DECISION RECORD for the OREGON GULCH FIRE SALVAGE RECOVERY PROJECT (DOI-BLM-OR-M060-2015-0004-EA)

United States Department of the Interior BUREAU OF LAND MANAGEMENT MEDFORD DISTRICT OFFICE ASHLAND RESOURCE AREA 3040 Biddle Road Medford, Oregon 97504

INTRODUCTION This document describes my decision, and reasons for my decision, regarding the selection of a course of action to be implemented for the Oregon Gulch Fire Salvage Recovery Project. The Medford District Bureau of Land Management (BLM), Ashland Resource Area, has completed the environmental analysis which is documented in the Oregon Gulch Fire Salvage Recovery Project Final Environmental Assessment (DOI-BLM-OR-M060-2015-0004-EA) (EA) for the proposed 683 acres of post-fire forest management recovery of BLM-administered land in the Oregon Gulch Fire area. Project activities will salvage standing dead trees, fire-injured trees, and hazard trees, rehabilitate sites through tree planting, and repair, maintain, and decommission road facilities on BLM-administered land. There will be a limited amount of temporary road construction (0.6 miles), to access salvage areas, which will be decommissioned after completion of harvest activities.

The Oregon Gulch Fire Salvage Recovery Project is located on lands administered by the Medford District BLM lands in the Upper Fall Creek drainage of the Iron Gate Reservoir-Klamath River fifth field watershed and the Beaver Creek drainage of the Copco Reservoir-Klamath River fifth-field watershed. The Public Land Survey System description for the project area is: T. 40 S., R. 04 E., Sec. 25 and 35; T. 41 S., R. 04 E. in Sec. 1; and T. 41 S., R. 5 E., Sec. 6, Willamette Meridian; Jackson County, Oregon.

BACKGROUND The Oregon Gulch Fire started on July 30, 2014 as a result of a lightning storm. The fire consumed about 35,302 acres with approximately 2,425 acres on public land managed by the Medford District BLM. Of the 2,425 acres consumed by the fire, 465 acres was in the Cascade-Siskiyou National Monument and the remaining 1,960 acres was on land allocated as Matrix. The Matrix land use allocation (LUA) is identified in the Medford District Resource Management Plan (RMP) as the area in which timber harvest and other silvicultural activities will be conducted with the objective to produce a sustainable supply of timber and other forest commodities (USDI 1995, p. 73). The fire burned with high intensity consuming most of the vegetation in its path and leaving a charred landscape with few trees with any green needles.

The existing condition of the burned landscape has resulted in trees that are dead and dying and are no longer on a trajectory for sustained yield. There is a need to remove the dead and dying trees and provide for a site that can support sustainable forest management in addition to conserving habitat elements as defined by the RMP. Timely salvage is critical to capture remaining merchantable timber values before further deterioration occurs. Salvaging dead or dying trees would allow the BLM to retrieve some

Oregon Gulch Fire Salvage Recovery Project Decision Record Page 1 economic value from these trees while retaining levels of coarse wood and standing snags needed to meet RMP standards and guidelines.

THE DECISION It is my decision to authorize the implementation of Alternative 2 as described in the Oregon Gulch Fire Salvage Recovery Project Final EA. This Decision authorizes the salvage harvest of approximately 683 acres on Matrix Land Use Allocation using ground-based and cable yarding systems (Maps 2-1 through 2-3). The Decision incorporates all Project Design Features (PDFs) and Best Management Practices (BMPs) as described in the Final EA, p. 2-16 through 2-25. To facilitate harvest activities, the construction of 0.6 miles of temporary road and use and maintenance of about 20 miles of existing roads will occur. The temporary routes will be decommissioned after use. In addition, 2.3 miles of existing roads will be decommissioned and 0.7 mile will be placed in long-term closure status.

Tables 1-4 provide further details on salvage units and road information for the Selected Alternative.

Table 1. Oregon Gulch Fire Salvage Recovery Project – Units by Harvest Method, Silvicultural Prescription, and Northern Spotted Owl (NSO) Habitat Harvest Silvicultural Prescription Unit No. Acres Associated Treatments Method Harvest Prescription NSO Habitat Type 1-1 49 Tractor Salvage Capable Plant w/ mixed conifers 1-2 41 Tractor Salvage Capable Plant w/ mixed conifers 25-1 61 Tractor Salvage Capable Plant w/ mixed conifers 25-2 66 Tractor Salvage Capable Plant w/ mixed conifers 25-3 116 Tractor Salvage Capable Plant w/ mixed conifers 25-4 17 Tractor Salvage Capable Plant w/ mixed conifers 25-5A 10 Cable Salvage Capable Plant w/ mixed conifers 25-5B 12 Cable Salvage Capable Plant w/ mixed conifers 35-1 132 Tractor Salvage Capable Plant w/ mixed conifers 35-2 54 Tractor Salvage Capable Plant w/ mixed conifers 35-3 54 Tractor Salvage Capable Plant w/ mixed conifers 35-4A 18 Cable Salvage Capable Plant w/ mixed conifers 35-4B 17 Cable Salvage Capable Plant w/ mixed conifers 35-4C 4 Cable Salvage Capable Plant w/ mixed conifers 35-5 32 Tractor Salvage Capable Plant w/ mixed conifers TOTAL 683

Oregon Gulch Fire Salvage Recovery Project Decision Record Page 2 Table 2. Oregon Gulch Fire Salvage Recovery Project –Temporary Road Construction and Road Renovation Approximate Length Surface Road Description Control (miles) Temp Road (41-5E-6.1) 0.50 Natural BLM Temp Spur 0.04 Natural BLM Temp Spur 0.04 Natural BLM Temp Spur 0.01 Natural BLM Road Renovation (40-4E-25.0) 0.38 Natural BLM

Table 3. Oregon Gulch Fire Salvage Recovery Project – Road Decommissioning Approximate Length Road Number Surface Control Decommission/Closure Type (miles) 40-4E-35.2 0.7 Natural BLM Fully Decommission, Mechanical 40-4E-35.1 0.2 Natural Fully Decommission, combination of BLM Mechanical and Natural Decommissioning 40-4E-26.0 0.1 Natural BLM Fully Decommission, Mechanical 40-4E-26.1 0.2 Aggregate BLM Fully Decommission, Mechanical 40-4E-25.4 0.3 Aggregate BLM Fully Decommission, Mechanical 40-4E-25.5 0.2 Natural BLM Fully Decommission, Natural 40-4E-25.2 0.1 Natural Fully Decommission, combination of BLM Mechanical and Natural Decommissioning Jeep Road 0.5 Natural BLM Fully Decommission, Natural Total Mileage 2.3 miles

Table 4. Oregon Gulch Fire Salvage Recovery Project – Long-Term Road Closures Approximate Length Road Number Surface Control Decommission/Closure Type (miles) 40-4E-35.3 0.3 Natural BLM Long Term Closure 40-4E-25.00 0.4 Natural BLM Long Term Closure Total Mileage 0.7

Oregon Gulch Fire Salvage Recovery Project Decision Record Page 3 N Map 2-1. Oregon Gulch Fire Salvage Recovery Area w E T. 41 S. , R. 4 E., Section 1 s

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4_nit: 35-5 32 acres

Legend

Stream Buffers BLM D Private Land 11 ------r-- 07

0 0.05 0.1 0.2 Miles No warra nty is made by the BLM for the accuracy, reliability, and I I I I I I I I completeness of the data. This information may not meet National Map Accuracy Standards. Oregon Gulch Fire Salvage Recovery Project Decision Record Page 4 Map 2-2. Oregon Gulch Fire Salvage Recovery Area T. 40 S., R. 4 E., Section 25

Unite- nit: 25-2 66 acres ( "\" ~ 't>

132 acres 35

0 0.05 0.1 0.2 Miles No warranty is made by the BLM for the accuracy, re~abtlity, and I I I I I completeness of the data. This infonnatJon may not meet Nauonal Map Accuracy Standards.

Oregon Gulch Fire Salvage Recovery Project Decision Record Page 5 N Map 2-3. Oregon Gulch Fire Salvage Recovery Area w E T. 40 S., R. 4 E., Section 35 s

Unit: 25~ .... 27 8 acres

Legend = Roads - Road Decommissioning - Temporary Roads c::J Proposed Salvage Units Stream Buffers - Green Tree Retention Buffer BLM D Private Land E2Z] Cascade-Siskiyou Nail. Monument

0 0.05 0.1 0.2 Miles No warranty is made by the BLM for the accuracy, reNability, and I I I I completeness of the data. This information may not meet NaHonal Map Accuracy Standards. Oregon Gulch Fire Salvage Recovery Project Decision Record Page 6 DECISION RATIONALE My decision to authorize the implementation of Alternative 2 as described in the Oregon Gulch Fire Salvage Recovery Project Final EA, and above, is based on consideration and evaluation of how well the purpose and need (Final EA, p. 1-7 to 1-9) are met, evaluation of decision factors, consideration of the environmental consequences of implementing or not implementing the Oregon Gulch Fire Salvage Project (as analyzed in the Final EA and documented in the FONSI), and review and consideration of public comments received in response to the Environmental Assessment.

RESPONSE TO PURPOSE AND NEED AND DECISION FACTORS

Matrix lands within the Oregon Gulch Fire Salvage Recovery Project Area are to provide for sustainable timber production in compliance with Oregon and California Railroad and Coos Bay Wagon Road Grant Lands Act of 1937 (O&C Act)(RMP p. 17) (Final EA p. 1-8). My Decision to authorize Alternative 2 will contribute to the sustainable supply of timber from O&C/Matrix lands through the timely salvage of fire-killed and damaged trees and replanting conifers to regenerate the forest. Both short- and long-term regeneration targets and timeframes are more likely to be met because Alternative 2 will expedite safe and effective tree planting operations and future monitoring and plantation maintenance to ensure conifer establishment and growth.

