cox, Caroline. “Glyphosate, Part 1: Toxicology” Journal of Pesticide Reform, Volume 15, Number 3, Fall 1995 http://terrazul.org/Archivo/Glyphosate_Fact_Sheets.pdf

North Nestucca Environmental Assessment Page 77

Appendix E – Attachment #9

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Herbicide Safety Testing Opposing View #81 - “EPA Investigates Monsanto

An internal memorandum by an official of the U.S. Environmental Protection Agency [EPA], has accused EPA of conducting a "fraudulent" criminal investigation of Monsanto, the St. Louis chemical corporation. [1] The 30-page memo, from William Sanjour to his supervisor, David Bussard, dated July 20, 1994, describes a two-year-long criminal investigation of Monsanto by EPA's Office of Criminal Investigation (OCI).

The Sanjour memo says EPA opened its investigation on August 20, 1990 and formally closed it on August 7, 1992. "However, the investigation itself and the basis for closing the investigation were fraudulent," the Sanjour memo says.

According to the Sanjour memo:

• EPA's investigation of Monsanto was precipitated by a memo dated February 23, 1990, from EPA's Dr. Cate Jenkins to Raymond Loehr, head of EPA's Science Advisory Board.

• The Jenkins memo said that EPA had set dioxin standards relying on flawed Monsanto-sponsored studies of Monsanto workers exposed to dioxin, studies that had showed no cancer increases among heavily exposed workers.

• Attached to the Jenkins memo was a portion of a legal brief filed by the plaintiffs as part of a trial known as Kemner v. Monsanto, in which

North Nestucca Environmental Assessment Page 78

Appendix E – Attachment #9

a group of citizens in Sturgeon, Missouri had sued Monsanto for alleged injuries they had suffered during a chemical spill caused by a train derailment in 1979.

• The Jenkins memo had not requested a criminal investigation; instead Jenkins had suggested the need for a scientific investigation of Monsanto's dioxin studies. But in August 1990, EPA's Office of Criminal Investigation (OCI) wrote a 7-page memo recommending that a "full field criminal investigation be initiated by OCI."

• Plaintiffs in the Kemner suit made the following kinds of allegations (which we quote verbatim from the Sanjour memo):

“Monsanto failed to notify and lied to its workers about the presence and danger of dioxin in its chlorophenol plant, so that it would not have to bear the expense of changing its manufacturing process or lose customers;...

"Monsanto knowingly dumped 30 to 40 pounds of dioxin a day into the Mississippi River between 1970 and 1977 which could enter the St. Louis food chain;

"Monsanto lied to EPA that it had no knowledge that its plant effluent contained dioxin;

"Monsanto secretly tested the corpses of people killed by accident in St. Louis for the presence of dioxin and found it in every case;...

"Lysol, a product made from Monsanto's Santophen, was contaminated with dioxin with Monsanto's knowledge." [The Sanjour memo says that, at the time of the contamination, "Lysol (was) recommended for cleaning babies' toys and for other cleaning activities involving human contact."]

"The manufacturer of Lysol was not told about the dioxin by Monsanto for fear of losing his business;

North Nestucca Environmental Assessment Page 79

Appendix E – Attachment #9

"Other companies using Santophen, who specifically asked about the presence of dioxin, were lied to by Monsanto;...

"Shortly after a spill in the Monsanto chlorophenol plant, OSHA measured dioxin on the plant walls. Monsanto conducted its own measurements, which were higher than OSHA's, but they issued a press release to the public and they lied to OSHA and their workers saying they had failed to confirm OSHA's findings;

"Exposed Monsanto workers were not told of the presence of dioxin and were not given protective clothing even though the company was aware of the dangers of dioxin;

"Even though the Toxic Substances Control Act requires chemical companies to report the presence of hazardous substances in their products to EPA, Monsanto never gave notice and lied to EPA in reports;

"At one time Monsanto lied to EPA saying that it could not test its products for dioxin because dioxin was too toxic to handle in its labs."...

“EPA Investigates Monsanto” RACHEL'S HAZARDOUS WASTE NEWS #400, July 28, 1994 http://www.ejnet.org/rachel/rhwn400.htm

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Herbicide Safety Testing Opposing View #82 - “A study by French researchers at the University of Caen of glyphosate residue discovered that the inert ingredients in the herbicide (solvents, preservatives, surfactants)

North Nestucca Environmental Assessment Page 80

Appendix E – Attachment #9

increased the toxic effect on human cells. According to the researchers, glyphosate residue can cause birth defects.

“This clearly confirms that the [inert ingredients] in Roundup formulations are not inert,” wrote the study authors. “Moreover, the proprietary mixtures available on the market could cause cell damage and even death [at the] residual levels” found on Roundup-treated crops.”

“Another study by Argentine scientists also found that glyphosate can cause birth defects at doses considerably lower than what is commonly used on crops, in this case, soybeans. The researchers injected amphibian embryo cells with glyphosate diluted to a concentration 1,500 times less than what is used commercially. The embryos grew into tadpoles with obvious birth defects.”

“A 2001 study by Swedish oncologists discovered links between non- Hodgkin’s lymphoma and glyphosate. The Swedish researchers found that Swedish people with non-Hodgkin’s lymphoma were 2.3 times more likely to be exposed to glyphosate.

Monsanto spokesperson John Combest defended the safety of Roundup. “Roundup has one of the most extensive human health safety and environmental data packages of any pesticide that’s out there. It’s used in public parks, it’s used to protect schools. There’s been a great deal of study on Roundup, and we’re very proud of its performance.” “

Cheeseman, Gina-Marie, “Can A Company That Makes Roundup Be Sustainable?” TriplePundit, November 20th, 2009 http://www.triplepundit.com/2009/11/can-a-company-that-makes-roundup-be- sustainable/

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

North Nestucca Environmental Assessment Page 81

Appendix E – Attachment #9

------

Herbicide Safety Testing Opposing View #83 - “Over twenty years ago, the dangers of Monsanto's glyphosate as well as its associated GMOs were known scientifically to cause human health difficulties and Swedish researchers years ago in the Journal 'Cancer' noted glyphosate was connected to human cancer. Anyway, many scientists and public health workers researching it were fired. It's a mad empire's rush--the U.S empire and its corporate proxies--to desire (hell, the reality of) to own the world's food and dominate the whole world. It is destroying thousands of years of biodiversity security in the process. And Monsanto's empire of glyphosate is in virtually everything in the USA and worldwide. One foolish company, one corrupt federal government of the USA. Everyone should learn more about Monsanto in the film "The World According to Monsanto." (90 minutes). Monsanto's corporate contract should be revoked for endangering world health and killing off global crop biodiversity of thousands of years of work destroyed in one generation--in the mad rush to dominate the whole world's biodiversity.

Monsanto and the USA will go down in history as the organizations that caused most biological devastation and human suffering in human history.”

“MONSANTO RoundUp (glyphosate) Empire causes BIRTH DEFECTS...in amphibian embryos, humans?” Portland independent media center, May 3, 2009 http://portland.indymedia.org/en/2009/05/391045.shtml

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

North Nestucca Environmental Assessment Page 82

Appendix E – Attachment #9

Herbicide Safety Testing Opposing View #84 - “BUENOS AIRES, Apr 15 , 2009 (IPS) - Glyphosate, the herbicide used on soybeans in Argentina, causes malformations in amphibian embryos, say scientists here who revealed the findings of a study that has not yet been published.”

"The observed deformations are consistent and systematic," Professor Andrés Carrasco, director of the Laboratory of Molecular Embryology at the University of Buenos Aires medical school and lead researcher on the National Council of Scientific and Technical Research (CONICET), told the Inter Press Service news agency IPS.

Reduced head size, genetic alterations in the central nervous system, an increase in the death of cells that help form the skull, and deformed cartilage were effects that were repeatedly found in the laboratory experiments, said the biologist.

The news was reported Monday by the Argentine newspaper Página 12.

Monsanto’s head of communications in Argentina, Fernanda Pérez Cometto, told IPS that the company has "several studies that show that the herbicide is harmless to humans, animals and the environment."

Valente, Marcela “Scientists Reveal Effects of Glyphosate” HEALTH-ARGENTINA, April 15 , 2009 http://www.ipsnews.net/news.asp?idnews=46516

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Herbicide Safety Testing Opposing View #85 - “It’s amazing how many organics people still think it’s OK to just use a bit of Roundup on those weeds in the bush or the driveway, or …. of course, not on the food, but the bush, that’s OK isn’t it?

North Nestucca Environmental Assessment Page 83

Appendix E – Attachment #9

Well, no, actually it isn’t, and here’s why: Roundup and various other formulations of the active ingredient glyphosate, have the potential to cause serious health and environmental effects, and have caused some severe poisoning problems.

Thorough PR by the developer of Roundup, Monsanto, has resulted in the widespread belief that glyphosate is ‘safe’. Registration processes have generally supported this attitude, and there are no national or international bans. However, independent scientific studies and widespread poisonings in Latin America resulting from aerial application are beginning to reveal the true effects of the world’s most widely used herbicide.”

Watts, Meriel Ph.D. “Roundup's Not OK” ORGANIC NZ, November/December 2009 http://www.livingorganics.co.nz/roundups-not-ok.php

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010). ------

Herbicide Safety Testing Opposing View #86 - Research on genetically modified seeds is still published, of course. But only studies that the seed companies have approved ever see the light of a peer-reviewed journal. In a number of cases, experiments that had the implicit go-ahead from the seed company were later blocked from publication because the results were not flattering. "It is important to understand that it is not always simply a matter of blanket denial of all research requests, which is bad enough," wrote Elson J. Shields, an entomologist at Cornell University, in a letter to an official at the Environmental Protection Agency (the body tasked with regulating the environmental consequences of genetically modified crops), "but selective denials and permissions based on industry perceptions of how ’friendly’ or ’hostile’ a particular scientist may be toward [seed- enhancement] technology."

North Nestucca Environmental Assessment Page 84

Appendix E – Attachment #9

Shields is the spokesperson for a group of 24 corn insect scientists that opposes these practices. Because the scientists rely on the cooperation of the companies for their research - they must, after all, gain access to the seeds for studies - most have chosen to remain anonymous for fear of reprisals. The group has submitted a statement to the EPA protesting that "as a result of restricted access, no truly independent research can be legally conducted on many critical questions regarding the technology."

It would be chilling enough if any other type of company were able to prevent independent researchers from testing its wares and reporting what they find - imagine car companies trying to quash head-to-head model comparisons done by Consumer Reports, for example. But when scientists are prevented from examining the raw ingredients in our nation’s food supply or from testing the plant material that covers a large portion of the country’s agricultural land, the restrictions on free inquiry become dangerous.

“Do Seed Companies Control GM Crop Research?” Scientific American, Editorial, August 2009 edition, published 21 July 2009 Reprinted by Combat-Monsanto.org http://www.combat-monsanto.co.uk/spip.php?article399

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Herbicide Safety Testing Opposing View #87 - “France’s highest court has ruled that U.S. agrochemical giant Monsanto had not told the truth about the safety of its best-selling weed-killer, Roundup. The court confirmed an earlier judgment that Monsanto had falsely advertised its herbicide as “biodegradable” and claimed it “left the soil clean.” Roundup is the world’s best-selling herbicide.

North Nestucca Environmental Assessment Page 85

Appendix E – Attachment #9

French environmental groups had brought the case in 2001 on the basis that glyphosate, Roundup’s main ingredient, is classed as “dangerous for the environment” by the European Union.

In the latest ruling, France’s Supreme Court upheld two earlier convictions against Monsanto by the Lyon criminal court in 2007, and the Lyon court of appeal in 2008, the AFP news agency reports.

Monsanto already dominates America’s food chain with its genetically modified seeds. Now it has targeted milk production. Just as frightening as the corporation’s tactics, including ruthless legal battles against small farmers, is its decades-long history of toxic contamination.”

France Finds Monsanto Guilty of Lying Infowars Ireland, November 23, 2009 http://info-wars.org/2009/11/23/france-finds-monsanto-guilty-of-lying/

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Herbicide Safety Testing Opposing View #88 - “Monsanto created Roundup in the 1970's to kill weeds and has since catapulted this product to be the world's number one selling herbicide. Before the patent on Roundup was set to expire in 2000, Monsanto needed a surefire way to keep the profits of Roundup from bottoming out. Monsanto quickly began purchasing the majority of the world's seed companies while simultaneously creating GMOs that farmers needed to sign contractual agreements to only use Roundup. Subsequently, revenue from Roundup never dropped and in fact topped more than $4 billion in 2008, up 59% from 2007 [2].

GM-soy is estimated to be present in up to 70% of all food products found in US supermarkets, including cereals, breads, soymilk, pasta and most

North Nestucca Environmental Assessment Page 86

Appendix E – Attachment #9

meat (as animals are fed GM-soy feed). Although Monsanto has consistently relied on industry-funded data to declare the safety of GM-soy and glyphosate, objective research published in peer-reviewed journals tells another story.

Toxicity of Glyphosate A recently published study by Italian researchers [3] examined the toxicity of four popular glyphosate based herbicide formulations on human placental cells, kidney cells, embryonic cells and neonate umbilical cord cells and surprisingly found total cell death of each of these cells within 24 hours. The researchers reported several mechanisms by which the herbicides caused the cells to die including: cell membrane rupture and damage, mitochondrial damage and cell asphyxia. Following these findings, the researchers tested G, AMPA and POEA by themselves and concluded that, "It is very clear that if G, POEA, or AMPA has a small toxic effect on embryonic cells alone at low levels, the combination of two of them at the same final concentration is significantly deleterious.”

Damato, Gregory Ph.D., “GM-Soy: Destroy the Earth and Humans for Profit” Fourwinds10.com, May 27, 2009 http://www.fourwinds10.com/siterun_data/science_technology/dna_gmo/news.php?q=1 243529527

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Herbicide Safety Testing Opposing View #89 - “If you're still not convinced that Roundup is a highly toxic and persistent pesticide, read on, while at the same time remembering the other contributions that Monsanto has made to society such as:

Saccharin, Astroturf, agent orange, dioxin, sulphuric acid, polychlorinated biphenyls (PCBs), plastics and synthetic fabrics, research on uranium for

North Nestucca Environmental Assessment Page 87

Appendix E – Attachment #9

the Manhattan Project that led to the construction of nuclear bombs, styrene monomer, an endless line of pesticides and herbicides (Roundup), rBGH (recombinant bovine growth hormone that makes cows ill), genetically engineered crops (corn, potatoes, tomatoes, soy beans, cotton), and it's most significant product to date; Lies, Factual Distortions and Omissions. Here's one of the distortions that Monsanto had on its website a while back. ‘Sustainability - the idea that the resources and people of this world are finite. That for any business decision we make, we must consider the effect it will have on us and our children. That the products we make must not use up all of a natural resource, or even worse, contaminate what is left behind.’ "

“Everything you Never Wanted to Know about Monsanto’s Modus Operandi (M.O.)” Mindfully.org http://www.mindfully.org/Pesticide/Monsanto-Roundup-Glyphosate.htm

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Herbicide Safety Testing Opposing View #90 - “ "The U.S. response (to questions about biotech crop safety) has been an extremely patronizing one. They say 'We know best, trust us,'" added Gurian-Sherman, now a senior scientist at the Union of Concerned Scientists, a nonprofit environmental group.”

“So far, that confidence has been lacking. Courts have cited regulators for failing to do their jobs properly and advisers and auditors have sought sweeping changes.”

“The developers of these crop technologies, including Monsanto and its chief rival DuPont, tightly curtail independent scientists from conducting their own studies. Because the companies patent their genetic alterations,

North Nestucca Environmental Assessment Page 88

Appendix E – Attachment #9

outsiders are barred from testing the biotech seeds without company approvals.”

“The agreements disallow any research that is not first approved by the companies. "No truly independent research can be legally conducted on many critical questions regarding the technology," the scientists said in their statement.”

“Outside researchers have also raised concerns over the years that glyphosate use may be linked to cancer, miscarriages and other health problems in people.”

Gillam, Carey “Patents Trump Public Interest in Monsanto's Ag Empire - Special Report: Are Regulators Dropping the Ball on Biocrops?” Reuters, April 13, 2010 http://www.commondreams.org/headline/2010/04/13-0

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

------

Herbicide Safety Testing Opposing View #91 - “Defining Toxic Asbestos is an extreme example, which I use here and in my book Pick Your Poison: How Our Mad Dash to Chemical Utopia is Making Lab Rats of Us All to make a point, but many other “nontoxic” products could be full of toxic chemicals. I’m hoping this essay leaves you with a general distrust of the nontoxic label, both in the past and currently. When you see “nontoxic” on a product, keep the following facts in mind:

• “Nontoxic” can still legally mean that there are no immediate, acute hazards as determined by the LD50 and LC50 tests.

• “Nontoxic” may mean there are little or no chronic data available on the substance. If the substance is not acutely toxic, and one can’t

North Nestucca Environmental Assessment Page 89

Appendix E – Attachment #9

prove it is toxic in the long term, many manufacturers feel that they have the right to call it nontoxic. Even if there are studies showing that the substance is toxic, manufacturers in the United States have traditionally waited for absolute, unequivocal proof, which in most cases is never available because we don’t study our chemicals.

• An art material is “nontoxic” if a toxicologist paid by the manufacturer decides it is safe. The dramatic failure in this labeling procedure was illustrated with the lead ceramic glazes and asbestos-containing materials such as talc. Asbestos-containing talcs are still found in some art and craft materials today.

Some art materials that have never been evaluated by a toxicologist may be labeled “nontoxic” illegally due to weak enforcement of the art materials labeling law. For example, in 1995, a cameraman and a reporter from Channel 9 in New York went with me to a major art materials outlet. That night on the evening news, we showed viewers about a dozen imported products that did not conform to the law, some labeled “nontoxic,” which were being sold illegally. This is still true today, and a little research will lead you to many sources of noncompliant “nontoxic” products.

• Labeling of ordinary consumer products is pretty much up to the manufacturer and its paid advisers. Because there is no enforcement mechanism in the regulations for the chronic hazard labeling of ordinary consumer products, there is not much incentive to provide warnings.

• There is no regulatory requirement to warn consumers about damage to most of the body’s organs, such as the lungs, the liver, and the kidneys. Only four types of chronic hazards are covered by the Federal Hazardous Substances Act regulations. These are cancer, and developmental, reproductive, and neurological damage.”

Rossol, Monona “Say What? A Chemical Can Damage Your Lungs, Liver and Kidneys and Still Be Labeled "Non-Toxic"?” Ms. Rossol is a research chemist, author and member of the American Industrial Hygiene Association

North Nestucca Environmental Assessment Page 90

Appendix E – Attachment #9

May 9, 2011 http://www.alternet.org/story/150888/say_what_a_chemical_can_damage_your_lungs% 2C_liver_and_kidneys_and_still_be_labeled_%22non-toxic%22?page=entire

Response: T This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

Herbicide Safety Testing Opposing View #92 -

Monsanto's Claims Independent Research Findings Roundup has a low Roundup is amongst the top most reported irritational potential for eye pesticides causing poisoning incidents (mainly and skin and otherwise is skin irritation) in several countries. It also not a risk to human health. causes a range of acute symptoms including, recurrent eczema, respiratory problems, elevated blood pressure, allergic reactions. Roundup does not cause In laboratory tests on rabbits glyphosate any adverse reproductive caused long lasting, harmful effects on semen effects quality and sperm counts. Roundup is not mutagenic DNA damage has been observed in laboratory in mammals. experiments in mice organs and tissue. Roundup is environmentally • In the agricultural environment, safe. glyphosate is toxic to some beneficial soil organisms, beneficial arthropod predators, and increases crops' susceptibility to diseases. • Sub-lethal doses of glyphosate from spray drift damages wildflower communities and can affect some species up to 20 metres away from the sprayer. • The use of glyphosate in arable areas may cause dieback in hedgerow trees.

Roundup is rapidly • Glyphosate is very persistent in soils inactivated in soil and and sediments. water. • Glyphosate inhibited the formation of nitrogen fixing nodules on clover for 120 days after treatment. • Glyphosate residues were found in lettuce, carrot, and barley when planted

North Nestucca Environmental Assessment Page 91

Appendix E – Attachment #9

a year after glyphosate was applied.

Roundup is immobile and • Glyphosate can readily desorb from soil does not leach from soils. particles in a range of soil types. It can be extensively mobile and leach to lower soil layers. • Glyphosate can be carried by soil particles suspended in run off.

Roundup does not In the UK, levels of glyphosate above the EU contaminate drinking water limit have been detected by the Welsh Water when used by local Company every year since 1993. The authorities on hard Drinking Water Inspectorate recommends that surfaces. glyphosate be monitored, particularly, in areas where it is used by local authorities on hard surfaces. It is nearly impossible for In 1996, glyphosate resistant ryegrass was glyphosate resistance to discovered in Australia. evolve in weeds. Outcrossing in oilseed rape The densities of oil seed rape pollen are much crops (and the transfer of higher and their dispersal patterns differ from genes from transgenic around large fields compared to those found in crops) occurs over a short experimental plots. Wind dispersal of pollen distance and can be easily occurs over much greater distances and at managed. higher concentrations than predicted by experimental plots. Significant levels of gene flow from transgenic oil seed crops is inevitable. Roundup Ready crops will Herbicide resistant crops will intensify and reduce levels of herbicide increase dependency on herbicide use in use. agriculture rather than lead to any significant reductions. A variety of herbicides will have to be reintroduced to control glyphosate resistant volunteers, feral populations of crops and resistant weeds. Source: References cited in Health and Environmental Impacts of Glyphosate, (Details available from the Pesticides Trust [now PAN UK]).

PAN UK “Resistance to glyphosate”

This data was first published in Pesticides News No. 41, September 1998, page 5 http://www.pan-uk.org/pestnews/Issue/pn41/PN41p5.htm

North Nestucca Environmental Assessment Page 92

Appendix E – Attachment #9

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010). ------Conclusion The results of independent, unbiased research on glyphosate-containing herbicides indicate this chemical is causing: birth defects, non-Hodgkin’s lymphoma, mitochondrial damage, cell asphyxia, miscarriages, attention deficit disorder, endocrine disruption, DNA damage, skin tumors, thyroid damage, hairy cell leukemia, Parkinson disease, premature births, decrease in the sperm count, harm to the immune system in fish, death of liver cells, severe reproductive system disruptions and chromosomal damage.

Non-native plants are causing havoc to the native forest ecosystems. However, this does not justify inflicting mammals & birds (including human visitors to the forest) with one of the many physical problems listed above. Fish? Just a minor amount of spray that contact water will kill aquatic life.

It’s unethical and unprofessional to apply this tragic poison to land owned by other people just because the forest service’s dated approval documents say it’s OK.

There are more costly (yet equally effective) alternatives to deadly herbicides when eradicating non-native plants. Please use them. This is a government expenditure that the public would support.

Last, please read Dan Rather’s very recent September 22, 2011 investigative report about the EPA’s corrupt approval process of man-made chemicals: http://www.panna.org/blog/dan-rather-pesticides-bees

North Nestucca Environmental Assessment Page 93

Appendix E – Attachment #9

Response: This project does not propose to use any herbicides. Any invasive weeds present according to the protocols in the Siuslaw Invasive Plant Treatment Project (EA) (2010).

North Nestucca Environmental Assessment Page 94

Appendix E – Attachment #15

Opposing Views Attachment #15

Forest Service Leaders Stress that Independent, Unbiased Science Conclusions should Always form the Basis for Proposed Public Land Treatments This project does not reflect best science. The agency leader’s statements below emphasizing best science are therefore opposing views.

Since the NEPA document References ONLY include literature that supports the project (with the vast majority of authors employed by the USDA) it clearly is not best science. The majority of references should be authored by unbiased, independent scientists.

Response: The North Nestucca EA cites 193 different references, the source of those references is as follows. Scientific Journals ----– 28% Books, thesis. Etc. –---- 13% USDA Forest Service –- 30% Other US Government – 22% State –------7%

The Responsible Official’s volume output goals might be compromised if some of the source literature for the opposing views were included in the References.

It’s illegal to tell the public half of the story and withhold information that might jeopardize the project.

North Nestucca Environmental Assessment Page 1

Appendix E – Attachment #15

Response: All practical means to avoid or minimize environmental harm have been adopted in the design of the Selected Alternative. Included in the project design features and mitigation measures that I believe are necessary to avoid, minimize, or rectify impacts on resources affected by implementation of the Selected Alternative. Conclusions are based on a review of the record that shows a thorough review using the best available science. The resource analyses disclosed in Chapter 3 of the EA identify the effects analysis methodologies, reference scientific sources which informed the analysis, and disclose limitations of the analysis.

Best Science Opposing View #1 - "The agency has been able to face changing and challenging times and incorporate new information based on science."

"I am very much involved in trying to integrate the science and the management sides of the Forest Service. It’s very, very important that we conduct that integration, because our management decisions are scientifically based, and there is an ever increasing need for more scientific information."

Excerpts from an interview with Hilda Diaz-Soltero Associate Chief for Natural Resources, USDA Forest Service Women in Natural Resources, Vol. 21, No. 3 August 2000 http://www.fs.fed.us/publications/2000/00nov02-Hilda-Diaz-Soltero-Interview.pdf

Response: We used the most site specific and relevant scientific information in developing the Proposed Action and analyzing its effects in the Project EA.

------Best Science Opposing View #2 - "Forest Service managers strive to use the best science available in their decision making."

Dr. Ann Bartuska, Deputy Chief for Research and Development, USDA Forest Service Excerpt from testimony before the House Resources Forest and Forest Health Subcommittee July 15, 2004 http://www.fs.fed.us/congress/108/house/oversight/bartuska/071504.html

North Nestucca Environmental Assessment Page 2

Appendix E – Attachment #15

Response: We used the most site specific and relevant scientific information in developing the Proposed Action and analyzing its effects in the Project EA.

------Best Science Opposing View #3 - "We are committed to accomplishing the aggressive treatments planned in the President’s Budget for FY 2005 using new authorities in the Healthy Forests Restoration Act that improve the condition class of the nation’s watersheds and thus protect communities and resources for future generations, and our Research Station directors are committed to providing the Forest Service with the best science available."

Dale Bosworth Chief, USDA Forest Service Excerpt from a statement before the Committee on Energy and Natural Resources United States Senate March 3, 2004 http://www.ourforests.org/fact/bosworthtestimony0304.pdf

Response: We used the most site specific and relevant scientific information in developing the Proposed Action and analyzing its effects in the Project EA.

------Best Science Opposing View #4 - “Our direction will address these emerging issues to ensure it is based on the available best science.”

Sally Collins Associate Chief USDA Forest Service Excerpt from testimony before the Committee on Energy and Natural Resources, United States Senate July 11, 2006 http://www.fs.fed.us/congress/109/senate/oversight/collins/071106.html

Response: Wind energy is not a proposed action in the Project EA. Other emerging issues were analyzed in the Project EA using the best available science.

North Nestucca Environmental Assessment Page 3

Appendix E – Attachment #15

------Best Science Opposing View #5 - "The American people have come to expect us to use the best science, and we ought to use the best science." (pg.4)

Dale N. Bosworth Chief USDA Forest Service Excerpt from a speech on Sustainable Management of the National Forests, at the Andrus Center for Public Policy, Boise State University December 12, 2001 http://www.andruscenter.org/images/transcripts/Sustainable_transcript.pdf

Response: We have used the most site specific and relevant science in developing the Proposed Action and analyzing its effects in the Project EA. We have incorporated new, relevant information as it becomes available in the scientific literature or from other sources such as public comments.

------Best Science Opposing View #6 - "Always use the best science. Science can’t decide for us, but it can help us understand the consequences of our decisions. Forest Service Research and others in academia can deliver some of the best science and technical resources to help inform how these special areas should be managed for the long term."

Sally Collins Associate Chief USDA Forest Service Excerpt from a speech to the Land Trust Alliance Rally “Protecting Open Spaces: Partners in a Common Cause” October 31, 2004 http://www.fs.fed.us/news/2004/speeches/10/open-spaces.shtml

Response: We have incorporated that approach in developing our Proposed Action and analyzing its effects based on the design criteria in Appendix A.

------

North Nestucca Environmental Assessment Page 4

Appendix E – Attachment #15

Best Science Opposing View #7 - "The new rule directs forest managers to use the best science available to protect species at a landscape level. The emphasis is to preserve ecosystems as a whole."

Statement by Heidi Valetkevitch National Media Officer USDA Forest Service to Joe Bauman, reporter for the Deseret Morning News December 24, 2004 http://www.deseretnews.com/article/600100084/New-forest-rules-focus-on-holistic- approach.html

Response: We have incorporated that approach in developing our Proposed Action and analyzing its effects based on the design criteria in Appendix A.

------Best Science Opposing View #8 - On June 29, 2007, Chief of the Forest Service, Gail Kimbell expressed her support of employees participating in professional societies. The following is an excerpt from her support letter:

“As stewards of forests and rangelands, we must respond to the many challenges of managing a wide variety of resources and values. To meet these various challenges, a diverse and highly qualified cadre of natural resource and other professionals is critical to assure that management approaches are based on the best science. More than ever, it is important for each of us to continue to learn, enhance our resource knowledge, and develop innovative approaches to cooperatively conserve this Nation’s natural resources.” (pg. 5)

Brown, Joel “Power to the People!” SRM Rangeland News, November 2007 http://www.rangelands.org/RN/Nov.RN07.pdf

Response: Several interdisciplinary team members for the Project EA regularly attend professional society meetings and other related trainings, read relevant scientific literature and communicate with scientists to ensure that they are using the most recent and best available science. The best available science was used to develop the Proposed Action and its design criteria and to analyze its effects.

North Nestucca Environmental Assessment Page 5

Appendix E – Attachment #15

------Best Science Opposing View #9 - “The Forest Service must be a leader in using the best science and the best managers to accomplish what I think is one of the noblest, most important callings of our generation bringing people together and helping them find ways to live within the limits of the land." (Pg. 30)

Statement by Chief Dr. Mike Dombeck “Forest Chief Shifts focus to clean water” April 1998 TRANSITIONS http://www.waterplanet.ws/transitions/tr9804/

Response: The Proposed Action was developed to restore terrestrial and aquatic conditions and processes based on the best available science.

------Best Science Opposing View #10 - “We have made great progress under New Perspectives to get land managers and scientists working together as a team in doing the best job possible. Let’s keep it up and make sure our decisions reflect the best science and close the gap between the level of scientific knowledge and its application in our day-to-day management.”

Chief F. Dale Robertson From a June 4, 1992 direction letter to Regional Foresters and Station Directors, Appendix B http://www.fs.fed.us/r1/wmpz/documents/existing-forest-plans/lolo_5_yr_review.pdf

------

North Nestucca Environmental Assessment Page 6

Appendix E – Attachment #15

Best Science Opposing View #11 - “In 1994 Chief Jack Ward Thomas of the U.S. Forest Service invited private foundations to join the USFS and other federal resource management agencies in co-funding a national workshop designed to bring the best science, broadly defined, to an 11-day workshop of agency natural resource managers.1 Having a science background himself, Thomas wanted to capture the scientific underpinnings of ecosystem dynamics in order to establish a more solid basis for sustainable resource management. Private foundations, invited for the first time to join the Forest Service in this way, would, Thomas felt, add legitimacy and assist in bringing in scientific talent from outside the government.”

Smith, Ted “Chief's Ecosystem Stewardship Conference Workshop Review” Eco-Watch, February 26, 1996 http://www.fs.fed.us/eco/eco-watch/ew960226.htm Response: Interdisciplinary team members for the Project regularly communicate and collaborate with many different people including professionals from government and non-government organizations, watershed councils, state agencies, scientists, and a variety of interest groups. These interactions are fundamental to landscape level management on and off the Siuslaw National Forest.

------Best Science Opposing View #12 - "Our challenge is to protect all the different uses of our forests which well-kept roads undoubtedly serve while protecting these remaining untouched places. This is a long and delicate process. It will not happen overnight. We must rely on the best science and broad-based public participation. But in the interim, I am prepared to authorize an 18-month moratorium on the construction of new roads in the last pristine areas of our national forests.”

Agriculture Secretary Dan Glickman From an Announcement of Interim Ban on Forest Road Construction Washington, D.C., February 11, 1999 http://www.usda.gov/news/releases/1999/02/0056

Response: We are not proposing any new permanent road construction. About3 miles of temporary road would be constructed for thinning and would be closed after

North Nestucca Environmental Assessment Page 7

Appendix E – Attachment #15

the thinning is completed. None of the actions are proposed in designated roadless areas.

------Best Science Opposing View #13 - “We have some of the best science, and we need to make sure we’re applying that, using that and sharing that as we move forward. I think we have a key leadership role, not only in the application of science but to help inform and educate our community and the folks we work with.”

Statement by USFS Chief Tom Tidwell From an interview with Rob Chaney of the Missoulian, June 19, 2009 http://westinstenv.org/sosf/2009/06/19/tidwell-interviewed-by-the-missoulian/

Response: The Proposed Actions in the Project EA are based on the best available science. Implementation of the activities in the Project EA would require regular communication and education with a wide variety of individuals and interest groups.

------Best Science Opposing View #14 - “Since that time, they have consulted with a wide array of scientists in the Forest Service, other agencies, universities, and consultants, with the aim of arriving at a consensus on the best science available to address this issue.”

Potyondy, John P. 2007 “The Evolution of Channel Maintenance Science in the Forest Service” Mr. Potyondy is the WO Watershed, Fish, Wildlife, Air, and Rare Plants Staff http://www.stream.fs.fed.us/afsc/pdfs/Potyondy.pdf

Response: The Proposed Action will not alter stream flows or affect channel maintenance flows.

North Nestucca Environmental Assessment Page 8

Appendix E – Attachment #15

------Best Science Opposing View #15 - “The FS manages the National Forest System's natural resources with a commitment to long term ecosystem sustainability, multiple use, local community involvement and economic stability, interaction of social and cultural values with forest resource management, and the use of management practices based on the best science available.”

Melle, Ann R. “The U.S. Forest Service Approach to Forest Law Enforcement” A presentation to the East Asia Ministerial Conference, September 12, 2001 Ms. Melle is the Asst. Director of Law Enforcement and Investigations, USDS Forest Service http://www.for.gov.bc.ca/hfd/library/documents/bib49682.pdf

Response: Comment noted.

------Best Science Opposing View #16 - “ “The responsible policy maker ought to seek out the best science, because ultimately that will yield the best result.". “

“To put things in perspective, Dombeck says, "Science should not be the only driver of policy; there are economic, social and political concerns, but ... scientists can provide information that informs policymaking; 'If we adopt this policy, this will be the outcome,' and that certainly does not appear to be happening." “

Statements by retired Chief Dr. Mike Dombeck “Politics vs. Science,” October 19, 2006 Published by the University of Wisconsin, Board of Regents. http://whyfiles.org/247sci_politics/index.php?g=5.txt

Response: The Project EA is directed by current policy, the Proposed Actions, its design criteria and its analysis of effects are based on the best available science.

North Nestucca Environmental Assessment Page 9

Appendix E – Attachment #15

------Best Science Opposing View #17 - “Carefully done science can provide common ground for agreement among different stakeholders, enabling communities to unify.”

“The best science available tells us that at some point we must reinstall this missing ecosystem process so the natural machinery functions properly again.” (pg. 9)

Kaufmann, Merrill R. 2005 “Good Fire,Bad Fire” Mr. Kaufmann is the Rocky Mountain Research Station's team leader for ecosystem management Fort Collins, CO, USDA Forest Service http://csfs.colostate.edu/pdfs/Good_Fire_Bad_Fire.pdf

Response: The Project will only treat excess fuels created by thinning near open roads.

------Best Science Opposing View #18 - “The general objective of this Symposium was to build on the best science and technology available to assure that the data and information produced in future inventory and monitoring programs are comparable, quality assured, available, and adequate for their intended purposes, thereby providing a reliable framework for characterization, assessment, and management of forest ecosystems in North America.”

Bravo, Aguirre Celedonio and Carlos Rodriguez Franco, compilers 1999. North American Science Symposium: Toward a Unified Framework for Inventorying and Monitoring Forest Ecosystem Resources. Guadalajara, Mexico (November 2-6,1998). Proceedings RMRS-P-12. U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station http://cwt33.ecology.uga.edu/publications/pubs_martha_new_01282003/Batch_2_@300 dpi/PDF/1389.pdf

North Nestucca Environmental Assessment Page 10

Appendix E – Attachment #15

Response: The Project was not specifically designed to mitigate or respond to climate change. The benefits to forest health and resiliency of the Proposed Action would allow the project area to better respond and adapt to climate change.

------Best Science Opposing View #19 - “The experience of the Zaca Fire demonstrates a window of opportunity to improve the link between science and management. A major concern often expressed in both fire research and fire management circles is that there is a lot of science being produced, but very little that can or is being incorporated (depending on your perspective) into fire management. There may be a current opening to change that state of affairs.”

McDaniel, Josh 2007 “The Zaca Fire: Bridging Fire Science and Management” Widland Fire Lessons Learned, http://www.wildfirelessons.net/Additional.aspx

Response: The Project will only treat excess fuels created by thinning adjacent to open roads.

------Best Science Opposing View #20 - “Accordingly, we find that the Final EIS fails to disclose and discuss responsible opposing scientific viewpoints in the final statement itself in violation of NEPA and the implementing regulations. We therefore reverse the district court's grant of summary judgment and remand to the district court with directions that it remand the final statement to the Forest Service for further proceedings consistent with this opinion. See Vitarelli v. Seaton, 359 U.S. 535, 545, 79 S.Ct. 968, 3 L.Ed.2d 1012 (1959) (standing for the well-established principle that an agency is generally required to follow its regulations); see also Cal. v. Block, 690 F.2d at 769 (“Agencies are ․ obliged to adhere to the procedures mandated by NEPA.”) (citing Vt. Yankee Nuclear Power Corp. v. Natural Res. Def. Council, Inc., 435 U.S. 519, 549 n. 21, 98 S.Ct. 1197, 55 L.Ed.2d 460 (1978)).

North Nestucca Environmental Assessment Page 11

Appendix E – Attachment #15

REVERSED AND REMANDED.”

CENTER FOR BIOLOGICAL DIVERSITY v. UNITED STATES FOREST SERVICE Argued and Submitted July 15, 2003. -- November 18, 2003 Before: KLEINFELD, WARDLAW, Circuit Judges, and POGUE, Judge. In the United States Court of Appeals,Ninth Circuit http://caselaw.findlaw.com/us-9th-circuit/1173711.html

Response: The Project EA has documented and addressed the best available science, including relevant opposing viewpoints.

