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Days Creek – South Umpqua River Harvest Plan Environmental Assessment DOI-BLM-ORWA-R050-2014-0008-EA South River Field Office, Roseburg District REVISED DRAFT Finding of No Significant Impact Introduction

The BLM signed a Record of Decision approving the Southwestern Oregon Resource Management Plan (2016 SWO ROD/RMP) on August 5, 2016. Revision of an RMP necessarily involves a transition from the application of the old RMP to the application of the new RMP. The 2016 ROD/RMP (pp. 10-12) allows the BLM to implement projects consistent with the management direction of either the 1995 RMP or the approved RMP, at the discretion of the decision maker, if the BLM began preparation of NEPA documentation prior to the effective date of the 2016 SWO ROD/RMP.

The South River Field Office began preparation of NEPA documentation prior to the effective date of the 2016 SWO ROD/RMP, as the Field Office initiated planning and NEPA documentation for this project with publication of the project in the Summer 2014 Roseburg District Quarterly Planning Update. The Days Creek – South Umpqua River Harvest Plan was designed to apply management direction from the 1995 Roseburg District Record of Decision and Resource Management Plan (ROD/RMP), which is tiered to the 1994 Roseburg District Proposed Resource Management Plan/Environmental Impact statement (1994 PRMP/EIS).

This project meets the criteria described in the 2016 SWO ROD/RMP that allows the BLM to implement projects that conform and are consistent with the 1995 ROD/RMP and does not propose actions that are prohibited by the 2016 SWO ROD/RMP (p. 11).

Overview

The Days Creek – South Umpqua River Harvest Plan Environmental Analysis (EA) considered a no action alternative (Alternative A; EA Section 2.1.), two action alternatives not carried forward (EA Section 2.5), and two action alternatives carried forward for detailed analysis (Alternatives B Modified and C; EA Sections 2.2 and 2.3.). Alternative B Modified applies upland commercial thinning to 1,301 acres in the Matrix land use allocations; variable retention harvest (VRH) on 571 acres in the General Forest Management Area land use allocation (GFMA); and commercial thinning to 433 acres in the Riparian Reserves land use allocation (RR). Alternative C applies upland commercial thinning on 1,753 acres in the Matrix land use allocations; VRH on 119 acres in the GFMA; and commercial thinning on 433 acres in the RR.

The BLM must consider both context and intensity in determining significance of the environmental effects of agency action (40 CFR 1508.27):

Context

The proposed activities are set in lands managed by the South River Field Office of the Roseburg District, Bureau of Land Management (BLM) in the Coffee Creek, Corn Creek-South Umpqua River, Saint John Creek-South Umpqua River, Days Creek, O’Shea Creek-South Umpqua River, Upper South Myrtle

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Creek, Lower South Myrtle Creek, and Judd Creek-South Umpqua River 12th-field subwatersheds1. These 12th-field subwatersheds, which collectively drain an area of approximately 138,595 acres. The BLM administers approximately 50,593 acres (37 percent) of these lands.

Alternatives B Modified and C include harvest of approximately 2,305 acres which represents approximately 1.7 percent of all lands and 4.6 percent of BLM-administered lands in the project subwatersheds. As such, the project does not bear any regional, statewide, national, or international importance.

Intensity

The Council on Environmental Quality includes the following ten considerations for evaluating intensity.

1. Impacts may be both beneficial and adverse. - 40 CFR 1508.27(b)(1)

Alternatives B Modified and C could potentially have impacts that are both beneficial and adverse, but which are not considered significant because they will be within the range and scope of those effects of timber management analyzed in the 1994 Roseburg PRMP/EIS, to which the EA is tiered, and adopted by the 1995 Roseburg ROD/RMP.

Thinning and VRH will provide timber for manufacturing that will in turn, provide a diversity of employment opportunities, wages to timber workers and employees in associated industries, and generate tax revenues for local, state, and federal governments.

Upland commercial thinning 1,301 acres (Alternative B Modified) or 1,762 (Alternative C) of densely stocked forest stands, approximately 41 to 153 years of age in 2017, will improve the health and vigor of individual trees and the stands they comprise. Thinning will enhance the commercial value of timber in the GFMA, and accelerate attainment of Aquatic Conservation Strategy objectives in the RR (EA, Sections 3.3, 3. 8, 3.9, and Appendix F). Thinning will benefit RR by increasing light infiltration, because when a stream is enclosed by a conifer canopy, the ecosystem shifts to a low-quality food base whereas a more open canopy provides greater diversity of nutrient inputs (EA, Section 3.9.2). A variety of land birds will also benefit from the establishment of diverse understory conditions (EA, Table C-1). Thinning also contributes to the annual Allowable Sale Quantity (EA, Table 2-5) and is consistent with the principles of sustained yield in suitable O&C lands.