This Decision meets management direction to, “harvest only mortality above the level needed to meet snag retention and other habitat goals and provide desired levels of coarse woody debris” (RMP, p.186; Final EA, p. 1-7). Large insect infestations are not expected and the reduction of host material for the insects would limit the potential damage and prolong the standing retention of snags (Final EA, p. 3-14). Coarse woody debris would be provided in a manner that meets the needs of species and provides for ecological functions per RMP requirements and snag retention would emphasize the largest trees available to ensure their longevity and to provide the unique structure and functions associated with these large trees (RMP, p. 39).

Alternative 1 (No Action) would not meet the purpose and need for this project because the economic recovery of fire killed and damaged trees would not occur, safety hazards from standing dead trees would not be mitigated through salvage harvest, and planting would be delayed, limiting abilities to control future fire hazard or provide initial control of the site to channel resources to desired vegetation. The benefits to soil, water, and aquatic species from 2.3 miles of road decommissioning and 0.3 miles of long- term road closure would not occur (Road 40-4E-35.3). Alternative 1 would further delay reestablishing productive stands through the effective tree planting operations.

The following responds to decision factors outlined in the Final EA (p. 1-9).

1. Meeting the Guidelines for Salvage in Matrix Land The Medford District Resource Management Plan includes Timber Resource Objectives to provide for salvage harvest of timber killed or damaged by wildfire consistent with management objectives for other resources (RMP, p. 72). The Oregon Gulch Fire Salvage and Recovery Project will salvage fire killed and damaged trees, above those needed to meet snag retention and coarse woody debris (CWD) requirements of the RMP. The BLM’s approach for the retention of snag and CWD meets the requirements of the 1995 Medford District RMP (pp. 73, 75) by retaining (marked for retention) 2 snags and 120 lineal feet per acre averaged over areas no larger than 40 acres (RMP, p. 75) of CWD greater

Oregon Gulch Fire Salvage Recovery Project Decision Record Page 7 than or equal to 16 feet in length and 16 inches diameter (Final EA p. 2-22)1. The BLM focused on retaining the largest available snags along with healthy green trees. While some retention trees posing a safety hazard will need to be felled, those trees will be retained within salvage units to provide for downed coarse woody debris. Any existing downed coarse woody material would be retained on site (Final EA, p. 2-16 and 2-22).

Comments were received suggesting that salvage units should be designed to include at least the outer edges of the Riparian Reserve areas with a no-cut buffer of about 10 meters to prevent disturbance nearest the channel to minimize the potential for sediment to enter streams. The objective cited for salvaging Riparian Reserves was to facilitate the regeneration of Riparian Reserves to desirable species and structure. This action was considered but not analyzed in detail due to concern from BLM’s watershed specialists that harvest activities within Riparian Reserves could lead to increased potential for sediment to streams in an area where all Riparian Reserve vegetation was consumed by fire leaving soils exposed. Additionally, the interdisciplinary team considered the benefits to wildlife species of retaining additional snag habitat by not salvaging Riparian Reserves. Riparian Reserves are to provide for more than stabilization of stream banks and filtering of sediment, they also are to provide habitats that benefit a variety of wildlife species (RMP, p. 26). Salvage should occur in Riparian Reserves when needed to attain ACS Objectives (RMP, p. 27). As described throughout the terrestrial wildlife section of the Final EA (pp. 3-56 to 3-78), there are many wildlife species that benefit from unsalvaged snag habitat. I find that the benefit to wildlife of leaving unsalvaged snag habitat dispersed throughout the planning area outweighs the benefits of accelerating the regeneration of conifer species within Riparian Reserves and the economic benefits of increased timber salvage outputs. Tree planting may be considered in the future, dependent on the safety of site conditions, to encourage regeneration of conifer species within Riparian Reserves and achieve attainment of ACS Objectives.

Project Design Features (PDFs) were included of the design of the Oregon Gulch Fire Salvage Project (Final EA, p. 2-16 to 2-25) to provide for multiple resource objectives outlined in the Medford District RMP.

2. Contribute to Road Safety and Fire Planning within the Matrix LUA This decision meets RMP guidance to maintain a transportation system that serves the needs of users in an environmentally sound manner, and reduce minor collector and local road densities where high road densities exist. The no-action alternative was not selected because this RMP guidance would not have been met.

With the selection of Alternative 2, the construction of 0.6 miles of temporary roads and maintenance of 20 miles of road will facilitate access to harvest operations. PDFs, BMPs, and seasonal restrictions will result in no instances of chronic erosion or excessive soil displacement (Final EA, pp. 3-33 to 3-34). The decommissioning 2.3 miles of roads and placing 0.7 miles of road into long-term closure status would reduce sediment production and the open road density as well as reducing potential impacts to water quality and aquatic habitat and disturbance to wildlife.

1 It takes 7.5 pieces of >16 inch diameter material 16 feet in length in decay class 1 or 2 to meet 120 linear feet of CWD. The number of trees marked for retention to meet this requirement would vary depending on the diameter and height of trees marked for retention. For example, one tree 44 inches in diameter plus one tree 16 inches in diameter would be marked per acre to produce about 7.5 pieces 16 feet in length x 16 inches in diameter. In areas with smaller diameter trees, four 20-inch diameter trees or eight 16-inch diameter trees would need to be marked for retention to meet the CWD requirement. Oregon Gulch Fire Salvage Recovery Project Decision Record Page 8 This decision also provides for the removal of safety hazards along roads within the project area mitigating the risk posed by roadside snags to strive for providing safe travel conditions for employees, the public, contractors, fire fighters, and users with reciprocal rights and easements on roads managed by the BLM.

3. Contribute toward the District’s Allowable Sale Quantity The Oregon Gulch Fire Salvage Recovery Project is located on BLM-administered lands allocated to produce a sustainable supply of timber (the Matrix land use allocation). My decision to salvage 683 acres of matrix land will provide for economic recovery of fire-killed and fire-injured trees in compliance with the Medford District RMP Timber Resource Objectives (RMP, p. 17 and 72-73); timber salvaged will contribute an estimated 6 to 7 million board feet (MMBF) toward the District’s assigned 2015 Allowable Sale Quantity (ASQ) of 46 MMBF. By salvaging fire killed and damaged trees in excess of snag and CWD requirements, the success of reforestation is improved by reducing safety hazards in units salvaged to allow forest workers to replant sites and conduct plantation maintenance activities such as seedling survival surveys, brush control by cutting and grubbing around planted trees, inter-planting to ensure reforestation and forest growth and succession on Matrix lands in the fire area. The successful reforestation of the Oregon Gulch Fire area will support the long-term sustainable production of timber from O&C Matrix land use allocation (Final EA pp. 3-12 to 3-13, RMP p. 184).

4. Meet the BLM’s obligation to protect resources consistent with existing laws, policy, and the direction of the 1995 Record of Decision and Resource Management Plan.

This decision is also in conformance with the direction given for the management of public lands in the Medford District by the Oregon and California Lands Act of 1937 (O&C Act), Federal Land Policy and Management Act of 1976 (FLPMA), the National Environmental Policy Act of 1969 (NEPA), the Endangered Species Act (ESA) of 1973, the Clean Water Act of 1987, Safe Drinking Water Act of 1974 (as amended 1986 and 1996), Clean Air Act of 1990, the National Historic Preservation Act of 1966 as amended, the Archaeological Resources Protection Act of 1979, and the Native American Graves Protection and Repatriation Act (NAGPRA) of 1990 (Final EA pp. 1-10 to 1-11) (FONSI pp. 1-11).

RESPONSE TO OTHER INFORMATION

This section addresses my rationale for selecting Alternative 2 in regard to other key issues addressed throughout project development and analysis that are not otherwise addressed above under response to Purpose and Need and Decision Factors. This is not intended to address all issues identified throughout project development and public involvement, but those issues that strongly influenced project design and this decision.

Black-backed woodpecker (BBWO) habitat

Based on my review of the Final EA, public comments, and black-backed woodpecker survey results, I have determined the Oregon Gulch Fire Salvage Recovery Project provides a balanced approach to fire salvage while also providing for the conservation of black-backed woodpeckers. While the implementation of Alternative 2 would reduce suitable nesting habitat and potentially reduce population recruitment, the effects would be local and are not expected to lead to a regional population decline or contribute to the need to list the species under ESA (Final EA, p. 3-77).

Oregon Gulch Fire Salvage Recovery Project Decision Record Page 9 The Medford BLM District will reserve 32 percent of suitable BBWO habitat within the Oregon Gulch Fire area from salvage harvesting (Final EA, p. 3-75). The Lakeview District will reserve 40 percent suitable habitat from fire salvage. Combined, the BLM is reserving 36 percent of suitable habitat from salvage harvesting within the Oregon Gulch Fire area (Final EA, p. 3-77). BLM is a cooperator in the Partners in Flight Habitat Conservation program. The Partners in Flight Conservation Strategy for Landbirds of the East Slope of the Cascade Mountains in Oregon and Washington recommend retaining 40 percent of post-fire suitable habitat in old-growth lodgepole pine (Final EA, p. 3-67). While the Partners in Flight Conservation Strategy does not have recommendations for forest types of the Oregon Gulch Fire area (Final EA p. 3-67), black- backed woodpeckers are found in most conifer forest types and are most common in stands with a high abundance of dead and dying trees, especially in stands that experienced high severity wildfire (Final EA, p. 3-66). The Partners in Flight Conservation Strategy provides valuable information; however, it is not a regulatory requirement and does not represent the policy of any agency or organization. While the 32 percent of habitat reserved on the Medford BLM (36 percent within the entire Oregon Gulch Fire area) falls short of the Partners in Flight recommended 40% retention goal, another 2,000 acres burned during the summer of 2014 in the 790 Fire located about 40 miles to the north in the Sky Lakes Wilderness. Suitable habitat within the 790 fire area would remain unsalvaged due to wilderness status. The ecoregion scale is the most appropriate scale to study impacts to migratory birds (Final EA p. 3-76). Reserve areas in the Oregon Gulch Fire, along with the 790 Fire and other wildfires that receive no salvage treatment, will provide dispersed areas across the Oregon Cascades and Klamath Mountains for BBWO nesting and population growth (Final EA p. 3-77).