North Nestucca Environmental Assessment Page 12

Appendix F

North Nestucca Environmental Assessment References

Abbe, T.B., and D.R. Montgomery. 1996. Large woody debris jams, channel hydraulics and habitat formation in large rivers. Regulated Rivers: Research and Management 12:201-222. Adams, J. N., & R. L. Beschta. 1980. Gravel bed composition in Oregon coastal streams. Can. J. Fish. Aquat. Sci. 37: 1514-1521. Alig, R.J. 2003. Biology, ecology, and economics at play: land use and land cover changes in the 21st century. Science Findings, Issue 55. Portland, OR: Department of Agriculture, Pacific Northwest Research Station. Altman, Bob, 1999, Conservation strategy for landbirds in coniferous forests of western Oregon and Washington, Version 1.0: Oregon-Washington Partners in Flight. Altman, Bob, Hagar, Joan, 2007, Rainfoest Birds: A Land Manger’s Guide to Breeding Bird Habitat in Young Conifer Forests in the Pacific Northwest, U.S. Geological Survey, Scientific Investigations Report 2006-5304, 60 p Anlauf, K. J., K. K. Jones, and C.H. Stein. 2009. The Status and Trend of Physical Habitat and Rearing Potential in Coho Bearing Streams in the Oregon Coastal Coho Evolutionary Significant Unit. OPSW-ODFW-2009-5, Oregon Department of Fish and Wildlife, Salem. Anderson, H.E. 1982. Aids to determining fuel models for estimating fire behavior. Gen. Tech. Rep. INT-122. Boise, ID: Department of the Interior, Bureau of Land Management, Boise Interagency Fire Center. 22 p. Anderson, P.D. et al. 2007. Riparian buffer and density management influences of microclimate of young headwater forests of western Oregon. [Journal] Forest Snow and Landscape Research. 53 (2007) 254-268. Andrews et al. 2005. Silvicultural approaches to develop northern spotted owl nesting sites, central coast ranges, Oregon. Western Journal of Applied Forestry. Andrews, P.T. 1986. Fire behavior prediction and fuel modeling system. Gen. Tech. Rep. INT- 94. Boise, ID: Department of the Interior, Bureau of Land Management, Boise Interagency Fire Center. Antoine, M.E. and B. McCune. 2004. Contrasting fundamental and realized ecological niches with epiphytic lichen transplants in old-growth Pseudotsuga forest. The Bryologist 107 (2): 163-173. April 2005 Final Environmental Impact Statement (FEIS) for the Pacific Northwest Region Invasive Plant Program: Preventing and Managing Invasive Plants (USDA 2005a) Ares, A., S. D. Berryman, and K. J. Puettmann. 2009. Understory vegetation response to thinning disturbance of varying complexity in coniferous stands. Journal of Applied Vegetation Science. 12(4): 472-487 Assmann, E. 1970. The principles of forest yield study. Pergamon Press, New York, NY. 506 p Aubry, Keith B., Jeffrey C. Lewis. 2002. Extirpation and reintroduction of fishers (Martes pennanti) in Oregon: implications for their conservation in the Pacific states. Biological Conservation 114 (2003) 79-90. Badura, George J., Legard, Harold A. and Meyer, LeRoy C., June, 1974, Siuslaw National Forest

North Nestucca Environmental Assessment Page 1 Appendix F

Soil Resource Inventory, Pacific Northwest Region, 139 p. Bailey, J.D.; [and others]. 1998. Understory vegetation in old and young Douglas-fir forests of western Oregon. Forest Ecology and Management. 112 (1998) 289-302. Bailey, J. D., and J. C. Tappeiner. 1998. Effects of thinning on structural development in 40- to 100-year-old Douglas-fir stands in western Oregon. For. Ecol. and Manage. 108:99-113. Bare, B. B.; Gustafson, R.; Mote, P.; Brubaker, L.; Perez-Garcia, J. 2005. Effect of global climate change on northwest forests. University of Washington. Denman Forestry Issues. Retrieved December 15, 2007 from http://uwtv.org/programs/displayevent.aspx?rID=2797 Beechie, T. J., and T.H. Sibley. 1997. Relationships between channel characteristics, woody debris, and fish habitat in northwest Washington streams. Transactions of the American Fisheries Society 126:217-229. Beechie, T.J., G. Press, P. Kennard, R.E. Bilby, and S. Bolton. 2000. Modeling recovery rates and pathways for woody debris recruitment in northwestern Washington streams. North American Journal of Fisheries Management 20:436-452. Benda, L. E., and T. W. Cundy. 1990. Predicting deposition of debris flows in mountain channels. Canadian Geotechnical Journal. 27:409-417. Berg, L, and T.G. Northcote. 1985. Changes in territorial, gill-flaring, and feeding behavior in juvenile coho salmon (Oncorhynchus kisutch) following short-term pulses of suspended sediment. Can. J. Fish. Aquat. Sci., 42:1410-1417. Beschta, R.L. 1980. Turbidity and suspended sediment relationships. In Proceedings of Watershed Management Symposium, Irrigation and Drainage Division, Amer. Soc. Civil Engineers, Boise, Idaho, July 21-23, 1980. 1-12. Bilby, R.E. 1985. Contributions of road surface sediment to a western Washington stream. For. Sci. 31:827-838 Bilby, R. E., K. Sullivan, and S. H. Duncan. 1989. The generation and fate of road-surface sediment in forested watersheds in southwestern Washington, Forest Science, 35(2), 453-468. Bilby, R.E. and J.W. Ward, 1989. Changes in Characteristics and Function of Woody Debris with Increasing Size of Streams in Western Washington. Transactions of the American FisheriesSociety 118:368-378. Bilby, R.E., and J.W. Ward. 1991. Large woody debris characteristics and function in streams draining old-growth, clear-cut, and second-growth forests in southwest Washington. Canadian Journal of Fisheries and Aquatic Sciences 48:2499-2508. Bisson, P.A., and R.E. Bilby. 1982. Avoidance of suspended sediment by juvenile coho salmon. North Amer. J. Fish. Mange. 4:371-374. Brown, E. Reade (ed). 1985. Management of Wildlife and Fish Habitats in Forests of Western Oregon and Washington (two volumes). USDA Forest Service, Pacific Northwest Region. Publication No.: R6-F&WL-192-1985. Pacific Northwest Region, 319 SW Pine, PO BOX 3623, Portland, Oregon 97208. Brown, G.W., 1988. Forest and Water Quality. OSU Bookstores, Inc., Memorial Union, Oregon State University, Corvallis, Oregon.

North Nestucca Environmental Assessment Page 2 Appendix F

Brown, G.W., and J.T. Krygier. 1971. Clear-cut logging and sediment production in the Oregon Coast Range. Water Res. Research 7(5) 1189-1198. Burnett, K.M., G.H. Reeves, D.J. Miller, S. Clarke, K. Vance-Borland, and K. Christianson. 2007. Distribution of salmon-habitat potential relative to landscape characteristics and implications for conservation. Ecological Applications 17(1):66-80. Burns, Russell M.; Honkala, Barbara H. (tech. Coords.) 1990. Silvics of North America: 1. Conifers; 2. Hardwoods. Agriculture Handbook 654, U.S. Dept. of Agriculture, Forest Service, Washington, D.C. vol.2. Carey, A.B.; Lippke, B.R.; Sessions, J. 1999. Intentional systems management: managing forests for biodiversity. Journal of Sustainable Forestry, Vol. 9 (3/4). Carey, A.B. 2003. Restoration of landscape function: reserves or active management; biocomplexity and restoration of biodiversity in temperate coniferous forest: inducing spatial heterogeneity with variable density thinning [2 papers in same journal]. Forestry, Vol. 76, No. 2. Carey, Andrew B.; AIMing for Healthy Forests: Active, Intentional Management for Multiple Values, USDA Forest Service, PNW Research Station, GTR PNW-GTR-721, November 2007. Castellano, M; J. Smith, T. O’Dell, E. Cázares, S. Nugent. 1999. Handbook to strategy 1 fungal species in the Northwest Forest Plan. General Technical Report PNW-GTR-476. Porland, OR. U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station. 195 p. Castellano, M; E. Cázares, B. Fondrick, and T. Dreisbach. 2003. Handbook to additional fungal species of special concern in the Northwest Forest Plan. General Technical Report PNW-GTR- 572. Portland, OR. U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station. 144 p. Chan, S.S., K. Mass-Hebner, and W. Emmingham. 1996. “Thinning Hardwood and Conifer Stands to Increase Light Levels: Have You Thinned Enough?” COPE Report 9(4): 2-6. Chan, S.S., M.D. Bailey, D. Karnes, R. Metzger, W.W. Kastner, Jr., 1997 “The Role of Silviculture in the Active Management of Riparian Zone Vegetation in the Oregon Coast Range: a Partnership between Researchers and Managers. Published from the proceedings of the National Silvicultural Workshop, May 21-23, 1997 GTR 238, Warren, Pennsylvania. Chan, S.S., D.Larson, P.D. Anderson. 2004. Microclimate patterns associated with density management and riparian buffers. An interim report on the Riparian Buffer Component of the Density Management Studies. USDI BLM and USDA Forest Service, Corvallis, OR. Chan, S.S. et al. 2004. Variable density management in riparian reserves: lessons learned from an operational study in managed forests of western Oregon, USA. [Report]. Forest Snow and Landscape Research. 78 (2004) 151-172. Chan, S.S., D.J. Larson, K.G. Maas-Hebner, W.H.Emmingham, S.R. Johnston, and D.A. Mikowski, 2006, Overstory and understory development in thinned and underplanted Oregon Coast Range Douglas-fir stands, Can J. For. Res., v. 36, p. 2696-2711. Chappell, HN, and A Osawa. 1991. The Stand Management Cooperative: A cooperative research program in silviculture, growth and yield, and wood quality in the Pacific Northwest. Hoppa Ringyo 43: 7–11. Christy, R.E. and S.D. West. 1993. Biology of bats in Douglas-fir forests. In M.H. Huff, R.M.

North Nestucca Environmental Assessment Page 3 Appendix F

Holthausen, K.B. Aubry, tech eds. Biology and management of old-growth forests. Gen. Tech. Rep. PNW-GTR-308. USDA Forest Service, Pacific NW Res. Station. Portland, OR. Csuti, B., T.A. O’neil, M.M. Shaughnessy, E.P. Gaines and J.C. Hak 2001. Atlas of Oregon Wildlife, Distribution, Habitat, and Natural History. OSU Press, Corvallis, OR 525 pp. Curtis, R. O., and D. D. Marshall. 1986. Levels-of-growing-stock cooperative study in Douglas- fir: Report no. 8 —the LOGS study: Twenty-year results. Res. Pap. PNW-356. USDA Forest Service, Pacific Northwest Research Station, Portland, OR. 113 p Curtis, R.O. and Carey, A.B. 1996. Timber supply in the Pacific Northwest: managing economic and ecological values in Douglas-fir forests. Journal of Forestry 94(9): 4-7, 35-37. Curtis, R.O.; DeBell, D.S.; Dean, S.; Harrington, C.A.; Lavender, D.P.; St. Clair, J.B.; Tappeiner, J.C.; and Walstad, J.D. 1998. Silviculture for multiple objectives in the Douglas-fir region. General Technical Report PNW-GTR-435. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station. 123 p. Deal, R.L. 2006. Red alder stand development and dynamics. In: Deal, R.L. and C.A. Harrington, eds. Red alder – a state of knowledge. General Technical Report PNW-GTR-669. Portland, OR: U.S. Department of Agriculture, Pacific Northwest Research Station: 45-54. DeBell, D.S. and Giordano, P.A. 1994. Growth patterns of red alder stand development and dynamics. In: Hibbs, D.E.; DeBell, D.S.; Tarrant, R.F., eds. The biology and management of red alder. Corvallis, OR: Oregon State University Press: 116-129. Dent, L., D.Vick, K. Abraham, S. Schoenholtz, and S. Johnson. 2008. Summer temperature patterns in headwater streams of the Oregon Coast Range. Journal of the American Water Resources Association 44(4): 803-813. Dodson, E. K., A. Ares, and K.J. Puettmann. 2012. Early responses to thinning treatments designed to accelerate late successional forest structure in young coniferous stands of western Oregon, USA. Canadian Journal of Forest Research. 42(2): 345–355 Duncan, S.H., R.E. Bilby, J.W. Ward, and J.T. Heffner. 1987. Transport of Road-Surface Sediment through Ephemeral Stream Channels. Water Resources Bulletin Vol 23. No. 1: 113- 119. Elliot, J. W. 2000. Roads and Corridors. In: Dissmeyer, G.E. (Editor). 2000. Forest and Grasslands: A Synthesis of Scientific Literature. General Technical Report SRS-39, Ashville, North Carolina: USDA Forest Service, Southern Research Station. Everest, F.H., R.L. Beschta, J.C. Scrivener, K.V. Koski, J.R. Sedell, and C.J. Cederholm. 1987. Fine sediment and salmonid production: a paradox. In E.O. Salo and T.W. Cundy (eds.) Streamside Management: Forestry and Fisheries Interactions, p. 98-142. FEMAT (Forest Ecosystem Management Assessment Team) 1993. Forest ecosystem management: an ecological, economic, and social assessment. US Government Printing Office 1993-793-071, USDA Forest Service, USDI Fish and Wildlife Service, Bureau of Land Management, and National Park Service, USDC National Oceanic and Atmospheric Administration and National Marine Fisheries Service, and US Environmental Protection Agency. Five Rivers Landscape Management Project Final EIS (USFS 2002c)

North Nestucca Environmental Assessment Page 4 Appendix F

Forsman, E.D.; Giese, A. 1997. Nests of northern spotted owls on the Olympic peninsula, Washington, Wilson Bull. 109(1), 1997, pp. 28-41. Franklin, J.F. and C.T. Dyrness, 1973. Natural Vegetation of Oregon and Washington. GTR PNW 8. Portland, OR. USDA, Forest Service. FVS web site - http://www.fs.fed. us/fmsc/fvs/index.shtml GeoBob. 2008. Inter-agency Geographic Biotic Observations. Ad hoc query of database downloaded from http://www.or.blm.gov/geobob/SM_Data/default.asp. Glenn, E.M.; Hansen, M.C.; Anthony, R.G. 2004. Spotted owl home-range use in young forests of western Oregon. Journal of Wildlife Management 68(1): 39-56. Grant, Gordon E.; Lewis, Sarah L.; Swanson, Frederick J.; Cissel, John H.; McDonnell, Jeffrey J. 2008. Effects of forest practices on peak flows and consequent channel response: a state-of- science report for western Oregon and Washington. Gen. Tech. Rep. PNW-GTR-760. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station. 76 p. Groom, J.D.; Dent, L; Madsen, L.J.; and Fleuret., J. [In press]. Response of Western Oregon (USA) Stream Temperatures to Contemporary Forest Management. Forest Ecology Mangagement. doi:10.1016/j.foreco.2011.07.012 Guenther, K. and T.E. Kucera. 1978. Wildlife of the Pacific Northwest: occurrence and distribution by habitat, BLM district and national forest. USDA Forest Service, Pacific NW Region. Hadfield, James S., D.J. Goheen, G.M. Filip, D.L., Schmitt and R.D. Harvey, 1986. Root Disease in Oregon and Washington Conifers. USDA Forest Service, PNW Region. Hagar, J.; Howlin, S. 2001. Songbird community response to thinning of young Douglas-fir stands in the Oregon Cascades--Third year post-treatment results for the Willamette National Forest young stand study. Corvallis, OR: Department of Forest Resources, Oregon State University. 7 p. Hann, D. W.; Marshall, D. D.; Hanus, M. L. 2006. Re-Analysis of the SMC-ORGANON Equations for Diameter-Growth Rate, Height-Growth Rate, and Mortality Rate of Douglas-Fir. Oregon State University Forest Research Laboratory Research Contribution 49. 24p. Harr, R. D. 1977. Water Flux in Soil and Subsoil on Steep Forested Slope. Journal of Hydrology, 33(1977) 37-58. Hassan, M.A., M. Church, T.E. Lisle, F. Brardinoni, L. Benda, and G.E. Grant, 2005a. Sediment Transport and Channel Morphology of Small, Forested Streams. Journal of the American Water Resources Association, (JAWRA) 41(4):853-876. Hays, David W., Kelly R. McAllister, Scott A. Richardson, and Derek W. Stinson. 1999. Washington State Recovery Plan for the Western Pond Turtle. Washington Department of Fish and Wildlife. 66 pp. http://www.wa.gov/wdfw/wlm/diversty/soc/recovery/pondturt/wptfinal.pdf Heimann, D.C. 1988. Recruitment trends and physical characteristics of coarse woody debris in Oregon Coast streams. MS Thesis, Oregon State University, Corvallis, Oregon. Hemstrom, Miles A., and Sheila E. Logan, 1986. Plant Association and Management Guide Siuslaw National Forest. USDA Forest Service, PNW Region. R6Ecol 2201986A Hibbs, D.E. and DeBell, D.S. 1994. Management of young red alder. In: Hibbs, D.E.; DeBell,

North Nestucca Environmental Assessment Page 5 Appendix F

D.S.; Tarrant, R.F., eds. The biology and management of red alder. Corvallis, OR: Oregon State University Press: 202-215. Hibbs, D.E. and P.A. Giordano. 1996. Vegetation characteristics of alder-dominated buffer strips in the Oregon coast Range. Northwest Science 70:213-222 Hibbs, D.E., and A.L. Bower. 2001. Riparian forests in the Oregon Coast Range. Forest Ecology and Management 154:201-213. Hobbs, Stephen D, (et al.) [Editors] 2002. Forest and Stream Management in the Oregon Coast Range. OSU Press, Corvallis, OR 276 pp. Huff, Mark H.; Raphael, Martin G.; Miller, Sherri L.; Nelson, S. Kim; Baldwin, Jim, tech. coords. 2006. Northwest Forest Plan—The first 10 years (1994-2003): status andtrends of populations and nesting habitat for the marbled murrelet. Gen. Tech. Rep. PNW-GTR-650. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station. 149 p. Impara, P.C. 1997. Spatial and temporal patterns of fire in the forests of the central Oregon Coast Range. A dissertation submitted to Oregon State University in partial fulfillment of the requirements for the degree of Doctor of Philosophy in geography. Corvallis, OR: Department of Geography, Oregon State University. IMST (Independent Multidisciplinary Science Team). 1999. Recovery of Wild Salmonids in Western Oregon Forests: Oregon Forest Practices Act Rules and the Measures in the Oregon Plan for Salmon and Watersheds. Technical Report 1999-1 to the Oregon Plan for Salon and Watersheds, Governor’s Natural Resources Office, Salem, Oregon. [IPCC] Intergovernmental Panel on Climate Change. 2007. Climate change 2007: the IPCC fourth assessment report. Working Group III Report "Mitigation of Climate Change" Chapter 9, Cambridge, UK: Cambridge University Press. ISSSSP 2007. Inter-agency Special Status Sensitive Species Program. USDI-USDA. Conservation Assessment for Fungi Included in Forest Service Regions 5 and 6 Sensitive and BLM California, Oregon and Washington Special Status Species Programs, Appendix 1. Unpublished report available on-line at http://www.fs.fed.us/r6/sfpnw/issssp/ Johnson, D.H. and T.A. O’Neil. 2001. Wildlife Habitat Relationships in Oregon and Washington. Oregon State University Press, 101 Waldo Hall, Corvallis, Oregon, 7331-6407. Johnson, S. 2004. Summary of habitat and fish monitoring data from East Fork and Upper Mainstem Lobster Creeks: 1988-2004. Oregon Dept. Fish. & Wildlife, Corvallis OR. Johnson, S.L. 2004. Factors influencing stream temperatures in small streams: substrate and a shading experiment. Canadian Journal of Fisheries and Aquatic Science 61:913-923. Jones, J.A. 2000. Hydrologic processes and peak discharge response to forest removal, regrowth, and roads in 10 small experimental basins, western Cascades, Oregon. Water Resources Research. 36(9): 2621–2642. Jones, J.A.; Grant, G.E. 1996. Peak flow responses to clear-cutting and roads in small and large basins, western Cascades, Oregon. Water Resources Research.32: 959–974. Juday, G.P., 1977. The Location, Composition, and Structure of Old-growth Forests of the Oregon Coast Range. Ph.D. Thesis, Oregon State University, Corvallis, OR.

North Nestucca Environmental Assessment Page 6 Appendix F

Kennedy, R.S.H., and T.A. Spies. 2004. Forest cover changes in the Oregon Coast Range from 1939 to 1993. Forest Ecology and Management 129-147 King, J.E. 1966. Site index curves for Douglas-fir in the Pacific Northwest. Weyerhaeuser Forestry Paper No. 8. Centralia, WA. Weyerhaeuser Company Forestry Research Center. Lancaster, S.T., Hayes, S.K., and G.E. Grant. 2003. Effects of wood on debris flow runout in small mountain watersheds: Water Resources Research, v. 39, p. 1168, doi: 10.1029/2001WR001227. Larson, K.R., and R.C. Sidle. 1980. Erosion and sedimentation data catalog of the Pacific Northwest. R6-WM-050-1981, USDA Forest Service, Pacific Northwest Region, Portland, OR, 64p. Late-Successional Reserve Assessment for Oregon’s Northern Coast Range Adaptive management Area (USDA, USDI 1998)) Lesica, P.B.; McCune, S.V.; Cooper; Hong, W.S. 1991. Differences in lichen and bryophyte communities between old-growth and managed second-growth forests in the Swan Valley, Montana. Canadian Journal of Botany 69: 1745–1755. Lienkaemper, G.W., and F.J. Swanson. 1987. Dynamics of large woody debris in streams in old-growth Douglas-fir forests. Canadian Journal of Forest Research 17:150-156. Lint, Joseph, tech. coord. 2005. Northwest Forest Plan—the first 10 years (1994–2003): status and trends of northern spotted owl populations and habitat. Gen. Tech. Rep. PNW-GTR-648. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station. 176 p. Lofroth, E. C., C. M. Raley, J. M. Higley, R. L. Truex, J. S. Yaeger, J. S. Yaeger, J. C. Lewis, P. J. Happe, L. L. Finley, R. H. Naney, L. J. Hale, A. L. Krause, S. A. Livingston, A. M. Meyers, and R. N. Brown. 2010. Conservation of Fishers (Martes pennant) in South-Central British Columbia, Western Washingtin, Western Oregon, and California – Volume I: Conservation Assessment. USDI Bureau of Land Management, Denver, Colorado, USA. Lorion, C. Oregon Department of Fish and Wildlife, Corvallis Research Lab. Personal communication with Jack Sleeper, fishery biologist, Siuslaw National Forest. Luce, C. H. and T. A. Black. 1999. Sediment production from forest roads in western Oregon. Water Resources, 35(8), 2561-2570. Luce, C.H. and T.A. Black, 2001. Spatial and Temporal Patterns in Erosion from Forest Roads. In: Land Use and Watersheds: Human Influence on Hydrology and Geomorphology in Urban Forest Areas, M.S. Wigmosta and S.J. Burges (Editors). American Geophysical Union, Water Science and Application 2, American Geophysical Union, Washington, D.C., pp. 165-178. Lutz, J.A., and C.B. Halpern. 2006. Tree mortality during early forest development: A long-term study of rates, causes, and consequences. Ecological Monographs, 76(2), pp.257-275 Mainwaring, D.B.; Maguire, D.A.; Kanaskie, A.; and Brandt, J. 2005. Growth responds to commercial thinning in Douglas-fir stands with varying severity of Swiss needle cast in Oregon, USA. Canadian Journal of Forest Research 35(Oct): 2394-2402. Marshall, D.B., M.G. Hunter, and A.L. Conteras, eds. 2003. Birds of Oregon: a general reference. Oregon State Univ. Press, Corvallis, OR

North Nestucca Environmental Assessment Page 7 Appendix F

Marshal, D.D.; Bell, J.F.; and Tappeiner, J.C.. 1992. Levels-of-growing-stock cooperative study in Douglas-fir: Report No. 10 – the Hoskins study, 1963 - 1983. Research Paper PNW-RP-448. Portland, OR: U.S. Department of Agriculture, Pacific Northwest Research Station: 65 p. Maser, Z.; Maser, C.; Trappe, J.M. 1985. Food habits of the northern flying squirrel (Glaucomys sabrinus) in Oregon. Canadian Journal of Zoology 64: 2086–2089.

Maser, C. 1998. Mammals of the Pacific Northwest. Oregon State Univ. Press, Corvallis. 406 pp. McCune, B. 1993. Gradients in epiphyte biomass in three Pseudotsuga–Tsuga forests of different ages in western Oregon and Washington. Bryologist 96: 405–411. McCune, B. 1993. Gradients in epiphyte biomass in three Pseudotsuga–Tsuga forests of different ages in western Oregon and Washington. Bryologist 96: 405–411. McCain, C. 2011. Personal communication with Siuslaw National Forest Ecologist. September 23, 2011 May, C.L. 2001. Spatial and temporal dynamics of sediment and wood in headwater streams in the Oregon Coast Range. Ph.D. Dissertation, Oregon State University, Corvallis, Oregon. May, C.L., and R.E. Gresswell. 2003. Large wood recruitment and redistribution in headwater streams in the southern Oregon Coast Range, U.S.A. Can. J. For. Res. 33:1352-1362 McCain, Cindy and Nancy Diaz. 2002. Field Guide to the Forested Plant Associations of the Northern Oregon Coast Range. US Department of Agriculture, Forest Service, Pacific Northwest Region, Portland, OR. R6-NR-ECOL-TP-02-02. McDade, M.H. 1988. The source area for coarse woody debris in small streams in western Oregon and Washington. MS Thesis, Oregon State University, Corvallis, Oregon. McDade, M.H., F.J. Swanson, W.A. McKee, J.F. Franklin, J. Van Sickle. 1990. Source distances for coarse woody debris entering small streams in western Oregon and Washington. Can. J. For. Res. 20:326-330 McGurk, B.J. and Fong, D.R. 1995. Equivalent Roaded Area as a Measure of Cumulative Effect of Logging. Environmental Management, 19(4), 609-621 McIntosh, B.A., J.R. Sedell, R. F. Thurow, S.E. Clarke, and G.L. Chandler. 2000. Historical changes in pools habitats in the Columbia River Basin. Ecological Applications 10(5): 1478- 1496. Melillo, J.M., R.J. Naiman, J.D. Aber, K.N. Eshleman. 1983. The influence of substrate quality and stream size on wood decomposition dynamics. Oecologia 58:281-285. Mellen-McLean, Kim, Bruce G. Marcot, Janet L. Ohmann, Karen Waddell, Susan A. Livingston, Elizabeth A. Willhite, Bruce B. Hostetler, Catherine Ogden, and Tina Dreisbach. 2009. DecAID, the decayed wood advisor for managing snags, partially dead trees, and down wood for biodiversity in forests of Washington and Oregon. Version 2.1. USDA Forest Service, Pacific Northwest Region and Pacific Northwest Research Station; USDI Fish and Wildlife Service, Oregon State Office; Portland, Oregon. Miadlikowska, Jolanta, Bruce McCune, and François Lutzoni. 2002. Pseudocyphellaria perpetua, a New Lichen from Western North America. The Bryologist vol. 105, 1:1-10. Michel, N., D. F. DeSante, D. R. Kaschube, and M. P. Nott, 2006. The Monitoring Avian

North Nestucca Environmental Assessment Page 8 Appendix F

Productivity and Survivorship (MAPS) Program Annual Reports, 1989-2003. NBII/MAPS Avian Demographics Query Interface Millar, C.; Stephenson, L.; Stephens, S. 2007. Climate change and forests of the future: managing in the face of uncertainty. Ecological Applications, 17(8), 2007, pp. 2145–2151. The Ecological Society of America. Muir, P.S.; Mattingly, R.L.; Tappeiner, J.C.; Bailey, J.D.; Elliott, W.E.; Hagar, J.C.; Miller, J.C.; Peterson, E.B.; Starkey, E.E. 2002. Managing for biodiversity in young Douglas-fir forests of western Oregon. Biological Sciences Report USGS/BRD/BSR-2002-006. 76 p. Murphy, M.L., and K.V. Koski. 1989. Input and Depletion of Woody Debris in Alaska Streams, and Implications for Streamside Management. North American Journal of Fisheries Management 9:427-436 Naiman, R.J., E.V. Balian, K.K. Bartz, R.E. Bilby, and J.J. Latterell. 2002. Dead Wood Dynamics in Stream Ecosystems. USDA Forest Service General Technical Report PSW-GTR- 181. Newton, M.; Cole, E.C. 1994. Stand development and successional implications: pure and mixed stand. In: Hibbs, D.E.; DeBell, D.S.; Tarrant, R.F., eds. The biology and management of red alder. Corvallis, OR: Oregon State University Press: 106-115. Nickelson, T.E., J.D. Rodgers, S.L. Johnson, and M.F. Solazzi. 1992. Seasonal changes in habitat use by juvenile coho salmon (Oncorhynchus kisutch) in Oregon coastal streams. Can. J. Fish. Aquat. Sci. 49:783-789 Nierenberg, T.R., and D.E. Hibbs. 2000. A characterization of unmanaged riparian areas in the central Coast Range of western Oregon. Forest Ecology and Management 129:195-206. NMFS (National Marine Fisheries Service). 2008. Endangered Species Act Section 7 Formal Consultation and Magnuson-Stevens Fishery Conservation and Management Act Essential Fish Habitat Consultation for the Little Nestucca Restoration Project, Wilson-Trask-Nestucca subbasin (4th Field HUC:17100203), Tillamook and Yamhill Counties, Oregon; West Alsea Landscape Management Project, Alsea River subbasin (4th field HUC: 17100205), Lincoln County, Oregon; and Lobster Landscape Management Project, Alsea River (4th field HUC: 17100205) and Siuslaw river (4th field HUC 17100206) subbasins, Lincoln, Benton, and Lane Counties, Oregon. NMFS Northwest Region, Seattle, WA. 78 p. Noggle, C.C. 1978. Behavioral, physiological and lethal effects of suspended sediment on juvenile salmonids. M.S. Thesis, Univ. of Washington, Seattle. 87 p. Nott, M. P., D. F. Desante, and N Michel 2007. Monitoring, Modeling and Managing Landbird Populations in Forests of the Pacific Northwest: The Application of MAPS Demographic Monitoring Data to Forest Bird Management and Conservation. http://birdpop.org/usfsr6/usfspnwr6.htm Nott, M. P., D. F. Desante, P. Pyle, and N. Michel. 2005. Managing Landbird populations in Forests of the Pacific Northwest Region Publication No. 254 of The Institute for Bird Populations. NRIS 2011. Natural Resources Information System. Ad hoc query of TESP database. ODFW (Oregon Department of fish and Wildlife). 2005. Oregon Coastal Coho Assessment, Habitat. Part 4(c) ODFW 3. Oregon Plan for Salmon and Watersheds.

North Nestucca Environmental Assessment Page 9 Appendix F

Ohmann, J.L., M.J. Gregory. 2002. Predictive mapping of forest composition and structure with direct gradient analysis and nearest-neighbor imputation in coastal Oregon, USA. Canadian Journal of Forest Research 32(4):725-741. Other references, methods, and data dictionary on http://www.fsl.orst.edu/lemma/main.php?project=common&id=dataDictionary&ref=nwfp) Old-Growth Definition Task Group 1986; Carey and Johnson 1995; Carey and Curtis 1996; Rapp 2003 Oliver, C.D.; Larson B.C. 1996. Forest stand dynamics. McGraw hill, New York. 467 pp. Oliver, C.D.; Larson B.C. 1996. Forest stand dynamics; updated edition. ISBN 0-471-13833-9. Published by John Wiley and Sons, Inc. 520 pp. Oregon Department of Forestry (2005), Oregon Smoke Management Plan Oregon Department of Environmental Quality (DEQ). 2002. Nestucca Bay Watershed Total Maximum Daily Load (TMDL) Oregon Department of Environmental Quality (DEQ). 2011. Oregon’s 2004/2006 Integrated Report Database. Website found at: http://www.deq.state.or.us/wq/assessment/rpt0406/search.asp#db Oregon Natural Heritage Information Center. 2007. Rare, Threatened and Endangered Species of Oregon. Oregon Natural Heritage Information Center, Oregon StateUniversity, Portland, Oregon. 100 pp. Ore Rich, T. D., Beardmore, C. J., Berlanga, H., Blancher, P. J., Bradstreet, M. S. W., G. S., Demarest, D. W., Dunn, E. H., Hunter, W. C., Inigo-Elias, E. E., Kennedy, J. A., Martell, A. M., Panjabi, A. O., Pashley, D. N., Rosenberg, K. B., Rustay, C. M., Wendt, J. S., Will, T. C., 2004, Partners in Flight North American Landbird Conservation Plan: Ithaca, N. Y., Cornell lab of Ornithology. gon Department of Environmental Quality (2003), Air Quality and Visibility Protection Plan ORGANON web site - http://www.cof.orst.edu/cof/fr/research/organon/ Pabst, R.J., and T.A. Spies. 1999. Structure and composition of unmanaged riparian forests in the coastal mountains of Oregon, U.S.A. Can. J. For. Res. 29: 1557-1573. Pettersson, R.B.; Ball, J.P.; Renhorn, K.E.; Esseen, P.A.; Sjo¨berg,K. 1995. Invertebrate communities in boreal forest canopies as influenced by forestry and lichens, with implications for passerine birds. Biological Conservation 74: 57–63. PFMC. 1999. Amendment 14 to the Pacific coast salmon plan. Appendix A: Description and Identification of Essential Fish Habitat, Adverse Impacts and Recommended Conservation Measures for Salmon. Portland, OR: Pacific Fishery Management Council. PIF (Partners in Flight). 2005. Southern Pacific Rainforest; Priority Bird Populations and Habitats. http://www.blm.gov/wildlife/pl_93sum.htm Pike, L.H. 1978. The importance of epiphytic lichens in mineral cycling. Bryologist 81:247–257.

Pike, L.H.; Tracy, D.; Sherwood, M.; Nielsen, D. 1972. Estimates of biomass and fixed nitrogen of epiphytes from old-growth Douglas-fir. Pages 177–187 in J. Franklin, L. Dempster, and R. Waring, editors. Proceedings: research on coniferous forest ecosystems, a symposium. Portland, OR: PacificNorthwest Forest and Range Experiment Station. Poage, N. J.; Anderson, P. D. 2007. Large-scale silviculture experiments of western Oregon and

North Nestucca Environmental Assessment Page 10 Appendix F

Washington. Gen. Tech. Rep. PNW-GTR-713. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station. 44 p. Poage, Nathan J.; Weisberg, P.J.; Impara, P.C.; Tappeiner, J.C.; Sensenig, T.S. 2009. Influences of climate, fire, and topography on contemporary age structure patterns of Douglas-fir at 205 old forest sites in western Oregon. Can. J. For. Res. 39: 1518-1530.

Pypker, T.G.; Unsworth, M.H.; Bond, B.J. 2006. The role of epiphytes in rainfall interception by forests in the Pacific Northwest. II. Field measurements at the branch and canopy scale. Canadian Journal of Forest Research 36: 819-832. Reeves, G.H., K.M. Burnett, and E.V. McGarry. 2003. Sources of large wood in the main stem of a fourth-order watershed in coastal Oregon. Can. J. For. Res. 33:1363-1370 Rich, T. D., Beardmore, C. J., Berlanga, H., Blancher, P. J., Bradstreet, M. S. W., G. S., Demarest, D. W., Dunn, E. H., Hunter, W. C., Inigo-Elias, E. E., Kennedy, J. A., Martell, A. M., Panjabi, A. O., Pashley, D. N., Rosenberg, K. B., Rustay, C. M., Wendt, J. S., Will, T. C., 2004. Partners in Flight North American Landbird Conservation Plan: Ithaca, N. Y., Cornell lab of Ornithology. http://www.partnersinflight.org Robison, G. E., and R. L. Beschta. 1990. Identifying trees in riparian areas that can provide coarse woody debris to streams. Forest Science 36:790–801. Root, H.; McCune, B.; Neitlich, P. 2010. Lichen habitat may be enhanced by thinning treatments in young Tsuga heterophylla - Pseudotsuga menziesii forests. Bryologist 113: 292-307. Rosenfeld, J.S., and L. Huato. 2003. Relationship between Large Woody Debris Characteristics and Pool Formation in Small Coastal British Columbia Streams. North American Journal of Fisheries Management 23:928-938. Siuslaw Thinning and Underplanting Diversity Study (Phase II) (USFS 2007e) Smith, David M.; 1986. The Practice of Silviculture, Eighth Edition. ISBN 0-471-80020-1. Published by John Wiley and Sons, Inc. 527 pp. Smith, D. M., & Smith, D. M. (1997). The practice of silviculture: Applied forest ecology. New York: Wiley “Special Areas; Roadless Area Conservation; Final Rule.” Federal Register 66 (January 12, 2001). http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5050459.pdf (Accessed on November 23, 2010). Spies, T.A.; Cline, S.P. 1988. Coarse woody debris in forests and plantations of coastal Oregon. In: Maser, C.; Tarrant, R.F.; Trappe, J.M,; Franklin, J. F.; tech eds. From the Forest to the sea: a story of fallen trees. General Tech. Rep. PNW-GTR-229. Portland, OR; U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station: 5-24. Spies, T.A.; Franklin, J.F. 1991. The structure of natural young, mature and old-growth Douglas- Fir forests in Oregon and Washington. In Wildlife and Vegetation of Unmanaged Douglas-Fir Forests Gen. Tech. Rept. PNW-GTR-285 Spies, Tom. 2008. Research Ecologist and Team Leader, Landscape and Ecosystems Team, Pacific Northwest Research Station, US Forest Service. Portland, OR: Region 6, pers. comm. Story, A., R. D. Moore, and J. S. Macdonald. 2003. Stream temperatures in two shaded reaches

North Nestucca Environmental Assessment Page 11 Appendix F

below cutblocks and logging roads: Downstream cooling linked to subsurface hydrology.Can. J. For. Res. 33(8):1383-1396. Spittlehouse, D.L.; Stewart, R.B. 2003. Adaptation to climate change in forest management. BC Journal of Ecosystems and Management 4 (1): 1-11. Stavins, R.N.; Richards, K.R. 2005. The cost of U.S. forest-based carbon sequestration. Prepared for the Pew Center on Global Climate Change. January 2005. Stout, H.A. and 15 coauthors. 2010. Draft Updated Status Review of Oregon Coast Coho Salmon. National Marine Fisheries Service, Northwest Fisheries Science Center. Newport, OR. Tappeiner, J.C.; Huffman, D.; Marshall, D. [and others]. 1997. Density, ages and growth ratios in old-growth and young-growth forests in coastal Oregon. Canadian Journal of Forest Research. 27:638-648. Thies, W.G.; Sturrock, R.N. 1995. Laminated root rot in western North America. Gen. Tech. Rep. PNW-GTR-349. Portland, OR: United States Department of Agriculture, Forest Service, Pacific Northwest Research Station. Pages 17, 24-25. In cooperation with Natural Resources Canada, Canadian Forest Service. Thomas, J.W., Forsman, E. D.; Lint, J.B., [and others]. 1990. A conservation strategy for the northern spotted owl: a report of the Interagency Scientific Committee to address the conservation of the of the northern spotted owl. Portland,OR: U.S. Department of Agriculture, Forest Service; U.S. Department of the Interior, Bureau of Land management, Fish and Wildlife Service, and National Park Service. Thomas, R.B.; Megahan, W.F. 1998. Peak flow responses to clear-cutting and roads in small and large basins, western Cascades, Oregon: a second opinion. Water Resources Research. 34(12): 3393–3403. USDA Forest Service Pacific Northwest Region. 1988. General Water Quality Best Management Practices. Portland, Oregon. USDA. Forest Service Manual - FSM 2602. 1991 http://fsweb.wo.fs.fed.us/directives/fsm/2600/ 2600_zero_code USDA Forest Service. 1990 Land and Resource Management Plan Siuslaw National Forest. Siuslaw National Forest, 4077 SW Research Way, PO Box 1148, Corvallis, OR. 97339. USDA Forest Service. 1992. Forest Plan Amendment No. 2, Siuslaw National Forest. Corvallis, OR: Siuslaw National Forest USDA Forest service. 1992. Neotropical Migrants on National Forests of the Pacific Northwest. USDA Forest Service, USDI Bureau of land Management. 1993. Forest Ecosystem Management: An ecological, Economic, and Social Assessment; report of the Forest Ecosystem Management Assessment Team. USDA Forest Service, 1994. Record of Decision (ROD) for Amendments to Forest Service and Bureau of Land Management Planning Documents in the Range of the Northern Spotted Owl and Standards and Guidelines for Management of Habitat for Late Successional and Old Growth Related Species Within the Range of the Northern Spotted Owl USDA Forest Service 1996. Management Plan for the Mt. Hebo Scenic-Biological Special

North Nestucca Environmental Assessment Page 12 Appendix F

Interest Area. USDA Forest Service, Hebo, OR USDA Forest Service. 1996. Nestucca Watershed Analysis. Corvallis, OR: Siuslaw National Forest. 113 p. plus maps and appendices. USDA Forest Service. 2002c. Final environmental impact statement, Five Rivers landscape man USDA Forest Service. 2007e. Siuslaw thinning and underplanting for diversity study—phase II. Corvallis, OR: Siuslaw National Forest. USDA Forest Service. 2009. Monitoring and Evaluation Report, Siuslaw National Forest, Fiscal Year 2009. Corvallis, OR: Siuslaw National Forest USDA Forest Service 2011. East Alsea Landscape Management Project Fisheries Biological Evaluation (Appendix H). In: USDA Forest Service. May 2011. Environmental Assessment, East Alsea Landscape Management Project. Waldport, OR: Siuslaw National Forest, Central USDA Forest Service. 2011. Revised Road Rules (in draft). Corvallis, OR: Siuslaw National Forest. Correspondence File # 7730Coast Ranger District. USDA Forest Service, USDC National Oceanic and Atmospheric Administration, Fisheries, USDI Bureau of Land Management, USDI Fish and Wildlife Service. 2004. Analytical Process for Development of Biological Assessments for Consultation on Federal Actions Affecting Fish Proposed or Listed Under the Endangered Species Act Within the Northwest Forest Plan Area. USDA Forest Service, USDI Bureau of land Management. 1994. Final Supplemental Environmental Impact Statement and Record of Decision for Amendments to Forest Service and Bureau of Land Management Documents within the Range of the northern Spotted Owl and Standards and guidelines for Management of Habitat for Late Successional and Old Growth Forest Related Species within the Range of the Northern Spotted owl. USDA Forest Service, USDI Bureau of Land Management. 1995. The Assessment Report for Federal Lands in and adjacent to the Oregon Coast Province. USDA Forest Service, USDI Bureau of Land Management. 1997.The Northern Coast Range Adaptive Management Guide USDA Forest Service, USDI Bureau of Land Management. 1997. Late-successional reserve assessment, Oregon Coast Province southern portion--version 1.3. Corvallis, OR: Siuslaw National Forest. USDA Forest Service, USDI Bureau of Land Management. 1998. Late-successional Reserve Assessment for Oregon’s Northern Coast Range Adaptive Management Area. Siuslaw National Forest, Corvallis, OR. USDA Forest Service, USDI Bureau of Land Management. 1998. North Coast Range Adaptive management Area Guide. Siuslaw National Forest, Corvallis, OR. USDA Forest Service, USDI Bureau of Land Management. 1999. Salmon-Neskowin Watershed Analysis). USDA Forest Service, USDI Bureau of Land Management. 2001. Record of decision and standards and guidelines for amendments to the survey and manage, protection buffer, and other mitigation measures standards and guidelines. Portland, OR. USDA Forest Service, USDI Bureau of Land Management. 2002. Survey Protocol For Red

North Nestucca Environmental Assessment Page 13 Appendix F

Tree Vole – Version 2.1 http://www.or.blm.gov/surveyandmanage/SP/RedTreeVole/200210/RTV%20protocol%20revision-V.2.1- final.pdf USDA Forest Service, USDI Bureau of Land Management. 2003. Survey Protocol for Survey and Manage Terrestrial Mollusk Species from the Northwest Forest Plan – Version 3.0. http://www.or.blm.gov/surveyandmanage/SP/Mollusks/terrestrial/Mollusk%20document.pdf – p. 31-39. USDA Forest Service, USDI Bureau of Land Management. 2005. Northwest Forest Plan Temperature TMDL Implementation Strategies. Evaluation of the Northwest Forest Plan Aquatic Conservation Strategy and Associated Tools to achieve and maintain stream temperature water quality standards. USDA Forest Service, USDI Bureau of Land Management., 2006. Conservation Assessment for the Foothill Yellow-legged Frog (Rana boylii) in Oregon; Version 1.0 USDA Forest Service, USDI Bureau of Land Management.. 2008. Biological Assessment FY2009 & FY2010 Activities in the North Coast Province which might Disturb Northern Spotted Owls or Marbled Murrelets. USDA Forest Service, USDI Bureau of Land Management., 2009. Biological Assessment of Activities proposed during FY2010-2013 in the north Coast Planning Province, Oregon which might Disturb but Are Not Likely to Adversely Affect Northern Spotted Owls or Marbled Murrelets. USDA Forest Service, USDI Bureau of Land Management.,. 2010. Biological Assessment of Habitat Modification Projects Proposed during Fiscal Years 2011 and 2012 that are Not Likely To Adversely Affect (NLAA) Northern Spotted Owls or Marbled Murrelets and their Critical Habitats. USDC National Marine Fisheries Service. 2008. Endangered Species Act – Section 7 Programmatic Consultation Biological Opinion and Magnuson-Stevens Fishery Conservation and Management Act Essential Fish Habitat Consultation. Fish Habitat Restoration Activities in Oregon and Washington, CY2007-CY2012. National Marine Fisheries Service, NMFS Nos.: FS 2008/03505. Seattle, WA. USDI Fish & Wildlife Service. 1989. Endangered and Threatened Wildlife and Plants; Proposed Threatened Status for the Northern Spotted Owl. Proposed Rule 54 FR 26666 http://ecos.fws.gov/docs/federal_register/fr1552.pdf USDI Fish and Wildlife Service. 1990. Endangered and Threatened Wildlife and Plants; Determiniation of Threatened Status for the Northern Spotted Owl. Final Rule. 55FR 26666. USDI Fish & Wildlife Service. 1990. Endangered and Threatened Wildlife and Plants; Determiniation of Threatened Status for the Northern Spotted Owl. Final Rule. 55FR 26666. http://ecos.fws.gov/docs/federal_register/fr1718.pdf USDI Fish & Wildlife Service. 1992. Endangered and Threatened Wildlife and Pland; Final Designation of Critical habitat for the Northern Spotted Owl. Final Rule. 57FR1796. http://ecos.fws.gov/docs/federal_register/fr2008.pdfUSDI Fish and Wildlife Service. 2008. Birds of Conservation Concern 2008. United States Department of Interior, Fish and Wildlife Service Division of Migratory Bird Management, Arlington, Virginia. 85 pp.