In 2014 the age class distribution of BLM forest lands in the GFMA in the analysis area was approximately 19 percent in the 0-30 ten-year age class, 28 percent in the 40-80 ten-year age class, and 52 percent in the 90+ ten-year age class (EA, Tables 2-5 and 3-6). Due to fire exclusion and the limited amount of regeneration harvest in the analysis area over the past two decades, there has been an overall decline in the abundance of early-seral forest with a roughly equal increase in mid-seral forest and a gradual increase in mature and late-seral forest (EA, Section 3.4.1).

The desired age-class distribution for lands managed by the Roseburg District depicted in the PRMP/EIS (Chapter 4-26 & 27) reflects the entire land base managed by the District. As no regeneration harvest is scheduled or authorized in Riparian Reserves and Late-Successional Reserves, only regeneration harvest

1 The U.S. Geological Survey implemented a new numbering/naming convention for hydrologic units (HUs) such that 5th-field watersheds are now designated as 10th-field HUs; 6th-field subwatersheds as 12th-field HUs; and 7th-field drainages as 14th-field HUs. 2 DRAFT in the Matrix Allocations and the Little River Adaptive Management Area provide the opportunity to create early (0-10 years) and mid (20-40 years) stages of forest succession.

Variable retention harvest, under Alternative B Modified, will aid in the development of a more desirable and balanced age-class distribution within the GFMA as described in the PRMP/EIS (Chapter 4-26 & 27), and consistent with the management direction from the Roseburg District ROD/RMP (pp. 601 and 515), by converting up to 571 acres of 66 to 133 year-old stands to age class 0 to 10, representing approximately 1.1 percent of the land base managed by the BLM in the project subwatersheds.

This shift in age class distribution will promote development of early-successional forest habitat for pollinators, resident and migratory bird species, small mammals (EA, Section 3.4.2 and Table C-1), and large mammals (EA, Table C-1) dependent upon or associated with this successional stage of forest development.

There could be both adverse and beneficial effects on species that are prey for the northern spotted owl. Harvest will displace prey species such as flying squirrels and red tree voles that favor closed canopy forest conditions (EA, pp. 89-90, 103-111). However, populations of prey species such as woodrats and brush rabbits are expected to increase in numbers post-harvest due to development of open early-seral conditions, which could boost local prey availability if increasing numbers of these small mammals move into adjacent forest edges and interior forest stands where they become available for capture (EA, p. 89- 90).

Removal of conifer-dominated forest could impact individual land bird, invertebrate and mammal species or their habitat, however the effects are unlikely to result in the decline of populations due to the abundance of potential suitable habitat in the project subwatersheds. Created early successional habitat patches, however, will be favorable to some land bird, invertebrate, and mammal species. Increases in herbaceous growth will improve foraging habitat by providing food sources for insects which form the prey base for other species such as bats. (EA, Appendix C, pp. 196-205)

Potential beneficial or adverse effects to species listed under the Endangered Species Act, and critical habitat designated for their survival and recovery are addressed below at consideration 9.

2. The degree to which the proposed action affects public health or safety. - 40 CFR 1508.27(b)(2)

The project involves timber harvest in a rural setting, removed from urban and metropolitan areas, on a landscape of Federal and private lands principally managed for timber production, and as such is not expected to have any demonstrable effects on public health and safety.

As described in the EA (Section 3.11.1), fifty harvest units are located in the Wildland Urban Interface as defined by the West Wide Wildfire Risk Assessment Wildland Development Areas data layer. Fuels reduction actions will reduce fire risk within these areas (EA, Section 3.11.2).