In addition to reserving unsalvaged habitat, the Medford BLM conducted pre-harvest surveys to determine the presence of nesting black-backed woodpecker pairs in or near the project area. Surveys conducted in the project area during the spring nesting period of 2015 did not detect any black-backed woodpecker nest sites (Final EA, p. 3-76). Project design features require surveys in unsalvaged habitat remaining in 2016 to protect any nesting pairs that may occur during the 2016 nesting period. A seasonal restriction will be applied from March 15 (start of breeding season) until May 31st. If BBWO nest site(s) are detected, a seasonal restriction would be enforced within 0.4 miles of the site until July 31st, or until young have fledged the nest (Final EA, p. 2-22).

This combined strategy of reserving habitat and conducting surveys will ensure the Oregon Gulch Fire Salvage Recovery Project does not contribute to the need to list the black-back woodpecker under the Endangered Species Act (Final EA, p. 3-76 and 3-77) (FONSI, p. 5-6).

Coarse woody debris and snag retention

Comments were received regarding concern for maintaining adequate snags and CWD for cavity nesting species. Commenters were concerned that RMP standards of two snags per acre are not adequate because many of these snags may have to be felled for safety. As described in “Response to Purpose and Need, Meeting the Guidelines for Salvage in Matrix Land,” additional standing trees were reserved to meet coarse woody debris requirements. It is assumed and preferred that some standing trees are felled to restore downed CWD within burned areas that are planned for salvage (Final EA p. 2-22). Additionally, Riparian Reserves (about 97 acres previously forested), the green tree retention area (about 20 acres), and other isolated or low density snag areas that remain unsalvaged are intermingled among units planned for salvage. These unsalvaged areas also contribute to meeting snag retention objectives that are to be averaged across areas no larger than 40 acres in size (RMP, p. 75). I am confident that snag

Oregon Gulch Fire Salvage Recovery Project Decision Record Page 10 retention requirements of the Medford District RMP will be met. Any snags or standing dead trees (reserved to meet CWD requirements) that must be felled for safety will contribute to restoring downed CWD for wildlife and soil benefits.

Water Quality and Hydrology Comments concerning impacts to water quality from increased sedimentation as a result of the implementation of three temporary spur roads (about 0.1 mile total) within Riparian Reserves. The Medford District RMP does allow for the construction of roads and landings within Riparian Reserves, although roads and landings should be minimized and designed to maintain Riparian Reserve function (RMP, p. 28). The reason there is a need to construct temporary spurs within Riparian Reserves is because the existing roads that access portions of Units 25-4, 35-1, and 35-5 are already located within Riparian Reserves and there will be less disturbance in Riparian Reserves by constructing short spurs to have log landings located outside of Riparian Reserves (Final EA, p. 3-45). The implementation of Alternative 2, including the construction and decommissioning of three temporary spur roads within Riparian Reserves would not have adverse impacts to water quality or Riparian Reserve Function because:

1. The temporary spurs are located within Riparian Reserves of short-duration intermittent streams with flows less than 30 days of the year (Final EA, p. 3-45). 2. Required Project Design Features incorporate Best Management Practices including constructing, using, decommissioning the road during the dry season to prevent the offsite transport of sediment and mulching and stabilizing disturbed soils prior to onset of fall rains (Final EA, p. 3-45). 3. The temporary spurs would have no direct hydrologic connectivity to active waterways and since they would be rehabilitated before the onset of fall rains, there would be no surface flow to the streams from the construction, use, or decommissioning to contribute sediment to streams (Final EA, p. 3-45). 4. None of the temporary Riparian Reserve spurs cross the stream channels, they are on the opposite side of the existing roads separating the new temporary construction from the existing channel. (Final EA, p. 3-45). 5. Any snags within the Riparian Reserve that needs to be felled for safety and operations would be retained within the Reserve for downed CWD (Final EA, p. 2-17).

There is also a potential for increased sediment due to log hauling on roads in close proximity to streams. However, with project design features such as requiring dry season (generally May 15th to October 15th) maintenance and use on natural surfaced roads and no hauling on adequately rocked roads between November 15th to May 15th (Final EA, pp. 2-19 to 2-20), any increases of sediment are not anticipated to be discernable above background levels (Final EA, pp. 3- 46 and 3-52).

Municipal water rights are held by the City of Yreka California for waters in Fall Creek would not be adversely affected by either Alternative. The water intake for the pumping station for the City of Yreka is over six miles away and outside of the Oregon Gulch Fire Salvage Recovery Analysis Area. Under the No Action Alternative, there will likely be episodic transport of sediment from headwater streams to Fall Creek during high intensity storm events for 3 to 5 years following the fire. However, the potential for the transport of sediment from the analysis area to the water intake is low because of the sediment storage capacity in the low gradient sections of Fall Creek within and downstream of the Analysis Area, the six mile distance to the intake, and the porosity of the rocky soils found in much of the Analysis Area, which provide for soil stability during vegetation recovery (Final EA, p. 3-41).

Oregon Gulch Fire Salvage Recovery Project Decision Record Page 11

The selection of Alternative 2 would not increase the timing or magnitude of peak flows beyond what may already occur as a result of the wildfire. This is because there would be no net increase in areas compacted with the implementation of required project design features (i.e., ground- based yarding would only occur from designated skid trails approved by the BLM and existing skid trails would be used to the extent practical) and there would be no reduction in canopy cover as all areas proposed for salvage had canopy already removed by the Oregon Gulch Fire (Final EA, p. 3-44). Following the completion of harvest activities, skid trails would be ripped to decompact soils to the extent allowed in rocky soil conditions (Final EA, p. 3-25 to 3-26).

Based on analysis documented in the Final EA, I find the Oregon Gulch Fire Salvage Recovery Project will not adversely impact water quality, and is compliant with the Safe Drinking Water Act, the Clean Water Act, and the 1995 Medford District RMP.

Soils The implementation of Alternative 2 requires the application of Best Management Practices (BMPs) as described in the Medford District Resource Management Plan (USDI 1995, p.166) such as the use of designated skid trails and the use of existing skid trails within stands to limit horizontal soil compaction to less than 12% of the harvest area.

Because of the loss of surface organic material and vegetation from the Oregon Gulch Fire area, there was an elevated concern for use of mechanized equipment such as feller bunchers off of designated skid trails. The concern is that organic material that would normally provide a buffer to protect soils from compaction and displacement is not present and therefore, in order to meet the RMP requirement of limiting compaction to 12% of the harvest area, equipment needs to be limited to designated skid trails.

Comments were received requesting consideration of feller bunchers off of designated skid trails. Literature submitted in support of wider use of feller bunchers and follow-up soil ripping was evaluated by the BLM soil scientist and hydrologist. The study (James 2014) evaluated soil erosion following the first winter season after the Ponderosa Fire. It is not comparable to the Oregon Gulch Fire area. The soil textures in the study area (Battle Creek watershed, northern California) range from sandy loam to loamy sand with depth. Coarse textured soils such as these tend to be more prone to hydrophobicity due to larger pores which can transmit heat and gas more readily than finer-textured soils with smaller micropores (NRCS 2000). Soil textures in the Oregon Gulch Fire area range from loams, to clay loams with a varying rock component. These soils are finer textures than those in the study area. Therefore, they are expected to have a lower potential for soil hydrophobicity and thus, less likely to experience the surface runoff in the first rainfall post-fire.

Additionally, slopes in the study area are not all the same between the different treatments. In general, the slope of the, “control” sites are 40%, whereas the slope of the “logged” sites are 18%. Slope is a major factor in determining the potential of soil loss. The steeper slope of the control may have been a variable which contributed to the extra soil loss.

Oregon Gulch Fire Salvage Recovery Project Decision Record Page 12 decompaction in some areas, the combination of requiring designated skid trails and follow-up ripping of skid trails, landings, and temporary roads is expected to ameliorate compaction and revegetation naturally or through artificial planting will further accelerate rehabilitation of soil resources. Waterbars, mulching, and seeding disturbed soils will reduce the potential for erosion and sedimentation.

The study did not address soil compaction or site productivity after feller buncher treatments and therefore, there no way to confirm whether the treatments (salvage-logging with mechanized equipment followed by subsoiling) achieved the RMP requirement limiting horizontal compaction to 12% of the harvest area.

Furthermore, based on the environmental analysis documented in the Oregon Gulch Final Environmental Assessment, a Finding of No Significant Impact (FONSI) was completed for this project. There will be no significant impacts resulting from the implementation of this decision (FONSI pp. 2-9).

PUBLIC INVOLVEMENT A scoping letter briefly describing the Proposed Action and inviting comments was mailed to adjacent landowners, interested individuals, organizations, and other agencies on October 10, 2014. During the public scoping process the BLM received four written comment letters regarding the proposed project. The BLM interdisciplinary team of resource specialists reviewed public input received, and identified relevant issues to be addressed during the environmental analysis.