North Nestucca Environmental Assessment Page 14 Appendix F

USDI Fish & Wildlife Service. 1993. . Endangered and threatened wildlife and plants; determination of threatened status for the Pacific coast populations of the western snowy plover. Final Rule 58FR12864. http://ecos.fws.gov/docs/federal_register/fr2236.pdf USDI Fish & Wildlife Service. 1996. Endangered and Threatened Wildlife and Plants; Final Designation of Critical Habitat for the Marbled Murrelet. Final Rule. 61 FR 26256. USDI Fish & Wildlife Service. 1997. Recovery plan for the threatened marbled murrelet (Brachyramphus marmoratus) in Washington, Oregon, and California. Fish and Wildlife Service, Portland, OR. 203 pp. USDI Fish & Wildlife Service. 2007. Biological Opinion and Letter of Concurrence, USDA Forest Service, USDI Bureau of Land Management, and the Coquille Indian Tribe for Programmatic Aquatic Habitat Restoration Activities in Oregon and Washington that affect ESA-Listed Fish, Wiidlife, and Plant Species and their Critical Habitats. (FWS TAILS Number 13420-2007-F-0055) Portland, OR. USDI Fish & Wildlife Service. 2007. Species Assessment and Listing Priority Assignment Form for Fisher-West Coast Distinct Population Segment USDI Fish and Wildlife Service. 2008. Final Recovery Plan for the Northern Spotted Owl, Strix occidentalis caurina. U.S. Fish and Wildlife Service, Portland, Oregon. USDI Fish & Wildlife Service. 2008. Birds of Conservation Concern 2008. United States Department of Interior, Fish and Wildlife Service Division of Migratory Bird Management, Arlington, Virginia. 85 pp. USDI Fish & Wildlife Service. 2008. Final Recovery Plan for the Northern Spotted Owl, Strix occidentalis caurina. U.S. Fish and Wildlife Service, Portland, OR. http://ecos.fws.gov/docs/recovery_plan/NSO%20Final%20Rec%20Plan%20051408_1.pdf USDI Fish & Wildlife Service. 2008. Endangered and Threatened Wildlife and Pland; Final Designation of Critical habitat for the Northern Spotted Owl. Final Rule. 73FR47325.USFWS. USDI Fish & Wildlife Service. 2008. Letter of concurrence on the Effects of Habitat Modification Activities on the Northern Spotted Owl (Strix occidentalis caurina), Marbled Murrelets (Brachyramphus marmoratus) and Critical Habitat in the North Coast Planning province, FY2009-2010, proposed by the Eugene District, Bureau of Land Managemetn, Salem District, Bureau of Land Managemetn; and theSiuslaw national forest (FWS Reference Number 13420-2008-I-0125) Portland, OR. USDI Fish & Wildlife Service. 2009. Consultation for activities with potential to disturb spotted owls (Strix occidentalis caurina) and marbled murrelets (Brachyramphus marmoratus) within the North Coast Planning Province for FY 2010-2013 (FWS Reference Number 13420-2009-I- 0152) Portland, OR. USDI Fish & Wildlife Service. 2010. Letter of Concurrence on the Effects of Habitat Modification Activities on the Northern Spotted Owl (Strix occidentalis caurina), Marbled Murrelet (Brachyramphus marmoratus), and Critical Habitat in the North Coast Planning Province, FY 2011 – 2012, proposed by the Eugene District, Bureau of Land Management; Salem District, Bureau of Land Management; and the Siuslaw National Forest (FWS Reference Number 13420-2010-I-0105) Portland, OR.

North Nestucca Environmental Assessment Page 15 Appendix F

USDI Fish & Wildlife Service Forest Service. April 2011. East Alsea Landscape Management Project Fisheries Biological Evaluation (Appendix H). In: USDA Forest Service. May 2011. Environmental Assessment, East Alsea Landscape Management Project. Waldport, OR: Siuslaw National Forest, Central Coast Ranger District Verts B.J.; Carraway. 1998. Land mammals of Oregon. Los Angeles, CA: University of California Press Berkeley. Wilkerson, Ethel, John Hagan, Darlene Siegel, and Andrew Whitman. 2006. The effectiveness of different buffer widths for protecting headwater stream temperature in Maine. Forest Science 52(3): 221-231 Wimberley, M.C., 2002. Spatial simulations of historical landscape patterns in coastal forests of the Pacific Northwest. Can. J. Res. 32: 1316-1328. Worthington, N.P.; Ruth, R.H.; and Matson, E.E. 1962. Red alder: its management and utilization. Misc. Publ. 881. Portland, OR: U.S. Department of Agriculture, Pacific Northwest Range and Experiment Station.

North Nestucca Environmental Assessment Page 16 Appendix G-1

Appendix G

North Nestucca Restoration Project Deadwood Assessment

INTRODUCTION The North Nestucca project area is about 16 air miles south of Tillamook, Oregon. The project area lies within portions of the Nestucca River, Little Nestucca River, Sand Lake-Frontal Pacific Ocean and Tillamook River fifth-field watersheds. The project area includes portions of ten sixth-field watersheds: Beaver Creek, Lower Little Nestucca River, Lower Nestucca River/Farmer Creek, Middle Nestucca River/Powder Creek, Nestucca Bay-Frontal Pacific Ocean, Nestucca River/Niagara Creek, Sand Lake-Frontal Pacific Ocean, Upper Nestucca River/Moon Creek, Upper Nestucca River/Testament Creek and Upper Tillamook River. The project area covers approximately 75,113 acres. Approximately 34 percent (25,279 acres) of the area is on National Forest System (NFS) land, of which 42 percent (10,579 acres) of NFS ownership is comprised of young forest plantations less than 65 years of age. About 41 percent of the project area is privately owned, 16 percent is managed by the Bureau of Land Management, eight percent by the state of Oregon and less than one percent is managed by the US Fish and Wildlife Service.

Figure 1 - Ownership

Approximately 58 percent of the NFS land within the project area (14,583 acres) consists of natural stands greater than 65 years old and includes a minor amount in roads, streams and rivers, and meadows. About 42 percent of the NFS lands within the planning area are young plantations (10,579 acres). Forested stands proposed for commercial thinning comprise about 25 percent (6,297 acres) of NFS land in the project area. Of these stands proposed for commercially thinning, 5,229 acres are prescribed to be commercial thinned and the remaining 1,068 acres

North Nestucca Environmental Assessment Page 1

Appendix G-1

would be left as no-cut buffers. Approximately 40 percent of the plantations on NFS lands within the planning area (4,282 acres) would be deferred (Figure 2).

Figure 2 – Proposed Project

MANAGEMENT DIRECTION Late-successional Reserve Assessment Guidance The Late-Successional Reserve Assessment for Oregon’s Northern Coast Range Adaptive Management Area (LSRA) for this planning area documents the stand structure and composition of mature natural stands in Table 14 (Table 1) of the assessment (USDA Forest Service 1998). Tables 18 and 19 (based on Spies et. al 1988) in the assessment discloses the range of snags or down wood volumes per acre found in natural stands of different age classes in the Oregon Coast Range. Table 2 in this report summarizes those tables. The objective of the late successional reserves is to protect and restore habitat related to late successional species. The assessment concluded that the loss of the large coarse woody debris (CWD) component is long-term and there is very limited opportunity to create CWD >20" in diameter in the 25-50 year old plantations. The assessment recommended prescriptions that would set managed stands on a trajectory to meet the snag and downed wood levels found in mature and old-growth stands while still providing for an acceptable level of CWD in young stands.

Northern Spotted Owl and Marble Murrelet Recovery Plan Guidance Deadwood in the form of snags and downed wood are important habitat components for a variety of species. The recovery plans for the northern spotted owl (USFWS 1992, USFWS 2008) and the marbled murrelet (USFWS 1997) recommended changing the trajectory of managed stands from wood fiber production to a condition that more closely replicates natural stand conditions.

North Nestucca Environmental Assessment Page 2

Appendix G-1

Table 1. From LSRA - Table 14. Structure and Composition of the Mature Condition of Late-Successional Stands by Sub-Series Environments. Information is expressed in numbers of trees, logs or snags per acre; all data was rounded to the nearest whole number) Hemlock- Dry (18 plots) Hemlock- Moist (21 plots) Hemlock- Wet (36 plots) Species Small Med. Large Giant Total Small Med. Large Giant Total Small Med. Large Giant Total Bigleaf maple 1 <1 1 Douglas-fir 20 25 6 <1 51 28 23 6 <1 58 9 10 6 <1 25 Red alder 2 <1 2 7 1 9 13 2 15 Sitka spruce <1 <1 <1 1 <1 0 <1 1 2 1 <1 <1 2 Western hemlock 19 10 2.2 <1 31 25 11 2 <1 37 23 11 3 <1 36 Western redcedar 4 <1 <1 4 4 <1 <1 <1 4 5 1 <1 <1 6 Total Live Trees 45 36 8 1 89 (44) 64 36 9 1 109 (45) 53 24 9 1 86 (32) Hard Conifer Snags 15 2 1 <1 17 14 2 <1 <1 16 4 1 <1 <1 6 Soft Conifer Snags 2 2 3 1 8 3 3 2 1 8 1 1 1 1 3 Hard Log 23 6 1 30 14 2 1 <1 18 10 2 1 <1 13 Soft Log 5 2 2 1 10 7 5 5 1 18 3 6 2 1 11

Spruce- Dry (13 plots) Spruce- Moist (39 plots) Spruce- Wet (33 plots) Douglas-fir 8 13 10 <1 31 3 6 3 <1 11 9 5 5 <1 20 Red alder 11 1 <1 13 8 1 <1 8 8 2 <1 10 Sitka spruce 6 7 3 <1 16 8 11 9 2 29 3 3 4 2 11 Western hemlock 19 6 2 27 33 17 4 <1 53 12 7 3 <1 22 Western redcedar 1 1 <1 2 <1 <1 2 <1 <1 <1 3 102 Total Live Trees 46 28 16 <1 89 (43) 51 34 15 2 34 16 12 2 64 (28) (50) Hard Conifer Snags 4 1 <1 <1 5 9 2 1 <1 12 5 1 1 <1 7 Soft Conifer Snags 1 2 3 1 6 1 1 2 1 5 1 1 2 1 4 Hard Log 6 2 <1 9 12 4 2 <1 18 8 3 3 1 16 Soft Log 4 2 3 1 9 8 4 5 1 18 3 5 2 1 11 Live tree data from 1987 Vegetation Resource Survey – 109 plots and 1984 Siuslaw Ecoplot Intensive Survey – 51 plots. (X) Total Medium, Large and Giant conifer trees Size classes: Small = 9.0-20.9 inches diameter at breast height (DBH) Medium = 21.0-31.9 inches DBH Large = 32.0-47.9 inches DBH Giant = 48.0+ inches DBH Snags = dead standing conifers 10 feet tal or taller, with DBH in the above size classes. Hard snags = snags in decay classes I, II, and III (Cline 1977) Soft snags = snags in decay classes IV and V 9Cline 1977) Logs = pieces greater than 20 feet long, having the large end of the log in the above size classes. Hard logs = logs in decay classes I, II, and III (Fogel, Ogawa and Trappe 1973) Soft logs = logs in decay classes IV and V 9Fogel 1973)

North Nestucca Environmental Assessment Page 3

Appendix G-1

EXISTING SNAG AND CWD LEVELS COMPARED TO REFERENCE CONDITION Analysis was undertaken to determine how many snags and how much down wood there is on Siuslaw National Forest lands in the Nestucca watershed. Available snags and CWD were analyzed to determine how much exists in the natural stands. This data was used to compare natural stands to managed stands. The current snag and down wood levels were compared to the reference condition.

Methodology The analysis used the Gradient Nearest Neighbor (GNN) data (Ohmann and Gregory 2002) that combines satellite imagery and imputed inventory plot data to assess standing and down material in overall snag (≥10” DBH) and large snag (≥20” DBH) categories. Stands were put into three size classes: large (>20” mean DBH), small (10-20” mean DBH), and open (<10” mean DBH or non-forest). Data on current conditions came from interpretation of imagery taken in 2006.

The analysis used the following Geographic Information System spatial data: watershed boundaries (fifth and sixth field watershed scales), the USFS R6 Ecology Program Potential Natural Vegetation model at the plant association group level, the Siuslaw NF management activity layer (managed stands versus natural (no management history recorded) stands), and the GNN data. The variables in GNN data included: − STPH_GE_25 (snags per hectare >25cm DBH) − STPH_GE_50 (snags per hectare >50 cm DBH) − DCOV_GE_12 (% cover in logs)>12cm diameter) − DCOV_GE_50 (% logcover in logs>50 cm diameter).

Snags included in the GNN variables were at least two meters in height and logs were at least three meters in length. Each size class was calculated independently, and snags were also calculated together across size classes to match DecAID summaries of total snags greater than 25 cm (10”) DBH.

The analysis assigned vegetation types to match sub-series vegetation classes used in the LSRA. for The analysis summarized snags (snags per acre) and down wood (cover per acre) on Forest Service lands in the Nestucca watershed and displayed it by density or cover classes matching such classes corresponding to those from DecAID.

Results The analysis used results from a Forest Service ecology study in northwest Oregon to compare current condition (combining stands across size classes) to the reference condition (McCain, 2011). That study combined DecAID reference distributions of coarse wood by stand size class for each Wildlife Habitat Type (WHT) with reference seral stage distributions developed for Fire Regime-Condition Class (FRCC) for each fifth field watershed. The analysis assigned reference conditions by comparing vegetation subseries to FRCC Biophysical Setting and DecAID WHT and summing by area occupied by each WHT in the fifth-field watershed.

The results of the analysis are coarse approximations. The GNN data is recommended for dead wood analysis at a fifth field watershed scale. This analysis analyzed at a smaller scale, dividing Forest Service lands within the Nestucca watershed into stands size classes. The distribution of snags and down wood is highly variable across the landscape, therefore it’s unwise to rely on North Nestucca Environmental Assessment Page 4

Appendix G-1 estimates from plot data when extrapolated to small parcels of that landscape. The range of variability increases at smaller scales. However, the data approximates the observed differences in managed and unmanaged stands in the Coast Range. The following summary table shows deadwood in the inclusive and large size classes by stand size classes in the Nestucca River watershed. Table 1. Deadwood by Size Class Percent Percent Snags per Snags per Cover Cover Size Snags ≥10" Snags ≥20" acre ≥10" acre ≥20" of Logs of Logs class Acres DBH DBH DBH DBH ≥5" ≥20" Large 32,943 523,000 255,000 16 8 4 3 Small 24,523 298,000 102,000 12 4 4 3 Open 12,059 37,000 22,000 3 2 3 2

Small and open stands hold about 40 percent of the total snags (>10” DBH) on approximately 53 percent of the area, but only 33 percent of the large snags. The large size class of stands is dominantly older natural forest. This large size class holds 60 percent of all snags, and two-thirds of large snags.

The following histograms (Figures 3 and 4) show the percent of Forest Service lands in the Nestucca fifth-field watershed by density class (snags per acre) for the coastal western lowland conifer hardwood wildlife habitat type (68,691 acres). Other wildlife habitat types in the watershed occupy only 1250 acres, less than two percent of the watershed, and are not analyzed in this section.

Seventy-nine percent of the open and 60 percent of the small (managed) stands have less than 6 snags per acre, compared to only 23 percent of the large (principally natural) stands. Thirty-two percent of the landscape under reference conditions has less than 6 snags per acre, reflecting a typical distribution among all three size classes. Most of the high snag densities are in large stands. Thirty-seven percent of large stands had densities greater than18 snags per acre; only 11 percent of small stands had greater than18 snags per acre. Ninety-eight percent of all large stands have some snags. Eighty-eight percent of small stands had at least one snag, while 73 percent of open stands had at least one snag.

North Nestucca Environmental Assessment Page 5

Appendix G-1

Figure 3. Percent of Forest Service Lands by Snag Density Class 40.00

Snags (10"+) on FS lands in Nestucca 35.00 fifth field watershed % of Coastal western lowland conifer- 30.00 hardwood wildlife habitat type in snag density class

25.00 Small stand (10-20") Large 20.00 stand(20"+) Open/young 15.00 Reference

10.00

5.00

0.00 0 gt0to6 6to12 12to18 18to24 24plus

The histograms of snags greater 20” DBH (Figure 2) show current distribution on Siuslaw NF lands within the Nestucca fifth-field watershed compared to a reference condition based on information for the Wildlife Habitat Types from DecAID and the Forest Service Fire Regime Condition Class data for this area. The major shift away from the reference condition is reflected in fewer acres in the 6-10 snags per acre density classes; those acres instead have less than 4 snags per acre. As expected from the stand ages, the small, managed stands have very few of the large snags, compared to natural stands. Further, the watershed saw multiple fires that consumed some of the potential legacy woody material for those acres. The stands planted in with off-site tree seed (the offsite stands), are now old enough to have grown into the large (≥20” DBH) size class, but may lack large snags and logs due to their age and their history of repeated fire. Overall, the discrepancy between the reference and current condition is due to a combination of harvest and fire history, which resulted in a lower number of old growth stands than might be typical in this part of the Coast Range. However, the range of natural conditions for a fifth field watershed in the Coast Range could encompass wider variation around the reference condition, given the large size of fires that make up the fire regime in the area.

North Nestucca Environmental Assessment Page 6

Appendix G-1

Figure 2. Large Snags on Forest Service Lands (Percentage of Forest Service Lands by Snag Density Class) 25.00 Large snags (20"+) on FS lands in Nestucca fifth field watershed 20.00 Open/young

Small stand 15.00 (10-20") Large stand(20"+) 10.00 reference

5.00

0.00

DESIRED CONDITION, BASED ON SUCCESSIONAL PATHWAYS Successional pathways are defined by the typical, dominant compositional and structural stages that can be expected as vegetative communities develop following disturbance. Conceptual models of succession were developed for each environment by using inventory information (Table 14) and field observation. (LSRA, 1998)

Research by Tappenier, et.al. (1997) has shown evidence that many of the Coast Range’s old- growth forests appear to have developed from relatively widely spaced trees that were established in the wake of a series of infrequent disturbances. They quickly developed large, tapered stems, big crowns, and general vigor; all of which contributed to their longevity and stature in old-growth forests. In contrast, young stands today are developing from dense, single- aged, uniformly planted stands or naturally established conifers. Thinning is an opportunity to move plantations to densities closer to those developed naturally.

Deadwood is only one element considered in restoration thinning. Other important components in restoration of late-successional habitat include development of individual tree structure to provide large diameter limbs and providing nesting habitat for northern spotted owls and marbled murrelets; and the opening of tree canopies to provide enough light to reach the forest floor which enhances understory development, diversity, and provides a multi-story canopy. Without thinning, understory tree development and large diameter limb development is substantially delayed. Large limb development may never occur within these overstocked stands.

North Nestucca Environmental Assessment Page 7

Appendix G-1

MODELING DEADWOOD SIZE AND FREQUENCY IN UNTHINNED PLANTATIONS The size and number of snags created in unthinned plantations through time is an important component for assessing the effects of proposed thinning prescriptions the in Late Successional Reserves (USDA Forest Service 1994). Growth models calibrated for this region are being used to project live tree growth and mortality. Forest Vegetation Simulator- Pacific Northwest Variant (http://www.fs.fed. us/fmsc/fvs/index.shtml) and ORGANON (http://www.cof.orst.edu/cof/fr/research/organon/) are two models commonly used predict tree growth and suppression mortality as stands approach expected maximum tree densities. The Forest Vegetation Simulator (FVS_PN) provides the ability to modify most growth and mortality functions to conform to local observations of stand development. The intent of this analysis is to compare suppression mortality projections from available growth model using default growth model parameters to observed growth data from the Siuslaw National Forest. Following the comparison, the model most accurately representing the observed mortality data will project potential suppression mortality within an unthinned stand at age 101 years. The Siuslaw National Forest participates in the Siuslaw Thinning and Underplanting Density Study (STUDS) with the USFS Pacific Northwest Research Station and Oregon State University Forest Science Department (Chan et. al, 2006, Poage and Anderson, 2007). The purpose of STUDS is to determine responses to density treatment ranges considered for LSR development. This analysis uses the year 14 and 15 measurements of the unthinned treatments to validate growth model projections and infer which models may be the appropriate to project mortality into the future in dense, uniform stands. This analysis uses three no-thin, unplanted one-acre STUDS plots on three sites distributed across the Siuslaw National Forest to assess mortality development patterns. Diameter distributions of live trees and accumulated mortality by diameter at death at the end of the growth period (age 46 years) are displayed in figures 5, 6, and 7. Mortality is almost exclusively occurring in the smaller diameter classes. Virtually all mortality is suppression mortality with the exception of a broken top occurring in a larger tree within the first 8 years of the study at the Wildcat site.

Figure 5.

North Nestucca Environmental Assessment Page 8

Appendix G-1

Figure 6.

Figure 7.

The Cataract site plot was used to compare actual observed data with growth model projections. The initial data set from this plot at age 31 was entered into three models: FVS_PN, ORGANON_SMC and ORGANON_NWO. The FVS_PN variant was developed in 1995 from Forest Service and Bureau of Land Management data sets. The model is intended to represent the Siuslaw and Olympic national forests and adjacent forest lands (Keyser, 2008). The ORGAON_SMC version was developed and continues to be updated with plot information from the Stand Management Cooperative (SMC) data set. This data set is composed of uniform planted stands with intense density control. Data from older uniform naturally stocked stands were used to supplement the younger SMC data set (Clappell, 1991, Hann et. al, 2006). The Northwest Oregon version of ORGANON (ORGANON_NWO) was developed from from permanent plots in the predominantly natural stands in the Oregon State University school forest.

Projections using the initial Cataract plot data at age 31 were projected for 15 years to age 46 to coincide with the end data set. Figures 8, 9 and 10 display the projected 15-year live tree distribution and accumulated mortality for each model. The two ORGANON models concentrate suppression mortality within the smaller diameter classes, while the FVS_PN distributes

North Nestucca Environmental Assessment Page 9

Appendix G-1

suppression mortality proportionally across diameter classes. This relationship is inconsistent with the STUDS data and other related studies (Dodson, 2012). The two ORGANON models simulate mortality distributed in the smaller size classes. This is more consistent with the observed STUDS data and other related studies than the FVS_PN simulation. The suppression mortality distribution in FVS_PN is a recognized inaccuracy and is under consideration for recalibration (Smith-Mateja, 2012). This analysis indicates that plantation stands would be expected to create suppression mortality similar to the range of projections found with the SMC and NWO_ORGANON models. Figure 8.

Figure 9.

North Nestucca Environmental Assessment Page 10

Appendix G-1

Figure 10.

The two ORGANON models were used to project the Cataract plot data through time to determine a possible range of snag size development to age 101 years. The results are displayed in figures 11 and 12. The majority of mortality in these simulations occurred in the smaller diameter classes of less than 20 inches. It is unlikely that much suppression-created deadwood greater than 20 inches in diameter will develop in the unthinned plantation stands prior to age 101 years.

Figure 11.

North Nestucca Environmental Assessment Page 11

Appendix G-1

Figure 12.

EFFECTS OF THINNING ON DEADWOOD CREATION Silvicultural Prescriptions and Unit Size Plantations are reviewed by the interdisciplinary team. The original clearcut boundary is used as a starting point evaluating stands for restoration thinning. These boundaries are adjusted by stream buffers, hardwood dominated areas, acceptable stocking levels, unstable areas and logging feasibility resulting in generally a smaller area than the original clearcut boundary proposed for treatment.

Thinning removes smaller diameter trees that potentially would experience suppression mortality. Snags and coarse woody debris are created following thinning. The no-cut buffers would still experience suppression mortality. Following thinning the stands retain more live trees than the target natural stand as derived from Table 14 - Structure and Composition of the Mature Condition of Late-Successional Stands by Sub-Series Environment found in the LSRA (shown above).

Thinning from below is generally practiced. This removes the smaller diameter trees and leaves the larger dominant and co-dominant trees. Trees harvested range from 6 inches diameter and larger. About three to five years following thinning the stand is evaluated to determine if mechanical or if natural forces wind, insects or disease have created snags or coarse wood. At that point it is determined how many snags and coarse wood pieces need to be created to meet the silvicultural prescription. Snags and coarse woody debris are created from the remnant trees generally 14 to 18 inches in diameter.

North Nestucca Environmental Assessment Page 12

Appendix G-1

Deadwood Development The snags and coarse woody debris less than 21 inches in diameter (Table 9, LSRA, 1997) develop from the understory trees that regenerate following thinning as space and light are increased. Additional evidence is from the summary of Tables 18 and 19 from LSRA, 1998. These snags may develop from the effects of suppression, insects, disease, or wind. The snags in the medium, large and giant would generally develop from trees that remain following thinning. These snags develop from the effects of insects, disease or wind with the effect of suppression mortality playing no or an insignificant role.

Table 3. Summary of LSR Assessment tables 18 and 19 Spies and Franklin (1988) Total # of Total # of Total # of Cubic Down Wood Snags/Acre> or Snags/Acre> or Snags/Acre Feet/Acre Cubic Stand Age = 20” DBH (all = 20” DBH and < 20” DBH** of All Snags Feet/Acre heights)* > 16 (all heights) feet tall Young 7 2 41 1229 1100 (<80 years) (4 to 10) (0 to 4) (24 to 58) (697 to 1761) (596-1604) Mature 7 3 47 1486 1729 (80-199 years) (2 to 12) (1 to 5) (11 to 83) (649 to 2326) (776-2682) Old Growth 7 4 9 2115 3258 (>199 years) (5 to 9) (2 to 6) (7 to 11) (1247 to 2983) (3258-4126) *Includes all heights greater than 4.5’ **Includes snags > or = 3.9” Thinning removes potential suppression mortality trees from stands. However, mortality from insects, disease and wind can and will continue following thinning. Early results from the Siuslaw Thinning and Understory Development Study (Yachats) indicate that mortality does occur, not just from suppression.

The Siuslaw Thinning and Under-planting for Diversity Study is designed to characterize the effects of thinning to increase structural heterogeneity on stand composition, structure vegetative diversity and productivity in young even-age managed stands. At one of the replication sites (Yachats) the number of snags >10” diameter at breast height (DBH) 16 years after the initial thinning and one year after a second thinning is disclosed in Table 4. The other sites have not been analyzed yet but appear to have similar number of snags per acre.

Table 4. Snags/Acre in Yachats Site Treatment Snags/Acre >15" DBH Unthinned 7 0 100 TPA 8.5 2 60 TPA 7 1 30 TPA 4.5 2.5 TPA = Trees Per Acre

Two studies from the Oregon Coast Range were designed to focus on snag and coarse woody debris development. Spies, (1988) showed that about 41 snags per acre less than 20 inches were in stands less than 80 years old. Carey, (2007) showed that about 33 snags per acres less than 20 inches were in stands less than 80 years old. Carey broke the diameter classes a little further

North Nestucca Environmental Assessment Page 13

Appendix G-1

showing that about 26 of those 33 snags per acre were between 4 and 7 inches DBH leaving about 7 trees per acre in between 8 and 19 inches in diameter.

Influence of Stand Density on Tree and Stand Characteristics Several studies have evaluated the effects of thinning on young Coast Range conifer stands. The effects of stand density and competition on individual trees and stands have been widely documented (Assmann 1970; Curtis and Marshall 1986; Marshall et al. 1992; Smith et al. 1996). They include: − Stem size - At low density, trees develop thick tapered stems. − Crown characteristics - At low density, trees have large branches and wide, long crowns, and much of the stem is covered with foliage and branches. − Tree vigor and stability - At low density, individual trees are vigorous and better able to resist windthrow, insects, and diseases, and they may produce more seed. − Total stand growth and yield - Growth and yield are often low in very low-density stands. There is a tradeoff between tree size and the total volume of wood production. In addition, trees growing at low density develop large branches low on the stem, resulting in knots that might reduce wood quality. However, management objectives may include leaving some tress with large branches for wildlife habitat. − Mortality from inter-tree competition - Mortality is less in low-density stands, and the trees that do die are generally considerably larger than dead trees in high-density stands. Understory vegetation. The less dense the stand, the more developed the understory vegetation. Regeneration of herbs, understory shrubs, hardwoods, and conifers is much higher under less dense stands because there are fewer overstory trees to compete for light and water.

Regeneration of Understory Species Reducing overstory density and shrub cover frequently enables conifers, hardwoods, and shrubs to become established in the understory (Bailey and Tappenier 1998). In a comparison of paired thinned and unthinned stands on BLM land, seedling frequency ranged from 0.3 to 1.0 in thinned stands and 0.0 to 0.2 in unthinned stands. Douglas-fir occurred in 91 percent of the thinned stands but only 22 percent of the unthinned stands. Western hemlock and western redcedar, shade-tolerant species, were the most common conifers in the understory in all stands; their densities and frequencies were highest in thinned stands.

Individual Stand Analysis For each stand in the proposed action, stand analysis of the original clearcut size, the proposed unit size, the residual stand trees per acre, the target structure and composition of mature condition of late-successional stands by Plant Association Group (PAG), and the number of created snags and downed wood prescribed following harvest was preformed. It was found that stocking levels of live remnant trees per acre still exceeded the target for live and snag levels at the medium, large and giant size when the stand reached maturity. Size and levels of snags and coarse wood that are prescribed following thinning (created or natural) are within the tolerance levels for this stand age. Additionally, the no-cut buffers provide the opportunity for the effects of suppression mortality to continue.

North Nestucca Environmental Assessment Page 14

Appendix G-1

Stand 504373 This stand was modeled showing growth and mortality with no thinning, thinning to 30 trees per acre (TPA) and thinning to 60 trees per acre at ages 55 and 125 years with thinning occurring at age 35. The model was run for mortality rate at ages 55 and 125 for the 30 and 60 trees per acre scenarios and the unthinned stand. Suppression mortality for the unthinned stand occurred, but even at 125 years of age no snags were greater than 19 inches DBH. Suppression mortality essentially is non-existent following thinning in the 30 and 60 trees per acre scenarios. Mortality at lower stand densities is a result of other causes such as disease, insects, or wind effects. Increase diameter growth through thinning provides the opportunity of this mortality in the 20 inch and greater diameter. The model was not run to include understory tree development which we assert is the place that smaller diameter snags and down wood will develop as the trees remaining following thinning will produce the snags in the large and giant size classes.

CONCLUSION Review of the snag and coarse wood strategies outlined in the Late-Successional Reserve Assessment finds that the commercial thinning prescriptions generally fall between Strategy 2 – Balance long-term and short-term needs by supplying a steady input of CWD over time and Strategy 3 – Develop large trees for future CWD. Some snags and coarse wood are created following thinning (Strategy 2) and commercial thinning accelerates diameter growth compared to leaving a stand unthinned (Strategy 3). Strategy 4 - Allow natural successional processes to dominate by maintain some untreated areas is prescribed within the no-cut buffers. Strategy 1 - Immediately improve nutrient cycling, fungal and soil invertebrate health, and habitat dependent species is prescribed within the pre-commercial thinning units within the watershed where the cut material is left on site.

Furthermore, about 77 percent of the North Nestucca project area is within natural stands where Strategy 4 - Allow natural successional processes to dominate by maintain some untreated areas occurs.

North Nestucca Environmental Assessment Page 15

Appendix G-1

WORKS CITED

Assmann, E. 1970. The principles of forest yield study. Pergamon Press, New York, NY. 506 p

Bailey, J. D., and J. C. Tappeiner. 1998. Effects of thinning on structural development in 40- to 100-year-old Douglas-fir stands in western Oregon. For. Ecol. and Manage. 108:99-113.

Carey, Andrew B.; AIMing for Healthy Forests: Active, Intentional Management for Multiple Values, USDA Forest Service, PNW Research Station, GTR PNW-GTR-721, November 2007.

Chan, S.S.; Larson, D.J.; Maas-Hebner, K.G.; Emmingham, W.H.; Johnston, S.R.; Mikowski, D.A. 2006. Overstory and understory development in thinned and underplanted Oregon Coast Range Douglas-fir stands. Canadian Journal of Forest Research. 36: 2696-2711

Curtis, R. O., and D. D. Marshall. 1986. Levels-of-growing-stock cooperative study in Douglas- fir: Report no. 8 —the LOGS study: Twenty-year results. Res. Pap. PNW-356. USDA Forest Service, Pacific Northwest Research Station, Portland, OR. 113 p

Dodson, E. K., A. Ares, and K.J. Puettmann. 2012. Early responses to thinning treatments designed to accelerate late successional forest structure in young coniferous stands of western Oregon, USA. Canadian Journal of Forest Research. 42(2): 345–355

Hann, D. W.; Marshall, D. D.; Hanus, M. L. 2006. Re-Analysis of the SMC-ORGANON Equations for Diameter-Growth Rate, Height-Growth Rate, and Mortality Rate of Douglas-Fir. Oregon State University Forest Research Laboratory Research Contribution 49. 24p.

Keyser, Chad E., comp. 2008 (revised March 16, 2012). Pacific Northwest Coast (PN) Variant Overview – Forest Vegetation Simulator. Internal Rep. Fort Collins, CO: U. S. Department of Agriculture, Forest Service, Forest Management Service Center.

Marshall, D.D., J. F. Bell, and J. C. Tappeiner. 1992. Levels-of-growing stock cooperative study in Douglas-fir: Report no. 10-The Hoskins study, 1963-83. Res. Pap. PNW-RP-448. USDA Forest Service, Pacific Northwest Research Station, Portland, OR.

McCain, C. 2011. Personal communication with Siuslaw National Forest Ecologist. September 23, 2011

North Nestucca Environmental Assessment Page 16

Appendix G-1

Poage, N. J.; Anderson, P. D. 2007. Large-scale silviculture experiments of western Oregon and Washington. Gen. Tech. Rep. PNW-GTR-713. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station. 44 p.

Smith, D. M., & Smith, D. M. (1997). The practice of silviculture: Applied forest ecology. New York: Wiley

Smith-Meteja, E. 2012. Personal communication with Forest Vegetation Simulator Staff. April, 2012

Spies, T.A., Franklin, J.F., Thomas, T.B. 1988. Coarse woody debris in Douglas-fir forests of western Oregon and Washington. Ecology. 69: 1689-1702.

Tappeiner, J.C.; Huffman, D.; Marshall, D. [and others]. 1997. Density, ages and growth ratios in old-growth and young-growth forests in coastal Oregon. Canadian Journal of Forest Research. 27:638-648

USDA Forest Service and USDI Bureau of Land Management 1998. Late-successional Reserve Assessment for Oregon’s Northern Coast Range Adaptive Management Area. Corvallis, OR.

USFWS 1992 Endangered and Threatened Wildlife and Pland; Final Designation of Critical habitat for the Northern Spotted Owl. Final Rule. 57FR179

USDA Forest Service, 1994. Record of Decision (ROD) for Amendments to Forest Service and Bureau of Land Management Planning Documents in the Range of the Northern Spotted Owl and Standards and Guidelines for Management of Habitat for Late Successional and Old Growth Related Species Within the Range of the Northern Spotted

U.S. Fish and Wildlife Service. 1997. Recovery Plan for the threatened marbled murrelet (Brachyramphus marmoratus) in Washington, Oregon and California. Portland, Oregon. 203 pp.

{USDI}. USDI Fish and Wildlife Service. 2008. Birds of Conservation Concern 2008. United States Department of Interior, Fish and Wildlife Service Division of Migratory Bird Management, Arlington, Virginia. 85 pp

North Nestucca Environmental Assessment Page 17

OWN ACRES BAY 1882 1882 BLM 1 BLM 116 BLM 354 BLM 56 BLM 40 BLM 40 BLM 84 BLM 155 BLM 37 BLM 726 BLM 38 BLM 736 BLM 1362 BLM 82 BLM 118 BLM 164 BLM 41 BLM 3579 BLM 121 BLM 3 BLM 85 BLM 1295 BLM 461 9692 PVT 96 PVT 120 PVT 157 PVT 148 PVT 53 PVT 333 PVT 88 PVT 15 PVT 40 PVT 162 PVT 141 PVT 84 PVT 312 PVT 100 PVT 102 PVT 110 PVT 37 PVT 199 PVT 13 PVT 15 PVT 288 PVT 50 PVT 355 PVT 638 PVT 320 PVT 434 PVT 667 PVT 159 PVT 1110 PVT 36 PVT 521 PVT 11 PVT 294 PVT 5840 PVT 368 PVT 641 PVT 516 PVT 30731 45301 RIV 662 662 SNF 3 SNF 156 SNF 24809 SNF 0 SNF 2 SNF 89 SNF 207 SNF 199 SNF 1220 SNF 8 SNF 495 SNF 14836 42025 STA 27 STA 161 189 North Nestucca Project Area Ownership OWN Acres BLM 12,251 (Acres) FWS 178 Private 31,064 8% USFS 25,279 16% 0% BLM State 5,766 FWS Total 74538 34% Private USFS 42% State North Nestucca Environmental Assessment Appendix- G-2

North Nestucca Restoration EA Condition Acres North Natural Stand 14,583 Proposed Project Deferred Plantation 4,282 1,068 117 opsed Commercial T 5,229 Buffer 1,068 Natural Stand Non-Forested 117 5,229 Deferred Plantation 25279 Propsed Commercial Thin 14,583 4,282 Buffer Non-Forested Appendix H

FISHERIES BIOLOGICAL EVALUATION

Project Name: North Nestucca Landscape Management Project NEPA Document Name: North Nestucca Landscape Management Project Environmental Assessment Watershed Analysis: Nestucca Watershed Analysis, Siuslaw National Forest, 1996 Terrestrial ESA Consultation: FWS Ref. No. 1-7-05-F-0664 and 1-7-06-F-0192 Administrative Unit: Siuslaw National Forest, Hebo Ranger District Prepared By: Jason Wilcox, Fish Biologist; David Skelton, Fish Biologist; Ron Hudson, Hydrologist; Michael Reichenberg, Silviculturist; Mike Brouwer, Transportation Planner; Doug Shank, Soils; Matt Ruedy, Logging Systems; John Casteel, NEPA Planner Date: March 30, 2012 Signature: Jason M. Wilcox

Table 1. Federally listed species, Critical Habitat and Essential Fish Habitat addressed in this Biological Assessment.