There will be no cumulative or long-term effects on air quality resulting from prescribed burning as the direct and indirect effects from the projects will be local and of short duration (EA, pp. 14 and 41-42). Smoke management from pile burning will adhere to the Oregon Smoke Management Plan (EA, p. 14). As described in the EA (pp.14 and 41), pile burning will be accomplished in the autumn or winter months during unstable weather conditions when winds and atmospheric instability favor rapid smoke dispersion, and precipitation washes particulates from the air. Burning under an inversion or otherwise very stable conditions will be avoided to minimize the risk of smoke settling into the valleys or along roadways and persisting for an extended period of time. Potential impacts to air quality within one-quarter to one mile of units are expected to persist for one to three days and will be characterized by some haziness. 3 DRAFT

Broadcast burning may result in burning phases exceeding 15-20 hours. However, burning when winds and atmospheric instability favor rapid smoke dispersion will limit the duration and extent of impacts to air quality. In the event of a forecast inversion, aggressive mop-up will be employed to reduce the risk of an extended period of impacts to the local airshed. (EA, p. 14)

Herbicide use is not proposed in the Days Creek – South Umpqua River Harvest Plan EA. The BLM uses herbicides addressed by the Roseburg District Integrated Weed Control Plan (USDI/BLM 1995b). The BLM is only authorized to use herbicides for noxious weed control that generally involves the treatment of individual plants, does not allow for aerial application, and employs additional protective measures in proximity to bodies of water (EA, p. 19). The time and location of herbicide application is restricted based upon forecast weather conditions, proximity to live water and riparian areas, and proximity to residences or other places of human occupation (EA, p. 19). For these reasons, herbicide use will not be a public health or safety issue associated with this project.

3. Unique characteristics such as proximity to historic or cultural resources, park lands, prime farmlands, wetlands, wild and scenic rivers, or ecologically critical areas. - 40 CFR 1508.27(b)(3)

The BLM evaluated and inventoried cultural resources within proposed harvest units, road construction locations and the rock quarry expansion area in 2014 and 2015. Inventory efforts have been documented in cultural resource inventory report CRS#SR1413. (EA, Section 1.5.2)

Six documented sites (35DO78, 35DO370, 35DO582, 35DO679, 35DO1066, 35DO1081) and one previously undocumented site (OR-10-328) are located in the analysis area. Five of the sites have not been formally evaluated and are assumed to be eligible for listing on the National Register of Historic Places (NRHP). All of the unevaluated sites have been excluded from treatment areas. As designed, proposed activities will not affect any of these sites. Two other sites, 35DO582 and 35DO679, were evaluated prior to this analysis and are ineligible to be listed on the NRHP. Both of these sites require no further consideration.

If any objects of cultural value (e.g. historic or prehistoric ruins, graves, fossils, or artifacts) are found during the implementation of the selected alternative, operations will be suspended until the materials and site(s) have been evaluated by the District Archeologist to determine appropriate conservation measures. In this way, no cultural resources will be affected by this project. Consequently, the BLM is in compliance with Section 106 of the National Historic Preservation Act under the guidance of the 2012 National Programmatic Agreement and the 2015 Oregon Protocol. In accordance with BLM policy and legal requirements, the locations of these sites are not disclosed in public documents in order to diminish the potential for violations of the Archaeological Resources Protection Act.

As discussed in the EA (p. 13), the project area does not contain any parklands or prime farmlands. There are no Wild and Scenic River segments, either designated or proposed, in the project watersheds. Wetlands will be protected by establishment of RR, at a minimum, or by exclusion from the project. No ecologically critical areas exist in proximity to any proposed harvest units.

4. The degree to which the effects on the quality of the human environment are likely to be highly controversial. - 40 CFR 1508.27(b)(4)

The environmental effects on the quality of the human environment are within the scope of those considered in the 1994 Roseburg District PRMP/EIS. The CEQ guidelines relating to controversy refer not to the amount of public opposition or support for a project, but to a substantial dispute as to the size, nature, or effect of the action. The effects of the analyzed alternatives are well known and not 4 DRAFT scientifically controversial. The BLM has conducted timber management similar to the proposed actions across western Oregon for decades. Effects will be consistent with those documented in published literature cited in the EA, and not highly controversial, in a scientific sense. Personal dislike of the BLM implementing management direction of the Roseburg District RMP does not constitute scientific controversy.