On October 29, 2014, the BLM held a public field trip to the Project Area to review the project proposal, visit sample units, and to provide an understanding of the overall magnitude of the wildfire. Five members of the public attended the field trip.

The Oregon Gulch Fire Salvage Recovery Project EA was completed on January 23, 2015 and made available for public review on the BLM’s Medford District website, through publication of a legal notice in the Medford Mail Tribune newspaper, and at the Medford District BLM office to all individuals for a 30-day public comment period. The EA was also sent to those who responded to the scoping letter or requested to be kept informed about the project. The EA public review period ended on February 23, 2015. Written comments received in response to the EA were reviewed and substantive comments have been addressed in Appendix A, Response to Comments.

MONITORING Implementation monitoring is accomplished through the BLM’s contract administration process. Project Design Features included in the project description are carried forward into contracts as required contract specifications. BLM contract administrators and inspectors monitor the daily operations of contractors to ensure that contract specifications are implemented as designed. If work is not being implemented according to contract specifications, contractors are ordered to correct any deficiencies. Timber sale contract work could be shut down if infractions of the contract are severe. The contract violations would need to be corrected before the contractor would be able to continue work. If contract violations are blatant, restitution could be required.

Oregon Gulch Fire Salvage Recovery Project Decision Record Page 13 CONSULTATION AND COORDINATION Habitat assessments completed by the BLM in 2014 determined that there is no habitat remaining for the northern spotted owl or the Pacific fisher. Therefore; there would be no effects to either of these species and no consultation was required (Final EA, p. 1-10, 3-73, 3-74).

The gray wolf is a federally listed species in Oregon west of Highways 395 and 78. The Oregon Department of Fish and Wildlife (ODFW) updated the known wolf activity maps for the only known gray wolves in western Oregon on January 27, 2015. The Area Known Wolf Activity (AKWA) for OR-7, his mate, and pups (Rogue Pack) is no longer in the Oregon Gulch Fire Salvage Recovery project area. ODFW identified a second AKWA that covers approximately 177,380 acres. This area is the Keno AKWA. ODFW has only indicated that two wolves are present but their sex and reproductive status is unknown. The Oregon Gulch Fire Salvage Recovery Project area covers about 0.02 percent of the Keno AKWA. Currently, effects from this project are not expected because the proposed activities would not disturb key wolf areas such as known den sites and rendezvous sites, would not change prey availability, would not increase public access to areas known to be used for denning and rendezvous sites, and no effects from disturbance are expected. Communication between U.S. Fish and Wildlife Service, Oregon Department of Fish and Wildlife, and the BLM would occur to prior to project implementation to determine if any wolf activity (rendezvous sites, denning activity, etc.) is present in the Project Area. If wolves are found to be denning in or adjacent to the project area, activities would be suspended to allow BLM to assess the situation and complete any additional NEPA or Section 7 consultation that may be required. Project Design Features would prohibit forest management activities within 1.0 mile of any active gray wolf dens or rendezvous sites, if discovered, from April 15th through August 31st (Final EA, p. 2-23). ODFW was contacted in June 2015 and there is no new information that would trigger the need to reassess the project or implement seasonal restrictions outlined above (personal communication with BLMs District Wildlife Biologist).

The Project Area is outside the range of any Federally-listed T&E plant species. Therefore, there would be no effect on these species as a result of implementing this alternative (Final EA, p. 3-79).

There are no Threatened or Endangered fish species or their habitats in the Analysis Area or within the greater watersheds. Therefore, there is no designated critical or essential fish habitat (Final EA, p. 3-48) and no consultation with the National Oceanic and Atmospheric Administration or the USFWS is required under Section 7 of the ESA.

In accordance with the Protocol for Managing Cultural Resources on Lands Administered by the BLM and the National Historic Preservation Act of 1966 (specifically, section 106), as amended, a literature review and archaeological reconnaissance was conducted for the Oregon Gulch Fire Salvage Recovery Project Area. The Oregon Gulch Fire Salvage Recovery Project was reviewed for the potential for adverse impacts to cultural resources.

Sites within the Projects Area of Potential Effect (APE) would be protected during project implementation unless determined to be not eligible to the National Register of Historic Places with concurrence from the State Historic Preservation Office (SHPO). Proposed management direction includes protecting and managing the integrity of all historic/prehistoric sites identified in the cultural survey. The minimum level of protection for sites is avoidance. This includes timber removal, tree planting, and road work.

Oregon Gulch Fire Salvage Recovery Project Decision Record Page 14 Letters describing the Proposed Action initiating consultation with the local federally recognized Native American Tribes were sent in November 2014. Further consultation in the form of meetings, phone calls, and emails did not identify any concerns with the proposed activities.

PLAN CONFORMANCE The Oregon Gulch Fire Salvage Recovery Project is designed to be in conformance with the 1995 Medford District Record of Decision and Resource Management Plan (ROD/RMP). The 1995 Medford District RMP incorporated the Record of Decision for Amendments to Forest Service and Bureau of Land Management Planning Documents within the Range of the Northern Spotted Owl and the 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 and USDI 1994).

The Oregon Gulch Fire Salvage Recovery Project contains Project Design Features that apply Best Management Practices (BMPs) in Appendix D of the 1995 Medford District RMP (as modified by IM OR-2011-074). As designed, this project complies with Management Direction, Objectives, and Best Management Practices of the 1995 Medford District RMP.

The Oregon Gulch Fire Salvage Recovery Project is consistent with the Medford District 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). This project utilizes the December 2003 Survey and Manage species list. This list incorporates species changes and removals made as a result of the 2001, 2002, and 2003 Annual Species Reviews (ASRs) with the exception of the red tree vole.

The Oregon Gulch Fire Salvage Recovery Project is also consistent with BLM Manual 6840 (USDI 2008), the purpose of which is to provide policy and guidance for the conservation of BLM Special Status Species and the ecosystems upon which they depend on BLM-administered lands. BLM Special Status Species include those species listed or proposed for listing under the Endangered Species Act (ESA), as well as those designated as Bureau Sensitive by the State Director. The objectives of the BLM Special Status policy are:

• To conserve and/or recover ESA-listed species and the ecosystems on which they depend so that ESA protections are no longer needed for these species; and • To initiate proactive conservation measures that reduce, or eliminate, threats to Bureau Sensitive species to minimize the likelihood of and need for listing of these species under the ESA (USDI 2008, Section .02).

Oregon Gulch Fire Salvage Recovery Project Decision Record Page 15 ADMINISTRATIVE REMEDIES This decision is a Forest Management Decision. Administrative remedies are available to persons who believe that they will be adversely affected by this decision. A protest may be filed within 15 days of the publication of a Notice of Decision or Notice of Sale in the Medford Mail Tribune and Grants Pass Daily Courier newspaper.

When timber is offered for sale, a Notice of Sale will be published in the Medford Mail Tribune and Grants Pass Daily Courier. Publication of the first notice of sale establishes the effective date of the decision for those portions of this Decision Record to be implemented through a timber sale. The protest of the timber sale must be made within 15 days of the publication of the Notice of Sale.

-In accordance with the BLM Forest Management Regulations 43 CFR §5003.2 (a & c), the effective date of this decision, as it pertains to actions which are not part of an advertised timber sale is the date of publication of a Notice of Decision in the Medford Mail Tribune and and Grants Pass Daily Courier. Any protest must be made within 15 days of the publication ofNotice of Decision in the Mail Tribune or Daily Courier. Any contest of this decision should state specifically which portion or element of the decision is being protested and cite the applicable regulations.

43 CFR § 5003.3 subsection (b) states: "Protests shall be filed with the authorized officer and shall contain a written statement of reasons for protesting the decision." This precludes the acceptance of electronic mail (email) or facsimile (fax) protests. Only written and signed hard copies of protests delivered to the Medford District Office will be accepted. The Medford District Office is located at 3040 Biddle Road, Medford, Oregon.

If no protest is received by the close of business (4:30p.m.) within 15 days after publication of the Notice of Decision or Notice of Sale, the decision will become fmal. If a timely protest is received, the project decision will be reconsidered in light of the statement of reasons for the protest and other pertinent information available, and the Ashland Resource Area will issue a protest decision.

::::> Co I{~ I d-ais- Kristi1<~~~ Mastrofini Date Acting Field Manager, Ashland Resource Area Medford District, Bureau of Land Management

Oregon Gulch Fire Salvage Recovery Project Decision Record Page 16 Appendix A, Response to Comments

Written comments received in response to the Oregon Gulch Fire Salvage Recovery Project Environmental Assessment (EA) were reviewed by the interdisciplinary team and the responsible official. Substantive comments were identified and the BLM has responded to substantive comments listed below.

Substantive comments are those that: • Provide new information pertaining to the Proposed Action or an alternative; • Identify a new relevant issue or expand on an existing issue; • Identify a different way (alternative) to meet the purpose and need; • Identify a specific flaw in the analysis; • Ask a specific relevant question that can be meaningfully answered or referenced; • Identify an additional source of credible research, which if utilized, could result in different effects.

Non-substantive comments are those that: • Primarily focus on personal values or opinions; • Simply provide or identify a preference for an alternative considered; • Restate existing management direction laws or policies that were utilized in the design and analysis of the project (or provide a personal interpretation of such); • Provide comment that is considered outside of the scope of the analysis (not consistent or in compliance with current laws and policies, is not relevant to the specific project proposal, or is outside of the Responsible Official’s decision space); • Lack of sufficient specificity to support a change in the analysis or permit a meaningful response, or are composed of general or vague statements not supported by real data or research.

The following section contains substantive comments received and the BLM’s response to comments. Some comments listed below may have been received from more than one commenter. To avoid duplication, comment statements with similar content were summarized into a single comment statement. The comments and responses are intended to be explanatory in nature and, where applicable, to guide the reader towards analysis or information contained in the Environmental Assessment (EA).