LISTED SPECIES or HABITAT ESA STATUS ESA / EFH DETERMINATION Oregon Coast Coho Salmon Threatened No Effect Evolutionarily Significant Unit (ESU) Oregon Coast Coho Salmon Critical Habitat Designated No Effect

Coho Salmon Essential Fish Habitat N/A No Effect

Chinook Salmon Essential Fish Habitat N/A No Effect

North Nestucca Environmental Assessment Page 1

Table 2. North Nestucca Restoration Project Watersheds. NW Forest Plan Key HUC NAME USGS HUC CODE Drainages Watershed 4th Field Wilson/Trask/Nestucca 17100203 n/a

5th Field Nestucca River 1710020302 Yes

5th Field Little Nestucca River 1710020301 No

5th Field Tillamook River 1710020303 No Sand Lake Frontal- 5th Field 1710020309 No Pacific Ocean Nestucca Bay-Frontal 6th Field 171002030210 Clear, Horn, Smith Yes Pacific Ocean Lower Nestucca 6th Field 171002030209 Farmer, West, Wolfe Yes River/Farmer Creek Nestucca River/Niagara 6th Field 171002030204 Clarence, Slick Rock Yes Creek Middle Nestucca 6th Field 171002030206 Bays, Hatinger, Wake Yes River/Powder Creek Upper Nestucca 6th Field 171002030203 Unnamed Nestucca tributary Yes River/Testament Creek Upper Nestucca 6th Field 171002030205 East, Moon Yes River/Moon Creek 6th Field Beaver Creek 171002030207 East & West Beaver, Wildcat Yes Middle Little Nestucca 6th Field 171002030102 Bear No River Lower Little Nestucca 6th Field 171002030103 Fall No River Sand Creek Frontal-Pacific 6th Field 171002030902 Andy No Ocean 6th Field Upper Tillamook River 171002030301 Mills No

I. INTRODUCTION

The North Nestucca Landscape Management Project (North Nestucca Project) is located in watersheds currently providing habitat for the Oregon Coast Evolutionarily Significant Unit of coho salmon (Oncorhynchus kisutch); a species listed as threatened under the Endangered Species Act (Tables 1 & 2) and considered a Management Indicator Species (MIS) by the US Forest Service. This Biological Evaluation (BE) evaluates the effects that the project alternatives may have on these fish and their designated critical habitat, and also evaluates the effect of these alternatives on Essential Fish Habitat (EFH) as designated by the Magnusen-Stevens Fishery Conservation and Management Act, and upon coastal steelhead (Oncorhynchus mykiss irideus), listed by the US Forest Service as Sensitive on the Regional Forester’s Special Status Species List (2011) and as a Species of Concern by NMFS (2004). All analysis is based upon data available at the date of signing. The Southern Distinct Population Segment of North American Green Sturgeon (Acipenser medirostris) is ESA-listed as threatened. The only Critical Habitat in Oregon includes Coos Bay, Winchester Bay and Yaquina Bay. The Southern Distinct Population Segment of Eulachon (Thaleichthys pacificus) is ESA-listed as a threatened species. The Chum salmon (Oncorhynchus keta) is listed on the 2011 Regional Forester’s Special Status Species List as Sensitive. None of these species occur in the project area, and therefore project activities will have no effect on these species.

Two project alternatives have been identified and fully analyzed for the North Nestucca Project: Alternative 1, No Action and Alternative 2, the Proposed Action or the Project. The Proposed Action is described as Alternative 2 in the North Nestucca Landscape Management Project Environmental Assessment.

North Nestucca Environmental Assessment Page 2

Project design criteria (Appendix A) have been established to have no effect on ESA-Listed Threatened Oregon Coast coho salmon and their critical habitat. This Biological Evaluation (BE) presents project design criteria needed to make the project have no effect on coho, and it discloses the overall effects of the commercial timber sale activities portion of the project. The no effect design criteria are specific to the North Nestucca Project proposed actions and existing conditions and may not be appropriate in other locations. No Action would maintain existing conditions, avoiding short-term adverse effects to aquatic species. No actions would be implemented to improve habitat conditions in the long term. Actions proposed by the North Nestucca Project have been designed to avoid short-term, adverse effects to aquatic species. Improved road drainage would occur immediately after project implementation, and thinning would accelerate future recruitment of large woody debris (LWD) to some non-coho bearing stream channels, providing additional or higher quality spawning and rearing habitat in the long term.

This BE was prepared in accordance with the following guidance and direction: Endangered Species Act of 1973 (as amended), and Magnuson-Stevens Fishery Conservation and Management Act (§ 305(b)) and its implementing regulations (50CFR § 600).

II. Description of Proposed Action The following is a summary of the North Nestucca Project as it relates to fish and their habitat. Additional information is available in the North Nestucca Landscape Management Project Environmental Assessment and Notice of Decision. Purpose and Need - This project plans to accelerate the development of late successional habitat characteristics by thinning previously clear-cut and densely planted conifer stands. Project Elements - The project has four primary elements: Thinning, Yarding, Road Construction and Maintenance, and Timber Hauling. Detailed design criteria for these elements are in Appendix A. Thinning – There are 25,279 acres of National Forest System Land within the approximate 75,113 acre Project Area. Approximately 10,579 acres of large conifer forests within the National Forest have been replaced by densely planted stands (plantations) of mostly Douglas fir trees. This area is contained within about 92 harvest units that will be commercially thinned in managed stands (Alternative 2 Map). About 5500 acres contain stands that are 26 to 65 years old. These trees need to be thinned to allow increased growth in order to obtain LSR objectives. No harvest buffers will be applied as described in Table 3. A no harvest buffer of at least 15 feet and retention of at least one row of conifer along intermittent streams and 30 feet and retention of at least two rows of conifer along perennial streams will be maintained when conifers are present. Actual buffer widths will be determined by site conditions including vegetation, slope and soil stability, logging systems access feasibility, and will frequently exceed the minimum distances (see Design Criteria in Appendix A). The buffer widths are, in part, in response to the Nestucca Watershed Analysis recommendation (p 112) to manage young vegetation to produce large trees to increase the potential supply of LWD. The prescription calls for thinning to variable densities with the reservation of un-thinned areas within each stand. Units would be thinned down to 50-100 trees per acre with an average stocking of 71 trees per acre. Approximately 511 openings 1/2 to one-acre in size would be created to promote development of diverse stand characteristics and diverse under-story tree species. All openings will be at least 90 feet from any perennial stream channel and at least 150 feet from coho Listed Fish Habitat (LFH).

North Nestucca Environmental Assessment Page 3

Table 3. Design criteria and description of no cut buffer widths for Alternative 2. 1 Stand Location No Cut Buffer Description Minimum 100 feet and minimum retention of first two rows Containing or adjacent to coho salmon LFH of plantation conifers

Minimum 75 feet from stream and minimum retention of first two rows of plantation conifers (includes debris-flow prone tributaries identified in-field by soils specialist and GIS analysis); or Within 1000 feet upstream of coho salmon LFH Where plantation conifers do NOT exist within 75 feet of channel, a minimum buffer of 75 feet and the first row of plantation conifer that is encountered upslope of the 75 foot buffer will not be removed. Minimum buffer of 30 feet where plantation conifers exist within 30 feet of channel, and two rows of plantation conifer will not be removed; or Containing or adjacent to other perennial streams Where plantation conifers do NOT exist within 30 feet of channel, a minimum buffer of 30 feet and the first row of plantation conifer that is encountered upslope of the 30 foot buffer will not be removed. At least 15 feet from intermittent streams and minimum Containing or adjacent to other intermittent streams 2 retention of first single row of plantation conifers. 1 Buffers will at least include the inner gorge adjacent to streams and the active floodplain. 2 Most intermittent stream buffers will be approximately 30 feet minimum due to the proximity to the 1st row of conifers.

Most of the project is within Riparian Reserves. The North Nestucca Planning Area is within the Upper Nestucca Key 1 Watershed (USDA ROD, 1994). Key 1 Watersheds are those to be managed for at-risk anadromous salmonids due to their inherent beneficial characteristics as critical refugia. In general, silvicultural prescriptions are the same for both riparian reserves and upslope stands. The young managed stands in the project area form rather large, contiguous blocks with relatively narrow strips of older natural stands in-between. The older genetically offsite stands are located along the periphery of the younger managed and older natural stands. Management emphasizes maintaining and enhancing dispersal habitat for late-seral species and providing connectivity between blocks of existing late-successional habitat with the long-term goal of creating large blocks of late-successional forest. The stands proposed for treatment are densely stocked, not complex or diverse stands, which would only achieve late-successional conditions “on their own” over a long period of time due to stocking levels. Desirable components of the stand, such as large-limbed, open-grown trees, may not develop because of stocking levels. Species composition in the Project units overall is highly variable, though there is potential to increase the mix of Douglas-fir, hemlock, spruce, cedar and alder as appropriate at the site scale. Topography, proximity to the coast, and current stand densities raise the concern that if left un-thinned, many of these units have an increasing risk of blowing down during a major storm (such as the Columbus Day storm of 1962). Yarding - Logs produced from the silvicultural thinning will be yarded from units using ground-based, skyline and helicopter based systems. To minimize soil compaction and disturbance, ground-based yarding will be limited to slopes less than 30%, occur only during the dry season and on designated skid trails that are at least 100 feet apart, and use logging slash on the surfaces of designated skid-trails, where possible. The predicted level of detrimental soil conditions associated with the skyline yarded units is <1%. The majority of this affected soil condition will be at the terminus of the yarding, i.e. at the landings, which heal quickly upon project completion. Skyline corridors through riparian areas will be minimized and none will be located over LFH. Road Construction and Maintenance - This project will construct no new system roads, 3.2 miles of new temporary roads, and open about 17.2 miles of existing closed roads to facilitate access to harvest units (Alternative 2 Map). New road construction will not cross any stream channel or unstable areas or slopes and there will be no need for culvert

North Nestucca Environmental Assessment Page 4

installation. None of the new road segments have any direct hydrologic surface connection and none are valley bottom roads. Two re-opened roads (8170111 and 1004127) require re-installation of previously removed culverts that will again be removed upon completion of their respective project use. The closest temporary culvert installations are at perennial stream crossings and approximately 650 feet from LFH (Road 8170111, mile post 0.30) and will therefore be installed and removed during the dry season. All the temporary and re-opened roads would be stabilized and closed upon completion of harvest or end of current operating season, whichever comes first. Four existing rock pits have been identified for use at several locations in or near the planning area (Alternative 2 Map). Use of these sites would be within the existing pit development site. Some of these sites have young alder growing within the established rock pit. Development of the sites may require blasting and rock crushing operations. All rock pit sites are located on stable low gradient locations with no hydrologic surface connection and a minimum of approximately 275 feet from LFH (Alternative 2 Map). Rock would be used for re-surfacing prior to and during log haul. Rock will be placed on new roads only as necessary, and will be left in place after the project is completed. All roadwork other than occasional routine all-season haul route maintenance will be done during the dry season (June through October). Opening the closed roads will require some minor reconstruction/maintenance. Existing temporary roads would be opened by cutting and removing vegetation that may exist on the travelway, and the road surface would be rocked and reshaped by blading if necessary. These roads will be for temporary logging use only and will be re-closed at the completion of the project. Prior to closure, temporary roads used for the project would be stabilized with waterbars, scarified, and seeded to capture and remove any surface runoff. These roads would be closed and blocked to prohibit future disturbance by vehicles once commercial operations are concluded in the units they are associated with. All opened project roads will be storm proofed and blocked to traffic if they have to set through extended periods of wet weather. Project road maintenance on approximately 24 miles of log haul routes will require adding surface rock, repairing worn asphalt surfacing, cleaning ditches and culverts, and brushing. Road maintenance activities along the entire haul route are possible and will be designed to avoid effects to LFH (Alternative 2 Map). Culvert replacements within this Project Area Boundary are being assessed under a separate NEPA analysis. Maintenance will predominantly occur during dry soil conditions, prior to hauling logs, with occasional maintenance during all-season haul if necessary. Steps will be taken prior to and during haul to prevent sediment inputs into streams. Potential sediment producing conditions will be addressed proactively when necessary by installation and cleaning of ditch relief culverts and dips, blading, crowning and/or placing additional rock on the road surface and otherwise diverting water off of the road to be filtered prior to reaching streams. Straw bales, catchment basins, or similar sediment filters will be installed in areas with higher potential to contain sediment, as determined by Forest Service resource specialists and contract administrators. Landings are tentatively identified at this point in the project. Our logging systems specialist assesses logging feasibility and likely landing locations. Final landing locations are proposed by the operator and approved by the appropriate Forest Service Specialists. Landings will all be located along or at the ends of roads and all will be positioned on the ridge tops, not intersect stream channels, and compacted soils at these sites will be decompacted after use, if necessary.

Timber Hauling - Of the 92 units proposed for harvest, nearly half are partially restricted to dry season (generally June 15 – October 15) haul over approximately 21 miles, with additional all-season haul over approximately 72 miles (Alternative 2 Map). Overall, there are approximately 17 planned major log haul routes. All of these haul routes are located on crowned, aggregate roads with ditches and ditch-relief culverts, except paved bridge approaches and crossings over the Nestucca River on the 8533 road, Niagara Creek on the 8594 road, and West Creek on the 1004 road (Alternative 2 Map). Standard Best Management Practices (BMPs) and the Siuslaw Road Rules will provide appropriate protection for aquatic resources during the dry season, including provisions for Forest Service specialists to apply protective measures as deemed warranted on a site-specific basis. ESA-listed bird habitat is located in portions of the Project area and protective design criteria involving timing of haul will be applied accordingly. To avoid sedimentation into stream channels, blading of ditches will be minimized, roads will be monitored during periods of heavy rain, and appropriate erosion control methods will be used to trap sediment where needed on log haul routes. Haul will be suspended if it is determined that sediment directly produced from road haul may enter stream channels and additional active erosion controls will be implemented accordingly. Sediment producing areas will be repaired in addition to suspending haul. All haul will be suspended when rainfall exceeds 1-inch in a 24 hour period. Haul will be resumed after Forest Service specialists have inspected the area of concern and concluded that the sediment

North Nestucca Environmental Assessment Page 5

production potential has passed. Forest Service contract administration personnel will coordinate closely with agency hydrologists, fish biologists, and road engineers to apply these criteria.

North Nestucca Environmental Assessment Page 6

Alternative 2 Map. Commercial thinning activities of the North Nestucca Landscape Management Project, Siuslaw National Forest. (Higher resolution map available in Project file)

North Nestucca Environmental Assessment Page 7

Timing/Duration of Activities - Project activities will be spread out spatially and temporally over an estimated 15 year period. There will likely be 9 timber sales starting in 2013 and extending until approximately 2028. Roadwork will be implemented over an estimated 10-year period with the sales doing a proportion of the total work needed to support timber haul. III. Status of Listed Species and Critical Habitat

ESA/CH/EFH/Special Status – Coho salmon in the North Nestucca Action Area are part of the respective Oregon Coast Evolutionarily Significant Unit (ESU) and are currently listed as a threatened species under the ESA with designated critical habitat (Alternative 2 Map). Steelhead in the North Nestucca Action Area are part of the respective Oregon Coast ESU and Distinct Population Segment (DPS) and are currently listed by the US Forest Service as Sensitive on the Regional Forester’s Special Status Species List. NOAA’s Northwest Fisheries Science Center completed a status review for steelhead within the Oregon Coast ESU in 1996 (Status Review of West Coast Steelhead from WA, ID, OR & CA, August 1996, Northwest Fisheries Science Center, NOAA Fisheries) and subsequently classified it as a Species of Concern in 2004. Population Size and Distribution - Coho salmon and steelhead populations in the Nestucca basin have been depressed and appear to be static to slightly increasing in recent years and thus are assumed to be at risk. There is a hatchery summer and winter steelhead program in the Nestucca basin currently. NOAA’s Northwest Fisheries Science Center completed a status review for Oregon coho salmon in 2005 (Updated Status of Federally Listed ESU’S of West Coast Salmon and Steelhead, June 2005, Northwest Fisheries Science Center, NOAA Fisheries). This review found that the Nestucca River 5th Field watershed had average returns of 1902 adult spawners between 1990 and 2002, which is less than 3% of the overall period’s Oregon Coast ESU mean annual return. The Oregon Department of Fish & Wildlife (ODFW) conducts spawning surveys on the Oregon Coast. From this data they are able to estimate adult coho escapement to the Nestucca River basin, but not specifically for the sub-basins in the North Nestucca Planning Area. The 2004-10 estimated coho escapement for the Nestucca River basin was 4695, 686, 1876, 394, 1844, 4252, and 1947 fish. Uncharacteristically large escapements of over 10000 fish each occurred in 2002 and 2003, significant outlier returns for the period since 1990. ODFW spawning survey data for steelhead is limited, including the Nestucca basin. Overall Oregon Coast ESU steelhead populations appear static or slightly increasing in recent years. Coho salmon and steelhead spawn and rear in Clear, Horn, Farmer, Beaver, Bear, East, and other tributaries to the Nestucca River; and Andy Creek in the Sand Lake Frontal-Pacific Ocean basin (Alternative 2 Map). Growth and Survival – The trend in growth and survival rates are not well documented in the action area and thus they are assumed to be at risk. Life History Diversity and Isolation – Low habitat complexity in the North Nestucca basins may have reduced life history diversity. This indicator is assumed to be at risk. Persistence and Genetic Integrity – These indicators are assumed to be at risk primarily due to the long term declining trend in spawning population abundance. Hatchery steelhead management in the Nestucca River and the cumulative long term reduction in habitat quantity and quality and associated reduction in life history diversity as the area was settled over the last 100+ years has also contributed toward loss of species persistence and genetic integrity in the Project subwatersheds. IV. Environmental Baseline and Effects of the Proposed Action

This section will provide general background information for where this project is located, and then provide a specific discussion of the watershed and stream habitat condition at the watershed scale, and the ESA action area scale. General Information - The North Nestucca Project occurs within the area covered in the Nestucca Watershed Analysis (1996). The Nestucca Watershed Analysis (WA) area consists of approximately 163,000 acres. In the WA area, the USFS and BLM manage about 106,000 acres or 65% of the watershed. These lands include 105,598 acres of Adaptive Management Area (AMA), of which 78,816 acres are also Late Successional Reserves (LSR), as designated by the Northwest Forest Plan (NFP). At least 15,587 acres (71%) of the Project area are Riparian Reserves. There are also several administratively withdrawn areas on both BLM and USFS lands within the watershed, notably the Mt. Hebo Inventoried Roadless Area. General objectives for land allocations are given in the Record of Decision (ROD) (USDA and USDI 1994c, D-1, D-4, D-8, D-15).

North Nestucca Environmental Assessment Page 8

The WA identifies protection or enhancement of salmonid fisheries and aquatic species habitat as a critical issue (p. 124). The WA highlights the substantial reduction in large trees in riparian areas due to past logging and stream cleanout activities. Recovery of large diameter trees is being retarded because most riparian stands in the early seral stage are either densely stocked conifer plantations or alder and brush patches. The WA recommends manipulating young vegetation to produce large trees for eventual recruitment into stream channels (p. 125). The managed stands (i.e. plantations) were planted following clear-cutting. At that time, the primary management goal was to maximize timber production. The clearcuts were usually planted with 300 to 700 Douglas-fir seedlings per acre, and then were to be managed through a series of treatments to maximize timber production. The young plantations proposed for thinning are crowded, ranging from 111 to 313 (mean=246) conifer trees per acre. They are even-aged and single canopied. The trees have relatively small branches and crowns. The units have little or no under-story vegetation, depending on stand density. ESA Action Area - The North Nestucca project potentially affects portions of eleven 6th Field HUC’s totaling 203,454 acres. The actions proposed with the North Nestucca Project will not have effects transmitted downstream beyond the affected watersheds. Specific drainages within each 6th Field HUC are identified in Table 2. Indicator Baseline Condition and Effects of the Proposed Action This section provides a description of the North Nestucca Watershed environmental baseline. One stand, 57, has a small area (27 acres) that is within the Sand Creek watershed boundary adjacent to Andy Creek immediately west of the West Beaver Creek drainage in the Beaver Creek subwatershed. Two stands, number 1 and 3, are located predominantly (all of stand 1 and 84 acres of stand 3) within the Upper Tillamook River watershed boundary adjacent to Mills Creek. These stands are adjacent to Coho and Steelhead habitat and will be buffered from treatment accordingly (see Alternative 2 Map). The description of baseline condition and effects to indicators will pertain to these portions of these stands in addition to the Nestucca subwatersheds. Stands number 2 and 367, as well as 7, have small areas near and/or atop ridgetops that extend into the Little Nestucca and Upper Tillamook River watershed boundaries, respectively. Coho and Steelhead habitat is more than 0.8 miles downstream from these units (see Alternative 2 Map). The small area impacted by thinning and the distant proximity to coho, lead to no impact on coho and associated Critical Habitat and Essential Fish Habitat for all indicators in these areas. Therefore, the description of baseline condition and effects to indicators will focus on the Nestucca subwatersheds, unless otherwise indicated.

Temperature Environmental Baseline – Perennial streams in the North Nestucca Project area are typically densely shaded by shrubs and hardwood trees. Dense conifer stands adjacent to perennial streams are uncommon in this area. Pabst and Spies (1999) found that hardwoods make up 73% of basal area on floodplains, 80.5% on riparian terraces, and 41.7 % on the lower hill-slopes of riparian areas in natural stands. Hibbs and Bower (2001) demonstrate that in managed and unmanaged forests in the Oregon Coast range that riparian conifers rarely grow on the flat surfaces of riparian terraces or floodplains; topography that instead is dominated by alders and shrubs. Nierenberg and Hibbs (2000) not only show an increasing abundance of hardwoods relative to conifers with decreasing distance to the stream, but also suggests a continual regeneration of alders in riparian areas following disturbances such as debris flows, landslides, hydraulic scouring and deposition, and floods. On the Oregon Coast, longitudinal patterns of stream temperature (~500 m reaches) in small streams, similar to North Nestucca streams, are highly variable (Dent et al. 2008). They documented longitudinal patterns in maximum stream temperatures and found that some streams increased, some decreased, and some remained the same. Streams reaches can be cooled by conduction (Brown 1988), sediment deposits that allow cooling by hyporheic exchange, shade, and from colder inputs from groundwater and tributaries (Story et al. 2003; Johnson 2004). The mainstem Nestucca River downstream of Powder Creek is the only stream segment in the Project Area currently listed as water quality impaired on the Oregon Department of Environmental Quality’s 303d list, and is listed for dissolved oxygen.

North Nestucca Environmental Assessment Page 9

Sub-watersheds in the Project area are rated as At Risk since some streams in the area have 7 day average maximum temperatures that are between 57-64F, with the Powder Creek average sometimes exceeding 64F (on file, Siuslaw NF). It is likely that the condition of this indicator will improve on Federal Lands as late successional habitats develop. Potential Effects of the Action –Riparian thinning and yarding corridors have the potential to remove trees that provide shade to perennial streams thus potentially affecting stream temperature. Timber Haul will not affect stream shade and therefore will have no effect on this indicator. Proximity – All skyline corridors will be upstream of coho habitat. There will be no skyline corridors through LFH riparian areas. Yarding corridors will create small openings (10-20 ft wide) and they will remove no more than 20% of the canopy within a given 1000 ft of stream. It is not expected that these widely spaced, small openings will affect stream temperature in coho habitat, thus corridors are not expected to affect this indicator. A variable width no harvest buffer will be placed on each side of all stream channels within and adjacent to thinning stands (Table 3), (Alternative 2 Map), (USDA and USDI 2005). Channels with a high likelihood of recruiting wood into coho habitat from fluvial transport or debris flows, as determined in-field by a Forest Service soils specialist, will have a minimum 75 ft no thin buffer (Alternative 2 Map). The buffer will be designed to maintain existing shade around perennial streams, except at yarding corridors. No harvest buffers on most perennial streams will be larger than 30 feet (typically 50-60 feet) because thinning will only occur in dense conifer units that can be yarded without resource damage, and it is rare to have dense conifers within 30 feet of perennial streams because the riparian areas are usually dominated by hardwoods. Almost all of the streams in and adjacent to thinning units are 1st and 2nd order streams with small channel widths (1-3 ft) and each has a relatively small drainage area (<10%) compared to coho habitat. Most streams are densely shaded. Thinning units will be spatially and temporally dispersed considering the layout of units across watersheds and the 15 year time frame to complete thinning. Probability – The probability of thinning near streams decreases as stream size increases in the action area. The area of dense conifer stands that would benefit from thinning is largest in the headwaters and decreases as stream size increases. Pabst and Spies (1999) found similar trends in conifer distribution in unmanaged stands on the central Oregon coast. Abrupt slope breaks near stream channels occasionally prevent yarding resulting in these areas being left un-thinned. Monitoring of similarly designed thinning after harvest on the Siuslaw National Forest has found that the first 2 rows of conifers adjacent to perennial streams and a thinned stand provide about 80% canopy closure over the stream when measured with a Solar Pathfinder. Siuslaw National Forest monitoring of stream temperature before and after thinning has found no detectable increase in stream temperature after harvest when using similar design criteria as the North Nestucca Project (Figures 1 & 2). Monitoring focused on streams with the highest potential to affect coho habitat, largest areas thinned, dense conifer close to the stream, and largest streams near coho habitat. Monitoring found that maximum water temperature was more correlated with average air temperature than maximum air temperature. The high stream temperature recorded in Traxel Creek in 2006 occurred during an extremely warm series of days. Air temperature in 2006 was higher than any other year during the monitoring period. Air temperature at Cannibal Mountain from 1997-2008 had an average maximum temperature of 71°F and minimum of 51°F. Cannibal Mountain average maximum was 86°F and its minimum was 62°F. The 7 day average maximum, average and minimum air temperature was 6°F warmer than any other year. For 3 consecutive day’s air temperature stayed above 69°F (range 69-95°F). Chan et al. (2004) did not detect any change in western Oregon streambed temperatures with thinning down to 40 trees per acre and variable width no cut buffers that were less than 25 feet wide.

North Nestucca Environmental Assessment Page 10

Figure 1. Effects of thinning on stream temperature, Figure 2. Effects of thinning on stream temperature, Siuslaw National Forest. Siuslaw National Forest Considering the small stream size adjacent to and within most thinning units; the dense brush cover over most of these streams; the first one or two rows of the dense conifer stand adjacent to perennial streams will be maintained (~72trees per acre); harvest units will maintain 50-70% canopy closure (Chan et al. 2006) adjacent to this no harvest buffer; only a very small proportion of the perennial stream miles at the action area and watershed scale will be affected; the effects are spatially and temporally dispersed; and monitoring data that indicates there has been no change in stream temperature due to thinning, thinning will have no effect on this indicator. Element Summary – Timber haul, thinning, road maintenance, and yarding corridors are expected to have no effect on the stream temperature indicator.

Suspended Sediment, Turbidity, Stream Substrate Environmental Baseline - The primary mechanism for delivering sediment to stream channels on the Oregon coast involves mass wasting of hillsides (debris flows, landslides, soil creep), while surface erosion is relatively minor due to the dense vegetative cover (Hassan et al. 2005). Once sediment is delivered to stream channels, coarse-grained sediments typically deposit in the channel while fine-grained (clay, silts, and fine sands) sediment are often transported downstream as suspended sediment, depending on flow (Bilby 1985). Coarse-grained sediments are transported downstream as bedload during high flows. Channel characteristics, such as the amount of wood and floodplain connectivity, have a major influence on where introduced sediment is deposited. Suspended sediment and turbidity are naturally occurring features of coho habitat in the North Nestucca area and the variability in annual suspended sediment yield is very high. In Oregon coastal streams, the highest turbidities usually occur during the first high flows in fall (Beschta 1980). Noggle (1978, as cited in Everest et al. 1987) demonstrated that coho salmon tolerance for suspended sediment was highest in fall when increased suspended sediment concentrations usually occur. Juvenile coho salmon acclimated to clear water (<0.3 NTU) and turbid water (2-15 NTU) did not exhibit significant sediment avoidance until turbidity reached 70 and 100 NTU, respectively (Bisson and Bilby 1982). A gradual increase in suspended sediment to produce a turbidity of 20 NTU did not alter behavior of coho salmon juveniles in laboratory streams (Berg and Northcote 1985). The Alsea Watershed Study documented the effects of different logging methods on physical and biological characteristics of small Oregon coastal streams. They found that sediment yield increased significantly where road construction caused landslides and where clearcut logging, yarding and slash burning occurred without a stream channel buffer (Beschta & Jackson 2008). The initial increase in annual sediment yield was the greatest and then it slowly declined toward pretreatment levels during the next five years. Some road segments in the Project area have increased fine sediment inputs into stream channels, including coho habitat. Road maintenance (ditch cleaning, culvert inlet cleaning, rock durability, etc.), road use and poor drainage design have all contributed to increase fine sediment inputs into coho habitat. Luce and Black (1999 and 2001) found that most road segments in the Oregon Coast Range produce very little sediment, but a few segments produced a large amount. They found that ditch cleaning created the largest increase in erosion from roads. They also found that sediment production from roads was proportional to the product of road segment length and the square of the slope. Aggregate quality

North Nestucca Environmental Assessment Page 11

(durability, % fines) has a major influence on the amount of fine sediment eroded from roads (Luce and Black 1999; Luce and Black 2001), as does the frequency of use (Bilby et al. 1989). Sediment eroded from roads is delivered to one of several storage areas adjacent to the road, including the ditch, near the outlet of ditch relief culverts, on the shoulder of the road, in erosion control devices and in stream channels or floodplains when delivered to streams. Bilby et al. (1989) found that settling ponds can capture and store fine sediment transported in the ditch, specifically the larger particle sizes (>0.063 mm). Road maintenance every few years periodically removes sediment from the ditch, shoulder deposits and erosion control devices and places it a stable location away from streams. Most sediment inputs from roads are delivered to small, non-fish bearing streams (Bilby et al. 1989). Duncan et al. (1987) found that about half of the fine sediment (<2 mm) input into small streams was not transported more than about 400 feet downstream during high flows, but retained within the small streams particularly those with abundant wood. They found that transport distance was inversely related to particle size. Retention and sorting of sediment inputs from roads in small streams plays an important role in determining effects to fish and their habitat downstream. The effect of sediment inputs from roads on spawning gravel composition in fish bearing channels in Washington was studied by Bilby (1985). He estimated that 21% of the annual suspended sediment load carried by the study stream was contributed from the road. Over 80% of the road sediment delivered to the stream, by weight, had a very small particle size (<0.004 mm). In contrast, more than 80% of the fine particle sizes in the spawning gravel ranged from 0.25 – 2.0 mm. Freeze core samples of streambed gravel upstream and downstream of the sediment inputs from the road found no significant difference (P<0.05) in the proportion of fine sediment, by weight, in the gravel. Bilby (1985) concluded that, in this case, road surface sediment was not making an appreciable contribution to the amount of sediment stored in the channel due to the small particle size of sediment inputs from the road. He noted that under different conditions, such as a steeper road segment, unvegetated ditch, or higher flow, larger particle sizes may be delivered to streams. There is considerable variation in the proportion of fine sediments (<0.1mm) comprising streambeds within streams and between streams undisturbed by logging. Adams and Beschta (1980) found that the proportion of fines averaged 19% and ranged from 11-29%. The proportion of fine sediment in spawning gravel beds is often reduced during periods of bedload movement (Adams & Beschta 1980) and when fish construct redds (Peterson & Quinn 1996). The Nestucca WA, stream surveys and field reviews indicate that sand and silt may be slightly elevated from historic conditions in most sub-watersheds. No quantitative data exist on turbidity for streams in the project area. The primary risk for sedimentation identified in the WA was the existing road system. All sub-watersheds are rated At Risk. Potential Effects of the Action - Yarding, road construction and maintenance, and timber haul have causal mechanisms that may affect sediment delivery rates to streams within the planning area. Thinning - Thinning of existing forest stands has no causal mechanism for mobilizing sediment for transport into streams therefore this project element has no effect on the indicator. Yarding – Helicopter, skyline, and ground based yarding methods will be used for this project and have the potential to input sediment into stream channels. Road Maintenance – Road grading and ditching have the potential to input sediment into coho habitat. Timber Haul – Timber haul has the potential to input sediment into coho habitat. Yarding - Effects of the Action – Full-suspension yarding may occur within 100 feet of coho, 30 feet of perennial streams and 15 feet of intermittent channels (Alternative 2 Map). Ground-based yarding will not occur within 100 feet of coho (Units 127 and 233), and 30 feet of perennial streams, and 15 feet of intermittent channels (Alternative 2 Map). Helicopter yarding may occur within 2,500 feet of coho, 30 feet of perennial streams, and 15 feet of intermittent channels (Units 2, 33, and 117) (Alternative 2 Map). Approximately 76% of the yarding will be skyline. Skyline yarding will have one-end suspension of trees brought to landings. Under-story vegetation and tops and limbs that break during yarding from the harvested trees will remain in the units and buffer soil from impact. Thinning removes the smallest trees in the units. Due to small tree size, existing vegetation, duff layer, and remaining limbs and tree tops, soil is protected from yarding impacts. In addition, due to the small tree size, generally whole trees are yarded to the landing. The limbs that remain on the trees tend to protect the ground from disturbance. Cable yarding corridors are narrow (10-15 feet wide), and soil is rarely disturbed if at all by the

North Nestucca Environmental Assessment Page 12

falling and removal of trees for thinning projects of this nature. No rutting occurs from yarding trees to the landings due to the small size of the timber, thick duff layer, under-story vegetation, and limbs and tops of trees yarded remaining on the ground in corridors. Full suspension above all streams throughout the no harvest buffers is required and will prevent ground disturbance within these buffers. Corridors are narrow 10-15 feet wide areas. This corridor width is a common spacing found between conifer trees of this age in a natural stand. Approximately 23% of the acres will be yarded with ground based equipment. All of these acres will be at least 100 feet from coho habitat (Alternative 2 Map). The closest ground based yarding with hydrologic surface connection to coho habitat is 100 feet from coho habitat (Units 127 and 233). The use of designated skids trails, seasonal restrictions, and vegetated filter strips over low gradient topography will prevent sediment from reaching coho habitat. Approximately 2% of the acres will be yarded with helicopter based equipment. Helicopter yarding will have full suspension of trees brought to landings that do not have hydrologic surface connection. Under-story vegetation and tops and limbs that break during yarding from the harvested trees will remain in the units and buffer soil from impact. Thinning removes the smallest trees in the units. Due to the vertical lift associated with this yarding technique, small tree size, existing vegetation, duff layer, and remaining limbs and tree tops, soil is protected from helicopter yarding impacts. Generally whole trees are yarded to the landings. Element Summary – Vegetated filter strips between yarding corridors and streams will prevent sediment inputs into stream channels, thus yarding will have no effect on this indicator. Road Construction/Maintenance – These activities require the exposure and compaction of soil, blasting and excavation of rock, and maintenance such as ditch cleaning, culvert cleaning, blading, and application of new aggregate surfacing, all possibly leading to increased delivery to streams. The design criteria associated with culvert cleaning, new temporary roads, and reopening existing roads and rock pits will minimize the potential to increase soil erosion. New roads are contained within the units and the remainder of the stand, along with the no cut buffer, will serve as a filter area for any soil disturbed by construction activity. The reopening of existing roads will be done with the same criteria as the new construction. This will primarily involve brushing and scraping of accumulated organic duff and spot rocking. Where feasible, road and rock pit surface runoff will be disconnected from directly entering streams and ditch and perimeter vegetation will be left intact to act as a filter strip for road and pit-derived sediment. The new roads proposed are either short segments branching off of existing roads or short extensions of the existing road system along stable low gradient ridgetops. No culverts are needed for the new temporary roads as no drainages will be crossed. Re-opened rock pits are located on stable low gradient sites that are not hydrologically connected overland. Effects of the Action – Ditch cleaning will occur where needed along all haul routes. Design criteria require retention of as much vegetation in the ditch as possible to ensure adequate sediment storage (filtration) in the ditch and prevent sediment from being delivered to stream channels. Additional erosion control devices will be installed where needed to prevent sediment from reaching stream channels. Approximately 2.6 miles of temporary road will be constructed and 17.2 miles of existing road will be reopened. All of the temporary roads are located at least 150 feet away from streams. Reopened roads are at least 800 stream feet (intermittent stream crossing in Stand 302180) from coho habitat and are primarily located on ridges and mid-slope positions. Road maintenance will occur throughout the project area, as funding is made available. The priority road systems to be maintained are roads 1004, 1034, 1500, 8170, 8300, 8376, 8573, and 8377. Maintenance will occur to improve the road surface and drainage of road systems to protect water quality and fish habitat. Element Summary - Considering protective design criteria, road maintenance (ditch cleaning, blading, etc.) is an ongoing activity that is part of the environmental background, and the location of temporary roads and reopened roads, road maintenance will have no effect on this indicator. Timber Haul - The transport of logs from the project area has the potential to increase the movement of soil from road surfaces to streams. Proximity - The all-season aggregate haul route does not cross coho occupied or critical habitat (Appendix I Map). All haul routes are located further from coho habitat or are on asphalt paved roads or will be used in the dry season only (Appendix I Map).

North Nestucca Environmental Assessment Page 13

Probability - Most of the haul crossings are on intermittent streams that have a moderate probability of being at a very low flow rate or dry during haul thus limiting sediment inputs that could reach coho habitat. Most crossings have at least a 50-foot wide vegetated filter strip between the road and stream channels that reduces the potential for haul sediment from reaching streams during winter haul. The aggregate haul route segments with close proximity to occupied coho habitat (Appendix I Map) will receive priority maintenance of surfacing and will be subject to suspension of haul at the authorized discretion of Forest Service sale administrators in coordination with agency hydrologists, fish biologists, and road engineers. Pre-haul road maintenance will bring roads up to standards and minimize the off road transport of surfacing material. Monitoring during haul will ensure the cessation of activity if any erosion of road surfacing occurs, and ensure the installation of mitigation measures to quickly reduce erosion at these sites. The perennial and intermittent streams along the haul route are small streams with most containing abundant wood. Most streams also flow through the forest in a step pool fashion that is likely to store sediment before it reaches coho habitat. BMPs require utilization of measures to mitigate for any foreseeable impacts to water quality as a result of our actions. Sale administration personnel applying design criteria will stop haul when road conditions have the potential to input sediment into stream channels, especially in areas near LFH. With implementation of the PDCs, any sediment produced by these activities is expected to settle on the road shoulder or ditchline, or be entrained by woody material and vegetation on the forest floor prior to entering coho habitat. Considering the small drainage size of streams that have the potential to input sediment into coho habitat, combined with design criteria, contract administration, and the retentiveness of small streams (Duncan et al. 1987), inputs into coho habitat are expected to have no effect upon LFH. Element Summary – Timber haul is expected to have no effect on the suspended sediment, turbidity, and stream substrate indicator.

Chemical Contamination / Nutrients Environmental Baseline – The mainstem Nestucca River downstream of Powder Creek is the only stream segment in the Project Area currently listed as water quality impaired on the Oregon Department of Environmental Quality’s 303d list, and is listed for dissolved oxygen. There is agricultural and rural residential use in the lower part of these watersheds. The headwater areas within the action area are categorized as Properly Functioning, while the watershed as a whole would best be categorized as At Risk due to agricultural activities along the lower mainstem. Potential Effects of the Action - Petroleum products will be present for use in vehicles and equipment used in the project. There is the potential of contamination from these products. Thinning, yarding, road activities and haul - All four project elements utilize fuel-powered machinery and have a potential negative effect if a fuel spill were to occur. Effects of the Action - Hand power equipment will be used to fall, limb and buck trees selected for thinning, or for creation of yarding corridors. These will be used within the unit boundaries, and refueling is not allowed within 50 feet of any stream. Dust abatement chemicals are not utilized with this project, but transport vehicles and support vehicles use diesel or gasoline. These will be refueled at landings or service areas located at least 150 feet away from stream channels. Road maintenance equipment also uses petroleum products, and these typically are refueled at service locations, away from streams. USFS timber administration personnel monitor equipment activity to ensure that BMP’s are properly implemented. Design criteria will prevent thinning, yarding, road activities and haul from having an effect on this indicator. Element and Indicator Summary - The likelihood that a fuel spill will occur is very low. Considering the design criteria that limits where refueling can occur, the likelihood of having a fuel spill affect coho or their habitat is much lower, thus the project will have no effect on this indicator.

Physical Barriers Environmental Baseline – Barriers to fish passage at a range of flows exist within the watersheds as a whole and in LFH, and therefore would best be categorized as Not Properly Functioning due to fish passage barriers in the watersheds. Potential Effects of the Action, Element and Indicator Summary – Road maintenance, Thinning, Yarding and Haul have no casual mechanism to affect this indicator, thus the project will have no effect on this indicator.