The 1994 Roseburg District Proposed Resource Management Plan Environmental Impact Statements (1994 PRMP/EIS; USDI/BLM 1994; p. Appendices 233) projected effects for 11,875 acres of regeneration harvest in the first decade (1995-2004) and 11,193 acres of regeneration harvest in the second decade (2005-2014). In actuality, the Roseburg District offered and harvested 1,825 acres of regeneration harvest (15 percent of the projected amount of regeneration harvest) in the first decade and 194 acres of regeneration harvest (1.7 percent of the projected amount of regeneration harvest) in the second decade. Under the 1994 PRMP/EIS, the projected effects in the third decade (2015-2024) were based upon 9,808 acres of regeneration harvest. The Days Creek – South Umpqua River Harvest Plan project is one of the first projects in the third decade, and at most includes approximately 5.8 percent (Alternative B Modified) of the projected decadal regeneration harvest. Given the discrepancy between the acreage of regeneration harvest assumed within the effects analysis of PRMP/EIS and what the Roseburg District has actually implemented, it is clear that the incremental effects of the harvest proposed in the Days Creek – South Umpqua River Harvest Plan project are well within the effects of the total regeneration harvest projected in the Roseburg District PRMP/EIS.

A notice of project initiation has been published in the Roseburg District Quarterly Planning Update since June 10, 2014 informing the general public of the nature of the proposed action. (EA, Section 1.4.2)

Letters were sent to landowners with property adjacent to BLM-administered lands where timber harvest was proposed, those whose property lies beside or astride identified haul routes, and those with registered surface water rights for domestic use located within one mile downstream of any harvest units. They were encouraged to share any concerns or special knowledge of the project area that they may have. The BLM received no responses. (EA, Section 1.4.2)

Letters were sent to the Cow Creek Band of Umpqua Indians, the Coquille Indian Tribe, the Confederated Tribes of the Siletz, and the Confederated Tribes of Grand Ronde at the time of project initiation requesting identification of any special interests or legal rights in the lands in question. The BLM received no responses. (EA, Section 1.4.2, 4.1)

The BLM received scoping comments from two organizations and the BLM addressed the comments as warranted in the analysis (EA, Section 1.4.2). None of the comments identified any aspects of the project that are highly controversial, in a scientific sense.

5. The degree to which the possible effects on the human environment are highly uncertain or involve unique or unknown risks. - 40 CFR 1508.27(b) (5)

The effects on the human environment are not highly uncertain and this project does not involve unique or unknown risks as the BLM has been conducting timber management for many decades. When professional experience is paired with the substantial body of literature on the subject, there is little uncertainty regarding the effects. None of the public comments received indicate unique or unknown risks to the human environment. The environmental effects are fully analyzed in Chapter 3 of the EA.

The 2011 Northern Spotted Owl Recovery Plan discusses scientific uncertainty regarding the informational needs for active forest management to achieve the goals of forest restoration for achieving northern spotted owl recovery, specifically (1) accurate ecological baseline information, and (2) confident 5 DRAFT predictions of outcomes of actions to restore conditions, given uncertainty in climate conditions. The 2011 Recovery Plan did not state that ecological forestry should be “tested” as a way of addressing these uncertainties, but rather these uncertainties were the reason for recommending application of ecological forestry (See RPNSO at II-11, III-18) as a solution for addressing those uncertainties and as a part of ensuring the best available science (which includes the recommended practice of ecological forestry) is used to benefit ecosystems and northern spotted owls in the long term. As discussed in more detail below, this project presents no serious question as to uncertain effects regarding the use of ecological forestry within the stands included in the proposed action to benefit northern spotted owls in the long-term.

The proposed action will affect less than two percent of lands in the affected watersheds. In addition to the field reconnaissance by interdisciplinary team, stand exams were completed on all of the harvest areas, so information about existing conditions in the action area is certain.

The BLM analyzed carbon release and sequestration in detail (EA, Section 3.12 and Appendix E). Any uncertainty in local climate conditions, or even regional or global climatic conditions, does not suggest the effects are highly uncertain, or that there is a serious question on such issues because BLM has a high degree of confidence in its prediction that the proposed action will improve long-term habitat quality, complexity, and resilience to support northern spotted owl recovery due to factors in harvest prescriptions and unit design (EA, Sections 2.2.1 and 2.4).

The BLM reduced potential short-term effects of VRH on northern spotted owl suitable habitat (Alt. B Modified = 396 acres; Alt. C = 7 acres) when refining the pool of candidate units for analysis (Section 1.1), developing unit prescriptions (Section 2.2.1), and developing alternatives and project design features (Sections 2.2, 2.3, 2.4 and 2.5). The action will improve long-term habitat quality, complexity, and resilience to support northern spotted owl recovery due to several factors in harvest prescriptions and unit design (EA, Section 2.2.1). Untreated RR and aggregate retention areas along with dispersed retention trees will accelerate development of future complex habitat that will assist northern spotted owl survival in the long-term. In conclusion, the effects of the proposed action are not highly uncertain and do not present unique or unknown risks with regard to stand or habitat development.