NEPA – GENERAL CUMULATIVE EFFECTS ANALYSIS

Comment 1: Analyze the cumulative effects from past, ongoing, and proposed activities on Medford District BLM lands, adjacent Lakeview District BLM lands and private lands in one document including logging, fire suppression, and the impacts from the Oregon Gulch Fire. The individual and cumulative impacts of the fire, fire suppression, and post-fire logging activities should not be split into two planning documents.

Response: The scales for cumulative effects analysis were set appropriately. The scales for environmental effects analysis were selected at the level for which the adverse or beneficial effects of the Oregon Gulch Fire Salvage Recovery Project could be detected. The BLM NEPA Handbook (H-1790-1) recommends the geographic scope for analyzing cumulative will be “different for each cumulative effects issue” (p. 58). The Affected Environment Section of each affected resource in Chapter 3 sets the framework and rationale for the scale of analysis. For example, the scale of analysis for vegetation, botany, fire hazard, soils (productivity, compaction, and erosion) is the area proposed for salvage, associated road work, and a designated skidding corridor outside a unit. Collectively, this is the affected area of vegetation and where ground disturbing activities would occur to support tree establishment and

Oregon Gulch Fire Salvage Recovery Project A-1 Response to Comments

growth on BLM-managed land. However, the scale of analysis for any offsite effects to water quality, aquatic habitat, and fish from erosion has been correctly noted in the Final EA as the two seventh- fields of Upper Fall Creek and Beaver Creek Drainage where activities are proposed. The scale of analysis for wildlife is set at the appropriate spatial scale for each species’ home ranges and dispersal movements.

The Final EA describes how the fire burned across three BLM Districts (Medford, Lakeview, and Redding), the Klamath National Forest, and private lands. In California, approximately 496 acres of BLM-managed lands on the Redding District and 456 acres of public land managed by the Klamath National Forest burned. Neither the Redding BLM nor the Klamath National Forest is proposing post-fire salvage (p. 1-1). The Medford and Lakeview Districts are proposing fire salvage recovery projects. Where analysis areas overlapped both districts, the effects of each district’s fire salvage and recovery projects, falling within the same analysis area, were considered together in the cumulative effects analysis.

It is assumed that all private forest lands with merchantable timber within the Oregon Gulch Fire would be harvested within the next year. The effects of the salvage logging on private lands was considered by resource in Chapter 3 – Affected Environment and Environmental Consequences of the Final EA (pp. 3-1 to 3-89).

There is no legal statute that requires the two BLM projects to be analyzed under one environmental analysis document. The Medford and Lakeview Districts coordinated throughout the planning process, but developed separate proposals because the two districts are distinct administrative units with separate resource management plans. The effects from both fire salvage recovery projects are accounted for in the cumulative effects analysis in each environmental assessment document.

Comment 2: The BLM’s scale of analysis is arbitrary and capricious since it did not include the 0.5 miles of road construction to access Unit 1-1 in the adjacent 7th field watershed in the project analysis area.

Response: Clarification for the primary Analysis Areas for the water resources, aquatic habitat, and fish sections has been made in Chapter 3 of the Final EA (p. 3-35 and 3-48). The Oregon Gulch Fire Salvage Recovery Project is proposed primarily in the Upper Fall Creek seven-field drainage of the Iron Gate- Klamath fifth-field watershed. One 50-acre unit and 0.5 miles of temporary road construction are proposed near the ridge of the adjoining Beaver Creek seventh-field drainage of the Copco Reservoir- Klamath River fifth-field watershed. There is no causal mechanism to transfer sediment and affect aquatic resources due to their location near the ridge of the watershed boundary and these project activities are not hydrologically connected to the rest of the Copco watershed. Therefore, there is no effect to water resources from the BLM project activities in the Beaver Creek seventh-field drainage. This clarification does not change the anticipated effects to these resources as described in the EA released in January 2015 (p. 3-35 and 3-48).

NEPA – RANGE OF ALTERNATIVES

Comment 3: The BLM should have developed and considered an action alternative that would have avoided Riparian Reserve road construction.

Response: The BLM is required to include a discussion of a range of reasonable alternatives to the proposed action, alternatives which are technically and economically feasible, meet the purpose and need, and have a lesser environmental impact.

Oregon Gulch Fire Salvage Recovery Project A-2 Response to Comments

The BLM considered a range of alternatives that were not analyzed in detail in Chapter 2 (p. 2-25 and 2 29) including a no new road construction alternative. This alternative was not considered in detail because it did not meet the purpose and need of the project for timely post-fire salvage recovery and re establish healthy, growing forests for a sustainable supply of timber to (EA, p. 1-7 to 1-8) as it does not meet the RMP direction to salvage fire damaged timber (p.186, 193) and it would compromise the economic viability to treat the proposed units. The RMP directs that all silvicultural systems (forest thinning strategies) applied to achieve forest stand objectives would be economically practical (ROD/RMP p. 180; PRMP/EIS p. 2-62).

The temporary road construction in the Riparian Reserve would be less than 0.1 miles to access Units 25 4, 35-1, 35-5. Should this not occur, access to these units would require the construction of approximately ½ to ¾-acre (21,780 to 32,670 square feet) of landings in Riparian Reserves. By constructing narrow roads (about 12 foot in width) (6,336 square feet) to move the landings outside of the Riparian Reserve, disturbance is reduced in the Riparian Reserves by moving landings out of Riparian Reserves. This meets RMP direction to minimize roads and landings within Riparian Reserves in order to attain Aquatic Conservation Strategy Objectives (RMP, p. 28).

Since the BLM has considered the possible access methods into these units an adequate range of alternatives are presented in the Final EA.

TEMPORARY ROAD CONSTRUCTION: ECONOMICAL EVALUATION

Comment 4: Identify which units would become uneconomical if temporary roads are not constructed and to disclose the tradeoffs associated with limiting salvage logging to stands that can be accessed from the existing transportation system.

Response: If the proposed temporary roads were not constructed for this project, 87 acres would be inaccessible for salvage and 750 thousand board feet (MBF) would not be economically recovered. This would further delay tree planting efforts across this acreage due to the large number of snags and the associated safety concerns. The ability to meet RMP objectives to grow healthy, sustainable forest would also be delayed (Final EA, p. 3-9). Seedlings damaged by falling snags could result in higher seedling mortality. Since all host material for insect infestation would be left on site, the tree kill of residual and adjacent green trees is expected to be higher (Final EA, p. 3-10). This effect may last several years after the fire (Peterson et al. 2009).

The RMP directs that all silvicultural systems (forest thinning strategies) applied to achieve forest stand objectives would be economically practical (ROD/RMP p. 180; PRMP/EIS p. 2-62). For example, the elimination of any new road construction would have required Unit 1-1 to be helicopter yarded which would have made it uneconomical to harvest this unit otherwise accessed by proposed new temporary road construction. Helicopter logging would add $140,760 operational costs. The value of the logs at the landing for both methods would be approximately $233,305. Tractor logging with road construction would result in net gain of approximately $154,570.00. Helicopter logging without road construction would result in a net gain of approximately $13,810.00. Therefore, requiring helicopter yarding of this unit would have challenged the overall economic feasibility of the sale, and dropping the unit altogether would not have been consistent with RMP direction for managing units for sustained timber production.

Oregon Gulch Fire Salvage Recovery Project A-3 Response to Comments

TEMPORARY ROAD CONSTRUCTION: NON-POINT SOURCE POLLUTION AND AQUATIC CONSERVATION STRATEGY OBJECTIVES

Comment 5: The EA indicates that the BLM intends to meet its requirements under the Clean Water Act for non-point source pollution in part by avoiding skid trail establishment in Riparian Reserves, yet it is unclear why the BLM proposes road construction in and through Riparian Reserves.

The EA reports that wildfire has created soils with easy displacement and with increased hydrologic connectivity. Since the bulk of road related sediment occurs during the first year after construction, post- fire temporary road construction in Riparian Reserves would not meet ACS standards and guidelines of the NW Forest Plan.

Response: The Medford District RMP which incorporated the Northwest Forest Plan, allows logging and road construction in Riparian Reserves. However, projects are to be designed to minimize disturbance in Riparian Reserves to maintain the multiple functions that Riparian Reserves are designed to provide such as filtering sediment, stream bank stability, maintenance of instream flows and water quality, habitat for riparian associated species, travel corridors for upland species, etc. (RMP, p. 26). The intent of avoiding skid trail placement in Riparian Reserves is to reduce the disturbance that would be associated with of dragging logs repeatedly across the same trail, especially in a burned landscape. The use of short temporary spur roads instead of skid trails or landings within Riparian Reserves will reduce the amount of disturbance within Riparian Reserves (also refer to the response for Comment 3 above).

The temporary spur road construction (less than 0.1 miles) in the Riparian Reserves would avoid constructing three landings in the Riparian Reserves, which would have created more ground disturbance within the Reserves. In consideration of placement, length, topographic conditions, and stream type, these temporary road segments were found to have minimal potential impacts.

The interdisciplinary team (IDT) applied the Best Management Practices (BMPs) of the Medford District RMP such as erosion prevention and sediment control measures that include limiting construction, use, and decommissioning to the dry season and winterizing the roads with waterbars, appropriate drainage, and mulching if used beyond the first season. These measures are expected to prevent offsite erosion (Final EA, p. 3-31 and 3-32). Re-establishment of ground vegetation would eliminate onsite erosion in 1 3 years. The temporary spur roads would not cross the stream channel and they are located in the Riparian Reserves of short-duration intermittent streams that flow less than 30 days of the year. Thus, there is a low risk of sediment reaching any water bodies.