North Nestucca Environmental Assessment Page 14

Large Woody Debris Environmental Baseline – Below is a summary of the environmental baseline describing how large wood affects coho habitat, the processes that recruit large wood to streams, and the effects that logging and other activities have on large wood recruitment to coho habitat. The effect that wood has on coho habitat is related to the size of the piece of wood relative to the channel size and gradient. For example, a large piece of wood often forms and maintains pool and floodplain habitats for coho that persist for several years, while a small piece of wood in the same stream may not form any coho habitat. Rosenfeld and Huato (2003) studied the effects of wood in small coastal streams (4-37 ft bank full width; 0.5-10.4% gradient) in British Columbia and found that large wood with a diameter of at least 24 inches formed pools 43% of the time, while pieces with a diameter of 6-12 inches only formed pools about 6% of the time. Literature suggests that large pieces of wood affect coho habitat much more than small pieces. Large pieces form and maintain larger pools (Bilby and Ward 1989), store more sediment (Bilby and Ward 1989, Montgomery et al. 1996, May and Gresswell 2003), decay slower (Melillo et al. 1983, Naiman et al. 2002), and are more resistant to breakage and movement during high flows (Siuslaw NF wood movement data) than small pieces. Pieces that are large enough to resist movement and breakage on a scale of years to decades eventually accumulate several years of organic and inorganic material during high stream flows, creating some of the highest quality coho habitat on the Oregon Coast. Field observations from the North Nestucca area are consistent with the literature that indicates that bank erosion, wind throw and landslides contribute most of the wood volume to streams with mortality being a relatively minor component. May and Gresswell (2003) documented that wind throw and landslides contributed 83-89% of wood recruited to NF Cherry Creek on the southern Oregon coast while natural mortality contributed only 5%. Murphy and Koski (1989) found that 73% of wood inputs came from bank erosion and wind throw while only 23% came from natural mortality in Alaska. Lutz and Halpern (2006) found in Oregon Cascade plantations, similar in age to many North Nestucca stands, that although suppression mortality killed 2.5 times as many trees as mechanical processes (wind and snow), biomass lost to mechanical processes was nearly 4 times that lost to suppression. Suppression mortality typically kills the shortest, smallest diameter stems in the stand (Lutz and Halpern 2006; ORGANON model results) and they typically decompose as standing dead trees with periodic bole breakage migrating from the top down. Wind throw trees are much larger, and therefore, much more likely to reach and affect stream channels than suppression trees (Lutz and Halpern 2006); and field observation indicates wind throw trees are typically uprooted with most of their entire length available to be recruited to streams. Tree height determines the distance from which wood is recruited into stream channels, excluding landslide areas. The probability of a tree being recruited into a stream channel decreases from approximately 50% at the channel edge to 0% when the distance from the stream is equal to tree height (Robinson and Beschta 1990). The majority of wood volume, pieces, and large pieces capable of forming high quality fish habitat originate disproportionately from the area closest to streams (McDade 1988). A 100 ft tall by 15 inch diameter tree within 10 ft of a stream could provide a 38 ft by 8 inch top diameter piece of wood if it fell directly toward the creek, while that same tree 50 ft from the stream could not provide any 8 inch diameter piece of wood but could provide a 28 ft by 4 inch piece (Robinson and Beschta 1990). In Alaska, 82% of the wood recruitment from old growth stands to streams was within 33 ft of the channel, and 99% within 98 ft (Murphy and Koski 1989). In western Oregon and Washington, McDade (1988) and McDade et al. (1990) documented that 61% of the wood recruitment from mature stands (mean tree height = 157 ft) to streams originated within 33 ft of the channel edge, and 97% within 98 ft. Considering average tree height of conifers in stands proposed for thinning in the North Nestucca Project is about 75 feet for the young managed stands, wood recruitment in this area will originate from much closer distances than described above. Average tree height of the offsite stands is larger, though these stands are at least 1500 feet upstream of LFH and therefore are extremely unlikely to contribute wood to these stands. A substantial proportion of the wood in the upper reaches of coho habitat originates from steep, debris flow prone tributaries that episodically deliver large volumes of wood, sediment and boulders to coho habitat (Reeves et al. 2003; May 2001; May & Gresswell 2003). Benda and Cundy (1990) found that debris flows can entrain 8 cubic meters of material (wood and sediment) per meter of headwater stream length they scour. Lancaster et al. (2003) found that debris flows have a smaller run out (they deposit sooner) if they contain abundant wood. May (1998) documented that the diameter distribution of wood in 53 debris flow deposits in the Siuslaw Basin was similar regardless of the age of the present day forest (i.e. clear-cut, young, mature). In addition, May (1998) found that wood diameters in debris flow deposits were typically much larger than the present day forest from where the debris flow originated, indicating that the

North Nestucca Environmental Assessment Page 15

wood in the debris flow deposits was recruited from a previous forest not the present day forest. May and Gresswell (2004) estimated debris flow recurrence intervals of 98-357 years in the Oregon Coast Range. Wood plays a key role in trapping and storing sediment in debris flow channels. May and Gresswell (2003) investigated sediment storage in debris flow prone channels in the Oregon Coast Range and found that 73% of the sediment stored in the channels was stored directly upstream of wood. Large wood stored 59% of the sediment and small wood (pieces <8 inches in diameter by <6 ft in length) stored 14%. May and Gresswell (2003) found that 37% of the wood pieces stored sediment. They also found that longer pieces (>49 ft) were only 22% of the total pieces of wood but they accounted for 78% of the total volume of wood. A proportion of wood in coho habitat is also recruited by fluvial transport of wood during high flows from tributaries that do not contain coho. The probability of wood being transported downstream increases as channel size increases or wood piece size decreases. Fluvial transport of wood pieces downstream is uncommon in channels where piece length is greater than bank full channel width (Lienkaemper and Swanson 1987; Nakamura and Swanson 1993). In southeast Alaska, Martin and Benda (1991) estimated that in 10-16 ft wide channel, there was a 90% probability that wood would be transported at least 164 ft and a 10% probability that transport could exceed 984 ft. The majority of wood pieces transported downstream were shorter than bank full channel width. In the North Nestucca Project area, a significant proportion of wood in coho habitat comes from hardwoods due to natural vegetation patterns on the Oregon Coast (Pabst and Spies 1999). Heimann (1988) looked at wood recruitment in the Oregon Coast range and found that the majority of instream wood for 94 years following a major disturbance event (wildfire, clear-cut) came from hardwoods. Others have shown that red alder was a significant source of instream wood in second growth stands (Bilby and Ward 1991). Nierenberg and Hibbs (2000) not only show an increasing abundance of hardwoods relative to conifers with decreasing distance to the stream, but also suggest a continual regeneration of alders in riparian areas following disturbances such as debris flows, landslides, hydraulic scouring and deposition, and floods. The substantial loss of large conifers in riparian areas over the last several decades is well documented in the North Nestucca area (Nestucca Watershed Analysis 1996) and throughout the Oregon Coast Range (IMST 1999; Kennedy and Spies 2004). The Nestucca Watershed Analysis, air photos, and field verification indicate that the abundance of small trees, like those proposed for thinning, within and adjacent to stands in the North Nestucca Project Area have increased in the last several decades as clear-cut logging has removed large diameter trees. Timber harvest has reduced the availability of large diameter trees on about 6,300 acres on the Siuslaw National Forest portion of the North Nestucca Planning area and converted the stands into unnaturally dense small diameter trees such as those planned for thinning. Prior to conversion, riparian areas in these stands averaged about 37 conifer trees per acre >21 inch dbh (Table14, USDA FS & USDI BLM 1998). These natural stands generally had more diverse tree species assemblages with more heterogeneous overstory, sub-canopy and under-story vegetation (Spies and Franklin 1991). Plantations were planted following clear-cut logging with the primary management goal at the time to maximize timber production. The clear cuts were usually planted with 300 to 700 Douglas-fir seedlings per acre, and were managed through a series of treatments to maximize timber production. The stands proposed for thinning are crowded, ranging from 111 to 371 (mean 239) conifer trees per acre. They are even-aged and single canopied. The trees have relatively small branches and crowns. The stands have little or no under-story vegetation. This conversion has substantially reduced the availability of large diameter trees and increased the availability of small diameter trees adjacent to stream channels. Removal of large diameter trees has increased the abundance of alder adjacent to streams that also function as a source of future small woody debris for streams. Roads reduce wood recruitment to coho habitat over large areas and for long periods of time (decades to centuries). Debris flows have been documented to deposit on valley bottom roads preventing the deposit from contributing wood to coho habitat. Most culverts are too small to allow large wood to be transported through them during high flows preventing recruitment into coho habitat The Oregon Coast Coho Assessment (ODFW 2005) documents that pool habitats are not significantly different than reference conditions throughout the ESU, although deep pools and large wood are significantly lower than reference conditions. The significant loss of large, deep pools in Pacific Northwest streams is well documented (McIntosh et al. 2000; FEMAT 1993). ODFW (2005) documents that winter habitat is the most limiting factor influencing coho salmon production. On the Oregon coast, Nickelson et al. (1992) documented that dammed pools and alcoves had significantly higher densities of coho juveniles than all other pool types in winter. Furthermore, they found that beaver ponds were significantly larger and deeper, and contained more coho at a higher density than the other dammed pools. Dammed pools

North Nestucca Environmental Assessment Page 16

and alcoves are formed by large channel obstructions, such as large wood (Nickelson 1992). Overwinter surveys on the Siuslaw National Forest have found that coho move into relatively large and deep pools to overwinter and are rarely found in small, shallow pools during winter (Chris Lorion, ODFW Research Biologist, personal communication). The loss of large diameter trees in coho riparian areas are widely recognized as a major cause of salmonid habitat degradation (FEMAT 1993; PFMC 1999; IMST 1999; IMST 2002). Burnett and others (2007) identified that less than 10% of high intrinsic potential coho habitat contains large (20-30 inches Quadratic Mean Diameter (QMD)) or very large trees (>30 inches QMD) in riparian areas. These large and very large trees are often responsible for creating the most complex stream habitat conditions (Abbe and Montgomery 1996). The NMFS Biological Review Team for Oregon coast coho salmon (Stout et. al 2010) recognizes large wood as a key component to instream habitat complexity. Four of the six primary constituent elements of coho critical habitat list large wood as a habitat feature that is essential to the conservation of Oregon Coast coho salmon. The lateral extent of designated critical habitat for Oregon Coast coho salmon is the width of the stream channel defined by the ordinary high-water line, or bankfull elevation (73 FR 7816; February 11, 2008). The Analytical Process for Development of Biological Assessments for Consultation on Federal Actions Affecting Fish Proposed or Listed Under the Endangered Species Act Within the Northwest Forest Plan Area (USDA Forest Service et al. 2004), defines large wood as pieces >24” diameter and >50 ft in length. The Oregon Department of Fish and Wildlife (Anlauf et al. 2009) defines key pieces of large wood to be at least 24” in diameter and greater than 40 feet in length. The Nestucca Watershed Analysis (WA) (1996) documents that the substantial reduction in large trees in the Project riparian areas was due to past logging and settlement activities and has had an adverse effect on salmonid habitat. The WA recommends manipulating young vegetation to produce large trees for eventual recruitment into stream channels (p. 112). Based on the Nestucca WA, stream survey data and field surveys, LWD is “Not Properly Functioning” for all watersheds. This is primarily due to past and present timber harvest, stream cleaning and agricultural activity. Stream surveys found that pieces of large wood (>24 inches in diameter) per stream mile ranged from none in Clarence and Smith Creeks to an average of 12 in Andy and Horn Creeks, which is far below the 80 pieces per mile required to be considered “Properly Functioning”. The condition is classified as Not Properly Functioning. Potential Effects of the Action – Thinning and yarding may reduce the number of trees that can be recruited to stream channels. Timber haul and road maintenance have no causal mechanism to affect this indicator, therefore haul will have no effect on this indicator. Thinning and Yarding Effects of the Action – Thinning will not occur within 100 feet of coho critical habitat. Thinning will not occur within 75 feet of debris flow channels that have a moderate to high probability of delivering wood to coho habitat. Thinning will not occur within 75 feet of channels that have a high probability of transporting wood to coho habitat during high flows (Appendix I Map). There are 13 units with acres proposed to be thinned (1, 22, 23, 39, 44, 57, 58, 94, 127, 165, 166, 180, and 233) within a site potential tree height (250 feet) and within 150 feet of coho habitat. ORGANON wood modeling indicates that tree heights and diameters comparable to those of the proposed thinning stands are too small to provide any wood recruitment (pieces >8 inches diameter) to coho habitat from beyond 150 ft for 100 years. Approximately 14 acres (less than 40%) within 150 ft of coho habitat in the Project area will be thinned. Thinning will occur between 100 ft and 150 ft of coho habitat where the probability of wood recruitment to coho habitat is very low. All skyline corridors are upstream of coho habitat and thus will have no effect on the indicator. Thinning will not remove any large trees (with a DBH larger than 24 inches) that could be recruited to coho habitat. Growth projection modeling of thinned and un-thinned stands in watersheds on the Siuslaw National Forest indicates that thinning will not reduce the number of 24 inch diameter trees that could be recruited to coho habitat for 100 years after thinning. Since there will be no loss of large wood to coho habitat in the short or long term, thinning will have no effect on this indicator. In the last several years, NMFS and others have documented concerns that thinning may reduce recruitment of wood pieces that are smaller than the indicator size to stream channels (NMFS 2008). NMFS required a 100 foot no thin buffer to maintain wood recruitment to coho habitat for the most recent Siuslaw NF LMP’s (NMFS 2008). Their concerns are

North Nestucca Environmental Assessment Page 17

primarily based on work from Beechie and Sibley (1997) that document relationships between wood and pool habitat in North Cascades and Puget Sound areas of Washington, and the subsequent wood recruitment model developed from this data (Beechie et al. 2000). Beechie and Sibley (1997) found that stable pieces of wood as small as 8 inches in diameter are significantly related to low flow pool spacing and percent pools. The concern is that a reduction in recruitment of these smaller pieces of wood to coho habitat will have an effect on low flow pool frequency.

The estimated average tree heights in the 11 units adjacent to coho critical habitat range from 66 feet in unit 166 to 97 feet in unit 233. Therefore, there are no Project units that have large enough trees to recruit any piece of wood directly to coho critical habitat from beyond the 100 feet no thin buffer, if the tree fell directly toward the stream. Considering the maximum stand average tree heights and diameters, any wood recruited into other stream channels would be approximately 2 inches in diameter and less than 3 feet in length, if the tree was located within 100 feet of the stream (Robison and Beschta 1990). That piece size is extremely abundant in the no thin buffers considering most trees, including hardwoods, and a high proportion of tree limbs can provide wood of that size. This piece size is far below the indicator value and below any standards for large wood in streams. Considering the environmental baseline, coho habitat use, design criteria, and thinning design that will remove understory trees and maintain dominant trees at higher densities after thinning (compared to natural stands), thinning more than 100 feet from coho habitat will have no effect on this indicator. Modeling growth without thinning of unit 504373 in the Alsea Basin on the Siuslaw National Forest, comparable to many North Nestucca units and streams, using the Northwest Version of ORGANON indicates that it will take 90 years from the present to produce a tree that is large enough to provide a bankfull long piece of wood (Lake Creek at unit 504373 has a 14 ft bankfull width, 8 inch diameter by 14 ft long) to coho habitat when it dies of suppression mortality. This assumes that the tree falls directly toward the stream (Robison and Beschta 1990), although the probability of that is extremely low. The model estimates that a cumulative total of only 3 trees per acre (TPA) will be tall enough to reach coho habitat from beyond 100 ft of a stream in the next 100 years. Model results indicate that suppression-killed trees will not be large enough in 100 years to provide any 8” diameter x 14 ft piece from beyond 107 feet from coho habitat. A total of 72 TPA die of suppression mortality during the 100 year period. The SMC ORGANON model grows the stand differently, predicting 133 suppression-killed trees per acre that are all too small to provide any piece of wood (>8”x14’) to coho habitat from beyond the 100 ft no thin buffer for 100 years. The thinned portion of the Project stands that are more than 100 ft from coho habitat will maintain at least 1.3 times more trees per acre (50-100) after thinning, than the average stocking (37 TPA) of large trees (>21” diameter) in natural stands on the Siuslaw National Forest (USDA FS & USDI BLM 1998). The probability of wood pieces falling directly toward the creek from more than 100 feet is extremely unlikely, particularly suppression killed trees through a dense no thin buffer. Furthermore, recruitment of wood pieces from more than 100 feet from coho habitat having an effect on coho habitat is not expected considering <1% of the coho wood recruitment area will be affected; the area thinned has the lowest probability of recruiting wood to coho habitat; the high abundance of small pieces in the environmental baseline; the 100 foot no thin buffer; the relatively limited effect that small wood has on coho habitat in the Project area; and thinning will maintain more residual TPA than natural stands that will provide a source of future large wood from beyond the 100 foot no thin buffer; thus thinning will have no effect on small wood pieces in coho habitat, pieces smaller than the indicator. Reduction of wood recruitment to debris flow channels and fluvial transport channels as a result of thinning is not expected based on the rationale above. Furthermore, the probability of wood being transported from these channels into coho habitat and it having an effect on coho habitat is extremely low considering the environmental baseline. Thinning will have no effect on wood recruitment to coho habitat from debris flow prone channels and channels large enough to transport wood. Element and Indicator Summary – Considering the proposed action, design criteria, and environmental baseline, thinning, yarding and road maintenance will have no effect on the indicator (24 inch diameter by 50 feet length) for 100 years, and no effect on all wood recruitment that has the potential to affect coho salmon or their critical habitat for 100 years.

North Nestucca Environmental Assessment Page 18

Suppression Mortality (SM) & Potential Wood Recruitment Stand 504373-NWO model

100 80 60 40 20 0 Trees Per Per Acre Trees 10 20 30 40 50 60 70 80 90 100 Years after Thinning

SM smaller pcs SM pc>8"x14' from > 30' SM >8"x5' from >75 ft Live pc>8"x14' from >30'

Figure 3. Maximum potential wood recruitment to streams from suppression mortality.

Pool Frequency and Quality, Large pools, Off Channel Habitat, Refugia, Width to Depth Ratio, Streambank Condition, And Floodplain Connectivity Environmental Baseline Pools - Oregon Coast Coho Assessment (ODFW 2005) documents that overall pool habitat frequency in the North Nestucca subbasins is not significantly different than reference conditions throughout the ESU, although deep pools and large wood are significantly lower in number than reference conditions. This assessment documents that winter habitat is the most limiting factor influencing coho salmon production. On the Oregon coast, Nickelson et al. (1992) documented that dammed pools and alcoves had significantly higher densities of coho juveniles than all other pool types in winter. Furthermore, they found that beaver ponds were significantly larger and deeper, and contained more coho at a higher density than the other dammed pools. Dammed pools and alcoves are formed by large channel obstructions, such as large wood (Nickelson 1992). The Nestucca WA and stream surveys indicate that pool frequency and large pools are At Risk. The lack of large pools is primarily due to the lack of large wood that creates and maintains these habitats. Off Channel Habitat and Refugia - Stream surveys indicate that off channel habitat areas are at Risk. LWD serves a major role in the formation of off-channel habitat and refugia so the low abundance of LWD is probably one causative agent for the shortage. W/D Ratio, Streambank Condition, and Floodplain Connectivity - Stream surveys indicate that streambanks in the upper forested areas are vegetatively stabilized with little active erosion. The lower reaches are much less stable due to human impacts. The lack of LWD contributes to poor floodplain connectivity, especially in the lower reaches. The lack of LWD also impacts the Width/Depth ratio, simplifying the stream system. All of these factors contribute to these indicators being At Risk for all sub-watersheds in the Project area, especially in the lower reaches. Potential Effects Of The Action - All of the PE’s have the potential to affect this indicator. Effects of the Action - The analysis of effects to Sediment/Substrate, and Woody Material indicators, above, showed that there would be no effects to these indicators. The analysis of effects to watershed indicators resulted in a conclusion that effects to these indicators would also not affect instream conditions. Since the condition of these aggregated indicators is

North Nestucca Environmental Assessment Page 19

largely dependent on effects to wood and sediment delivery rates, the project elements will have no effect on this group of indicators in the short and long term. Element and Indicator Summary – The project elements will have no effect to these indicators.

Change in Peak Base / Flows Environmental Baseline - The analysis area is typical of the Oregon Coast Range in both climatic and hydrologic features. Temperatures are mild; winters are wet and the summers cool and mostly dry. Annual precipitation falls mostly between November and March and averages about 80 inches, increasing with elevation. There is little natural water storage, consequently stream flow responds quickly to rainfall and is notably higher in winter than summer. Most peak flows are produced from large, moderately intense winter storms that last several days. Subsurface flow is the dominant storm runoff mechanism from undisturbed forests. Overland flow rarely occurs on the undisturbed forest floor due to the high soil infiltration and permeability rates (Harr 1977). Peak stream flow changes due to thinning are not well documented. Peak stream flow has been documented to increase in rain dominated areas when approximately 29-40% of the watershed area has been clearcut harvested (Grant et al. 2008). These changes in peak flows are most evident during peak flows with a recurrence interval of less than 1 year and in small watersheds (<2500 acres). Percent change in peak flow generally decreases with time after harvest (Jones 2000, Jones and Grant 1996, Thomas and Megahan 1998). Thinning should result in peak flow changes that are lower than those observed in response to clearcutting, and may be undetectable in some watersheds (Grant et al. 2008). The action area has hydrologic characteristics that are likely altered, in comparison to natural, undisturbed conditions, and are considered to be At Risk. Potential Effects of the Action – Thinning, yarding and road construction are the only project elements that have a causal mechanism that might affect flows, through changes in evapotranspiration as trees are cut, or through increased runoff due to new road construction and the associated compacted road surface. Haul will not affect vegetation or road drainage and thus will have no effect on this indicator. Effects of the Action - All the proposed treatment areas are within the rain-dominated zone with only transient snow accumulations. Thinning in the Project will occur predominantly in the Nestucca River watershed, with approximately 3.4% of the watershed area being thinned. Since thinning is expected to affect stream flow less than clearcuts, about 3.4% of the watershed area will be thinned, and thinning will occur over an estimated 15 year period, thinning will have no effect on this indicator. Cable yarding corridors for thinnings of this nature do not result in disturbed soil. Compaction and/or rutting are not found in corridors used for the removal of small timber with one end suspension. As a result overland flow is not expected in these areas and impacts on peak flows are not anticipated as a result of cable yarding, thus it will have no affect on this indicator. New road construction consists of 2.6 miles of short, temporary pieces of new road and/or short extensions of existing roads on ridge tops (Appendix I Map). The new segments will not cross streams or drainages; thus, no drainage structures will be needed for any of these new segments of road and there will be no cutbanks. All new roads are located on ridge tops and have no hydrologic surface connection to stream channels, thus road construction will have no effect on this indicator. Element and Indicator Summary – Thinning, yarding and road construction will have no effect on this indicator, individually and cumulatively. Increase in Drainage Network Environmental Baseline - The action area is rated as At Risk due to past and current forest management activities, the existing road network and development in the lower reaches. Potential Effects of the Action – Yarding and road activities are the only project elements that have a causal mechanism that might affect drainage network, through increased surface runoff due to the potential for compaction from yarding and new road construction. Thinning and Haul will not affect the drainage network and thus will have no effect on this indicator.

North Nestucca Environmental Assessment Page 20

Proximity, Probability, and Magnitude - There will be 3.2 miles of new temporary roads constructed for this project. The WA identified the North Nestucca subwatersheds as having less than 5 miles of road per square mile of US Forest Service land. New temporary roads will increase total road mileage temporarily over the 15-year implementation period. The reopened roads were already part of the baseline condition, and no change in the drainage network will be realized with opening the roads because all associated temporary culvert installations will maintain the existing drainage processes. New roads do not have any hydrologic surface connection, and are not located near streams, so the temporary increase in the drainage network should have no effect to the indicator. Yarding has the potential to increase compaction and change runoff characteristics, however, the small size of trees yarded, small amount of area impacted, its spatial and temporal dispersion, and distance from stream channels will result in no significant change in compaction and can therefore be determined to have no effect on the indicator. Reopened roads are already in place and won’t affect this indicator. Temporary roads will be closed at the end of the project so the duration of any effect will be short lived. Element & Indicator Summary - Both yarding and road construction were determined to have no effect on this indicator. Road Density & Location Environmental Baseline - The Nestucca WA indicates that most subwatersheds are Not Properly Functioning due to road density and/or stream adjacent roads. Road densities average less than 5 miles of road per square mile of US Forest Service land. With the Mt. Hebo Inventoried Roadless Area, road densities are relatively low in the Powder and Niagara Creek subwatersheds, though presence of some valley bottom roads poses a risk to streams in this area. Therefore, these subwatersheds are best characterized as At Risk for this indicator. Indicator Summary - There will be 2.6 miles of new temporary roads constructed for this project. Although there will be a very slight, temporary increase in the total miles of road in the watershed, the change in road density is minor. The reopened roads were already part of the baseline condition and no change in road density will be realized with reopening the roads. Temporary roads will be decommissioned at the end of the project.

Disturbance History and Regime Environmental Baseline - All sub-watersheds have been impacted by past timber harvest and settlement activities. Due to the extensive forestry and settlement impacts along the Nestucca River mainstem and the forest related activities in the upper watershed areas, these indicators are At Risk. Indicator Summary - The extensive forest management has created large areas of early seral classes mixed among some remnant mature stands. Thinning of overcrowded plantations has the potential to accelerate the development of LSR characteristics and create larger blocks of mature timber. Environmental disturbance will occur during this action, however it will be localized and short term. The project will create some temporary roads in the area. They will have an impact during the implementation phase of the project, but will be removed when the project is completed. The effects will be predictable and should not initiate any catastrophic events or changes. All activities are designed by soils and hydrology specialists to avoid areas of slope instability. Changes to this indicator are not expected to have any effect on any habitat indicators.

Riparian Reserves Environmental Baseline - The Nestucca WA, professional judgment, and stream survey data indicates that Riparian Reserves are “At Risk”. Agriculture and past timber harvest have substantially altered Riparian Reserves. Indicator Summary - The criteria for this indicator concern shade, LWD, habitat protection and connectivity, buffers or refugia for aquatic species, rangeland buffers, and species composition. The proposed action would not affect rangeland. Relevant to this proposed action, the following non-watershed condition indicators (non-WCI) are associated with the Riparian Reserve indicator criteria: Temperature, LWD, Off-channel Habitat, Floodplain Connectivity, and Refugia. A review of the individual indicator summaries for these non-WCI found that the proposed action would have no effect to those indicators. While none of the non-WCI would address the percent natural vegetation, the proposed thinning would strive to develop a more natural mix of Douglas-fir, hemlock, cedar, and alder within the riparian reserve, although coho riparian areas will not be affected.

North Nestucca Environmental Assessment Page 21

Primary Constituent Elements Potential Effects of the Action - All aspects of Primary Constituent Elements for coho salmon critical habitat have been addressed in the preceding discussion except forage that will be addressed in this section. Potential Effects of the Action – Timber falling, yarding, road construction and haul all have the potential to affect coho forage primarily through increases in riparian solar insolation and sediment inputs to streams. Effects of the Action – Timber falling and yarding will be at least 100 ft from coho habitat and since there is no causal mechanism to affect forage, these elements will have no effect on this indicator. The previous analysis determined that road construction and maintenance, and haul will have no effect on the sediment indicator, thus these elements are expected to have no effect on the forage indicator. Indicator Summary – Thinning, yarding, road construction and maintenance, and haul are expected to have no effect on the forage indicator. Direct Effects to ESA Listed Fish – Non Habitat Project Elements Potential Effects of the Action and Element and Indicator Summary – Thinning, yarding, road construction and maintenance, and haul will not have direct effects on coho individuals and thus these elements will have no effect on this indicator. The Siuslaw National Forest is planning culvert removal and replacements on or in the vicinity of LFH within the North Nestucca Project area under separate NEPA analyses that will have effects on coho salmon and their habitat. No deleterious cumulative effects from this work are expected because these culvert replacements will not occur in conjunction with the road maintenance and use activities of Alternative 2. Improved road crossing infrastructure is likely to protect the long term integrity of associated aquatic habitat and fisheries resources. Consultation for these activities will utilize the Fish Habitat Restoration Activities in Oregon and Washington, CY2007-CY2012 Biological Opinion (USDC National Marine Fisheries Service, 2008).

North Nestucca Environmental Assessment Page 22

V. ESA Effect Determination and Critical Habitat The analysis of potential effects to coho salmon using a habitat approach was discussed in detail in the previous sections. All indicators had a summary determination of No Effect (Table 4).

Table 4. Effects worksheet for the North Nestucca Project. P = Properly Functioning, N = Not Properly Functioning, R = At Risk, NE = No Effect

Forage

- Channel - Temperature Turbidity Chemical Barriers Substrate LWD Pool Freq. Large Pools Off Refugia Width/Depth Streambank Floodplain Flows Net. Drainage Road Density Disturbance Riparian Regime PCE Direct Effects

Lower Nestucca Baseline R R R N R N R R R R R R R R R N R R R River/Farmer Creek

Nestucca R R P N R N R R R R R R R R R R R R R River/Niagara Creek

Middle Nestucca R R R N R N R R R R R R R R R R R R R River/Powder Creek

Upper Nestucca River/Testament R R P N R N R R R R R R R R R N R R R Creek Coast Creek R R P N R N R R R R R R R R R N R R R (headwaters)

Element Thinning NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE Summary

Yarding NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE

Haul NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE

Road Construction NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE & Maintenance

Indicator Effect on Coho/CH NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE NE Summary

North Nestucca Environmental Assessment Page 23

The following dichotomous key was utilized to reach the appropriate ESA effect determination. Utilizing the indicator summaries from Table 4, the key provided an effect determination of No Effect to coho individuals and Critical Habitat, as shown in Table 5. Table 5. Project Effects Determination Key For Species and Critical Habitat 1) Do any of the indicators summaries have a positive or negative conclusion? Yes - Go to 2 X No – No Effect 2) Are the indicator summary results only positive? Yes – NLAA No – Go to 3 3) If any of the indicator summary results are negative, are the effects insignificant or discountable? Yes – NLAA No – LAA, fill out Adverse Effects Form VI. Aggregated Federal Effects The Siuslaw National Forest is planning culvert replacements on or in the vicinity of LFH within the North Nestucca Planning Area under separate NEPA analyses that will have effects on coho salmon and their habitat. Consultation for these activities will utilize the Fish Habitat Restoration Activities in Oregon and Washington, CY2007-CY2012 Biological Opinion (USDC National Marine Fisheries Service, 2008). We are not aware of any other proposed federal actions for which a Biological Assessment has been submitted contemporaneously with this BE for ESA consultation, which would affect the ESA action area for this project. All ongoing actions with potential adverse effects (where ESA consultation has been concluded), and effects of completed federal actions, are included in the environmental baseline for each indicator and have been considered in this analysis.

VII. Endangered Species Act Cumulative Effects Endangered Species Act cumulative effects are the future effects of state, tribal, local, and private actions that are reasonably certain to occur within the action area associated with the federal action. The private land in the North Nestucca area is primarily located downstream from the action area. It is expected that development and land use within and outside the project area by the state and private property owners will continue in the future in a manner similar to that of recent years. It is also expected that activities on these lands will comply with county, state, and federal laws and regulations.

VIII. EFH and Special Status Species Assessment When the Magnuson-Stevens Act of 1976 was re-authorized in 1996, it directed Regional Fishery Management Councils to identify Essential Fish Habitat (EFH) for commercial fish species of concern. The Forest Service updated the Regional Forester’s Special Status Species List in 2008, documenting vertebrate and non-vertebrate species of concern found on Forest Service or Bureau of Land Management land in Oregon or Washington. Effects analysis contained in this BE addresses potential effects to EFH and Special Status Species. Regional Forester's Special Status Species Oregon Coast Steelhead of all life history stages can be found in the project area at various times. Steelhead utilize these watersheds for both spawning and juvenile rearing. In freshwater, steelhead need clean gravel for spawning, and cool temperatures. Ideal conditions are similar to those for coho, including off channel rearing habitat, and pools with complex large woody debris (LWD) and the analysis conducted for coho is sufficient for steelhead for those areas where the distributions of the two species overlap. Steelhead distribution extends upstream up to approximately 1.4 mile beyond coho distribution in several subwatersheds in the Project area. Thinning associated with the Project will accelerate the development of large diameter trees in riparian areas and may result in a minor reduction in small wood recruitment to steelhead habitat upstream of coho considering the larger no thin buffers. Growth modeling of a comparable Siuslaw National Forest stand (East Alsea Land Management Plan Unit 504373) using the Northwest ORGANON model indicates that most suppression-killed trees are too small to provide many 8 inch diameter by bank full long pieces of wood to stream channels from outside the proposed no thin buffers upstream of coho habitat (Figure 3). There is a decreasing probability that these pieces will fall directly toward the stream as the no thin buffer width is increased. Project activities will not contribute to a loss of viability, or cause a significant trend toward listing under the ESA for either of these species.

Two species with EFH may be impacted by this project, coho salmon and Chinook salmon. Chinook salmon are distributed primarily in mainstem Nestucca River and its mainstem low gradient perennial tributaries (i.e. Bays, Beaver, Clear, East, and Farmer Creeks). Chinook use these reaches for spawning and early rearing. Juvenile Chinook generally migrate out of fresh water by June, and continue rearing in estuary areas over the summer. There is some overlap in freshwater areas and the analysis conducted for coho is sufficient for Chinook. The Project will not adversely affect EFH for Chinook or coho salmon.

IX. Management Indicator Species and Other Fish Species Management indicator species were selected because a change in their population, in response to management activities, is believed to represent changes in a larger group of species. Coho salmon were selected as a Management Indicator Species to be an ecological indicator, an indicator for fished species, and represent pool and low gradient stream habitat for the Siuslaw National Forest (FEIS 1990 pp III-67-68). The discussion above documents existing coho habitat conditions in the Project area and any effects of the project on coho and their habitat. The documentation concluded that the Project will have “No Effect” on coho salmon or their critical habitat. Considering this, the Project will have No Effect on the Forest-wide viability of coho salmon on the Siuslaw National Forest. Other fish species, including resident and Coastal Cutthroat trout, Chum salmon, Pacific and Brook lamprey, and sculpin reside in Project area streams. Project activities will not contribute to a loss of viability, or cause a significant trend toward listing under the ESA for any of these species.

XI. References Cited

Abbe, T.B., and D.R. Montgomery. 1996. Large woody debris jams, channel hydraulics and habitat formation in large rivers. Regulated Rivers: Research and Management 12:201-222.

Adams, J. N., & R. L. Beschta. 1980. Gravel bed composition in Oregon coastal streams. Can. J. Fish. Aquat. Sci. 37: 1514- 1521.

Anlauf, K. J., K. K. Jones, and C.H. Stein. 2009. The Status and Trend of Physical Habitat and Rearing Potential in Coho Bearing Streams in the Oregon Coastal Coho Evolutionary Significant Unit. OPSW-ODFW-2009-5, Oregon Department of Fish and Wildlife, Salem.

Beechie, T.J., G. Press, P. Kennard, R.E. Bilby, and S. Bolton. 2000. Modeling recovery rates and pathways for woody debris recruitment in northwestern Washington streams. North American Journal of Fisheries Management 20:436-452.

Beechie, T. J., and T.H. Sibley. 1997. Relationships between channel characteristics, woody debris, and fish habitat in northwest Washington streams. Transactions of the American Fisheries Society 126:217-229.

Benda, L. E., and T. W. Cundy. 1990. Predicting deposition of debris flows in mountain channels. Canadian Geotechnical Journal. 27:409-417.

Berg, L, and T.G. Northcote. 1985. Changes in territorial, gill-flaring, and feeding behavior in juvenile coho salmon (Oncorhynchus kisutch) following short-term pulses of suspended sediment. Can. J. Fish. Aquat. Sci., 42:1410-1417.

Beschta, R.L. 1980. Turbidity and suspended sediment relationships. In Proceedings of Watershed Management Symposium, Irrigation and Drainage Division, Amer. Soc. Civil Engineers, Boise, Idaho, July 21-23, 1980. 1-12.

Bilby, R.E. 1985. Contributions of road surface sediment to a western Washington stream. For. Sci. 31:827-838.

Bilby, R. E., K. Sullivan, and S. H. Duncan. 1989. The generation and fate of road-surface sediment in forested watersheds in southwestern Washington, Forest Science, 35(2), 453-468.

Bilby, R.E. and J.W. Ward, 1989. Changes in Characteristics and Function of Woody Debris with Increasing Size of Streams in Western Washington. Transactions of the American Fisheries Society 118:368-378.

Bilby, R.E., and J.W. Ward. 1991. Large woody debris characteristics and function in streams draining old-growth, clear-cut, and second-growth forests in southwest Washington. Canadian Journal of Fisheries and Aquatic Sciences 48:2499-2508.

Bisson, P.A., and R.E. Bilby. 1982. Avoidance of suspended sediment by juvenile coho salmon. North Amer. J. Fish. Mgmt. 4:371-374.

Brown, G.W., 1988. Forest and Water Quality. OSU Bookstores, Inc., Memorial Union, Oregon State University, Corvallis, Oregon.

Brown, G.W., and J.T. Krygier. 1971. Clear-cut logging and sediment production in the Oregon Coast Range. Water Res. Research 7(5) 1189-1198.

Burnett, K.M., G.H. Reeves, D.J. Miller, S. Clarke, K. Vance-Borland, and K. Christianson. 2007. Distribution of salmon- habitat potential relative to landscape characteristics and implications for conservation. Ecological Applications 17(1):66-80.

Chan, S.S., D.Larson, P.D. Anderson. 2004. Microclimate patterns associated with density management and riparian buffers. An interim report on the Riparian Buffer Component of the Density Management Studies. USDI BLM and USDA Forest Service, Corvallis, OR. Chan, S.S., D.J. Larson, K.G. Maas-Hebner, W.H. Emmingham, S.R. Johnston, and D.A. Mikowski. 2006. Overstory and understory development in thinned and underplanted Oregon Coast Range Douglas-fir stands. Can. J. For. Res.36:2696-2711. Dent, L., D.Vick, K. Abraham, S. Schoenholtz, and S. Johnson. 2008. Summer temperature patterns in headwater streams of the Oregon Coast Range. Journal of the American Water Resources Association 44(4): 803-813.

Duncan, S.H., R.E. Bilby, J.W. Ward, and J.T. Heffner. 1987. Transport of Road-Surface Sediment through Ephemeral Stream Channels. Water Resources Bulletin Vol. 23. No. 1: 113-119.

Everest, F.H., R.L. Beschta, J.C. Scrivener, K.V. Koski, J.R. Sedell, and C.J. Cederholm. 1987. Fine sediment and salmonid production: a paradox. In E.O. Salo and T.W. Cundy (eds.) Streamside Management: Forestry and Fisheries Interactions, p. 98- 142.

FEMAT (Forest Ecosystem Management Assessment Team) 1993. Forest ecosystem management: an ecological, economic, and social assessment. US Government Printing Office 1993-793-071, USDA Forest Service, USDI Fish and Wildlife Service, Bureau of Land Management, and National Park Service, USDC National Oceanic and Atmospheric Administration and National Marine Fisheries Service, and US Environmental Protection Agency.

Grant, Gordon E.; Lewis, Sarah L.; Swanson, Frederick J.; Cissel, John H.; McDonnell, Jeffrey J. 2008. Effects of forest practices on peak flows and consequent channel response: a state-of-science report for western Oregon and Washington. Gen. Tech. Rep. PNW-GTR-760. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station. 76 p.

Harr, R. D. 1977. Water Flux in Soil and Subsoil on Steep Forested Slope. Journal of Hydrology, 33(1977) 37-58.

Hassan, M.A., M. Church, T.E. Lisle, F. Brardinoni, L. Benda, and G.E. Grant, 2005a. Sediment Transport and Channel Morphology of Small, Forested Streams. Journal of the American Water Resources Association, (JAWRA) 41(4):853-876.

Heimann, D.C. 1988. Recruitment trends and physical characteristics of coarse woody debris in Oregon Coast streams. MS Thesis, Oregon State University, Corvallis, Oregon.

Hibbs, D.E., and A.L. Bower. 2001. Riparian forests in the Oregon Coast Range. Forest Ecology and Management 154:201- 213.

IMST (Independent Multidisciplinary Science Team). 1999. Recovery of Wild Salmonids in Western Oregon Forests: Oregon Forest Practices Act Rules and the Measures in the Oregon Plan for Salmon and Watersheds. Technical Report 1999-1 to the Oregon Plan for Salon and Watersheds, Governor’s Natural Resources Office, Salem, Oregon.

Johnson, S. 2004. Summary of habitat and fish monitoring data from East Fork and Upper Mainstem Lobster Creeks: 1988- 2004. Oregon Dept. Fish. & Wildlife, Corvallis OR.

Johnson, S.L. 2004. Factors influencing stream temperatures in small streams: substrate and a shading experiment. Canadian Journal of Fisheries and Aquatic Science 61:913-923.

Jones, J.A. 2000. Hydrologic processes and peak discharge response to forest removal, regrowth, and roads in 10 small experimental basins, western Cascades, Oregon. Water Resources Research. 36(9): 2621–2642.

Jones, J.A.; Grant, G.E. 1996. Peak flow responses to clear-cutting and roads in small and large basins, western Cascades, Oregon. Water Resources Research.32: 959–974.

Kennedy, R.S.H., and T.A. Spies. 2004. Forest cover changes in the Oregon Coast Range from 1939 to 1993. Forest Ecology and Management 129-147

Lancaster, S.T., Hayes, S.K., and G.E. Grant. 2003. Effects of wood on debris flow runout in small mountain watersheds: Water Resources Research, v. 39, p. 1168, doi: 10.1029/2001WR001227.

Larson, K.R., and R.C. Sidle. 1980. Erosion and sedimentation data catalog of the Pacific Northwest. R6-WM-050-1981, USDA Forest Service, Pacific Northwest Region, Portland, OR, 64p.

Lienkaemper, G.W., and F.J. Swanson. 1987. Dynamics of large woody debris in streams in old-growth Douglas-fir forests. Canadian Journal of Forest Research 17:150-156.

Lorion, C. Oregon Department of Fish and Wildlife, Corvallis Research Lab. Personal communication with Jack Sleeper, fishery biologist, Siuslaw National Forest.

Luce, C. H. and T. A. Black. 1999. Sediment production from forest roads in western Oregon. Water Resources, 35(8), 2561- 2570.

Luce, C.H. and T.A. Black, 2001. Spatial and Temporal Patterns in Erosion from Forest Roads. In: Land Use and Watersheds: Human Influence on Hydrology and Geomorphology in Urban Forest Areas, M.S. Wigmosta and S.J. Burges (Editors). American Geophysical Union, Water Science and Application 2, American Geophysical Union, Washington, D.C., pp. 165-178.

Lutz, J.A., and C.B. Halpern. 2006. Tree mortality during early forest development: A long-term study of rates, causes, and consequences. Ecological Monographs, 76(2), pp.257-275

May, C.L. 2001. Spatial and temporal dynamics of sediment and wood in headwater streams in the Oregon Coast Range. Ph.D. Dissertation, Oregon State University, Corvallis, Oregon.