Climate change and greenhouse gas emissions have been identified as an emerging resource concern by the Secretary of the Interior (Secretarial Order No. 3226; January 16, 2009) and the OR/WA BLM State Director (IM-OR-2010-012, January 13, 2010 (EA, Section 3.12).

The U.S. Geological Survey, in a May 14, 2008 memorandum (USDI USGS 2008) to the U.S. Fish and Wildlife Service, summarized the latest science on greenhouse gas emissions and concluded that it is currently beyond the scope of existing science to identify a specific source of greenhouse gas emissions or sequestration and designate it as the cause of specific climate impacts at a specific location. Additionally, Federal thresholds for carbon storage and release related to individual actions have not been established. However, to make informed decisions, the EA includes estimates of carbon storage and release to the analysis area. (EA, Section 3.12)

Federal thresholds for carbon storage and release related to individual actions have not been established. Uncertainty associated with all estimates of carbon storage and release in this analysis is predicted to be circa 30 percent (2008 RMP FEIS, p. 538). The direct release of carbon will be too small to lead to a detectable change in global carbon storage, and existing climate models do not have sufficient precision to reflect the effects on climate from such a small fractional change in global carbon storage (EA, Section 3.12). Alternatives B Modified and C will result in the direct release of carbon at an estimated 0.001- 0.002 percent of annual U.S. emissions and 0.0003 to 0.0005 percent of annual global emissions (EA, Section 3.12.2).

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Taking into account the continued sequestration of carbon by trees retained in thinning units, and dispersed and aggregate retention in variable retention harvest units, re-sequestration of carbon released by harvest will occur in approximately six and thirteen years. In the first 50 years, post-harvest, carbon storage will increase between 424,534 and 646,566 tonnes, an increase of between 78 to 118 percent over the current condition (EA, Section 3.12.2).

6. The degree to which the action may establish a precedent for future actions with significant effects or represents a decision in principle about a future consideration. - 40 CFR 1508.27(b)(6)

The action alternatives will implement the plan-level decision made in the 1995 ROD/RMP to manage lands in the Matrix for sustainable timber production (pp. 1 and 3), and does not establish precedent or a decision in principle about future actions.

The BLM rigorously analyzed the potential environmental consequences of Alternatives A, B Modified, and C in the EA. The future preparation, auction, and award of timber sale contracts associated with the action alternatives does not set a precedent or represent a decision in principle about future actions or considerations, as any new proposals for timber management will be subject to site-specific evaluation and analysis, consistent with the management direction in effect at the time.

7. Whether the action is related to other actions with individually insignificant impacts but cumulatively significant impacts. - 40 CFR 1508.27(b)(7)

The interdisciplinary team considered and analyzed the alternatives in the context of past, present, and reasonably foreseeable actions. No cumulatively significant effects to the following resources are predicted from implementation of the alternatives: Recreation and Off-Highway Vehicle Use, Visual Resources, Special Status and Survey and Manage Plants, Noxious Weeds, Cultural and Historical Resources (EA, Section 1.5.2); Timber Resources (EA, Sections 3.3 and 3.4); Wildlife Resources (EA, Sections 1.5.2, 3.5, 3.6, 3.7, and Appendix C); Fish, Aquatic Habitat and Water Resources (EA, Sections 1.5.2, 3.8, 3.9, Appendix F); Soils (Section 3.10); Fuels Management (EA, Section 3.11); and Carbon Storage and Release (EA, Section 3.12).

As stated previously, the 1994 PRMP/EIS and 1995 ROD/RMP predicted the amount of regeneration harvest that will occur each decade. Given that less than ten percent of the predicted regeneration harvest has been implemented to date and that the assumptions used in the 1994 PRMP/EIS for non-federal forest management continues to be representative of on the ground activities, we are well below the level of impacts authorized under the RMP. Therefore, the action in combination with other activities within the analysis area does not rise to the significance thresholds set forth in those documents.