The Final EA completed a consistency review for the ACS (pp. 3-54 through 3-56). Since the temporary roads proposed in the Riparian Reserves would not have any stream crossings and construction, decommissioning, and use is limited to the dry season, features needed for the protection of aquatic systems would be maintained including water quality, sediment regime, and in-stream flows and the Aquatic Conservation Strategy Objectives would not be compromised. For this project, road related actions would occur during the dry season to avoid the winter season when the greatest potential for increased sediment delivery exists. The Oregon Gulch Fire Salvage and Recovery Project is compliant with the Medford District RMP (including the Aquatic Conservation Strategy Objectives) and the Clean Water Act (Final EA, pp. 3-40 to 3-48 and 3-54 to 3-56).

Oregon Gulch Fire Salvage Recovery Project A-4 Response to Comments

Comment 6: Salvage logging “impedes the recovery and restoration of aquatic systems, lowers water quality, shrinks the distribution and abundance of native aquatic species, and compromises the flow of economic benefits to human communities that depend on aquatic resources”; CWWR 1996; NRC 1996, 2002; McIntosh et al. 2000; Beschta et al. 2004.

Response: Alternative 1 (No Action) analyzed the effects of natural succession for each of the affected resources (Final EA). The noted publications are focused on natural succession and ecological restoration, which is not the primary driving element of this project. The primary land use allocation of this project is Matrix, which is to restore timber productivity on these lands and meet reforestation objectives as defined by the 1995 Medford District RMP. The Final EA explains (p. 1-1), “There is a need to remove the dead and dying trees and provide for a site that can support sustainable forest management in addition to conserving habitat elements as defined by the RMP. Salvaging dead or dying trees would allow the BLM to retrieve some economic value from these trees while retaining levels of coarse wood and standing snags needed to meet RMP standards and guidelines.”

“The design and development of the Oregon Gulch Fire Salvage Recovery Project is consistent with the goals and resource management objectives in the 1995 Medford District ROD/RMP to maintain or restore healthy, functioning ecosystems from which a sustainable production of natural resources can be provided, (Final EA, p.1-7).”

Comment 7: Develop an alternative with some degree of salvage in Riparian Reserves. If there are sedimentation concerns due to effects of the fire, restrict yarding in Riparian Reserves to dry weather conditions.

Response: The Medford District RMP does allow salvage within Riparian Reserves. In deciding whether or not to salvage in Riparian Reserves the interdisciplinary team considered the effects of disturbance within the fire burned landscape. Based on interdisciplinary team input, a management decision was made to not propose prescribed salvage in Riparian Reserves. BLM’s watershed specialists were concerned that salvage activities within Riparian Reserves could lead to increased potential for sediment to streams in an area where all Riparian Reserve vegetation was consumed by fire leaving soils exposed. Additionally, the interdisciplinary team also considered the benefits to wildlife species of retaining additional snag habitat by not salvaging in Riparian Reserves. Riparian Reserves are to provide for more than stabilization of stream banks and filtering of sediment, they also are to provide habitats that benefit a variety of wildlife species (RMP, p. 26). Salvage should occur in Riparian Reserves when needed to attain ACS Objectives (RMP, p. 27). As described throughout the terrestrial wildlife section of the Final EA (pp. 3-56 to 3-78) there are many wildlife species that benefit from unsalvaged snag habitat. While the effects from salvage yarding on the potential for erosion and sedimentation could have been mitigated through project design, there were other factors to consider related to the post-fire function of Riparian Reserves as noted above. This action was considered but not analyzed in detail and is accounted for in the range of alternatives considered (Final EA, pp. 2-28 to 2-29).

LANDING CONSTRUCTION

Comment 8: The EA should distinguish the ground disturbing effects between landings and temporary roads. Landings are often subjected to impacts that may not be present near all new road locations. Disclose and analyze the location, number, and impacts associated with landing establishment. The BLM proposes constructing temporary roads in Riparian Reserves to avoid the additional impacts associated with landing construction in the Reserves.

Response: The BLM disclosed any landing expansions or construction of new landings outside of proposed units. Those within unit boundaries were analyzed as part of the anticipated ground disturbance

Oregon Gulch Fire Salvage Recovery Project A-5 Response to Comments from salvage harvest. The anticipated effects from yarding operations are accounted for and are analyzed in the Final EA (pp. 3-26 to 3-27).

The BLM analyzed the effects of the proposed temporary road construction in Riparian Reserves and compared it to constructing landings in the Reserves. Less than 0.10 miles of temporary road is proposed under Alternative 2 to reduce the amount of disturbance in Riparian Reserves adjacent to three units. Not constructing this 0.10 mile of temporary road would have made necessary the construction of approximately ½ acre (21,780 square feet) of landings in riparian reserves. By constructing narrow roads (about 12 foot in width) (6,336 square feet) to move the landings outside of the Riparian Reserve, disturbance is reduced in the Riparian Reserve by moving landings out of Riparian Reserves (Final EA, p. 2-26).

MODERATE BURN SEVERITY

Comment 9: Distinguish the effects on resources (soils, hydrology, wildlife, and vegetation) between moderate versus high fire severity areas. Consult with the U.S. Fish and Wildlife Service for wildlife where stands experienced moderate fire intensity.

Response: Salvage harvest is proposed primarily within areas that sustained high burn severity (86.3%). Small inclusions of moderate burned severity (12.7%) are mixed inseparably within the areas selected for salvage harvest (Final EA, Map 2-A, p. 2-4). The larger aggregations of moderate and low severity burned areas within the fire perimeter were not considered for salvage harvest. Treatment areas were developed using a combination of soil and vegetation burn severity models and ground reconnaissance (Final EA, p. 2-1). The differences in effects between moderate and high severity within the proposed salvage units are not distinguishable for each of the affected resources because the areas of moderate fire severity are scattered throughout larger areas of high fire severity and are small in size (92% are less 2 acres each), see Maps 2-A and 3-1 of the Final EA. The vegetative conditions on-the-ground in areas mapped as moderate severity are indistinguishable from the areas mapped as high fire severity in the proposed units. There are high levels of tree mortality with little to no canopy cover, much of the organic matter and vegetation on the soil surface was removed, and the stands were reset to an early seral conditions (early-successional stage) (Final EA, pp. 3-7, 3-18, and 3-30).

Since the Proposed Action does not occur in spotted owl critical habitat, would not treat current owl habitat, and the other nearest known spotted owl sites would not be affected from potential noise disturbance; the Proposed Action would result in a No Effect determination. The determination not to consult with the USFWS is consistent with the BLM 6840 Special Status Species Management Policy: “If the BLM determines, after a review of the project and any interrelated or interdependent actions, that there is no reasonable likelihood that listed species are in the action area, or that there will be no direct or indirect effects to the species in the action area, the action is determined to have ‘no effect’ on listed species or critical habitat. No consultation is required under these circumstances.”

Comment 10: The BLM claims that moderately burned stands will not provide a seed source for future forest establishment. Trees within the “green tree retention area” could provide a seed source for in proposed salvage Units 25-3 and 25-4…BLM claims salvaging these units is necessary to assure plantation establishment objectives.

Response: The purpose and need for the Medford BLM Oregon Gulch Fire Salvage and Recovery Project includes multiple objectives. While one objective is to facilitate the regeneration of conifer forest through planting and reducing safety hazards, another objective is to provide for salvage harvest of timber killed or damaged by events such as wildfire, harvest only mortality above the level needed to meet snag retention, habitat goals, and to provide desired levels of coarse woody debris (RMP, p.186), and to

Oregon Gulch Fire Salvage Recovery Project A-6 Response to Comments

produce a sustainable supply of timber to provide jobs and contribute to community stability (RMP, p. 38).

The interdisciplinary team analyzed a no-action alternative that would rely on natural regeneration. The no-action scenario allows nature to take its course, which runs the risk of delaying or not achieving long- term sustained growth and yield objectives as well as meeting species diversity goals. Without conifer tree planting, re-establishment of a conifer stand through natural regeneration could be delayed for 100 years or longer (Final EA, p. 3-9) in much of the project area. The “green tree retention area,” which burned at low severity (Final EA, Map 2-A), may provide a seed source to its surrounding area; however, the reliance on natural seeding is neither guaranteed nor predictable and depends on burn severity, proximity to seed source, the variety of abiotic factors that stimulates seed proliferation and germination (moisture, temperature, wind, seedbed etc.), and biotic factors of post-fire colonization that can result in intense competition and delayed reestablishment (Final EA, p. 3-7).

As described in the Final EA (pp. 2-1, 3-7, 3-18, and 3-30), interspersed areas with moderate fire severity within the proposed units have little to no canopy or ground cover. There are few to no green trees remaining with undamaged cones in proposed units, “the Planning Area has a lack of green trees able to produce a viable cone crop (Final EA, p. 3-18).”

The BLM took a comprehensive look at the effects and consideration of the proposed action as well as no-action in order to evaluate different courses of action.

FIRE HAZARD

Comment 11: The significant cumulative impact of an increased fire hazard across the Oregon Gulch Fire area (Medford and Lakeview Districts, and on private timber industry) from plantation establishment across the fire area must be analyzed in an Environmental Impact Statement.

Response: The appropriate scale of analysis was determined by BLM’s fire and fuels specialist as the Oregon Gulch Fire Salvage and Recovery project area. This is the area potentially affected by Medford BLM’s proposal to salvage fire killed and damaged timber, and subsequently plant conifer seedlings on about 683 acres in the Oregon Gulch fire area. This is the appropriate scale because the effects of the proposed salvage and tree planting on fire hazard would not extend beyond the proposed units.