May, C.L., and R.E. Gresswell. 2003. Large wood recruitment and redistribution in headwater streams in the southern Oregon Coast Range, U.S.A. Can. J. For. Res. 33:1352-1362

McDade, M.H. 1988. The source area for coarse woody debris in small streams in western Oregon and Washington. MS Thesis, Oregon State University, Corvallis, Oregon.

McDade, M.H., F.J. Swanson, W.A. McKee, J.F. Franklin, J. Van Sickle. 1990. Source distances for coarse woody debris entering small streams in western Oregon and Washington. Can. J. For. Res. 20:326-330

McIntosh, B.A., J.R. Sedell, R. F. Thurow, S.E. Clarke, and G.L. Chandler. 2000. Historical changes in pools habitats in the Columbia River Basin. Ecological Applications 10(5): 1478-1496.

Melillo, J.M., R.J. Naiman, J.D. Aber, K.N. Eshleman. 1983. The influence of substrate quality and stream size on wood decomposition dynamics. Oecologia 58:281-285.

Murphy, M.L., and K.V. Koski. 1989. Input and Depletion of Woody Debris in Alaska Streams, and Implications for Streamside Management. North American Journal of Fisheries Management 9:427-436

Naiman, R.J., E.V. Balian, K.K. Bartz, R.E. Bilby, and J.J. Latterell. 2002. Dead Wood Dynamics in Stream Ecosystems. USDA Forest Service General Technical Report PSW-GTR-181.

Nickelson, T.E., J.D. Rodgers, S.L. Johnson, and M.F. Solazzi. 1992. Seasonal changes in habitat use by juvenile coho salmon (Oncorhynchus kisutch) in Oregon coastal streams. Can. J. Fish. Aquat. Sci. 49:783-789

Nierenberg, T.R., and D.E. Hibbs. 2000. A characterization of unmanaged riparian areas in the central Coast Range of western Oregon. Forest Ecology and Management 129:195-206. 28

NMFS (National Marine Fisheries Service). 2008. Endangered Species Act Section 7 Formal Consultation and Magnuson- Stevens Fishery Conservation and Management Act Essential Fish Habitat Consultation for the Little Nestucca Restoration Project, Wilson-Trask-Nestucca subbasin (4th Field HUC:17100203), Tillamook and Yamhill Counties, Oregon; West Alsea Landscape Management Project, Alsea River subbasin (4th field HUC: 17100205), Lincoln County, Oregon; and Lobster Landscape Management Project, Alsea River (4th field HUC: 17100205) and Siuslaw river (4th field HUC 17100206) subbasins, Lincoln, Benton, and Lane Counties, Oregon. NMFS Northwest Region, Seattle, WA. 78 p.

Noggle, C.C. 1978. Behavioral, physiological and lethal effects of suspended sediment on juvenile salmonids. M.S. Thesis, Univ. of Washington, Seattle. 87 p.

ODFW (Oregon Department of fish and Wildlife). 2005. Oregon Coastal Coho Assessment, Habitat. Part 4(c) ODFW 3. Oregon Plan for Salmon and Watersheds.

Pabst, R.J., and T.A. Spies. 1999. Structure and composition of unmanaged riparian forests in the coastal mountains of Oregon, U.S.A. Can. J. For. Res. 29: 1557-1573.

PFMC. 1999. Amendment 14 to the Pacific coast salmon plan. Appendix A: Description and Identification of Essential Fish Habitat, Adverse Impacts and Recommended Conservation Measures for Salmon. Portland, OR: Pacific Fishery Management Council.

Reeves, G.H., K.M. Burnett, and E.V. McGarry. 2003. Sources of large wood in the main stem of a fourth-order watershed in coastal Oregon. Can. J. For. Res. 33:1363-1370

Robison, G. E., and R. L. Beschta. 1990. Identifying trees in riparian areas that can provide coarse woody debris to streams. Forest Science 36:790–801.

Rosenfeld, J.S., and L. Huato. 2003. Relationship between Large Woody Debris Characteristics and Pool Formation in Small Coastal British Columbia Streams. North American Journal of Fisheries Management 23:928-938.

Story, A., R. D. Moore, and J. S. Macdonald. 2003. Stream temperatures in two shaded reaches below cutblocks and logging roads: Downstream cooling linked to subsurface hydrology. Can. J. For. Res. 33(8):1383-1396.

Stout, H.A. and 15 coauthors. 2010. Draft Updated Status Review of Oregon Coast Coho Salmon. National Marine Fisheries Service, Northwest Fisheries Science Center. Newport, OR.

Thomas, R.B.; Megahan, W.F. 1998. Peak flow responses to clear-cutting and roads in small and large basins, western Cascades, Oregon: a second opinion. Water Resources Research. 34(12): 3393–3403.

USDA Forest Service. 1990. Land and Resource Management Plan (as amended by the 1994 Northwest Forest Plan). Corvallis, OR: Siuslaw National Forest.

USDA Forest Service. 1996. Nestucca Watershed Analysis. Corvallis, OR: Siuslaw National Forest. 113 p. plus maps and appendices.

USDA Forest Service. 2011. Revised Road Rules (in draft). Corvallis, OR: Siuslaw National Forest. Correspondence File # 7730.

USDA Forest Service, USDI Bureau of Land Management. 1994. Record of decision for amendments to Forest Service and Bureau of Land Management planning documents within the range of the northern spotted owl and standards and guidelines for management of habitat for late-successional and old-growth forest related species within the range of the northern spotted owl. Portland, OR.

USDA Forest Service, USDI Bureau of Land Management. 1998. Late-successional Reserve Assessment for Oregon’s Northern Coast Range Adaptive Management Area. Corvallis, OR: Siuslaw National Forest.

USDA Forest Service, USDC National Oceanic and Atmospheric Administration, Fisheries, USDI Bureau of Land Management, USDI Fish and Wildlife Service. 2004. Analytical Process for Development of Biological Assessments for Consultation on Federal Actions Affecting Fish Proposed or Listed Under the Endangered Species Act Within the Northwest Forest Plan Area.

USDA Forest Service, USDI Bureau of Land Management. 2005. Northwest Forest Plan Temperature TMDL Implementation Strategies. Evaluation of the Northwest Forest Plan Aquatic Conservation Strategy and Associated Tools to achieve and maintain stream temperature water quality standards.

USDC National Marine Fisheries Service. 2008. Endangered Species Act – Section 7 Programmatic Consultation Biological Opinion and Magnuson-Stevens Fishery Conservation and Management Act Essential Fish Habitat Consultation. Fish Habitat Restoration Activities in Oregon and Washington, CY2007-CY2012. National Marine Fisheries Service, NMFS Nos.: FS 2008/03505. Seattle, WA.

Appendix I

Wildlife Specialist Report For the North Nestucca Landscape Project

Includes Assessments for the Following Elements:

A. Biological Evaluation (Wildlife) B. Survey and Manage Species C. MIS Wildlife Species D. Land Bird Assessment E. Dead Wood Assessment F. Aquatic Conservation Strategy

Siuslaw National Forest, USDA Forest Service June, 2012

Prepared by: /s/Michelle Dragoo June 12, 2012 Michelle Dragoo Date Wildlife Biologist Siuslaw National Forest Hebo Ranger District

North Nestucca Environmental Assessment Page 1

Appendix I

PROJECT DESCRIPTION AND LOCATION The North Nestucca Restoration Project (the Project) area includes about 25,279 acres of National Forest System (NFS) lands within the Nestucca River watershed and is about 40 miles northwest of Corvallis, Oregon, (EA map 1).

All action alternatives incorporate the design criteria and monitoring requirements disclosed in Appendix A of the EA as well as the design criteria associated with the programmatic consultations for habitat modification for fiscal years 2011-2012, disturbance for fiscal years 2010-2013 and aquatic restoration for fiscal years 2006-2012 (USFWS 2007,2010). The quantities for proposed stand treatments and associated actions by stand number are displayed in Appendix B of the EA and proposed road treatments are identified in Appendix C of the EA.

No Action (Alternative 1) Selecting this alternative would continue the following resource management actions:

• Forest management would rely on natural processes such as inter-tree competition, wind, diseases, insects, and fire to develop late-successional and old-growth forests, improve biocomplexity, and restore watersheds. • Relying on natural processes: • Development of late-successional forest habitat, especially large trees and large dead wood, would take decades in developing; • Bio-complexity would not substantially improve until a major disturbance occurs; • Understory development of grasses, forbs, shrubs, and small trees would be slow in developing; • No plantations would be commercially or non-commercially thinned under this alternative, and no temporary roads would be reopened or built; • No additional projects are anticipated for the next 10 years, unless a catastrophic event such as a wind storm, flood or fire occurs. Proposed Action (Alternative 2) To meet the Project needs, this alternative would implement the management actions listed below.

• Diversifying stand species and structure on approximately 5,229 acres in 92 stands than 65 years old that were previously thinned, then diversifying stand species and structure, creating dead wood, and creating openings in these stands. These stands will be treated in the following way: • Commercial thin to 50-100 TPA create transitory gaps in young plantations ~ 5,229 acres • Plant transitory gaps within plantations, ~ 66 acres • Underplant Commercially Thinned Plantations, ~ 130 acres; • Fall and leave 0-15 trees per acre within the commercially thinned stands to create Coarse Woody Debris (CWD); • Top live trees to create snags in plantations, up to 15 snags per acre; • Top live trees to create snags in natural plantations, up to 2 per acre • Repair and maintain approximately 24.0 miles of key and non-key forest roads;

North Nestucca Environmental Assessment Page 2

Appendix I

• Open approximately 17.2 miles of existing temporary roads which would be waterbarred and closed through the timber sale contract after harvesting activities; • Construct approximately3.2 miles of new temporary road in the plantations which will be waterbarred and closed through the timber sale contract after harvesting activities;

North Nestucca Environmental Assessment Page 3

Appendix I

A. Biological Evaluation for Federally Proposed, Endangered, and Threatened Species, and Regional Forester Sensitive Species (PETS)

I. INTRODUCTION Section 7 of the Endangered Species Act of 1973 (as amended in 1978, 1979, and 1982) directs Federal departments/agencies to assure that actions authorized, funded, and/or conducted by them are not likely to jeopardize the continued existence of any threatened or endangered species or result in destruction or adverse modification of their critical habitat. The Act also directs each Federal agency to confer or consult with the appropriate Secretary on any action that is likely to jeopardize or affect the continued existence of any species or its habitat. All Forest Service projects, programs and activities require review and documentation of possible effects on Proposed, Endangered, and Threatened or Sensitive (PETS) species (FSM 2672.4). In compliance with these directions and policies a biological evaluation must be performed for all federalized ground disturbing activities.

II. EVALUATION OF EFFECTS There are 92 stands proposed for commercial thinning in Alternative 2. These 92 stands (5,229 acres) are young managed stands established between 1947 and 1986 after the original stand was regeneration harvested. The Silviculture report describes in detail the history of these stands. Over the last 15 years, the Siuslaw National Forest has sold over 60 commercial thinning sales with similar harvest and management histories associated with the units. When current buffer standards, stand development characteristics and harvest systems are combined, the actual thinning unit boundaries are less than the original plantation acres. While the entire plantation is evaluated for potential treatment and effects to species, the actual thinning acres are expected to be between 60 and 90% of the original harvest acres. Stand characteristics and response to treatments are described in the silvicultural report for the project and are not repeated in this report.

The PETS species listed for the Siuslaw National Forest (table 1) are based on the Regional Forester’s Sensitive Species List for Region 6 (dated January 31, 2008). Exhibit 1 outlines the steps used to summarize the assessment procedures for PETS species currently). Effects of the proposed project were evaluated in relationship to (1) habitat components (Exhibit 2), (2) designated critical habitat for listed species, and (3) disturbance.

Records in Forest offices were reviewed to determine if any PETS (proposed, endangered, threatened, or sensitive) species habitats, individuals or populations are documented in the project area. This record search included: (1) incidental reports of presence of PETS species from qualified individuals, (2) review of data describing habitats within or adjacent to the project area and (3) field review of habitat existing within or adjacent to the project area.

III. EFFECTS ANALYSIS North Nestucca Environmental Assessment Page 4

Appendix I

Federally-listed Species Based on the above information, no known nest sites, suitable habitat, or proposed or designated critical habitat exists in the project area for Oregon silverspot butterfly, California brown pelican (removed from listing under ESA on December 17, 2009) or Western Snowy Plover. Thus Alternatives 1 and 2 would have no effect on these species or their habitats.

Marbled Murrelet (Brachyramphus mamoratus) Marbled murrelets, a robin sized seabird that nests in the coast range, are closely associated with late- successional and old growth habitat. The species was listed as threatened due to the “loss and modification of nesting habitat (older forests) primarily due to commercial timber harvesting.” Mortality associated with gill netting off the coast of Washington and from oil spills were also identified as threats to the species.

An account of the taxonomy, ecology and reproductive characteristics of the murrelet is found in the 1988 Status Review (Marshall 1988), the final rule designating the species as threatened (USFWS 1992), the final rule designating critical habitat for the species (USFWS 1996), the Fish and Wildlife Service biological opinion for Alternative 9 (USFWS 1994) of the Final Supplemental Environmental Impact Statement on Management of Habitat for Late-Successional and Old-Growth Forest Related Species Within the Range of the Spotted Owl (USDA, USDI. 1994), the Recovery Plan for the Threatened Marbled Murrelet (USFWS 1997), the marbled murrelet 2009 five year review (USFWS 2009) as well as the biological opinion for Programmatic Aquatic Habitat Restoration Activities in Oregon and Washington That Affect ESA-listed Fish, Wildlife and Plant species and their Critical Habitat (USFWS 2007) and Letter of Concurrence on the effects of Habitat Modification Activities on the Northern Spotted Owl (Strix occidentalis caurina), Marbled Murrelet (Brachyramphus marmoratus), and Critical Habitat in the North Coast Planning province, FY 2011-2012 (USFWS 2010).

The Siuslaw National Forest is part of the North Coast Planning Province. In conjunction with the Salem and Eugene BLM Districts the Forest consults on project activities that may affect marbled murrelets. The most recent biological assessment concerning habitat modification evaluated the effects from activities planned in fiscal years 2011-2012 (USFS/BLM 2010) included the North Nestucca project. The Fish and Wildlife Service concurred with the conclusions of the biological assessment (USFWS 2010) when the design criteria disclosed in the assessments were incorporated into the project. The documents concluded:

• Light to moderate thinning and terrestrial habitat enhancement activities in forest that is not yet suitable or that contain no potential nesting structure would have no effect on murrelets because these areas do not currently contain any potential nesting structure and therefore are not used by murrelets. If the treatment is adjacent to suitable habitat, no edge effect is created by light to moderate thinning thus maintaining the suitability of the adjacent stand. • Light to moderate thinning in stands with potential nesting structure, that are implemented in accordance with options 2 or 3 of the Level 2 policy for the management of potential nesting structure, may affect, but is not likely to adversely affect, the species because the potential nesting structure would be excluded from the treatment area or protected within the treatment area, and other protection measures would be implemented to prevent disturbances. Such treatments would not affect individual murrelets.

North Nestucca Environmental Assessment Page 5

Appendix I

• Terrestrial habitat enhancement activities in suitable habitat may affect, but is not likely to adversely affect murrelets. • Activities that generate noise, smoke or human presence above ambient levels of the project site may disturb murrelets and effect essential nesting behavior. When conditions and design criteria described in the consultation documents are followed, disturbance associated with commercial thinning may affect but is not likely to adversely affect murrelets. • Light to moderate thinning and terrestrial habitat enhancement activities in critical habitat may affect but is not likely to adversely affect murrelet critical habitat because no suitable nest trees will be removed and the function of suitable habitat will be maintained.

There are 171 stands defined as occupied by marbled murrelets that are entirely or partially within 0.25 miles of the planning area with all or portions of 115 of those stands within 0.25 miles of units evaluated for commercial thinning. Of the 171 occupied stands, all are located in the late-successional land allocation and164 are located in designated critical habitat.

Alternative 1 No Action--Alternative 1 would have no direct effects on 15,433 acres of existing suitable habitat in the planning area. Considering the silvicultural analysis for this project in the long term, the no action alternative will indirectly affect the development of managed stands resulting in slower growth with smaller tree sizes at higher tree densities than natural stands of a similar age. As a result of inter-tree competition, managed stands are expected to have fewer trees exhibiting larger limbs than natural stands. Thus when managed stands are of an age that is considered mature, it is uncertain that the structural composition of the stands will provide the same level of suitable nesting habitat for marbled murrelets as a natural stand of a similar age. Associated activities to create deadwood (i.e. snags and downed wood), as well as under story development grasses, forbs, shrubs, and small trees would have no effect on murrelets since these are not habitat components used by nesting murrelets.

Alternative 2—Habitat--Considering the available information, none of the 92 stands evaluated contain suitable habitat or potential nesting structure for marbled murrelets within areas planned for thinning. Thus under Alternative 2, commercial thinning, building new temporary roads, creating snags and downed wood in these stands will have no affect on marbled murrelet habitat. Considering the silvicultural analysis for this project, in the long term Alternatives 2 will indirectly affect the development of managed stands resulting in growth with tree sizes and densities similar to natural stands of a similar age. As a result of reduced inter-tree competition, managed stands are expected to have more trees with larger limbs than managed stands that are not thinned, but less than natural stands. When managed stands are of an age that is considered mature, it is expected that the structural composition of the stands will have more suitable nesting habitat for marbled murrelets than stands not treated but less than natural stands of a similar age. Creating snags in natural stands alters the snag composition of the stand to enhance cavity nesting habitat for species associated with mature stands. Although individual trees or small groups of trees maybe treated within murrelet suitable habitat or habitat with potential nesting structure, considering the design criteria no suitable habitat or potential nest trees would be selected, less

North Nestucca Environmental Assessment Page 6

Appendix I

than 10% of the planning area would be affected the function of the stand would be maintained. Thus creating snags in mature stands may affect but is not likely to adversely affect murrelet habitat.

Critical Habitat—73 of the 92 stands are located in designated critical habitat for marbled murrelets. The areas planned for thinning within the stands do not contain individual trees with potential nesting platforms and they do not average one-half the site potential tree height, thus they do not contain the primary constituent elements for marbled murrelets. Since commercial thinning and associated activities in the plantations will not change the primary constituent elements, commercial thinning the 73 stands will have no effect on marbled murrelet critical habitat. Natural stands where mature tree topping is proposed are in designated critical habitat that contains primary constituent elements. Considering the design criteria, no suitable nest trees would be selected, suitable nest trees would protected against incidental damage and the function of the stands would be maintained, mature tree topping in critical habitat may affect but is not likely to adversely affect critical habitat.

Disturbance— Three of the 92 stands are greater than 100 yards from suitable habitat. Activities associated with these stands are outside the disruption distance that may affect murrelets. Thus noise associated with commercial thinning operations, building new temporary roads, creating snags and downed wood in the three stands (302026, 302052, 302061) will have no affect on essential nesting behavior.

Of the 92 stands, all or a portion of 49 stands are within 100 yards of known occupied stands (table xxx). Commercial thinning, building new temporary roads, creating snags and downed within 100 yards of occupied stands may occur outside the critical nesting season (April 1-August 5) and require hourly operating restrictions during the balance of the nesting season (August 6-September 15). Considering the above information, the season of operation along with the use of hourly timing restrictions, the noise associated with commercially thinning operations (including building new temporary roads, creating snags and downed wood in these 49 stands may affect but is not likely to adversely affect the breeding activity of nesting marbled murrelets.

All or portions of 40 stands are within 100 yards of suitable murrelet habitat where occupancy is unknown. These units may be commercially thinned at any time with the requirement that hourly operating restrictions be applied during the entire marbled murrelet nesting season (April 1-September 15) when operating within 100 yards of suitable habitat. Considering the above information, the season of operation along with the use of hourly timing restrictions, the noise associated with commercially thinning operations (including building new temporary roads, creating snags and downed wood) in the 14 stands, including building new temporary roads, may affect but is not likely to adversely affect the breeding activity of nesting marbled murrelets.

Northern Spotted Owl (Strix occidentalis caurina) Northern spotted owls are closely associated with late-successional and old growth habitat. The species was listed as threatened primarily “due to the loss and adverse modification of suitable habitat as a result

North Nestucca Environmental Assessment Page 7

Appendix I

of timber harvesting, and exacerbated by catastrophic events such as fire, volcanic eruption and windstorms” (U.S. Fish and Wildlife Service, 1990).

Detailed accounts of the taxonomy, ecology, and reproductive characteristics of the northern spotted owl are found in the 1989 and 1990 Fish and Wildlife Service proposed and final rule to list the northern spotted owl as threatened (U.S. Fish and Wildlife Service, 1989; U.S. Fish and Wildlife Service, 1990), the Interagency Scientific Committee Report (Thomas et al., 19900), the Forest Ecosystem Management Assessment Team report (USDA/USDI, 1993), the 1992 final rule designating critical habitat (U.S. Fish and Wildlife Service 1992), the 2008 final rule designating critical habitat (U.S. Fish and Wildlife Service 2008) and the Final Recovery Plan for the Northern Spotted Owl (U.S. Fish and Wildlife Service, 2008).

The Siuslaw National Forest is part of the Coast Planning Province. In conjunction with the Salem and Eugene BLM Districts the Forest consults on project activities that may affect northern spotted owls. The most recent biological assessment concerning habitat modification evaluated the effects from activities planned in fiscal years 2011-2012 (USFS/BLM 2010) included the North Nestucca project. The Fish and Wildlife Service concurred with the conclusions of the biological assessment (USFWS 2010) when the design criteria disclosed in the assessments were incorporated into the project. The documents concluded:

• Heavy thinning of habitat in forest that is in forest that is not yet suitable for northern spotted owls, where in the opinion of the unit wildlife biologist, dispersal would not be limited in the area after treatment may affect, but is not likely to adversely affect northern spotted owls. • Light to moderate thinning of dispersal habitat in less complex stands does not change that habitat to the point that it no longer provides protection from avian predators and minimal foraging activities. In more complex stands that contain roosting habitat and a larger prey base, light to moderate thinning maintains the stand complexity (for instance structural diversity, coarse woody debris, and understory structure sufficiently remain in the unit to support the prey base) to support owl roosting or foraging characteristics of that stand. Since sufficient dispersal habitat will be maintained post-treatment and stands would be placed on a trajectory that would attain late- successional forest conditions sooner than if the stands were left un-thinned, light to moderate thinning of dispersal habitat may affect, but is not likely to adversely affect, northern spotted owls. • Because no suitable nest trees would be treated, and minimal impact to the suitability of the area for spotted owl use is anticipated, terrestrial habitat enhancement activities may affect, but are not likely to adversely affect spotted owls. The creation of snags or coarse woody debris in areas where snags and coarse woody debris are insufficient would have indirect beneficial effects on the spotted owl, because such treatments would accelerate the growth of forest conditions needed by the owl. • Disturbances from proposed actions conducted beyond the disruption distance but within 0.25 mile of suitable habitat between March 1 and July 7, may affect, but are not likely to adversely affect, nesting northern spotted owls. • Light to moderate thinning of dispersal habitat may affect but is not likely to adversely affect critical habitat because, even though it would modify the stand, it would maintain the current primary constituent elements (dispersal characteristics) at the stand scale and, therefore, the conservation value of the habitat. • Considering the scope of the proposed actions and their effects on owl habitat including critical habitat, the changes within or amount of suitable or dispersal habitat are not likely to harm spotted owls.

North Nestucca Environmental Assessment Page 8

Appendix I

There are three known owl sites (East Beaver, Moon Creek and Salal Point) and there are five projected owl sites (353,366,383,394,403) whose provincial home range (1.5 miles) overlaps at least a portion of the planning area. All of the known or projected owl sites are located in the late successional reserve land allocation. Two of the three known sites (East Beaver, Moon Creek) and two of the five projected sites (353,403) are in designated critical habitat. Two of the known owl sites (East Beaver and Moon Creek) are located in a reserve pair area.

Alternative 1 No Action--Alternative 1 would have no direct effects on 15,433 acres of existing suitable northern spotted owl nesting, roosting and foraging habitat in the planning area. The Nestucca River Watershed Analysis (USDA, USDI 1994) concluded that second growth managed stands are frequently deficient in snags and down wood. The managed stands evaluated in the project area are considered dispersal habitat for spotted owls. The silvicultural analysis for this project disclosed that in the long term the no action alternative will in-directly affect the development of managed stands resulting in slower growth with smaller tree sizes at higher tree densities than natural stands of a similar age. As a result of inter-tree competition, managed stands are expected to have fewer trees exhibiting larger limbs, and less species complexity than natural stand. Thus when managed stands are of an age that is considered mature, it is uncertain that the structural composition of the stands will provide the same level of suitable nesting, roosting and foraging habitat for spotted owls as a natural stand of a similar age. Based on the information provided in the watershed analysis, about 66,696 acres of federal land within the 163,119 acre watershed (105,598 acres of federal land) are considered dispersal habitat (stands greater than 11” DBH and greater than 40% canopy cover) for spotted owls. The amount of dispersal habitat under the no action alternative will increase through time as more managed stands increase in average size to over 11” DBH (occurs at about 30 years of age) with 40% canopy cover. The US Fish and Wildlife Service designated portions of the planning area as critical habitat for northern spotted owls in 1992 (USFWS 1992). They revised the designated critical habitat in 2008 (USFWS 2008). Considering the above information, the No Action alternative would have no affect on suitable or dispersal habitat of northern spotted owls; their breeding behavior or designated critical habit.

Alternative 2—Suitable Habitat--Considering the available silvicultural information, the 92stands evaluated do not contain suitable nesting, roosting or foraging habitat for northern spotted owls. Thus under Alternative 2, commercial thinning and associated activities in plantations, will have no affect on suitable nesting, roosting or foraging habitat. Considering the silvicultural analysis for this project, in the long term Alternative 2 will in-directly affect the development of managed stands resulting in growth with tree sizes and densities similar to natural stands of a similar age. As a result of reduced inter-tree competition, managed stands are expected to have more trees with larger limbs than managed stands that are not thinned, but less than natural stands. When managed stands are of an age that is considered mature, it is expected that the structural composition of the stands will have more suitable nesting roosting and foraging habitat for spotted owls than stands not treated but less than natural stand of a similar age. Creating snags in natural stands will increase the complexity of the stands, thus accelerating the development of forest conditions needed by owls. Because no nest trees would be removed, all trees

North Nestucca Environmental Assessment Page 9

Appendix I

would remain on site and the suitability of the treatment area for spotted owls would be maintained, creating snags in natural stands may affect but is not likely to adversely affect spotted owls.

Dispersal Habitat—Considering the design criteria, along with the unit prescriptions, the number of trees per acre left after commercial thinning and downed wood creation in treated plantations will maintain sufficient canopy cover (greater than 40% canopy cover) to facilitate owl dispersal. Under alternative 2, the total amount of dispersal habitat will not change in the short term. In the long term the amount of dispersal habitat will increase as more stands increase in average size to over 11” DBH. Thus commercial thinning and dead wood creation in plantations may affect but is not likely to adversely affect spotted owls because dispersal habitat may be modified, but will not be removed from its function as dispersal habitat.

Critical Habitat—Under the 2008 critical habitat designation, 23 of the 92 stands proposed for treatment are designated as critical habitat. Since no suitable habitat will be removed, there will be no affect to the primary constituent elements associated with nesting, roosting or foraging habitat. Since the proposed commercial thinning, including the creation of gaps up to 1 acre, snags and downed wood in managed stands will maintain greater than 40% canopy cover, the function of the dispersal habitat will be maintained, thus commercial thinning of the 13 units including the creation of gaps, snags and down wood, may affect but is not likely to adversely affect spotted owl critical habitat. Creating snags from mature trees in natural stands increases the complexity associate with forest conditions needed by spotted owls. The consultation documents concluded that while creating snags in critical habitat may alter the primary constituent elements, these actions would facilitate the development of late-successional habitat characteristics and promote recovery. Therefore these actions may affect but is not likely to adversely affect critical habitat.

Disturbance—6 of the 92 stands are within 1.5 miles of known owl sites, and 21 are within 1.5 miles of a projected owl site. There are no stands within 0.5 miles or 0.25 miles of known owl pairs. There are 6 stands within 0.5 miles of a projected owl pair. There are no stands within 0.25 miles of a known owl pair and 4 stands within 0.25 miles of a projected owl pair. Road maintenance and reconstruction activities associated with commercial thinning may occur within 0.25 miles of known or projected owl sites. Considering the design criteria to limit activities within 65 yards of know or projected owl sites during the critical nesting season that may disrupt nesting owls, that most proposed activities are greater than 0.25 miles from known or projected owl sites, actions under Alternative 2 may affect but is not likely to adversely affect the breeding activity of spotted owls.

Reserve Pair Areas—Of the 92 stands planned for commercial thinning, 4 stands (302013, 302020,302032,302033) are in the Moon Creek reserve pair area. All 4 stands are within the provincial home range of a known owl pair (East Beaver). Of the remaining 88 stands, 2 are within the provincial home range of the Salal Point owl pair, and 21 are within the provincial home range of five predicted owl sites. The Moon Creek owl pair is located in the late successional reserve land allocation as well as in designated critical habitat. The reserve pair is a subset of the known owl sites evaluated above. Since no

North Nestucca Environmental Assessment Page 10

Appendix I

suitable habitat will be removed, and all units are greater than 0.25 miles from the pair the affects disclosed above apply to the reserve pair.

Sensitive Species Based on the above information including the project locations, proposed activities and design criteria, no known nest sites, or suitable habitat exists in the project area for California brown pelican (removed from listing under ESA on December 17, 2009), bufflehead, peregrine falcon, harlequin duck, California wolverine, foothill yellow-legged frog, Newcomb’s littorine snail, roth’s blind ground beetle, Oregon plant bug, hoary elfin, coastal greenish blue butterfly and Haddocks rhyacophilan caddisflys,. Thus Alternatives 1and 2 would have no effect on these species or their habitat.

Northern Bald Eagle, Purple Martin The Northern bald eagle and purple martin have the potential for occurring in the project area. Eagles nest in a variety of areas when suitable nest trees are available. There are 9 known nest trees within 1 mile of planning area. Of these 9 known nests, 4 are within planning area and 2 of these are within 1 mile of stands proposed for treatment. All known nests are greater than ½ mile from stands proposed for treatment. Purple martins tend to nest in natural and artificial cavities (snags, bird houses or pilings) near open water. Eagles and purple martins will forage along estuaries, bays, meadows and rivers. Bald eagles consume a variety of prey including birds, fish and mammals while purple martin primarily feed on insects. Both species have been observed in areas of high human use and occupancy such as Tillamook.

Considering the use of the area by these species, that known nest sites are protected, no treatment sites are within 0.25 miles of known bald eagle nest sites, and no habitat will be removed along with the summary information above; Alternative 1 will have no affect on these species while Alternative 2 may temporarily disrupt individuals, but would not likely contribute to a trend towards federal listing or cause a loss of viability to the population or species.

Red Tree Vole, Pacific Fisher Red tree voles are arboreal, and closely associated with late-successional and old growth habitat. The current conditions associated with suitable habitat in the planning area for red tree voles are similar to those discussed for marbled murrelets and northern spotted owls. Red Tree Voles are a species for which pre-disturbance surveys are required for forest containing elements of suitable habitat. Red tree voles have been documented in younger stands, but it is thought that these stands may be acting as population sinks (Carey1991). Active nests have also been found in remnant older trees in younger stands indicating the importance of legacy structural characteristics (Biswell, unpublished data).

No commercial thinning is proposed in late-successional and old growth habitat under Alternative 2. Roads are not considered suitable habitat for Red Tree Voles. Since there will be no change in the amount or function in late-successional and old growth habitat, the no action alternative; commercial thinning, temporary roads, and deadwood creation in plantations associated with Alternatives 2 would not affect this species or its habitat. Topping mature trees to create snags could alter individual trees currently used by red tree voles; however the function of the stand would not be altered. Considering the design criteria

North Nestucca Environmental Assessment Page 11

Appendix I

for tree selection, snag creation in mature stands under Alternative 2 may impact individuals but the effects will not contribute to a trend towards federal listing or cause a loss of viability to the population or the species.

Pacific fishers are closely associated with late-successional and old growth habitat. Though historically distributed in coniferous forests throughout western Oregon, they are currently restricted to two distinct populations in southern Oregon, and believed to be extirpated throughout the remainder of their historic range in Oregon, including the project area (Lofroth et al 2010, Aubry 2002). The current conditions associated with suitable habitat in the planning area for pacific fishers are the same as those discussed for marbled murrelets and northern spotted owls. Research indicates that fishers tend to use large trees, snags and logs associated with late-successional coniferous forests for resting and denning, and that these forest types are more limiting than foraging habitat. As described in more detail in the Deadwood Assessment (Appendix G), the project area has experienced a history of timber harvest coupled with several large fires which has created a lost legacy of large deadwood. Suppression mortality in unthinned densely stocked plantations will result in mortality of the small diameter size classes, and retard the development of large trees and deadwood as compared to thinning. Thinning of the densely stocked plantations in the project is designed to accelerate the growth of the residual trees, which over time will result in larger live trees and dead trees, which would serve as resting and denning and foraging habitat for fishers.

No commercial thinning is proposed in late-successional and old growth habitat under Alternative 2. Roads are not considered suitable habitat for fishers. Since there will be no change in the amount or function in late-successional and old growth habitat, the no action alternative; commercial thinning, temporary roads, and deadwood creation in plantations associated with Alternative 2 would not affect this species or its habitat. Thinning of plantations would in the short term reduce the amount of small diameter deadwood in the stands, but in the long term will provide larger live and dead trees more typical of high quality fisher habitat. Topping mature trees to create snags would alter individual trees in mature stands; however the function of the stand would not be altered. Considering that currently fishers are extirpated from the project area, the design criteria for thinning, tree selection, and the function of existing late- successional and old growth habitat would be maintained, thinning in plantations and snag creation in mature stands under Alternative 2 would not affect pacific fishers. It is anticipated that over time, the changes to the habitat will be beneficial, and will not contribute to a trend towards federal listing or cause a loss of viability to the population or the species.

Fringed Myotis Fringed myotis roost in natural (i,e snags, rocks, cliff faces) and artificial (buildings and bridges) crevices. Primarily nocturnal in their activities, they feed on a variety of invertebrates, primarily beetles and moths. Foraging primarily occurs in riparian forest areas. Since no habitat will be removed, Alternatives 1 and 2 would have no effect on fringed myotis habitat.

Considering the summary information discussed above, the design criteria for the project, and the nocturnal nature of fringed myotis, there is a low likelihood of fringed myotis being disturbed by project

North Nestucca Environmental Assessment Page 12

Appendix I activities. Thus Alternative 2 may impact individuals, but the effects will not contribute to a trend towards federal listing or cause a loss of viability to the population or species.

Northwest Pond Turtle The western pond turtle is associated with a variety of aquatic habitats, both permanent and intermittent. They may be found in slower moving streams, ponds and lakes where emergent basking sites are available, but generally avoid heavily shaded areas. They tolerate brackish water. Habitats may have a variety of substrates including solid rock, boulders, cobbles, gravel, sand, mud, decaying vegetation, and combinations of these. In many areas turtles are found in rocky streams with little or no emergent vegetation. Northwest pond turtles use upland areas to disperse, reproduce, overwinter, and aestivate. They tend to be wary of near-by human activity (Hays et al 1999). There has been limited documentation of pond turtles in Oregon coastal lakes and estuaries.

Considering no work will occur in coastal lakes, estuaries or streams and the design criteria protects stream zones with no harvest buffers, no habitat for pond turtles will be removed or modified. Alternatives 1and 2 would have no effect on pond turtle habitat or individuals.

Evening Fieldslug, Pacific Walker The Evening Fieldslug (Derocersa hesperium) is associated with perennially wet meadows in forested habitats; microsites include a variety of low vegetation, litter and debris; rocks may also be used as refugia. Little detail is known about exact habitat requirements for the species, due to the limited number of verified sites. However, this species appears to have high moisture requirements and is almost always found in or near herbaceous vegetation at the interface between soil and water, or under litter and other cover in wet situations where the soil and vegetation remain constantly saturated. Because of the apparent need for stable environments that remain wet throughout the year, suitable habitat may be considered to be limited to moist surface vegetation and cover objects within 30 m. (98 ft.) of perennial wetlands, springs, seeps and riparian areas (Duncan 2005).

The Evening Fieldslug is listed as sensitive on the 2008 Regional Foresters Special Status Species List. This species is also listed as a Category B survey and manage species for which surveys are required for habitat affecting activities in suitable habitat. A summary of compliance with the survey and manage requirements for this species can be found in the survey and manage species section of this report.

Alternative 1 would have no effect on habitats associated with these species. With Alternative 2, the potential exists during yarding to temporarily disturb but not remove habitat used by this species. There is a chance that individuals may be impacted, but the effects will not contribute to a trend towards federal listing or cause a loss of viability to the population or species.

The Pacific walker is associated with the wet conditions associated with perennial wetlands, springs, seeps, or riparian areas near flowing water where humidity remains high. The potential exists during yarding to temporarily disturb but not remove habitat used by this species. Considering no habitat will be removed, Alternatives 1and 2 would have no effect on habitats associated with this species. However,

North Nestucca Environmental Assessment Page 13

Appendix I

Alternative 2 may impact individuals, but the effects will not contribute to a trend towards federal listing or cause a loss of viability to the population or species.

Salamander Slug, Tillamook Western Slug, Spotted Tail-dropper These slug species are generally associated with late-successional and old growth habitat, but may be found in younger plantations. The potential exists during yarding to temporarily disturb but not remove habitat used by these species. Considering no habitat will be removed, Alternatives 1and 2 would have no effect on habitats associated with these species. However, Alternative 2 may impact individuals, but the effects will not contribute to a trend towards federal listing or cause a loss of viability to the population or species.

Johnson’s Hairstreak This species primarily feeds on dwarf mistletoe of the genus Arceuthobium, which is closely associated with mature to old-growth conifer forests. It primarily lives and reproduces in the forest canopy. Activities in plantations including commercial thinning, creation of deadwood, building temporary roads or repairing existing roads would not affect suitable habitat. Mature tree topping in natural stands may impact individual trees, but the function of the stand and suitability of the habitat would not be removed. Considering no habitat will be removed, Alternatives 1 and 2 would have no effect on habitat associated with this species. However, Alternative 2 may impact individuals, but the effects will not contribute to a trend towards federal listing or cause a loss of viability to the population or species.

Table 1. Siuslaw National Forest Threatened (T), Endangered (E) and USFS Region 6 Sensitve (S) Wildlife Species List Scientific Name Common Name Classification Brachyramphus mamoratus Marbled murrelet T Strix occidentalis caurina Northern spotted owl T Pelecanus occidentalis California brown pelican S californicus Charadrius alexandrinus Western snowy plover T nivosus Speyeria zerene hippolyta Oregon silverspot butterfly T Bucephala albeola Bufflehead S Falco peregrinus anatum American peregrine falcon S Haliaeetus leucocephalus Northern bald eagle S Histrionicus histrionicus Harlequin Duck S Progne subis Purple Martin S Rana boylii Foothill Yellow-legged frog S Actinemys marmorata Northwestern pond turtle S marmorata Arborimus longicaudus Red tree vole S silivicola Gulo gulo luteus California wolverine S Martes pennanti Pacific Fisher S Myotis thysanoides Fringed myotis S Algamorda newcombiana Newcomb”s Littorine Snail S Cryptomastix hendersoni Columbia Gorge Oregonian S North Nestucca Environmental Assessment Page 14

Appendix I

Scientific Name Common Name Classification Deroceras hesperium Evening fieldslug S Gliabates oregonius Salamander slug S Hesperarion mariae Tillamook western slug S Prophysaon vanattae pardalis Spotted tail-dropper S Pomatiopsis californica Pacific walker S Pterostichus rothi Roths’s blind ground beetle S Lygus oregonae Oregon plant bug S Callophrys johnsoni Johnson’s hairstreak S Callophrys polios maritima Hoary elfin S Plebejus saepiolus littoralis Insular blue butterfly S Rhyacophila haddocki Haddock’s rhyacophilan S caddisflys

Table 2. Biological Evaluation Process Summary by Species SPECIES Step #1 Step #2 Step #3 Step #4 Prefield Conflict Analysis of USFWS (TES) Review Determination Significance Review Habitat, Consultation Species Conflict? Important? Completed? present?

BIRDS Marbled murrelet YES NO NO NO Northern spotted owl YES NO NO NO California brown pelican NO NO NO NO Western snowy plover NO NO NO NO Bufflehead NO NO NO N/A American peregrine falcon NO NO NO N/A Northern bald eagle YES NO NO N/A Harlequin Duck NO NO NO N/A Purple Martin YES NO NO N/A MAMMALS Red tree vole NO NO NO N/A California wolverine NO NO NO N/A Pacific fisher YES NO NO N/A Fringed myotis YES NO NO N/A HERPTILES Foothill yellow-legged frog NO NO NO N/A Northwestern pond turtle YES NO NO N/A INVERTEBRATES Oregon silverspot butterfly NO NO NO NO Newcomb’s Littorine Snail NO NO NO N/A Columbia Gorge Oregonian NO NO NO N/A Evening fieldslug YES NO NO N/A Salamander slug YES NO NO N/A Tillamook western slug YES NO NO N/A Spotted tail-dropper YES NO NO N/A Pacific walker YES NO NO N/A Roths’s blind ground beetle NO NO NO N/A

North Nestucca Environmental Assessment Page 15

Appendix I

SPECIES Step #1 Step #2 Step #3 Step #4 Prefield Conflict Analysis of USFWS (TES) Review Determination Significance Review Habitat, Consultation Species Conflict? Important? Completed? present?