8. The degree to which the action may adversely affect districts, sites, highways, structures, or objects listed in or eligible for listing in the National Historic Register or may cause loss or destruction of significant scientific, cultural, or historical resources. - 40 CFR 1508.27(b)(8)

As discussed above at 3, cultural resource inventories have been completed. Six documented sites (35DO78, 35DO370, 35DO582, 35DO679, 35DO1066, 35DO1081) and one previously undocumented site (OR-10-328) are located in the analysis area. As designed, proposed activities will not affect any of these sites.

If any objects of cultural value (e.g. historic or prehistoric ruins, graves, fossils, or artifacts) are found during the implementation, operations will be suspended until the materials and site(s) have been evaluated to determine any appropriate mitigation action. In this way, no cultural or historic resources will be affected by this project (EA, Section 1.5.2).

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9. The degree to which an action may adversely affect an endangered or threatened species or its habitat that has been determined to be critical under the Endangered Species Act of 1973. – 40 CFR 1508.27(b)(9)

There are no Threatened or Endangered botanical species that will be affected, as none were identified where suitable habitat exists (EA, Section 1.5.2).

The Roseburg District completed consultation with the U.S. Fish and Wildlife Service (Service) and the project complies with the Endangered Species Act. In a Biological Opinion (TAILS #: 01EOFW00-2016- F-0065, dated February 9, 2016), the Service found the proposed actions will not jeopardize the continued existence of the northern spotted owl and will not adversely modify critical habitat for the northern spotted owl.

As described in the EA (Section 1.5.2), there will be no effect to the northern spotted owl from disturbance as seasonal restrictions will be applied as described in the EA (Section 2.4.7). Effects to the northern spotted owl will be associated with the modification or removal of northern spotted owl dispersal and suitable habitat. The effects of the analyzed alternatives will be consistent with those described in the 1994 PRMP/EIS (Chapter 4-62 to 65).

Effects of the project are likely to enhance the quantity and quality of suitable northern spotted owl habitat in thinned areas by accelerating the development of older forest with structural characteristics that should support adequate levels of northern spotted owl prey as well as provide improved habitat for nesting and roosting (EA, Sections 3.3.2 and 3.4.2).

Alternative B Modified includes application of VRH in 396 acres of suitable northern spotted owl habitat, representing one percent of the available suitable habitat. Additionally, application of thinning will downgrade suitable habitat function to dispersal habitat function (Alt. B Mod. = 645 acres, Alt. C = 1,043 acres) which is two to three percent of the suitable habitat in the analysis area. Under the action alternatives, the analysis area will reduce suitable habitat from approximately 53 percent to approximately 51 percent. (EA, Section 3.5.2, Table 3-9)

Both action alternatives will remove dispersal habitat (Alt. B Mod = 166 acres; Alt. C = 112 acres), representing approximately one percent of the dispersal habitat in the analysis area (EA, Table 3-9). Dispersal habitat will be created from thinning in suitable habitat under both action alternatives (Alt. B Mod = 645, Alt. C = 1,043 acres); representing an increase of approximately one percent in the analysis area.

Variable retention harvest (Alt. B Mod = 571 acres, Alt. C = 119 acres) will create areas of retention aggregates, interspersed with areas of concentrated harvest with dispersed retention. Existing levels of canopy closure will be maintained in retention aggregates, but the total basal area of the unit will be reduced to between 20 and 30 percent (EA, Section 2.2.1), which will downgrade habitat function to capable.

The action will improve long-term habitat quality, complexity, and resilience to support northern spotted owl recovery due to factors in harvest prescriptions and unit design, including the fact that 20 to 30 percent of the basal area in VRH units will be retained (EA, Section 2.2.1). Untreated aggregate areas and dispersed retention trees will provide dispersal connectivity. The long-term creation of complex habitat will provide higher quality habitat conditions sooner than leaving the stands untreated (EA, Sections 3.3.2 and 3.5.2). Planting and stand maintenance will effectively promote the development of trees with structural features that are beneficial to northern spotted owl, especially in combination with the continued presence of older trees in untreated areas and the dispersed retention trees (EA Sections 2.2.1, 3.5.2).

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In VRH units, retained habitat components will contribute to future development of suitable habitat; providing the necessary habitat diversity such as multi-layered canopy, large trees and snags. Development of suitable habitat will occur as the stands regenerate. Treated areas will begin functioning as dispersal habitat in approximately 40 years. Suitable habitat will develop in approximately 60-80 years. (EA, Section 3.5.2).