43 Code of Federal Regulations (CFR) § 46.115 states that when considering cumulative effects analysis, the agency must analyze the effects in accordance with relevant guidance issued by the Council on Environmental Quality (CEQ). The CEQ stated in this guidance that “[g]enerally, agencies can conduct an adequate cumulative effects analysis by focusing on the current aggregate effects of past actions without delving into the historical details of individual past actions.” This is because a description of the current state of the environment inherently includes the effects of past actions. The Council of Environmental Quality (CEQ) regulations define cumulative effects as “…the impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or person undertakes such actions” (40 CFR 1508.7). (Final EA, p. 3-1 to 3-2).

A large portion of the landscape was reset to an early seral condition as a result of the Oregon Gulch Wildfire. This represents the current condition and is documented as such throughout the Final Oregon Gulch Salvage and Recovery Project EA. The current condition for fire hazard within the project area is low due to high severity wildfire consuming fine fuels. The Final EA (p. 3-18) describes that little to no surface, ground, and ladder fuels are present and aerial fuels have been burned so needles and many of the small diameter limbs are absent due to the intensity of the wildfire. Existing fuel loadings in these stands

Oregon Gulch Fire Salvage Recovery Project A-7 Response to Comments

would not sustain a fire due to the absence of surface, ground, ladder, and aerial fuels. The EA analyzed the effects of the proposed fire salvage and subsequent tree planting with consideration of current condition.

The Final EA acknowledges that over time the fire hazard would increase in these stands with the growth of brush, hardwoods, and conifers, with or without salvage logging, as vegetation is re-established on the landscape (Final EA, p. 3-18).

The tree planting in the Final EA or the Emergency Stabilization and Recovery (ESR) Plan does not propose establishing conditions typically seen in single species, even spaced plantations. “Due to the natural variation of planting sites that includes rocky and/or shallow soils, fallen snags, and coarse woody debris, tree spacing will be inherently heterogeneous. Natural mortality would further contribute to variable spacing…Salvage harvesting would expedite tree planting and ensure that more fire-resilient species become established and protected from future fire (Tappeiner et al. 2007; 289, 256),” (Final EA, pp. 3-12 to 3-13). Management intervention, such as the proposed scalping or grubbing of sites 3 to 5 years after tree planting, and brushing every 3 to 5 years after that, would accelerate the development of large fire-resilient tree structure by many decades (Final EA, p. 3-13).

Fire hazard was analyzed at appropriate scale and it was determined that the effects of the proposed fire salvage and recovery project are low for the first five to 10 years. Cumulatively, from 10 to 20 years the primary effect of BLMs proposed fire salvage and recovery actions would be from establishment of conifer plantations in combination with natural shrub regrowth resulting from the wildfire. However the effects of conifer plantations when combined with shrub growth would only increase flame lengths (should a wildfire occur) by one foot when compared to the no-action alternative. Additionally, by removing excess snags (beyond those needed to support RMP objectives for wildlife and CWD) on 683 acres, the safety of firefighters and ability for direct fire suppression tactics are improved. The effects of BLM’s action which is to salvage fire killed and damaged trees and plant conifer seedlings was determined to be insignificant (FONSI, p. 2-9).

FLEXIBILITY IN USE OF LOGGING EQUIPMENT

Comment 12: The ability to yard and haul timber in winter months often makes the difference between a sale selling and not. We encourage the BLM to continue to look for ways to accommodate this.

Response: The Oregon Gulch Fire Salvage and Recovery Project does include required Project Design Features to limit operations (yarding and hauling) to the dry months (May 15th to October 15th for natural surfaced roads and May 15th to November 15th for rocked roads). However, there are stipulations included to allow logging operations and hauling to occur outside of these dates dependent on soil moisture and weather conditions. • Tractor yarding on designated skid trails would be allowed when soil moisture content is 25% or less to ensure that soil rutting or displacement beyond the trail does not occur (Final EA, p. 2 18). • Operations outside of restricted dates may occur if soil and weather conditions allow but would require a specific erosion control plan specifying measures to stabilize soils and protect water quality (e.g. rocking, waterbarring, seeding, mulching, barricading) in the event of forecasted rain anticipated to saturate soils to the extent there is potential for movement of sediment to streams (Final EA, p 2-19). • Hauling may occur if it is determined by the authorized officer with input from BLM’s engineer and hydrologist/aquatic specialist that hauling would not result in road damage or the transport

Oregon Gulch Fire Salvage Recovery Project A-8 Response to Comments

of sediment to nearby stream channels (based on soil moisture conditions, frozen conditions, or rain events) (Final EA, p. 2-20).

BLM would restrict operations only to the extent necessary to prevent excessive soil damage within units, road damage and/or off-site impacts to water quality.

Comment 13: There are opportunities to use ground equipment such as feller bunchers and processors in the units to make cable yarding more efficient. Use of processors and feller bunchers can greatly increase economic viability, and in some cases decrease disturbance by decreasing the amount of cable corridors, reduce damage to the residual stand, and provide a more even distribution of woody debris following harvest.

Response:

The implementation of Alternative 2 requires the application of Best Management Practices (BMPs) as described in the Medford District Resource Management Plan (USDI 1995, p.166) such as the use of designated skid trails and the use of existing skid trails within stands to limit horizontal soil compaction to less than 12% of the harvest area (Final EA, p. 3-25).

Aside from these differences, there may still be a potential for soil hydrophobicity (although not observed) in the Oregon Gulch project area. As this study suggests, soil surface disturbance breaks up soil hydrophobicity. There will be soil disturbance in the project area. All designated skid trails, landings (not part of existing road system) and temporary roads would be sub-soiled to reduce compaction following the completion of harvest activities. While rock may prevent full decompaction in some areas, the combination of requiring designated skid trails and follow-up ripping of skid trails, landings, and temporary roads is expected to ameliorate compaction and revegetation naturally or through artificial

Oregon Gulch Fire Salvage Recovery Project A-9 Response to Comments planting will further accelerate rehabilitation of soil resources. Waterbars, mulching, and seeding disturbed soils will reduce the potential for erosion and sedimentation.

TPCC REFORESTATION RESTRICTED

Comment 14: Since most of the project area is Timber Production Capacity Classification (TPCC) restricted for reforestation due to moisture and temperature concerns, the ability to reforest cleared and compacted Riparian Reserves and the green tree retention area adjacent to Unit 25-3 to facilitate road construction and tractor skid trails should be analyzed.

Response: The Final EA analyzed the reforestation capability from proposed activities including salvage and any associated temporary road construction on soils designated as TPCC restricted for reforestation.

The proposed tree planting and PDFs in Chapter 2 of the Final EA would protect salvaged stands’ reforestation capability. In units harvested using ground-based logging systems, the PDF to require equipment to stay on designated skid trails would markedly contribute to reforestation success. This way, at least 78% of the ground-based units would not have additional compaction effects. The 12% compacted would be subsoiled to assist in regaining productivity over time (Final EA, p. 3-27).

These PDFs include soil decompaction on skid trails, mulching, and planting after activities are complete (Final EA, p. 2-16 through 2-20).

SOIL (PRODUCTIVITY AND EROSION), SEDIMENTATION, AND PEAK FLOW IMPACTS

Comment 15: Disclose in the EA the location, acreage, and significant impacts to soils from dozer fire lines created during the Oregon Gulch Fire suppression activities. The disturbance associated with dozer fire lines causes compaction and produces sediment that has the potential to be delivered to stream systems. Ground-based logging and fuels treatment equipment, and the presence of forest roads and trails has the potential to increase sedimentation, soil compaction and alter water quality and the frequency and magnitude of peak streamflows.

Response: No dozer lines were constructed from the fire suppression activities in the units proposed for salvage (Final EA, p. 3-30). The dozer lines on private land are located on flat ridgelines, which were rehabilitated to reduce compaction and minimize any transport of sediment within the Analysis Area.

Best Management Practices and PDFs were identified and incorporated to address concerns for compaction, displacement, and erosion (Final EA p. 2-16 to 2-21). Field surveys were used to identify and defer areas that have the potential to result in chronic erosion and excessive soil displacement (such as the 25 foot no-salvage buffer placed on the dry draw down the middle of Unit 25-5) as a result of this project (Final EA, p. 3-31). As stated in the EA, “There would be no instances of chronic erosion or excessive soil displacement that would occur as a result of this project (Final EA, p. 3-34).” The magnitude and extent of soil erosion would be consistent with the impact analysis and conclusions provided in the 1994 Medford RMP EIS (Final EA, p. 3-34).

Oregon Gulch Fire Salvage Recovery Project A-10 Response to Comments

Peak streamflows are not expected to be affected by soil compaction resulting from this project because harvesting equipment is not allowed off designated skid trails, existing skid trails will be used to the extent possible, and designated skid trails and temporary roads will be decommissioned and subsoiled to decompact skid trails and temporary roads following the completion of harvest activities (Final EA, pp. 2 18 to 2-19). Another factor that can contribute to changes in peak flow is the loss of canopy cover. There will be no change in canopy cover as a result of this project because the forest canopy was already removed by the Oregon Gulch Fire (Final EA, p. 3-37, 3-48, 3-49, and 3-53).

Erosion and sediment movement are not expected to extend beyond the project area as a result of the Proposed Action with the implementation of required Project Design Features and BMPs, such as allowing operations only during the dry season, decommissioning skid trails and temporary spurs through subsoiling, not expanding existing landings into Riparian Reserves, mulching, and seeding disturbed soils prior to the onset of fall rains would greatly reduce sedimentation from reaching stream channels (Final EA, p. 3-52). Additionally, the gentle terrain within the project area is not conducive to erosion and transport of sediment (Final EA, pp. 2-20 and 3-41).