Oregon plant bug NO NO NO N/A Johnson’s hairstreak YES NO NO N/A Hoary elfin NO NO NO N/A Coastal greenish blue NO NO NO N/A butterfly Haddocks’ rhyacophilan NO NO NO N/A caddisfly

Exhibit 1

BIOLOGICAL EVALUATION PROCESS - THREATENED, ENDANGERED, PROPOSED AND SENSITIVE SPECIES PROJECT PROPOSAL

Biological evaluation-- St e p 1-prefield review of No evidence Appropriate ------Project available inform at ion ------of species or documentation Proceeds and idenfication of habitat------species known or potentially occurring | Evidence of species or habit at | Biological evaluation------No adverse ------Appropriate ------Project St e p 2-conflict ---- documentation Proceeds determination effect or conflict | Potential for adverse effect or conflict | Is modification of Appropriate ------Project project to remove ------Yes------documentation Proceeds adverse or questionable ---- conflict possible? | \ | \ No Sensitive Wit hdraw | Species------Project | \ | \ Proposed or Analysis of ------Dat a not Federally significance sufficient Listed Species of effects t o assess significance | | |

North Nestucca Environmental Assessment Page 16

Appendix I

Follow consultation Dat a ------Biological/ (conference) sufficient botanical requirements with t o assess investigation USFWS/ N M FS Ex h i b i t s 1 significance & 2 | Project disposition based on determination of significance of effects on species conservation and population objectives

North Nestucca Environmental Assessment Page 17

Appendix I

Exhibit 2 Siuslaw National Forest Threatened, Endangered, and Sensitive Wildlife Species List

(Status Codes: T = Threatened, E = Endangered, C = Critical, P = Proposed, S = Regional Forester Sensitive, V = Vulnerable, U = undetermined, D = Documented to occur on forest (All others are Suspected to occur on forest). Listing order is: Regional Foresters List/Federal/State/Documented to occur on the forest.)

Birds Habitat Status Marbled Murrelet Nests in mature forests within 50 miles of the -/T/T/D (Brachyramphus marmoratus) coast Northern Spotted Owl Nests in mature forests with old growth -/T/T/D (Strix occidentalis caurina) characteristics California Brown Pelican Lakes, estuaries, coastlines, and bays (Pelecanus occidentalis S/-/-/D californicus) Western Snowy Plover Nests on sandy beaches and in dunes (Charadrius alexandrinus -/T/T/D nivosus) Bufflehead Cavity nester, nesting inland, mainly in Canada. S/-/U/D (Bucephala albeola) Winter resident in salt bays American Peregrine Falcon Nests and feeds along coast near cliffs and S/-/-/D (Falco peregrinus anatum) headlands Northern Bald Eagle Nests and roosts in mature forests near lakes, S/-/-/D (Haliaeetus leucocephalus) coast, rivers Harlequin Duck Breeds primarily in Cascades and Rockies, but (Histrionicus histrionicus) some records in Coast Range. Nests along fast- S/-/U/S flowing streams. Winters along rocky coast. Purple Martin Variety of terrestrial habitats, preferably near (progne subis) open water with access to natural or artificial S/-/C/D cavities (snags, bird houses, pilings etc.)

Mammals Habitat Status Red Tree Vole Mature and overmature/oldgrowth conifer (Arborimus longicaudus dominated stands. S/-/-/D silivicola) California Wolverine Subalpine, remote forest areas. Extirpated in S/-/-/S (Gulo gulo luteus) Coast Range Pacific Fisher Mature and over mature/old growth conifer S/-/V/D (Martes pennanti) dominated stands. Fringed Myotis Utilize caves, mines, and buildings for (Myotis thysanoides) hibernation, maternity, and solitary roosts. Feed predominately on moths along forest edges, S/-/V/S roads, or open areas within the forest. Utilizes, but not dependent upon snags or down material.

North Nestucca Environmental Assessment Page 18

Appendix I

Reptiles and Amphibians Habitat Status Foothill yellow-legged frog Known distribution does not occur on SNF, but (Rana boylii) species is suspected on eastern foothills. Highly S/-/V/S aquatic and found in vicinity of permanent streams with open cobble gravel bars. Northwestern Pond Turtle Ponds, slow moving water mostly in (Actinemys marmorata Willamette Valley S/-/C/D marmorata)

Invertebrates Habitat Status Oregon Silverspot Butterfly Coastal meadows with viola adunca spp. -/T/T/D (Speyeria zerene hipppolyta) Newcomb’s littorine snail Inter-tidal habitat on glasswort/pickleweed salt S/-/-/S (Algamorda newcombiana) marshes at the edges of bays and estuaries. Columbia Gorge Oregonian Identified incorrectly as being documented on (Cryptomastix hendersoni) the Siuslaw. Based on the literature this species S/-/-/- has not been located west of the confluence of the Columbia and Willamette Rivers. Evening Fieldslug The Evening Fieldslug has been reported to be (Deroceras hesperium) associated with wet meadows in forested habitats in a variety of low vegetation litter and debris; rocks may also be used. Little is known S/-/-/D about this species or its habitat. Surveys may be limited to moist surface vegetation and cover objects within 30 m. (98ft.) of perennial wetlands, springs, seeps and riparian areas. Salamander slug Douglas fir leaf litter associated with a vine (Gliabates oregonius) maple, sword fern and Oregon grape S/-/-/S understory. Tillamook western slug Moist mature forested habitats in coastal fog S/-/-/D (Hesperarion mariae) zone. Spotted tail-dropper Leaf litter under bushes in mature conifer (Prophysaon vanattae forest, also, moist, mature forested habitats; or pardalis) in the coastal “fog” zone very near the ocean. S/-/-/S Sites are relatively diverse in both plant and mollusk species, with a significant deciduous tree or shrub component generally present. Pacific walker Semiaquatic; characteristically found among wet (Pomatiopsis californic)a leaf litter and vegetation beside flowing or standing water in shaded situations where humidity remains S/-/-/D high. Range limited to coastline, inland up to 0.5 miles.

North Nestucca Environmental Assessment Page 19

Appendix I

Invertebrates Habitat Status Roths’s blind ground beetle Restricted to cool, moist, closed-canopy (Pterostichus rothi) coniferous forests with well drained, deep, coarse-crumb structure soils that have S/-/-/D developed in place, not alluvial soils on floodplains. Associated with deeply embedded rocks and logs on slopes 20-50%. Oregon plant bug Host-specific and lives on Ambrosia (Lygus oregonae) chamissonis (Beach-bur) a composite S/-/-/S associated with open sand adjacent to tidal influence. Johnson’s hairstreak Old-growth and late successional second (Callophrys johnsoni) growth coniferous forests that contain mistletoes of the genus Arceuthobium. The S/-/-S mistletoes occur mainly on western hemlock and occasionally true fir. Hoary elfin All life stages are closely associated with (Callophrys polios maritime) kinnikinnick. Oregon populations occupy sites S/-/-/D on coastal bluffs and ancient sand dunes. Coastal greenish blue butterfly Coastal terrace meadows. The species (Insular blue) overwinters as early instar caterpillar in flower S/-/-D (Plebejus saepiolus littoralis) head of host clover Haddock’s rhyacophilan Cool mountain streams in the Mary’s Peak caddisflys area. S/-/-/D Rhyacophila haddocki

North Nestucca Environmental Assessment Page 20

Appendix I

B. Survey and Manage Species – On December 17, 2009, the U.S. District Court for the Western District of Washington issued an order in Conservation Northwest, et al. v. Sherman, et al., No. 08-1067-JCC (W.D. Wash.), granting Plaintiffs’ motion for partial summary judgment and finding NEPA violations in the Final Supplemental to the 2004 Supplemental Environmental Impact Statement to Remove or Modify the Survey and Manage Mitigation Measure Standards and Guidelines (USDA and USDI, June 2007). In response, parties entered into settlement negotiations in April 2010, and the Court filed approval of the resulting Settlement Agreement on July 6, 2011. Projects that are within the range of the northern spotted owl are subject to the survey and management standards and guidelines in the 2001 ROD, as modified by the 2011 Settlement Agreement.

The North Nestucca Landscape Project is consistent with the Siuslaw National Forest Land and Resource Management Plan as amended by the 2001 Record of Decision and Standards and Guidelines for Amendments to the Survey and Manage, Protection Buffer, and other Mitigation Measures Standards and Guidelines (2001 ROD), as modified by the 2011 Settlement Agreement

The North Nestucca Landscape Project applies a 2006 Exemption from a stipulation entered by the court in litigation regarding Survey and Manage species and the 2004 Record of Decision related to Survey and Manage Mitigation Measure in Northwest Ecosystem Alliance v. Rey, No. 04-844-MJP (W.D. Wash., Oct. 10, 2006) for those portions of the project where the exemption applies. Previously, in 2006, the District Court (Judge Pechman) invalidated the agencies’ 2004 RODs eliminating Survey and Manage due to NEPA violations. Following the District Court’s 2006 ruling, parties to the litigation entered into a stipulation exempting certain categories of activities from the Survey and Manage standards and guidelines, including both pre-disturbance surveys and known site management. Also known as the Pechman Exemptions, the Court’s Order from October 11, 2006 directs: “Defendants shall not authorize, allow, or permit to continue any logging or other ground-disturbing activities on projects to which the 2004 ROD applied unless such activities are in compliance with the 2001 ROD (as the 2001 ROD was amended or modified as of March 21, 2004), except that this order will not apply to: a. Thinning projects in stands younger than 80 years old: b. Replacing culverts on roads that are in use and part of the road system, and removing culverts if the road is temporary or to be decommissioned; c. Riparian and stream improvement projects where the riparian work is riparian planting, obtaining material for placing in-stream, and road or trail decommissioning; and where the stream

North Nestucca Environmental Assessment Page 21

Appendix I

improvement work is the placement large wood, channel and floodplain reconstruction, or removal of channel diversions; and d. The portions of project involving hazardous fuel treatments where prescribed fire is applied. Any portion of a hazardous fuel treatment project involving commercial logging will remain subject to the survey and management requirements except for thinning of stands younger than 80 years old under subparagraph a. of this paragraph.”

Per the 2011 Settlement Agreement, the 2006 Pechman Exemptions remain in force: “The provisions stipulated to by the parties and ordered by the court in Northwest Ecosystem Alliance v. Rey, No. 04-844-MJP (W.D. Wash. Oct. 10, 2006), shall remain in force. None of the following terms or conditions in this Settlement Agreement modifies in any way the October 2006 provisions stipulated to by the parties and ordered by the court in Northwest Ecosystem Alliance v. Rey, No. 04844-MJP (W.D. Wash. Oct. 10, 2006).”

The North Nestucca Landscape Project meets Exemptions A and B above because it proposes thinning only in stands less than 80 years old (Appendix B-2) and replacing or removing culverts from roads. In addition, the Project would not propose any regeneration harvesting (chapters 1 and 2).

C. Wildlife Management Indicator Species (MIS)

The Siuslaw National Forest Land and Resource Management Plan Final Environmental Impact Statement (FEIS) (USDA 1990) identified 11 terrestrial and 1 aquatic management indicator species. The EIS stated the following: “Management indicator species were selected because a change in their population, in response to management activities, is believed to represent changes in a larger group of species. Selection of management indicator species was based on the following categories as specified in 36 CFR 219.19:”

1. Endangered and threatened plant and animal species identified on state and federal lists for the planning area. 2. Species with special habitat requirements s that may be influenced significantly by planned management programs. 3. Species commonly hunted, fished, or trapped. 4. Non-game species of special interest. 5. Additional species selected because their population changes are believed to indicate the effects of management activities on other species of selected major biological communities or on water quality.

North Nestucca Environmental Assessment Page 22

Appendix I

Table 3 summarizes the information on the 11 terrestrial management indicator species identified in the FEIS. The Record of Decision (ROD) for the Siuslaw National Forest Land and Resource Management Plan Final Environmental Impact Statement did not change the management indicator species list and there have been no subsequent forest plan amendments that changed the list. On the date the Record of Decision was signed (March 7, 1990), there were five species listed on the Endangered Species Act of 1973 as amended (ESA) including four species that were previously identified as endangered under the Endangered Species Preservation Act of 1966. Since 1990, four of the listed species are considered fully recovered and have been removed from the endangered species list. Two management indicator species were added to the endangered species list after the ROD was signed. Thus the table reflects both the basis for why the species was included as a management indicator species at the time of the final EIS as well as its current legal status under the Endangered Species Act.

Four of the management indicator species on the Siuslaw are primarily associated with coastal habitats (deflation plain wetlands, beach/estuary environments, costal bluffs/cliffs). Three of the four (Aleutian Canada goose, brown pelican and peregrine falcon) are considered fully recovered and have been removed from the endangered species list. Their primary habitats, and thus the basis for their decline, recovery objectives and ultimate recovery were associated with habitats and populations not associated with lands administered by the Siuslaw National Forest. Management for the Aleutian Goose (nests in the Aleutian’s) and brown pelican (nests in southern California-northern Mexico) was primarily to insure protection of potential habitat that may be used in the Oregon Dunes National Recreation Area during the non-breeding season for these two species. Seasonal closures are used at the Cascade Head Scenic Research Area to protect the known nesting activities of one peregrine pair using the site.

The management objectives, standards and guidelines and associated monitoring questions associated with management indicator species was based on the land allocations and anticipated management actions associated with the 1990 Forest Plan. The majority of the forest was identified as being in MA 15 Timber/Wildlife/Fish with the primary emphasis on producing timber while maintaining and or enhancing fish and wildlife habitat. The 467,361 acres in this allocation included about 340,344 acres considered suitable for timber harvest and about 127,000 that were considered unsuitable for timber harvest. Additional harvest was planned from MA 14 (33,666 acres) which was equally split between suitable and unsuitable for timber harvest. At the time about 193,400 acres of the 357,200 acres considered suitable were over 80 years of age. Planned harvest included about 5,200 acres of regeneration harvest and about 600 acres of commercial thinning per year. Between 1990 and 1994 about 9,100 acres have been regeneration harvested and planted, with all sales being planned and sold prior to the Siuslaw Forest Plan being fully implemented. Between 1995 and 1997 about 800 acres were planted after regeneration harvest activities were completed. These last sales were primarily regeneration of alder stands.

North Nestucca Environmental Assessment Page 23

Appendix I

Table 3 Siuslaw Management Indicator Species (MIS) Forest Plan EIS (Table Specific Habitat on Nature Federal Sp e cie s III-15, pg State Status Siuslaw Serve Status III-68) Habitat Feature Inland lakes and large expanses of List ed flooded deflation Endangere plain on the Oregon d 3/ 11/ 1967 Aleutian T&E Dunes NRA for Reclassified Canada G5T4S2N habitat potential Threatened goose migratory/transitor 1/ 11/ 1991 y habitat-little if Delisted any suitable 3/ 20/ 2001 feeding habitat. Multi-storied stands with old- List ed growth Endangere components near d 3/ 11/ 1967 water bodies which T&E G5S4BS4 Reclassified Bald eagle support an Threatened habitat N Threatened adequate food 8/ 11/ 1995 supply. Includes Delist ed large conifer trees 8/ 8/ 2007 or snags(50-90 inches in diameter) List ed Resting/roosting in Endangere Brown T&E estuaries and along G4T3S2N Endangered d 6/ 2/ 1970 pelican habitat beaches on the Delisted Oregon Dunes NRA. 12/ 17/ 2009 Mat ure Mature and older conifer Sensitive/ Vulnerabl Mart in age stands of G5S3S4 (down e timber logs) Old Old growth and Northern growth mature conifer List ed spotted & habitat(large trees, G3T3S3 Threatened Threatened owl m at ure multi-storied, large 6/ 26/ 1990 conifer snags, down logs) Open coast al List ed Silverspot T&E grasslands, G5T1S1 Threatened Butterfly habitat including ocean 7/ 2/ 1980 spray m eadow s List ed Rocky cliffs with Endangere Peregrine T&E Sensitive/ Vulnerabl ledges for nesting G4T4S2B d 6/ 2/ 1970 falcon habitat e near foraging areas Delisted 2/ 25/ 1999 Pileated Mat ure Large snags, Sensitive/ Vulnerabl G5S4 woodpecke conifer defective trees, e

North Nestucca Environmental Assessment Page 24

Appendix I

Forest Plan EIS (Table Specific Habitat on Nature Federal Sp e cie s III-15, pg State Status Siuslaw Serve Status III-68) Habitat Feature r (large down material. snags, down logs) Prim ary Sn ag s Dead and defective cavity (≥20” trees throughout excavat ors dbh) the forest types. Mix of Mosaic of foraging forage Ro o sevelt areas close t o and G5 Elk thermal and hiding cover cover. areas Open Sandy areas Western sand List ed virtually devoid of Sn o w y near G4T3S3B Sensitive/ Critical Threatened vegetation, Plover est uarie 3/ 5/ 1993 driftwood,. s The Northwest Forest Plan significantly changed the land allocations and management objectives of the Forest but did not change the management indicator species to reflect the amended forest plan. Considering the land allocations currently in place, less than 5% of the Siuslaw land base is in an allocation that would allow for regeneration harvest activities. No timber sales sold since 1991 on the Siuslaw have included regeneration harvest of mature conifer habitat. Thus the amount of mature habitat for northern spotted owl, pileated wood peckers, and marten on the Siuslaw National Forest, has not significantly changed since the Northwest Forest Plan was adopted. The loss of snags due to regeneration harvest activities has also been reduced. Overall as stands mature, an increase in snags is anticipated in natural stands. Early seral habitat conditions (preferred by elk for forage) from past regeneration harvest have been lost due to the maturation of plantations past 15 years of age. The vast majority of plantations are over 20 years of age.

The potential effects from the proposed project to the spotted owl, bald eagle, brown pelican, Oregon silverspot butterfly, peregrine falcon, and western snowy plover were disclosed in earlier sections. Because the proposed treatments do not include activities around lakeshores, or flooded deflation plains there will be no impacts to Aleutian Canada geese or their habitats.

Pileated woodpeckers, marten and primary cavity nesters Mature conifer habitat along with deadwood in the form of snags and downed wood are important habitat components for pileated woodpeckers, martens and primary cavity nesters. The Late-successional reserve assessment for this planning area (USDA, USDI 1998) documents the stand structure and composition of mature natural stands.

North Nestucca Environmental Assessment Page 25

Appendix I

The Northwest Forest Plan EIS (Appendix H of the EIS) included a viability assessment for species associated with late-successional and old-growth forests. Based on the amount of remaining suitable habitat associated with late successional and riparian reserves in the Oregon coast range, the assessment concluded that populations of pileated wood peckers, marten and primary cavity nesters would remain viable in the coast range.

Alternative 1 No Action--Except for snags considered danger trees along key forest roads, there will be no change in the amount of habitat associated with pileated woodpecker, martens or primary cavity nesters.

Alternative 2 -- In addition to danger trees along key forest roads, some danger trees along non-key roads that access commercial thinning units, or that are adjacent to the units may be felled. Except for danger trees, no mature conifer habitat is proposed for removal. The proposed silvicultural treatment, commercial thinning (including temporary road construction) will leave stocking levels that exceed the small tree levels found in natural stands. The creation of deadwood in plantations and mature stands will increase the amount of deadwood in treated areas above existing levels but below measured levels in natural stands. Considering the information above along with the project design criteria, there will be a short term increase in deadwood (≤20” dbh) in commercially thinned stands in the short term while retaining sufficient trees for future recruitment of deadwood over time. Alternative 2 may impact individuals, but the effects will not contribute to a loss of mature conifer habitat or snags ≥ 20” dbh associated with these species. Considering the above information including the current habitat conditions in late successional and riparian reserves across the forest, and the deadwood analysis discussed in Section E, the Alternative 2 will not lead towards a federal listing or cause a loss of viability to pileated woodpecker, martens or primary cavity nester populations or species.

Elk Roosevelt Elk are found throughout the project area and use all seral habitats. Larger herds tend to associate with large open meadows and fields typically associated with agricultural lands that are adjacent to forest land. Smaller herds tend to be associated with more forested areas with smaller forest gaps and meadows. Regeneration harvests provides transitory early seral habitat for elk, which lasts about 10-15 years. With the reduction of regeneration harvests on federal lands in the planning area, the amount of transitory early seral habitat is in decline. Under Alternative 1, the amount of transitory early seral habitat associated with plantations on federal lands will continue to decline and dependence on more open stands will increase. As plantations mature more open plantations would eventually occur, allowing for development of more complex herbaceous and shrub layers to form. Under Alternative 2 commercially thinning plantations will open up the understory allowing for more complex herbaceous and shrub layers to form sooner. Building temporary roads and creating deadwood will not change the amount or suitability of elk habitat. Considering the above information Alternatives 1 and 2 may impact individuals but the effects will not contribute to a trend towards federal listing or cause a loss of viability to the population or species.

D. Landbird Assessment

North Nestucca Environmental Assessment Page 26

Appendix I

Landbirds include resident, short-distance and neotropical migrant species, that generally use terrestrial and wetland habitats. Since 1999 a number of conservation and management guides have been prepared addressing landbird conservation at the national, regional and local scales (Altman 1999, Rich et.al. 2004, Nott et.al. 2005, Altman and Hager 2007, US Fish and Wildlife Service 2008). In conjunction with the Institute for Bird Populations (the Institute), the Siuslaw NF has participated in the Monitoring Avian Productivity and Survivorship (MAPS) program since 1992. The Institute developed websites and publications disclosing the species found and the productivity on the forest (Michel et. al. 2006). The habitats landbirds occupy in the planning area range from early seral openings to late-successional old growth. Table 4 represents the species of concern identified in the conservation plans documented at the monitoring stations operated by the Institute.

Table 4 Fish and Wildlife Service and Partners in Flight bird species of concern or conservation focal species associated with forest habitats on the Siuslaw National Forest Fish and Wildlife Partners In Flight Partners in Flight MAPS Site Species Species of Concern High Priority Focal Focal Species in Breeding Status4 in BCR 51 Species in Oregon2 Oregon3 Band-tailed Pigeon X X 5-U, 1-O Black-throated Gray X X 1-B, 3-U, 1-O, 1-T Warbler Brown Creeper X 3-B, 3-O Hammonds X 3-U, 2-O, 1-T Flycatcher Hermit Warbler X X 3-B, 2-U, 1-O Hutton Vireo X 2-U, 3-O, 1-NL Olive-sided X X X 1-B, 1-O, 1-T, 3-NL Flycatcher Pacific-slope X X 6-B Flycatcher Pileated X 5-U, 1-O Woodpecker Rufus Hummingbird X X X 1-B, 3-U, 2-O Varied Thrush X X 4-B, 2-U Willow Flycatcher X 1-U, 4-T, 1-NL Wilson’s Warbler X 6-B Winter Wren X 6-B 1Birds of Conservation Concern 2008 (US Fish and Wildlife Service 2008) 2Rainforest Birds: A Land Manager’s Guide to Breeding Bird Habitat in Young Conifer Forest in the Pacific Northwest (Altman and Hagar 2007) 3Conservation strategy for landbirds in coniferous forests of western Oregon and Washington (Altman 1999) 4Cumulative breeding status at six sampling stations on the Siuslaw National Forest from 1992-2003 B- Regular breeder. Summer resident or suspected summer resident during all years the station was operated. U- Usual breeder. Summer resident or suspected summer resident for more than ½ of the years stations were operated. O- Occasional breeder. Summer resident or suspected summer resident for ½ or fewer of the years stations were operated. T- Transient. The station lies in the species breeding range, but no individual of the species was a summer resident during any year. NL- Not listed. The station did not have a record of the species for any year the station was operated. Based on the MAPS data for the Siuslaw National Forest, Nott et. al. (2005) evaluated adult population trends for 12 species. They concluded that six species were showing measurable changes in the adult population, One neotropical migrant (western flycatcher), and two short-distance migrants (chestnut-

North Nestucca Environmental Assessment Page 27

Appendix I

backed chickadee and winter wren) were declining. Two neotropical migrants (swainson thrush and Wilson’s warbler) and one short-distance migrant (song sparrow) were increasing in populations. Considering the stability of habitat conditions on the forest, Nott (personal communication) has indicated that weather conditions along migration routes and winter grounds in Mexico and Central America currently has a greater influence on population trends for neotropical migrants as the condition on the breeding grounds.

Altman and Hager (2007) evaluated the findings of nine studies that evaluated the effects of thinning in young conifer forests in the Pacific Northwest, including four studies conducted in the Oregon Coast Range. Based on those findings Appendix E of their paper displays the relationships between thinning and breeding bird species in young conifer forests. Table 4 summarizes the information for the species of concern listed in table 5. In general they concluded:

• Thinning does not change habitat so dramatically that some species are no longer able to occupy the treated habitat. • Species that nest in closed forest canopies generally decline in abundance, and species associated with open forest canopies generally increase. • Although the abundance of some priority and/or declining species is often reduced in thinned stands in the short-term, most of these species show similar or increased abundance in the longer term (10-20 years). • Some species consistently show a pattern of initial change in abundance in the first few years after thinning followed by a return to their pre-thinning abundance. • Some species show no consistent pattern of response to thinning. Most are understory associated indicating the importance and variability of local conditions both pre and post-thinning. • Species that generally respond positively to thinning represent a broad range of successional stage associations from early- (for example Dark eyed Junco, MacGillivray’s Warbler) , to mid- (for example Western Tanager) and even late-successional species (for example Hammond’s flycatcher).

Alternative 1 No Action--Alternative 1 would have no direct effects on the early-, mid-, or late- successional habitats in the planning area. Considering the available information there is no measuarble effect under the no action alternative to existing habitat or landbird populations in the short (1-5 years) and long term (10-20 years).

Alternative 2—Commercial thinning (including building temporary roads) in 92 young managed conifer stands would modify the existing conditions of those stands. Considering the available information, we would expect similar mixed effects on landbird habitat and population responses as those described above. Since some units are expected to be harvested during the nesting season, individual nests could be lost. Thus commercial thinning may impact individuals, but the effects will not contribute to a trend towards federal listing or cause a loss of viability to the population or species. Creating deadwood in plantations and topping mature trees to create snags would alter

North Nestucca Environmental Assessment Page 28

Appendix I

individual trees in plantations and mature stands; however the function of the stands would not be altered. Considering the design criteria for tree selection, and the function of existing plantations and late-successional and old growth habitat would be maintained, deadwood creation under Alternative 2 would not affect landbirds.

North Nestucca Environmental Assessment Page 29

Appendix I

Table 5. Summary of Appendix E in Rainforest Birds: A land Manager’s Guide to Breeding Bird Habitat in Young Conifer Forests in the Pacific Northwest (Altman and Hager 2007) Similar Lower Higher Abundance Abundance Species Abundance in Comments In Thinned Thinned and Thinned Unthinned Limited data suggests thinning results in no Band-tailed change in abundance in the mid-term (5-10 X Pigeon years); short and long-term effects on abundance not reported. Mixed results suggest thinning results in lower Black-throated abundance or no change in abundance in the X X short and mid to long-term (1-15 years); thus Gray Warbler local effects and/or thinning intensity may result in variability in response. Mixed results suggest thinning results in lower abundance in the short-term (1-5 years) and no change in abundance in the mid and long-term Brown Creeper X X X (5-20 years) or higher abundance in the mid to long term (5-15 years); thus local effects and/or thinning intensity may result in variability in response. Thinning usually results in higher abundance in Hammonds the short, mid and long-terms (1-20 years). X X Flycatcher Thinning intensity does not appear to make a difference. Mixed results suggest thinning usually results in lower abundance in the short to mid-term (1-10 years0, with local effects resulting in no change Hermit Warbler X X X in abundance or higher abundance in the mid to long-term (5-20 years). Heavier intensity thinning appears more likely to result in reduced abundance than lighter intensity thinning. Mixed results suggest thinning results in lower abundance or no change in abundance in the short, mid and long-terms (1-20) years) or Hutton Vireo X X X higher abundance in the mid-term (5-10 years); thus local effects and/or thinning intensity may result invariability in response. Olive-sided Not reported in studies Flycatcher Mixed results suggest thinning results in no change in abundance in the short term (1-5 Pacific-slope years) or lower abundance in the short, mid and X X Flycatcher long-term (1-20 years); thus local effects and/or thinning intensity may result in variability in response. Limited data suggests thinning results in no Pileated change in abundance in the mid-term (5-10 X Woodpecker years0; short and long-term effects on abundance not reported. Limited data suggest thinning results in no Rufus change in abundance in the short-term (1-5) X Hummingbird years; mid and long-term effects on abundance not reported. Thinning usually results in lower abundance in the short-term (1-5 years) and no change in abundance in the mid-term (5-10 years) and Varied Thrush X X long-term (10-20 years). Heavier intensity thinning appears more likely to result in reduced abundance than lighter intensity thinning. Willow Not reported in studies Flycatcher Mixed results suggest thinning most often results in no change in abundance in the short Wilson’s and mid to long-term (1-15 years); although X X X local effects and /or thinning intensity may Warbler result in lower abundance in the short-term (1-5 years and higher abundance in the mid and long- terms (5-20 years).

North Nestucca Environmental Assessment Page 30

Appendix I

Similar Lower Higher Abundance Abundance Species Abundance in Comments In Thinned Thinned and Thinned Unthinned Mixed results in studies; thus local effects Winter Wren X X X and/or thinning intensity may result in variability in response.

E. Deadwood Assessment

Deadwood in the form of snags and downed wood are important habitat components for a variety of species. The recovery plans for the northern spotted owl (USFWS 1992, USFWS 2008) and the marbled murrelet (USFWS 1997) recommended changing the trajectory of managed stands from wood fiber production to a condition that more closely replicates natural stand conditions.

The Late-successional reserve assessment (LSRA) for this planning area (USDA, USDI 1998), documents in Table 14 of the assessment, the stand structure and composition of mature natural stands. Tables 19 and 20 in the assessment discloses the range of snags or down wood volumes per acre found in natural stands of different age classes in the Oregon Coast Range. The objective of the late successional reserves is to protect and restore habitat related to late successional species. The assessment concluded the loss of the large CWD component is long-term and there is very limited opportunity to create CWD >20" in diameter in the 25-50 year old plantations. The assessment recommended prescriptions that would set managed stands on a trajectory to meet the snag and downed wood levels found in mature and old-growth stands while still providing for an acceptable level of CWD in young stands.

Wildlife use and distribution of deadwood in Oregon coastal conifer and hardwood landscapes are documented by Mellen et. al (2009) through the decayed wood advisor and management aid (DecAID). DecAID is an advisory tool to help managers evaluate effects, of forest conditions and existing or proposed management activities on organisms that use snags and down wood. DecAID was developed as a tool to replace the biological potential models which were used to develop the standards and guidelines for the Northwest Forest Plan. Since that time, it has been determined that the biological potential models are flawed (Rose et. al, Mellen-McLean 2011) and are no longer used in determining deadwood management strategies across planning areas. The guidelines associated with the use of DecAID indicate the fifth-field watershed is the appropriate scale to conduct the analysis of snags and downed wood. A full description on DecAID as well as a tutorial, cautions, glossary and references can be found at http://www.fs.fed.us/r6/nr/wildlife/decaid/index.shtml.

Details on deadwood descriptions, assessment methods and current conditions on are found in Appendix G of the North Nestucca Environmental Assessment. To utilize DecAid, the deadwood analysis will be limited to the Nestucca River watershed.

The Siuslaw NF lands in the Nestucca River watershed, which includes the North Nestucca planning area, are all part of the Western Lowland Conifer-Hardwood NW Oregon Coast wildlife habitat type (WHT)(Mellen 2009). Natural stands administered by the Siuslaw National Forest represent about 57% of the total lands administered by the Forest in the Nestucca River watershed. These stands can be further

North Nestucca Environmental Assessment Page 31

Appendix I

divided by species composition as detailed in the Silviculture report. Young plantations (managed stands) administered by the Siuslaw National Forest represent about 34% of the total lands administered by the Forest in the watershed. Of the total plantation acres,16% are in a designated roadless area, which is reserved from thinning activities under current direction. Offsite plantations represent about 10% of the total lands administered by the Forest in the watershed, of which, 9% is in the roadless land designation.

In using DecAID for this analysis, the natural mature conifer stands are classified as being in the Large (≥20” dbh) structural class. In using DecAID for this analysis, the managed stands are classified as being in the Small/Medium (≥10”-20” dbh) structural class.

The following is a summary of the DecAID and current stand condition data information associated with the Western Lowland Conifer-Hardwood NW Oregon Coast wildlife habitat type, in the Small/medium structural class (>10”-20<” dbh) and the Larger structural class (≥20” dbh). Landscape distribution conditions described for the watershed are limited to those acres administered by the Siuslaw National Forest and not the entire watershed. Snag Size Summarizing the available literature on species use of snags by diameter class, DecAID’s cumulative species curves (Figures 1-5) identifies seven species (northern pygmy owl, Northern flying squirrel, brown creeper, red breasted nut hatch, long eared myotis, pileated woodpecker, and hairy woodpecker) that use snags smaller than 20” dbh for nesting, denning, resting, roosting or foraging, in both the small/medium as well as the larger tree structural classes. None of these species are closely associated with young stands containing snags ≤ 20”dbh. All either require or prefer large (≥20”) snags in the managed stands or stands of mature to late successional forest that are in close proximity to the young stands (Johnson, et.al, 2001). Stands containing snags up to 20” could provide habitat for these seven species with a low level of assurance (30% tolerance level) of potential use. None of the other species plotted on the 30% curve would be provided for and no species plotted on the 50% (moderate level of assurance) and 80% (high level of assurance) curves would be provided for when a stand only contains snags ≤ 20” dbh. There are no species known to be associated only with snags < 20” dbh.

Alternative 1 No Action—Considering the information discussed in the Deadwood Assessment (Appendix G, North Nestucca EA); along with the above information, there would be no change in the contribution of snags ≥20” dbh in managed stands in the near or long term. There would also be no change in the contribution of snags ≥20” dbh in natural stands. Suppression mortality in managed stands would develop snags ≥10” dbh. Thus managed stands would be expected to contain snags of a size that provides for 7 species at the 30% tolerance level at age 125. There is a low likelihood that other species would be provided for in plantations because the snags would be too small. Since there is no planned change in the amount of natural stands, they would continue to be the primary source for small and large size snags in the watershed and provide for all the species evaluated across all tolerance intervals.

Alternative 2—Considering the information discussed in the Deadwood Assessment (Appendix G, North Nestucca EA); along with the above information, residual trees in thinned stands would grow to a size ≥20” dbh. While suppression mortality would not provide snags in thinned stands, non-suppression

North Nestucca Environmental Assessment Page 32

Appendix I mortality (i.e. insects, disease, wind events snapping tree tops) would develop snags. Thus thinned stands would develop snags of a size that provides for all the species evaluated at the 30% tolerance level and three of the species at the 50% tolerance level. Since there is no planned change in the amount of natural stands, they would continue to be the primary source for small and large size snags in the watershed and provide for all the species evaluated across all tolerance intervals.

Figures 1-8 are similar to the cumulative species curves in DecAID. Measurements are in inches and acres rather than centimeters and hect ares. Figure 1 Cumulative species curves for snag/tree dbh (in) used for nesting or denning in relation to snag size for 30%, 50% and 80% tolerance levels in the Westside Lowland Conifer-Hardwood Forest (Oregon Coast), Small/medium Trees Structural Condition Class.

12 CBCH CBCH SCNB RBSA SCNB CBCH 10 PIWO RBSA PCE SCNB PCE BRCR 8 CNB CNB RBSA NOFL PIWO RBNU 6 PCE RBNU CNB HAWO NOFL PIWO 4 RBNU BRCR NOFL 30% tolerance level BRCR HAWO NFSQ 50% tolerance level 2 NFSQ NFSQ HAWO NPOW NPOW NPOW 80% tolerance level Cumulative species or groups 0 0 10 20 30 40 50 60 70 80 Snag dbh (in)

Figure 2 Cumulative species curves for snag/tree dbh (in) used for nesting or denning in relation to snag size for 30%, 50% and 80% tolerance levels in the Westside Lowland Conifer-Hardwood Forest (Oregon Coast), Larger Trees Structural Condition Class.

12 CBCH CBCH SCNB RBSA SCNB CBCH 10 PIWO RBSA PCE SCNB PCE BRCR 8 CNB CNB RBSA NOFL PIWO RBNU 6 PCE RBNU CNB NFSQ BRCR NFSQ 4 HAWO NOFL PIWO 30% tolerance level RBNU NFSQ NOFL 50% tolerance level 2 BRCR HAWO HAWO NPOW NPOW NPOW 80% tolerance level Cumulative species or groups species Cumulative 0 0 10 20 30 40 50 60 70 80 Snag dbh (in)

Figure 3 Cumulative species curves for snag/tree dh (in) used for resting and roosting in relation to snag size for 30%, 50%, and 80% tolerance levels in the Westside Lowland Conifer-Hardwood Forest

North Nestucca Environmental Assessment Page 33

Appendix I

Wildlife Habitat Type (Oregon Coast), Small/Medium Tree and Larger Trees Structural Condition Classes.

5 30% tolerance level 4 50% tolerance PIWO level PIWO PIWO 80% tolerance level 3 BBBA BBBA BBBA

2 LLMY LLMY LLMY

1 LEMY LEMY LEMY

Cumulative species or groups species Cumulative 0 0 10 20 30 40 50 60 70 80 Snag dbh (in)

Figure 4 Cumulative species curves for snag/tree dh (in) used for foraging in relation to snag size for 30%, 50%, and 80% tolerance levels in the Westside Lowland Conifer-Hardwood Forest Wildlife Habitat Type (Oregon Coast), Small/Medium Tree Structural Condition Class.

2 PIWO HAWO HAWO

30% tolerance level 1 HAWO PIWO PIWO 50% tolerance level

80% tolerance level

Cumulative species or groups species Cumulative 0 0 10 20 30 40 50 60 70 80 Snag dbh (in)

North Nestucca Environmental Assessment Page 34

Appendix I

Figure 5 Cumulative species curves for snag/tree dh (in) used for foraging in relation to snag size for 30%, 50%, and 80% tolerance levels in the Westside Lowland Conifer-Hardwood Forest Wildlife Habitat Type (Oregon Coast), Larger Tree Structural Condition Class.

3 NOFL 30% tolerance level 50% tolerance 2 level PIWO 80% tolerance level PIWO PIWO 1 HAWO

Cumulative species or groups species Cumulative 0 0 10 20 30 40 50 60 70 80 Snag dbh (in)

Snag Density Based on the available information on species use of snags relative to snag density, DecAID’s cumulative species curves documents four species use of snags ≥10” dbh for nesting, roosting or occurrence, and five species use of snags ≥20” dbh at the 30%, 50% and 80% tolerance levels (Figures 6 and 7). Figure 6 Cumulative species curves for density (#/ac) of snags ≥ 10 in dbh: species use of areas for nesting, roosting and occurrence with documented snag densities for 30%, 50%, and 80% tolerance levels in the Westside Lowland Conifer-Hardwood Forest Wildlife Habitat Type for the Small/medium and Larger Structural condition Classes.

CNB 4 CNB CNB

3 BTWR BTWR BTWR

2 30% tolerance NFSQ NFSQ NFSQ level 50% tolerance level 1 DOSQ DOSQ DOSQ 80% tolerance level

Cumulative species or groups species Cumulative 0 0 5 10 15 20 25 30 35 40 Snag Density (#/ac); snags ≥ 10 in dbh

North Nestucca Environmental Assessment Page 35

Appendix I

Figure 7 Cumulative species curves for density (#/ac) of snags ≥ 20 in dbh: species use of areas for nesting, roosting and occurrence with documented snag densities for 30%, 50%, and 80% tolerance levels in the Westside Lowland Conifer-Hardwood Forest Wildlife Habitat Type for the Small/medium and Larger Structural condition Class.

6 PIWO* PIWO* PIWO* 5 PIWO CNB LLMY 4 CNB * PIWO from CNB PIWO foragingsites 3 BBBA LLMY BBBA 30% tolerance level 2 LLMY BBBA LEMY 50% tolerance level 1 LEMY 80% tolerance LEMY PIWO level

Cumulative species or groups species Cumulative 0 0 5 10 15 20 Snag Density (#/ac); ≥ 20 in dbh

In the Small/medium structural class for snags ≥10” dbh (figure 8), the percentage of the Nestucca River watershed that has no measurable snag density is 12% or 9% less than reference conditions (21%). The percentage of the watershed that provides for the 0-30% tolerance interval is 17 (DecAID Reference 9%). The percentage of the watershed that provides for the 30-50% tolerance interval is 31 (DecAID Reference 20%). The percentage of the landscape that provides for the 50-80% tolerance interval is less than reference conditions (DecAID Reference 30%-Current 25%). The percentage of the Nestucca River watershed that provides for the species at the 80% tolerance level is less than reference (DecAID Reference 20%-Current 15%), reflecting a lack of large snags due to harvest.

Integrating wildlife utilization data with the availability of snags relative to density in the Small/medium structural class, about 31% of the Nestucca River watershed has snags (≥10” dbh) with a density that could provide for all four species at the 30% tolerance interval (figures 6, 8). Three of the four species are provided for at the 50% tolerance interval on about 25% of the landscape. About 15% of the landscape could provide for the four species at the 80% tolerance intervals.