Thinning (Alt. B Modified = 1,734 acres, Alt. C = 2,195 acres) focuses on the growth of selected trees leading to crown expansion and differentiation in dominant trees, release of shade tolerant species, and can promote development of multilayered, multi-species stand configurations, accelerating the development of suitable habitat characteristics by up to 20 years. The increase in vegetative diversity, structural heterogeneity, and fine scale variation will promote development of high quality northern spotted owl dispersal and suitable habitat. (EA, Section 3.5.2).

In thinned stands, northern spotted owl may shift use to untreated areas, leading to expansion of nonbreeding home range size, reduced use of thinned areas, and a shift in foraging and roosting areas away from thinned areas near nest trees. Expanding the home range size will require northern spotted owls to expend greater amounts of energy in foraging, as they travel longer distances in search of prey, reducing reproductive fitness (EA, Section 3.5.2).

Thinning may reduce use of the stands by northern spotted owls because of increased exposure to weather and increased risk of predation from other raptors as they move across the landscape, which will persist until the stands return to pre-thinning levels of canopy cover (EA, Section 3.5.2).

Thinning will increase tree growth, foster understory flower and fruit production and promote growth of grasses, forbs, shrubs, and hardwoods in the understory, which will provide habitat for prey species. Thinning and VRH will increase habitat for prey species associated with early- and mid-successional habitats and increase the abundance of these species, thus benefitting the northern spotted owl. The increase in early-successional habitats will be balanced by a reduction in habitat for prey species associated with older habitats. (EA, Section 3.5.2).

Proposed actions will not occur in any northern spotted owl nest patches. The BLM generally avoids harvest activities in known owl activity centers (KOACs), but 12 acres of thinning (Unit 29-03-21A) will occur in dispersal habitat in KOAC P2197 (site 2197O) under both action alternatives. The BLM has not detected northern spotted owls in Site 2197O since 2002, so effects to northern spotted owls are not expected. Dispersal habitat will be modified by thinning but function will be maintained. Thinning will accelerate development of suitable habitat. (EA, Section 3.5.2)

Both action alternatives include proposed harvest in the core area of six occupied northern spotted owl sites. Three occupied sites (0568O, 1809B, 4538O) are above the suitable habitat viability threshold at the core area scale and three sites (0247A, 0569O, 1998O) are below the threshold. The viability status of five of these sites will not change under either action alternative. (EA, Section 3.5.2)

Both action alternatives will reduce suitable habitat in the core area of site 0568O from 313 acres to 215 acres, which is below the suitable habitat viability threshold at the core area scale. Alternative B Modified removes 51 acres and downgrades 47 acres of suitable habitat in site 0568O whereas Alternative C does not remove any suitable habitat but downgrades 98 acres. Under both action alternatives, reducing suitable habitat in site 0568O below 250 acres compromises the viability of the site and use of this core area is not expected to continue in the long-term. However, the core area of site 0568O may support northern spotted owl use in the short-term. Reproduction at site 0568O has not been documented (EA, Table 3-7), and treatments in the site may reduce the potential of reproductive success in the short-term.

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The proposed actions are within the Klamath East Critical Habitat Subunit 2 (KLE-2). The EA (Table 2- 1) shows 36 units (974 acres of treatment) are located within the KLE-2 subunit. The EA (Table 3-13) summarizes the amount of critical habitat modified or removed for each action alternative. Habitat removal and modification will not affect the ability of KLE-2 to fulfill its intended role of providing landscape-level dispersal connectivity and demographic support to the local and regional spotted owl population in any meaningful measure. (USFWS 2016, p. 104).

The conservation needs of the northern spotted owl will be reduced modestly in the KLE-2 subunit and range-wide scales because the proposed action will maintain the conservation value of northern spotted owl critical habitat at each scale. The proposed activities will not appreciably diminish the conservation support function of the affected subunit or critical habitat at the Provincial and range-wide scales primarily because the project impacts will be modest relative to these scales. Proposed actions, including project design features, (EA, Sections 2.1 and 2.4) retain northern spotted owl prey habitat features and the broad distribution of actions across the landscape are likely to provide some benefits to northern spotted owls. (USFWS 2016, p. 109)

The project occurs in occupied, critical Oregon Coast coho salmon habitat in the, Days Creek-South Umpqua, and Myrtle Creek 10th-field watersheds. (EA, Appendix A – Maps).

Thinning in the outer zone of RR (up to 433 acres) will have no direct effects to fish inhabiting streams adjacent to or downstream of harvest units because there will be no direct effects to the aquatic habitat (EA, Section 3.9.2). Many of the harvest units are located along ridges, well-removed from fish-bearing streams. On fish-bearing reaches bordering harvest units, a minimum 120-foot wide “no-treatment” area, measured from the edge of the stream, will be established on both sides of the streams (EA, Section 2.4.1). The “no-treatment” areas will prevent sediment from reaching streams, and will maintain streamside shade (EA, Sections 3.9.2, Appendix F).

Based on the detailed haul route analysis, the existing locations and conditions at road/stream crossings, and application of PDFs (Section 2.4) and BMPs, wet season timber haul on gravel and paved routes will have no effect on fish species, including Oregon Coast coho salmon, Oregon Coast coho salmon critical habitat, and Bureau sensitive species. Application of sediment arresting PDFs (e.g. “no treatment” areas, filters, fences, straw bales) as described in Section 2.4 will ensure sediment is captured in ditch lines or RR and will not be transported to streams. (EA, Section 3.9.2). Under both action alternatives, there will not be a quantity of sediment generated from road management that will have the capacity to detrimentally affect the role and function of stream habitat with application of Best Management Practices (BMPs) and project design features (Section 2.4).

Variable retention harvest will not be utilized adjacent to streams occupied by Oregon Coast coho salmon. Upland thinning and VRH as proposed in the action alternatives will not affect Oregon Coast coho salmon, critical habitat for the Oregon Coast coho salmon, Essential Fish Habitat or Bureau sensitive species (EA, Sections 2.4 and 3.9.2).

Both action alternatives will have no effect on the Oregon Coast coho salmon, critical habitat for the Oregon Coast coho salmon, or Essential Fish Habitat for the Oregon Coast coho and Chinook salmon (EA, Section 3.9.2). The “no-treatment” areas in this project are wider than the buffers examined by Rashin et al. (2006), and will be completely effective at filtering any project-derived sediment before it reaches fish-bearing streams (EA, Section 3.9.2) Thinning in RR could reduce future availability of large wood as thinning will reduce the pool of trees available for future recruitment but thinning will also promote development of large trees that are sources of large functional wood in streams (EA, Section 3.9.2).

10 DRAFT

10. Whether the action threatens a violation of Federal, State. or local law or requirement imposed for the protection of the environment.- 40 CFR 1508.27(b)(10)

The action alternatives were designed in conformance with management direction from the Roseburg District Record of Decision and Resource Management Plan (1995 ROD/RMP), which itself is in conformance with all applicable laws and regulations. Furthermore, the PDFs described in the EA (Section 2.4) ensure that the proposed action complies with all applicable laws (1995 ROD/RMP, p. 5).

With respect to environmental justice, action alternatives are consistent with Executive Order 12898 which address Environmental Justice (EA, Section 1.5.2). No potential impacts to low income or minority populations have been identified by the BLM internally or through public involvement. Employment associated with the timber sales will typically involve local contractors who engage in similar work throughout Douglas County.

Correspondence with local Native American tribal governments has not identified any known, unique, or special resources in the project areas that provide religious, employment, subsistence or recreation opportunities (EA, Sections 1.4.2 and 4.1).

As discussed in the EA (Section 1.5.2), implementation of the Roseburg District Integrated Weed Management Program, in association with project design and contract provisions is expected to minimize the risk of introduction or spread of noxious weeds in association with road construction and timber harvest. Measures to be implemented may include but not be limited to mulching disturbed areas and seeding with native grasses to discourage establishment of new weed populations, and pressure washing or steam cleaning logging and road construction equipment prior to move-in to avoid introducing weeds from outside the project area. These actions are consistent with the intent and requirements of the Lacey Act; the Federal Noxious Weed Act of 1974, as amended; and Executive Order 13112, Invasive Species.

Finding

Based on the analysis of potential environmental impacts contained in the EA, I have determined that Alternative B Modified and Alternative C will not have any significant impact on the human environment within the meaning of Section I 02(2) (c) of the National Environmental Policy Act of 1969, and an environmental impact statement is not required. I have also determined that the action alternatives conform to management direction from the Record of Decision and Resource Management Plan (RODIRMP) for the Roseburg District, approved by the Oregon/Washington State Director on June 2, 1995. Furthermore, the Days Creek- South Umpqua River Harvest Plan complies with the transition language contained in the 2016 SWO ROD/RMP.

______Michael J. Korn Date Field Manager South River Field Office

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