Reminder: For comparison between the watershed and DecAID, managed stands in the North Nestucca project are classified as being in the Small/ medium structural class.

North Nestucca Environmental Assessment Page 36

Appendix I

Figure 8 Distribution of snag density in the Westside Lowland Conifer-Hardwood Forest Wildlife Habitat Type; Small/medium Structural Condition Class for the Nestucca River Watershed within tolerance intervals for snags ≥10 in.

35 DecAID 31 30 30 Reference Nestucca River 25

25 21 20 20 20 17 15 15 12 Percent of Area 10 9

0 0 0-30% 30-50% 50-80% >80% 0 Snags/Acre 0-2 Snags/Acre 2-6.5 Snags/Acre 6.5-16.7 Snags/Acre >16.7 Snags/Acre Tolerance Interval

In the Small/medium structural class for snags ≥20” dbh (figure 9), the percentage of the Nestucca River watershed that has no measurable snag density is less than the reference conditions (DecAID Reference 29%-Current 21%). The percentage of the watershed that has 0-1.1 snags per acre (0-30% tolerance interval) is 18%; the DecAID Reference is 1%. The percentage of the landscape that currently provides for the 30-50% tolerance interval is less than reference conditions (DecAID Reference 20%-Current 14%). The percentage of the watershed that has 2.1- 9.7 snags per acre is 38% (DecAID Reference 30%). The percentage of the Salmon watershed that provides for the species at ≥80% tolerance intervals is less than the reference conditions (DecAID Reference 20%-Current 9%), reflecting a lack of large snags in managed stands.

Integrating wildlife utilization data with the availability of snags ≥20” dbh relative to density in the Small/medium structural class, about 14% of the Nestucca River watershed has snags with a density that provides for 2 of the five species at the 30% tolerance intervals (figures 7, 9). On about 38% of the Nestucca River watershed, three species from the 30% tolerance interval are provided for and all five species are provided for at the 50% tolerance interval. Approximately 9% of the Nestucca River watershed could provide for one species at the 50% tolerance interval and all five species at the 80% tolerance interval.

North Nestucca Environmental Assessment Page 37

Appendix I

Figure 9 Distribution of snag density in the Westside Lowland Conifer-Hardwood Forest Wildlife Habitat Type; Small/medium Structural Condition Class for the Nestucca River Watershed within tolerance intervals for snags ≥20 in. 38 40 DecAID Reference 35 Nestucca River 29 30 30

25 21 20 20 20 18 14 15

Percent of Percent of Area 9 10 5 1 0 0 0-30% 30-50% 50-80% >80% 0 Snags/Acre 0-1.1 Snags/Acre 1.1-2.1 Snags/Acre 2.1-9.7 Snags/Acre >9.7 Snags/Acre Tolerance Interval

In the Large structural class (natural stands) for snags ≥10” dbh (figure 10), the percentage of the Nestucca River watershed that has no measurable snag density is 2% of the landscape or 2% more than reference conditions. There is a higher percentage of the Nestucca River watershed that provides less than 8 snags per acre than reference conditions (DecAID Reference 30%-Current 34%). Currently there is a smaller percentage of the Nestucca River watershed that provides snag densities at the 30 to 50% tolerance interval than found in the reference conditions (DecAID Reference 20%- Current 15%). The percentage of the watershed that provides for the 50-80% tolerance interval currently is higher than reference conditions (DecAID Reference 30%-Current 37%). The percentage of the Nestucca River watershed that provides for the species at the 80% tolerance level is lower than reference conditions (DecAID Reference 20%-Current 11%).

Integrating wildlife utilization data with the availability of snags relative to density in the Large structural class, about 15% of the Nestucca River watershed has snags (≥10” dbh) with a density that could provide for all of the four species at the 30% tolerance level and three of the four species at the 50% tolerance level (figures 6, 10). One of the four species at the 50% tolerance level and three of the four species at the 80% tolerance level are provided for on about 37% of the Nestucca River watershed. About 11% of the Nestucca River watershed could provide for all four species at the 80% tolerance level.

North Nestucca Environmental Assessment Page 38

Appendix I

Figure 10 Distribution of snag density in the Westside Lowland Conifer-Hardwood Forest Wildlife Habitat Type; Larger Structural Condition Class for the Nestucca River Watershed within tolerance intervals for snags ≥10 in.

40 37 DecAID 34 35 Reference 30 30 30

25 20 20 20 15 15

Percent of Percent of Area 11 10

5 2 0 0 0 0-30% 30-50% 50-80% >80% 0 Snags/Acre 0-8 Snags/Acre 8-13.3 Snags/Acre 13.3-29 Snags/Acre >29 Snags/Acre Tolerance Interval

In the Large structural class, the percentage of the Nestucca River River watershed that has no measurable snag density for snags ≥20” dbh, slightly less than the reference conditions (figure 11, DecAID Reference 4%-Current 3%). The percentage of the watershed that currently provides for the 0-30% tolerance interval is higher than the reference conditions (DecAID Reference 26%-Current 37%). The percentage of the watershed that provides for the 30-50% tolerance interval is less than the reference conditions (DecAID Reference 20%-Current 15%). The percentage of the landscape that provides for the species at the 50-80% tolerance interval equal to the reference conditions (DecAID Reference 30%-Current 30%). The percentage of the watershed that provides for the 80% tolerance level is less than the reference conditions (DecAID Reference 20%-Current 15%).

Integrating wildlife utilization data with the availability of snags relative to density in the Large structural class, about 15% of the Nestucca River watershed has snags (≥20” dbh) with a density that could provide for all five species at the 30% tolerance interval and three of the five species at the 50% tolerance interval (figures 7, 11). One species at the 30% tolerance interval, all five species at the 50% tolerance interval and three of the five species at the 80% tolerance interval are provided for on about 30% of the Nestucca River watershed. About 15% of the Nestucca River watershed could provide for the five species at the 80% tolerance intervals.

North Nestucca Environmental Assessment Page 39

Appendix I

Figure 11 Distribution of snag density in the Westside Lowland Conifer-Hardwood Forest Wildlife Habitat Type; Larger Structural Condition Class for the Nestucca River Watershed within tolerance intervals for snags ≥20 in. 40 37 DecAID Reference 35 30 30 Nestucca River 30

26 25 20 20 20 15 15 15 Percent of Percent of Area 10 4 5 3

0 0 0-30% 30-50% 50-80% >80% 0 Snags/Acre 0-4 Snags/Acre 4-6.8 Snags/Acre 6.8-11.9 Snags/Acre >11.9 Snags/Acre Tolerance Interval

Effects on Snag Size and Density Alternative 1 No Action—Considering the information discussed in the Deadwood Assessment (Appendix G, Niagara Boulder EA); except for snags considered danger trees along key forest roads, there would be no change in the current amount or recruitment rate (about 1 every 2 years at 200 trees per acre) of snags greater than 10” dbh in managed stands. Thus the average number of snags per acre greater than 10” dbh would be about 7 per acre in 16 years with no snags greater than 20” dbh expected.

At the expected snag size in managed stands this would provide for 7 of the 12 species identified at the 30% tolerance level for snag size (figures 1, 3, 4) in the short term or at age 125. None of the other species plotted on the 30% curve would be provided for and no species plotted on the 50% (moderate level of assurance) and 80% (high level of assurance) curves would be provided for when a stand only contains snags ≤ 20” dbh (figures 1, 3, 4).

There would be no change in the current amount or recruitment rate of snags, ≥10” dbh or ≥20” dbh in natural stands, except for snags considered danger trees along key forest roads. Based on the current natural stand condition data (Appendix G, Niagara Boulder EA), the natural stands contain a range of snag sizes ≥20” dbh to provide for all the species at the 30%, 50% and 80% tolerance levels (figures 2, 3, 5). Thus natural stands would continue to be the primary source for small and large size snags in the watershed and provide for all the species evaluated across all tolerance intervals.

Considering that few, if any trees, ≥20” dbh were retained in regeneration units; that trees ≥20” dbh from the current cohort of trees would be the most dominant in the stand and therefore least likely to succumb

North Nestucca Environmental Assessment Page 40

Appendix I

from suppression mortality, the recruitment of snags ≥20” dbh is not likely to occur at a level that would change the current distribution of snags ≥20” dbh in the small/medium structural class until the structural class has grown to an average size that would classify it in the large structural class.

Until a larger scale event such as a major wind storm, insect outbreak or large scale fire occurs; snag densities in natural stands across the Nestucca River watershed are not expected to change from the existing conditions. Thus the distributions of snag densities across the landscape by tolerance levels are not expected to change the Large structural class (figures 10, 11).

Alternative 2 —Considering the information discussed in the Deadwood Assessment (Appendix G, North Nestucca EA); along with the above information, and the current size of trees in managed stands there would be no change in the number of snags in managed stands greater than 20” dbh in the short term (16 years). The majority of the residual trees are expected be ≥20” dbh by age 80.

Thus snags created in managed stands as part of this project would provide for 7 of the 15 species identified at the 30% tolerance level for snag size (figures 1, 3, 4). The remaining 8 species would not be provided for at the 30% tolerance level and none of the species would be provided for at the 50% or 80% tolerance levels in managed stands. In the longer term (80-125 years), suppression mortality would not provide snags in thinned stands, however non-suppression mortality (i.e. insects, disease, wind events snapping tree tops) would develop snags. Thus thinned stands would develop snags of a size that provides for all the species evaluated at the 30% tolerance level and three of the species at the 50% tolerance level.

Since there is no planned change in the amount of natural stands, they would continue to be the primary source for small and large size snags in the watershed and provide for all the species evaluated across all tolerance intervals. Based on the design criteria to select trees in natural stands that are 30-50” dbh to mitigate for the loss of large snags in plantations, creating up to 1,134 snags would provide for all species nesting, denning and foraging at the 30% and 50% tolerance levels (figures 2, 5). This size range will provide snags for potential resting and roosting for all four species at the 30% tolerance level and three of four species at the 50% tolerance level (figure 3). These sizes will provide potential nesting for 8 of 12 species at the 80% tolerance level; potential resting and roosting for 1 of 4 species at the 80% tolerance level; and potential foraging for the one species reported at the 80% tolerance level (figures 2, 3, 5).

The managed stands evaluated for commercial thinning in the North Nestucca project represent less than 25% of the small/medium structure class administered by the Siuslaw National Forest in the Nestucca River watershed. The creation of about 4 snags per acre would add to the 7 snags expected to develop naturally in thinned stands over the next 16 years. Due to the small percentage of managed stands considered for treatment in the watershed, the addition of snags in these stands above what would be created naturally is not expected to appreciably change the distribution of snag density in the Nestucca River watershed across the tolerance intervals.

Though large snags would be created (about 1,134), the scale is too small to influence snag density in the Large structural class in the Nestucca River watershed. Thus measurable changes in the distributions of

North Nestucca Environmental Assessment Page 41

Appendix I snag densities across the landscape by tolerance levels are not expected to change (figures 10, 11) in Large structural classes until a larger scale event such as a major wind storm, insect outbreak or large scale fire occurs

Downed Wood Summarizing the available literature on species use of downed wood by size, DecAID’s cumulative species curves (figures 12-13) identifies 17 species that use downed wood ≥4” for foraging and occupancy at the 30%, 50% and 80% tolerance levels. The cumulative species curves for the Small/medium and Large structural condition class are the same. Table 1 displays the average or individual piece size required to provide for all 17 species at each tolerance level.

Figure 12 Cumulative species curves for down wood diameter (in) used at foraging sites and occupied sites in relation to average down wood size for 30%, 50%, 80% tolerance levels in the Westside Lowland Conifer- hardwood Forest Wildlife Habitat Type; Small/medium and Large tree Structural Condition Class. 16 PWSH PGSA PGSA 14 PGSA BTWR BTWR 30% tolerance BTWR ERMI level PWSH 12 CLSA TOVO PJMO 50% tolerance TOVO CLSA TOVO 10 level WSSK WWSK CLSA NFSQ PJMO 80% tolerance PWSH 8 WRSA WRSA NFSQ level SHMO FDSQ SHMO 6 NWSA SHMO ENSA VASH ENSA VASH 4 EMSA NWSA NWSA PJMO VASH WSSK 2 DOSQ ERMI WRSA Cumulative species or species or Cumulative groups ERMI DOSQ DOSQ 0 0 2 4 6 8 10 12 14 16 18 20 Average down wood diameter (in)

Figure 13 Cumulative species curves for down wood diameter (in) used at foraging sites and occupied sites in relation to individual down wood size for 30%, 50%, 80%, tolerance levels in the Westside Lowland Conifer- hardwood Forest Wildlife Habitat Type; Small/medium and Large trees Structural Condition Class.

30% tolerance level 6 WIWR WIWR WIWR ENSA HAWO HAWO 4 CLSA CLSA CLSA WRSA WRSA WRSA HAWO ENSA 2 PIWO PIWO PIWO ENSA Cumulative species or species or Cumulative groups 0 0 5 10 15 20 25 30 35 40 45 50 55 Individual down wood diameter (in)

North Nestucca Environmental Assessment Page 42

Appendix I

Table 1-Down wood diameter required to provide for all species evaluated by tolerance level

30% Tolerance 50% Tolerance 80% Tolerance

Level Level Level

Average Size ≥9.3” ≥12.6” ≥17.3”

Single Piece ≥22.2” ≥34.4” ≥51.7”

Based on the available silvicultural information, the majority of the stands evaluated for commercial thinning have average tree sizes that potentially could meet the documented down wood sizes used by species at the 30 and 50% tolerance levels. The majority of these stands could potentially meet the sizes documented for 8 of the 15 species at the 80% tolerance level. The stands likely contain individual trees of a size that meet the needs for 4 of the 6 species at the 30% and 3 of the 6 at the 50%. None are likely to meet the documented sizes at the 80% tolerance level. Recruitment of downed wood through suppression mortality is most likely going to result in the smaller trees (≤10”) in the stand, which would only provide for species at the 30% tolerance level. Recruitment of downed wood through windthrow or disease (i.e. laminated root rot) may occur at any size class in the stand. The natural stands provide the full range of down wood sizes used by wildlife. Primary recruitment is the result either of snag decay, windthrow or disease (i.e. laminated root rot) causing root failure

Summarizing the available literature on species use of downed wood by percent cover, DecAID’s cumulative species curves (figures 14 & 15) identifies 23 species that use downed wood ≥4” for foraging and occupancy at the 30%, 50% and 80% tolerance levels.

North Nestucca Environmental Assessment Page 43

Appendix I

Figure 14 Cumulative species curves for percent cover of down wood (≥4 in diameter) in areas used for foraging or at occupied sites for 30%, 50%, and 80% tolerance levels in the Westside Lowland Conifer-hardwood forest wildlife Habitat Type and Small/Medium trees Structural Condition Class.

24 CLSA NFSQ NFSQ 22 ENSA WRSA WRSA PWSH PGSA PGSA 20 NFSQ TOCH TOCH WSSK PWSH PJMO 18 WRSA PJMO BTWR PJMO WSSK PWSH 16 NWSA BTWR WSSK TOCH ENSA SEMI 14 DOSQ ENSA * Class 4 and 5 SHMO CLSA CLSA down wood only ERMI 12 PGSA ** minimum size SHMO SHMO WRBV WRBV VASH measured = 7 in 10 TRSH VASH WRBV vs 4 in for other Cumulative species species Cumulative PIWO** PASH species 8 PASH TRSH FOSH PASH FOSH DEMO FOSH 6 DEMO VASH TRSH DEMO NWSA DOSQ 4 TOVO 30% tolerance level SPOW* DOSQ NSWA 50% tolerance level ERMI TOVO TOVO 2 PIWO** 80% tolerance level PIWO** BTWR SPOW* SPOW* 0 0 2 4 6 8 10 12 14 16 18 20 22 Down wood percent cover

Figure 15 Cumulative species curve for percent cover of down wood (≥4 in diameter) in areas used for foraging or at occupied sites for 30%, 50%, and 80% tolerance levels in the Westside Lowland conifer-Hardwood Forest Wildlife Habitat Type and Larger Trees Structural Condition Class.

24 WRBV*** WRBV*** WRSA 22 CLSA WRSA PGSA PWSH PGSA WRBV*** 20 NFSQ PWSH PJMO WSSK PJMO BTWR 18 WRSA WSSK PWSH PJMO BTWR WSSK 16 NWSA CLSA ERMI DOSQ ERMI NFSQ * Class 4 and 5 14 SHMO CLSA NFSQ wood only PGSA SHMO SHMO ** minimum size 12 PGSA ENSA VASH measured = 7 in WRBV WRBV ENSA 10 TRSH vs 4 in for other

Cumulative species species Cumulative VASH WRBV species PIWO* PASH 8 PASH TRSH *** Class 3-5 FOSH PASH FOSH DEMO FOSH 6 DEMO VASH TRSH DEMO NWSA DOSQ 30% tolerance level 4 TOVO SPOW* DOSQ NSWA 50% tolerance level ERMI TOVO TOVO 2 PIWO** 80% tolerance level BTWR PIWO** SPOW* SPOW* 0 0 2 4 6 8 10 12 14 16 18 20 Down wood percent cover

North Nestucca Environmental Assessment Page 44

Appendix I

In the Small/medium structural class for down wood ≥5” (figure 16), the percentage of the Nestucca River watershed that has no measurable down wood is similar to reference conditions (DecAid Reference 5%-Nestucca River 4%). Current conditions reflect a greater percentage of the watershed in the 0-30% (DecAID Reference 25% Nestucca River 38%) and 30-50% tolerance intervals (DecAID Reference 20% Nestucca River 23%) than the DecAID Reference. The percentage of the Nestucca River watershed that provided for species at the 50-80% tolerance level is less than the reference conditions (DecAID Reference 30% Nestucca River 26%). The percentage of the Nestucca River watershed that provided for species at the 80% tolerance level is less than the reference conditions (DecAID Reference 20%-Nestucca River 9%). The largest amount of downed wood measured in the watershed is 14.6% ground cover.

Figure 16 Distribution of down wood in the Westside Lowland Conifer-Hardwood Forest Wildlife Habitat Type and Small/medium Structural Condition Class for the Nestucca River Watershed within tolerance intervals for down wood ≥5 in.

50 DecAid 45 Ref 40 38

35 30 30 25 26 23 25 20 20 20

Percent of Percent of Area 15 9 10 5 4 5 0 0 0-30% 30-50% 50-80% >80% 0% Ground Cover 0-2.9 % Ground 2.9-5% Ground 5-9.4% Ground >9.4% Ground Cover Cover Cover Cover Tolerance Interval

Integrating wildlife utilization data with the percent cover of down wood in the Small/medium structural class, about 23% of the Nestucca River watershed has down wood (≥5”) that could provide for all 23 species at the 30% tolerance level and 3 of 23 species at the 50% tolerance level (figures 14, 16). About 26% of the landscape provides for 21 of the 23 species at the 50% tolerance level and 4 of the 23 species at the 80% tolerance level. About 9% of the landscape could provides for 19 of the 23 species at the 80% tolerance level when there is more than 9.4% ground cover.

In the Large structural class for down wood ≥5” (figure 17), the percentage of the Nestucca River watershed that has no measurable down wood is less than reference conditions (DecAid Reference 2%- Nestucca River 0%). Current conditions reflect a greater percentage of the watershed in the 0-30% tolerance interval than reference conditions (DecAID Reference 28%-Nestucca River 38%). The percentage of the Nestucca River watershed that provides for species at the 30-50% tolerance interval is higher than reference conditions (DecAID Reference 20% Nestucca River 27%). The percentage of the Nestucca River watershed that provides for species at the 50-80% tolerance interval is slightly lower than reference conditions (DecAID Reference 30% Nestucca River 29%). The percentage of the Nestucca

North Nestucca Environmental Assessment Page 45

Appendix I

River watershed that provided for species at the 80% tolerance level is less than reference conditions (DecAID Reference 20% Nestucca River 6%). The largest amount of downed wood measured in the watershed is 16.6% ground cover.

Figure 17 Distribution of down wood in the Westside Lowland Conifer-Hardwood Forest Wildlife Habitat Type and Large Structural Condition Class for the Nestucca River Watershed within tolerance intervals for down wood ≥5 in.

Decaid Ref 50 Nestucca River 38 40

30 29 30 28 27 20 20 20 Percent of Percent of Area

10 6 2 0 0 0 0-30% 30-50% 50-80% >80% 0% Ground Cover 0-2.9 % Ground 2.9-4.9% Ground 4.9-10% Ground >10% Ground Cover Cover Cover Cover Tolerance Interval

Integrating wildlife utilization data with the percent cover of down wood in the Large structural class, about 27% of the Nestucca River watershed has down wood (≥5”) that could provide for 22 of 23 species at the 30% tolerance level and 3 of 23 species at the 50% tolerance level (figures 15, 17). About 27% of the landscape provides for 1 species at the 30% tolerance level, 22 of the 23 species at the 50% tolerance level and 5 of the 23 species at the 80% tolerance level. About 6% of the landscape could provide for 17 of the 23 species at the 80% tolerance level when there is more than 10% ground cover.

In the Small/medium structural class for down wood ≥20” (figure 18), the percentage of the Nestucca River watershed that has no measurable down wood is less than the reference conditions (DecAid Reference 24%-Nestucca River 17%). Current conditions reflect a greater percentage of the watershed in the 0-30% (DecAID Reference 6% Nestucca River 23%) and 30-50% tolerance intervals (DecAID Reference 20% Nestucca River 25%) than the DecAID Reference. The percentage of the Nestucca River watershed that provided for species is less than the reference conditions at the 50-80% tolerance level (DecAID Reference 30% Nestucca River 27%) and at the 80% tolerance level (DecAID Reference 20%- Nestucca River 8%).

North Nestucca Environmental Assessment Page 46

Appendix I

Figure 18 Distribution of down wood in the Westside Lowland Conifer-Hardwood Forest Wildlife Habitat Type and Small/medium Structural Condition Class for the Nestucca River Watershed within tolerance intervals for down wood ≥20 in.

35 Decaid Ref 30 30 27 Nestucca river 25 24 25 23 20 20 20 17

Percent of Percent of Area 10 8 6 5

0 0 0-30% 30-50% 50-80% >80% 0 Snags/Acre 0-1.3 % Ground 1.3-3.1% Ground 3.1-7.3% Ground >7.3% Ground Cover Cover Cover Cover Tolerance Interval

Figure 19 Distribution of down wood in the Westside Lowland Conifer-Hardwood Forest Wildlife Habitat Type and Large Structural Condition Class for the Nestucca River Watershed within tolerance intervals for down wood ≥20 in.

35 32 Decaid Ref 30 30 Nestucca River 25 25 21 20 20 20 20 14 15 12

Percent of Percent of Area 10 5 5

0 0 0-30% 30-50% 50-80% >80% 0 Snags/Acre 0-1.1 % Ground 1.1-2.0% Ground 2.0-5.3% Ground >5.3% Ground Cover Cover Cover Cover Tolerance Interval

Alternative 1 No Action--There would be no change in the current amount or recruitment rate of down wood greater than 5” diameter in plantations. Considering the diameter of the trees in plantations, even though suppressed trees would most likely be recruited they would be of a size that would provide for all the species at the 30% tolerance level and most of the species at the 50% tolerance level.

The recruitment of about 7 trees per acre over the next 16 years would add about 0.5% ground cover (based on percent of an acre covered by a fallen 10”dbh Douglas fir) in plantations. Considering the

North Nestucca Environmental Assessment Page 47

Appendix I

existing distribution of down wood, a 0.5% increase in down wood has little influence on changing the current distribution of down wood ≥5” across the landscape (figure 16).

Considering there are few if any trees > 20’ diameter in plantations, the current distribution of down wood >20” is not expected to change in the short term (16 years). Even though suppression mortality is expected to occur in unthinned stands, modeling conducted as detailed in Appendix G indicates that even at 125 years of age no snags were greater than 19 inches DBH that could be recruited as down wood.

Until an event such as a windstorm, disease epidemic or large fire occurs, no change in the current amount or recruitment rate of down wood greater than 5” or 20” diameter in natural stands is expected. Thus the current distribution of down wood is not expected to change in natural stands.

Alternative 2-- The proposed silvicultural treatment, commercial thinning (including temporary road construction) would leave residual stocking levels that exceed the small tree levels found in natural stands and average greater than 12” dbh. Considering the size of the trees in the managed stands and that the proposed activities do not involve removing any existing down wood, there would be no change in the amount of down wood greater than 20” diameter in the short term. Prescriptions for treatments in stands include the creation of snags and down wood post thinning. The trees selected for down wood creation range between 12” and 20” dbh. Selecting trees in these size classes provides for all the species at the 30% tolerance level including individual down pieces; all the species at the 50% tolerance level for stand average, and five of the seven species identified with individual pieces; all the species at the 80% tolerance level for stand average, and one of the seven species identified with individual pieces.

In addition to the existing percentage of down wood ground cover in managed stands, about 0.6% (based on percent of an acre covered by a felled 15”dbh Douglas fir) would be created along with the natural development of 0.5% ground cover through natural mortality over the next 16 years. Considering the existing distribution of down wood, a 1.1% increase in down wood has a slightly greater, but still small influence on changing the current distribution of down wood ≥5” across the landscape.

Considering that trees greater than 20” inches in plantations are few in number, and typically are the most dominant trees on site, barring mortality associated with windthrow or disease, few if any trees > than 20” are expected to be recruited as down wood in plantations. Thus the distribution of down wood ≥20” is not expected to change in managed stands in the short term. In the long term (80-125 years) tree mortality at lower stand densities is a result of other causes such as disease, insects, or wind effects. Increase diameter growth through thinning provides the opportunity of this mortality in the 20 inch and greater diameter which over time will result in an increase in down wood ≥20” (Appendix G).

Until an event such as a windstorm, disease epidemic or large fire occurs, and because there is no proposal to fell trees in natural stands, no change in the current amount or recruitment rate of down wood greater than 5” or 20” diameter in natural stands is expected. Thus the current distribution of down wood is not expected to change in natural stands.

North Nestucca Environmental Assessment Page 48

Appendix I

North Nestucca Environmental Assessment Page 49

Appendix I

F. Aquatic Conservation Strategy Objectives-Wildlife

Objective 2--Maintain and restore spatial and temporal connectivity within and between watersheds. Lateral, longitudinal, and drainage network connections include floodplains, wetlands, upslope areas, headwater tributaries, and intact refugia. These network connections must provide chemically and physically unobstructed routes to areas critical for fulfilling life- history requirements of aquatic and riparian-dependent species. Proposed activities would not sever existing connections between essential habitats and among watersheds. The physical nature of existing movement corridors will remain unchanged. Objective 9--Maintain and restore habitat to support well-distributed populations of native plant, invertebrate, and vertebrate riparian-dependent species. Proposed activities are designed to reduce the influence of invasive species on native habitats, thus will have a beneficial effect on riparian-dependent species.

North Nestucca Environmental Assessment Page 50

Appendix I

Working References: Altman, Bob, 1999. Conservation strategy for landbirds in coniferous forests of western Oregon and Washington, Version 1.0: Oregon-Washington Partners in Flight. Altman, Bob, Hagar, Joan, 2007. Rainfoest Birds: A Land Manger’s Guide to Breeding Bird Habitat in Young Conifer Forests in the Pacific Northwest, U.S. Geological Survey, Scientific Investigations Report 2006-5304, 60 p. Aubry, Keith B., Jeffrey C. Lewis. 2002. Extirpation and reintroduction of fishers (Martes pennanti) in Oregon: implications for their conservation in the Pacific states. Biological Conservation 114 (2003) 79- 90. Brown, E. Reade (ed). 1985. Management of Wildlife and Fish Habitats in Forests of Western Oregon and Washington (two volumes). USDA Forest Service, Pacific Northwest Region. Publication No.: R6- F&WL-192-1985. Pacific Northwest Region, 319 SW Pine, PO BOX 3623, Portland, Oregon 97208. Csuti, B., T.A. O’neil, M.M. Shaughnessy, E.P. Gaines and J.C. Hak 2001. Atlas of Oregon Wildlife, Distribution, Habitat, and Natural History. OSU Press, Corvallis, OR 525 pp. Christy, R.E. and S.D. West. 1993. Biology of bats in Douglas-fir forests. In M.H. Huff, R.M. Holthausen, K.B. Aubry, tech eds. Biology and management of old-growth forests. Gen. Tech. Rep. PNW-GTR-308. USDA Forest Service, Pacific NW Res. Station. Portland, OR. Guenther, K. and T.E. Kucera. 1978. Wildlife of the Pacific Northwest: occurrence and distribution by habitat, BLM district and national forest. USDA Forest Service, Pacific NW Region. Hays, David W., Kelly R. McAllister, Scott A. Richardson, and Derek W. Stinson. 1999. Washington State Recovery Plan for the Western Pond Turtle. Washington Department of Fish and Wildlife. 66 pp. http://www.wa.gov/wdfw/wlm/diversty/soc/recovery/pondturt/wptfinal.pdf Hobbs, Stephen D, (et al.) [Editors] 2002. Forest and Stream Management in the Oregon Coast Range. OSU Press, Corvallis, OR 276 pp. Huff, Mark H.; Raphael, Martin G.; Miller, Sherri L.; Nelson, S. Kim; Baldwin, Jim, tech. coords. 2006. Northwest Forest Plan—The first 10 years (1994-2003): status andtrends of populations and nesting habitat for the marbled murrelet. Gen. Tech. Rep. PNW-GTR-650. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station. 149 p. Johnson, D.H. and T.A. O’Neil. 2001. Wildlife Habitat Relationships in Oregon and Washington. Oregon State University Press, 101 Waldo Hall, Corvallis, Oregon, 7331-6407. Lint, Joseph, tech. coord. 2005. Northwest Forest Plan—the first 10 years (1994–2003): status and trends of northern spotted owl populations and habitat. Gen. Tech. Rep. PNW-GTR-648. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station. 176 p. Lofroth, E. C., C. M. Raley, J. M. Higley, R. L. Truex, J. S. Yaeger, J. S. Yaeger, J. C. Lewis, P. J. Happe, L. L. Finley, R. H. Naney, L. J. Hale, A. L. Krause, S. A. Livingston, A. M. Meyers, and R. N. Brown. 2010. Conservation of Fishers (Martes pennant) in South-Central British Columbia, Western Washingtin, Western Oregon, and California – Volume I: Conservation Assessment. USDI Bureau of Land Management, Denver, Colorado, USA. Marshall, D.B., M.G. Hunter, and A.L. Conteras, eds. 2003. Birds of Oregon: a general reference. Oregon State Univ. Press, Corvallis, OR. Maser, C. 1998. Mammals of the Pacific Northwest. Oregon State Univ. Press, Corvallis. 406 pp. Mellen-McLean, Kim, Bruce G. Marcot, Janet L. Ohmann, Karen Waddell, Susan A. Livingston, Elizabeth A. Willhite, Bruce B. Hostetler, Catherine Ogden, and Tina Dreisbach. 2009. DecAID, the decayed wood advisor for managing snags, partially dead trees, and down wood for biodiversity in forests of Washington and Oregon. Version 2.1. USDA Forest Service, Pacific Northwest Region and Pacific North Nestucca Environmental Assessment Page 51

Appendix I

Northwest Research Station; USDI Fish and Wildlife Service, Oregon State Office; Portland, Oregon. http://www.fs.fed.us/r6/nr/wildlife/decaid/index.shtml Michel, N., D. F. DeSante, D. R. Kaschube, and M. P. Nott, 2006. The Monitoring Avian Productivity and Survivorship (MAPS) Program Annual Reports, 1989-2003. NBII/MAPS Avian Demographics Query Interface Nott, M. P., D. F. Desante, and N Michel 2007. Monitoring, Modeling and Managing Landbird Populations in Forests of the Pacific Northwest: The Application of MAPS Demographic Monitoring Data to Forest Bird Management and Conservation. http://birdpop.org/usfsr6/usfspnwr6.htm Nott, M. P., D. F. Desante, P. Pyle, and N. Michel. 2005. Managing Landbird populations in Forests of the Pacific Northwest Region Publication No. 254 of The Institute for Bird Populations. http://www.birdpop.org/usfsr6/usfspnwr6_publications.htm Oregon Natural Heritage Information Center. 2007. Rare, Threatened and Endangered Species of Oregon. Oregon Natural Heritage Information Center, Oregon StateUniversity, Portland, Oregon. 100 pp. PIF (Partners in Flight). 2005. Southern Pacific Rainforest; Priority Bird Populations and Habitats. http://www.blm.gov/wildlife/pl_93sum.htm Rich, T. D., Beardmore, C. J., Berlanga, H., Blancher, P. J., Bradstreet, M. S. W., G. S., Demarest, D. W., Dunn, E. H., Hunter, W. C., Inigo-Elias, E. E., Kennedy, J. A., Martell, A. M., Panjabi, A. O., Pashley, D. N., Rosenberg, K. B., Rustay, C. M., Wendt, J. S., Will, T. C., 2004. Partners in Flight North American Landbird Conservation Plan: Ithaca, N. Y., Cornell lab of Ornithology. http://www.partnersinflight.org Spies, T.A.; Cline, S.P. 1988. Coarse woody debris in forests and plantations of coastal Oregon. In: Maser, C.; Tarrant, R.F.; Trappe, J.M,; Franklin, J. F.; tech eds. From the Forest to the sea: a story of fallen trees. General Tech. Rep. PNW-GTR-229. Portland, OR; U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station: 5-24. Spies, T.A.; Franklin, J.F. 1991. The structure of natural young, mature and old-growth Douglas-Fir forests in Oregon and Washington. In Wildlife and Vegetation of Unmanaged Douglas-Fir Forests Gen. Tech. Rept. PNW-GTR-285. Thomas, J.W., Forsman, E. D.; Lint, J.B., [and others]. 1990. A conservation strategy for the northern spotted owl: a report of the Interagency Scientific Committee to address the conservation of the of the northern spotted owl. Portland,OR: U.S. Department of Agriculture, Forest Service; U.S. Department of the Interior, Bureau of Land management, Fish and Wildlife Service, and National Park Service. USDA. 1990. USDA Forest Service. Land and Resource Management Plan Siuslaw National Forest. Siuslaw National Forest, 4077 SW Research Way, PO Box 1148, Corvallis, OR. 97339. http://www.fs.fed.us/r6/siuslaw/projects/forestplan1990/index.shtml USDA. 1991. Forest Service Manual - FSM 2602. http://fsweb.wo.fs.fed.us/directives/fsm/2600/ 2600_zero_code USDA. 1992. Neotropical Migrants on National Forests of the Pacific Northwest. USDA, USDI. 1993. Forest Ecosystem Management: An ecological, Economic, and Social Assessment; report of the Forest Ecosystem Management Assessment Team. USDA, USDI. 1994. Final Supplemental Environmental Impact Statement and Record of Decision for Amendments to Forest Service and Bureau of Land Management Documents within the Range of the northern Spotted Owl and Standards and guidelines for Management of Habitat for Late Successional and Old Growth Forest Related Species within the Range of the Northern Spotted owl. Contact: USDA Forest Service, P.O. Box 3623, Portland, OR 97208. Northwest Forest Plan. http://www.reo.gov/library/policy/ USDA, USDI. 1994. Nestucca Watershed Analysis. Siuslaw National Forest, Corvallis OR.

North Nestucca Environmental Assessment Page 52

Appendix I

USDA, USDI. 1994. Record of decision for amendments to Forest Service and Bureau of Land Management planning documents within the range of the northern spotted owl and standards and guidelines for management of habitat for late-successional and old-growth forest related species within the range of the northern spotted owl. Portland, OR. http://www.reo.gov/library/policy/ USDA, USDI. 1998. North Coast Range Adaptive management Area Guide. Siuslaw National Forest, Corvallis, OR. USDA, USDI. 1998. Late-successional Reserve Assessment for Oregon’s Northern Coast Range Adaptive Management Area. Siuslaw National Forest, Corvallis, OR. USDA, USDI. 2001. Record of decision and standards and guidelines for amendments to the survey and manage, protection buffer, and other mitigation measures standards and guidelines. Portland, OR. USDA, USDI. 2002. Survey Protocol For Red Tree Vole – Version 2.1 http://www.or.blm.gov/surveyandmanage/SP/RedTreeVole/200210/RTV%20protocol%20revision-V.2.1- final.pdf USDA, USDI. 2003. Survey Protocol for Survey and Manage Terrestrial Mollusk Species from the Northwest Forest Plan – Version 3.0. http://www.or.blm.gov/surveyandmanage/SP/Mollusks/terrestrial/Mollusk%20document.pdf – p. 31-39. USDA, USDI. 2004. Annual Species Review of Survey and Manage species from the Northwest Forest Plan. http://www.or.blm.gov/surveyandmanage/Annual_Species_Review/2004/IM_OR_2004- 034_Table1-1.pdf USDA, USDI, 2006. Conservation Assessment for the Foothill Yellow-legged Frog (Rana boylii) in Oregon; Version 1.0 USFS/BLM. 2008. Biological Assessment FY2009 & FY2010 Activities in the North Coast Province which might Disturb Northern Spotted Owls or Marbled Murrelets. USFS/BLM. 2009. Biological Assessment of Activities proposed during FY2010-2013 in the north Coast Planning Province, Oregon which might Disturb but Are Not Likely to Adversely Affect Northern Spotted Owls or Marbled Murrelets. USFS/BLM. 2010. Biological Assessment of Habitat Modification Projects Proposed during Fiscal Years 2011 and 2012 that are Not Likely To Adversely Affect (NLAA) Northern Spotted Owls or Marbled Murrelets and their Critical Habitats. USFWS. 1989. Endangered and Threatened Wildlife and Plants; Proposed Threatened Status for the Northern Spotted Owl. Proposed Rule 54 FR 26666 http://ecos.fws.gov/docs/federal_register/fr1552.pdf USFWS. 1990. Endangered and Threatened Wildlife and Plants; Determiniation of Threatened Status for the Northern Spotted Owl. Final Rule. 55FR 26666. http://ecos.fws.gov/docs/federal_register/fr1718.pdf USFWS. 1992. Endangered and Threatened Wildlife and Pland; Final Designation of Critical habitat for the Northern Spotted Owl. Final Rule. 57FR1796. http://ecos.fws.gov/docs/federal_register/fr2008.pdf USFWS. 1992. Endangered and Threatened Wildlife and Plants; Determination of Threatened Status for the Washington, Oregon, and California population of Marbled Murrelet. Final Rule. 57 FR 45328. USFWS. 1993. . Endangered and threatened wildlife and plants; determination of threatened status for the Pacific coast populations of the western snowy plover. Final Rule 58FR12864. http://ecos.fws.gov/docs/federal_register/fr2236.pdf USFWS. 1996. Endangered and Threatened Wildlife and Plants; Final Designation of Critical Habitat for the Marbled Murrelet. Final Rule. 61 FR 26256. USFWS. 1997. Recovery plan for the threatened marbled murrelet (Brachyramphus marmoratus) in Washington, Oregon, and California. Fish and Wildlife Service, Portland, OR. 203 pp.

North Nestucca Environmental Assessment Page 53

Appendix I

USFWS. 2007. Biological Opinion and Letter of Concurrence, USDA Forest Service, USDI Bureau of Land Management, and the Coquille Indian Tribe for Programmatic Aquatic Habitat Restoration Activities in Oregon and Washington that affect ESA-Listed Fish, Wiidlife, and Plant Species and their Critical Habitats. (FWS TAILS Number 13420-2007-F-0055) Portland, OR. USFWS. 2007. Species Assessment and Listing Priority Assignment Form for Fisher-West Coast Distinct Population Segment USFWS. 2008. Birds of Conservation Concern 2008. United States Department of Interior, Fish and Wildlife Service Division of Migratory Bird Management, Arlington, Virginia. 85 pp. USFWS. 2008. Final Recovery Plan for the Northern Spotted Owl, Strix occidentalis caurina. U.S. Fish and Wildlife Service, Portland, OR. http://ecos.fws.gov/docs/recovery_plan/NSO%20Final%20Rec%20Plan%20051408_1.pdf USFWS. 2008. Endangered and Threatened Wildlife and Pland; Final Designation of Critical habitat for the Northern Spotted Owl. Final Rule. 73FR47325.USFWS. USFWS. 2008. Letter of concurrence on the Effects of Habitat Modification Activities on the Northern Spotted Owl (Strix occidentalis caurina), Marbled Murrelets (Brachyramphus marmoratus) and Critical Habitat in the North Coast Planning province, FY2009-2010, proposed by the Eugene District, Bureau of Land Managemetn, Salem District, Bureau of Land Managemetn; and theSiuslaw national forest (FWS Reference Number 13420-2008-I-0125) Portland, OR. USFWS. 2009. Consultation for activities with potential to disturb spotted owls (Strix occidentalis caurina) and marbled murrelets (Brachyramphus marmoratus) within the North Coast Planning Province for FY 2010-2013 (FWS Reference Number 13420-2009-I-0152) Portland, OR. USFWS. 2009. Final 2009 5-Year Review for the Marbled Murrelet U.S. Fish and Wildlife Service Region 1 Portland OR. USFWS. 2010. Letter of Concurrence on the Effects of Habitat Modification Activities on the Northern Spotted Owl (Strix occidentalis caurina), Marbled Murrelet (Brachyramphus marmoratus), and Critical Habitat in the North Coast Planning Province, FY 2011 – 2012, proposed by the Eugene District, Bureau of Land Management; Salem District, Bureau of Land Management; and the Siuslaw National Forest (FWS Reference Number 13420-2010-I-0105) Portland, OR.

North Nestucca Environmental Assessment Page 54