Roads used for haul are not anticipated to result in direct inputs of sediment into stream channels, since the haul routes are limited on the landscape, generally located in upland areas away from streams, and haul would be limited to dry conditions. Therefore, there would be no detectable increase in sediment to aquatic habitat “because any haul generated sediment that would migrate into stream channels would only do so during high intensity precipitation events (winter rain events), and contributions would be small amounts that would be assimilated into, and undetectable beyond, background conditions that would occur during winter rains regardless of haul. (Final EA p. 3-52).”

Comment 16: Salvage logging and associated activities (site preparation, fuel treatment, and planting) will killing understory vegetation which will significantly reduce site productivity.

Salvage logging will increase soil erosion and sedimentation through the following mechanisms, each of which must be addressed in detail in the NEPA analysis: 1. Soil disturbance, 2. damage to live and dead roots, 3. removal of organic material, 4. delay of re-vegetation, 5. construction of roads and landings, 6. increased channel erosion from peak flow caused by a. loss of large logs that help anchor snowpacks, b. mobilization of fine soil particles that seal the soil surface and increase c. loss of dead tree canopy;

See McNabb and Swanson, “Effects of Fire on Soil Erosion,” Chapter 14 in Natural and Prescribed Fire in Pacific Northwest Forests, Walstad, Radosevich, and Sandberg, editors, OSU Press.

Response: Soil productivity and compaction: The Final EA (p. 3-24 through 3-28) analyzed the anticipated effects to site productivity, which found with the application of BMPs and PDFs the magnitude of the impacts to soil compaction and productivity would remain consistent with the impact analysis and conclusions provided in the 1994 Medford RMP EIS. Each proposed Oregon Gulch Fire Salvage Recovery Project harvest unit would remain below 12% compaction and 5% productivity loss as analyzed in the 1994 Medford District FEIS RMP.

Oregon Gulch Fire Salvage Recovery Project A-11 Response to Comments

Damage to live and dead roots: Damage to live roots would be minimized through BMPs and PDFs such as intermittent subsoiling or through scarification. Dead roots may be cut during the salvage harvest but the roots would be left on site to contribute to the soil profile and stabilization.

Removal of organic material: The intensity of the fire left little to no organic material on the forest floor. The EA analyzed the effects on organic material (Final EA, p. 3-22 through 3-29) including the effects from temporary road construction and reintroducing organic material through seeding and mulching decommissioned roads, landings, skid trails, and logging corridors.

Delay of re-vegetation: The No Action Alternative would likely result in a delay of tree planting (as compared to the Proposed Action ) that would also delay watershed recovery (Final EA, pp. 3-9 and 3 14). Currently, the landscape is denuded of vegetation, putting the streams at risk for high temperatures and increased channelization of the stream beds.

Construction of roads and landings: The proposed road and landing construction are hydrologically disconnected from streams and wet areas. There would be a low risk of sediment reaching a water bodies. Erosion prevention and sediment control measures implemented during the construction and subsequent decommissioning would greatly limit any offsite soil movement (Final EA, pp. 3-31 to 3-32). These roads and landings would also be decommissioned during dry conditions and winterized with proper drainage to prevent sediment from transferring offsite.

Increased channel erosion from peak flow: A minimum of 120 linear feet of coarse woody debris per acre greater than or equal to 16 inches in diameter and 16 feet long would be left per the RMP management direction that would help anchor soil and snowpack (Final EA, p. 2-22).

There would be no noticeable increase in the magnitude or frequency of peak streamflows expected as a result of canopy cover reductions proposed under Alternative 2, since the existing canopy cover is minimal to nonexistent since the fire (Final EA, p. 3-44).

The BLM has analyzed the potential for effects as suggested above as documented in the Final EA. A Finding of No Significant Impact (FONSI) has been prepared and no significant impacts were identified.

RIPARIAN AND AQUATIC MANAGEMENT OBJECTIVES

Comment 17: Salvage logging will set back vegetation recovery that has already started and thereby slow attainment of riparian and aquatic management objectives.

Response: The salvage of fire-killed and damaged trees is expected from Matrix land allocation (RMP, pp. 72 and 186) and is the identified purpose and need for this project (Final EA p. 1-7 to 1-8). The proposed action includes a required project design feature of working from designated skid trails and the use of existing skid trails where possible to limit the extent of disturbance within harvest units to reduce increases in compaction and to reduce overall area disturbed. Skid trails, landings and temporary roads will be decommissioned and subsoiled to decompact areas following harvesting. Disturbed soils will be mulched and seeded and skidtrails and temporary roads on BLM lands will be planted with conifers to re establish the forest.

Also see responses to Comments # 5, 6, and 15 above for a discussion on attainment of the Aquatic Conservation Strategy Objectives, active versus passive restoration, and potential for effects to soil and water resources.

Oregon Gulch Fire Salvage Recovery Project A-12 Response to Comments

NORTHERN SPOTTED OWL (NSO)

Comment 18: Spotted owls may use burned forests as foraging habitat and post-fire logging is proposed in a historic spotted owl activity area. No surveys have established presence or absence of spotted owls in the project area since the Oregon Gulch fire event. Spotted owls show high rates of fidelity to established activity areas even after severe fire disturbance, and burned forests are suitable as "post-fire forage" habitat. The BLM is required to consult with the U.S. Fish and Wildlife Service to ensure that the project will avoid jeopardy to spotted owls.

Response: There is one northern spotted owl (NSO) site on BLM managed land in the perimeter of the Oregon Gulch fire, the Grizzly Mountain NSO historic site. Prior to the Oregon Gulch Fire, this site had suitable habitat (Nesting, Roosting, and Foraging (NRF)) in 8.3% of the home range and 29.2% of federal lands in the 0.5 mile core area, indicating there was a low likelihood this site was occupied prior to the fire. After the fire, the NRF habitat in the home range was reduced to less than 1%, and 0% within the 0.5 mile core area. Studies show that when less than 40 to 60% of the home range circle is in NRF habitat, the likelihood of spotted owl presence is lower, and survival and reproduction may be reduced (Thomas et al. 1990, Bart and Forsman 1992, and Dugger et al. 2005). This site is surrounded by private timberlands that have been extensively managed and much of the area is in an early-seral stage. The historic suitable NSO habitat remaining post-fire is considered capable habitat and does not currently provide dispersal, nesting, roosting, or foraging opportunities. Surveys are not necessary due to the low likelihood of occupancy. Approximately 117 acres (24%) of the 496 acres of spotted owl Dispersal habitat remains in the Planning Area; however, much of that is fragmented.

As noted by the Revised Recovery Plan for the Northern Spotted Owl (2001), there is spotted owl post- fire research that found spotted owls may use forest stands and may be affected by post-fire salvage (2011 Recovery Plan). However, the Oregon Gulch Fire burned at such a high severity that stands that were previously typed as NRF habitat before the fire do not currently meet post-fire foraging habitat and the structure suitable for foraging and protection from predators was also eliminated (Final EA, p. 3-60). The site fidelity only applies when owls are present prior to a fire and when some amount of NRF habitat exists post-fire in a mixed severity burn.

Since the Proposed Action does not occur in spotted owl critical habitat, would not treat current spotted owl habitat, and the other nearest known spotted owl sites would not be affected from potential noise disturbance, there would be no effects to spotted owls (Final EA, p. 3-73). The determination not to consult with the USFWS is consistent with the BLM 6840 Special Status Species Management Policy: “If the BLM determines, after a review of the project and any interrelated or interdependent actions, that there is no reasonable likelihood that listed species are in the action area, or that there will be no direct or indirect effects to the species in the action area, the action is determined to have ‘no effect’ on listed species or critical habitat. No consultation is required under these circumstances.”

GRAY WOLF

Comment 19: The BLM is obligated to consult under ESA on effects to gray wolf, whose presence also is presumed by the Oregon Department of Fish and Wildlife to occur in the project area.

BLM Response: Consultation is not required for the gray wolf because no effects are anticipated. The gray wolf is a federally listed species in Oregon, and is known to occur west of Highways 395 and 78. The Oregon Department of Fish and Wildlife (ODFW) updated the known wolf activity maps for gray wolves in western Oregon on January 27, 2015 and this information has been updated in the Final EA, (p. 3-63). The Area of Known Wolf Activity (AKWA) for OR-7, his mate, and pups (Rogue Pack) is no longer in the Oregon Gulch Fire Salvage Recovery project area. ODFW identified a second AKWA that

Oregon Gulch Fire Salvage Recovery Project A-13 Response to Comments

covers approximately 177,380 acres. This area is the Keno AKWA. ODFW has only indicated that two wolves are present but their sex and reproductive status is unknown. The Oregon Gulch Fire Salvage Recovery project area covers about 0.02 percent of the Keno AKWA. Currently, effects from this project are not expected because the proposed activities would not disturb key wolf areas such as known den sites and rendezvous sites, would not change prey availability, would not increase public access to areas known to be used for denning and rendezvous sites, and no effects from disturbance are expected. This updated information does not change the effects determination for the gray wolf resulting from the proposed salvage project since no effects are anticipated.

Prior to project implementation, communication between U.S. Fish and Wildlife Service, Oregon Department of Fish and Wildlife, and the BLM would occur to determine if any wolf activity is present in the Project Area. If T&E locations are present prior to or during project implementation, projects activities would be suspended and the BLM would assess the situation and apply necessary seasonal restrictions, other mitigation, and complete any additional NEPA and Section 7 consultation that is needed. The Project Design Features of the EA would prohibit forest management activities within 1.0 mile radius of active gray wolf dens and rendezvous sites, if they are identified, from April 15th through August 31st (Final EA, p. 3-74).

ODFW was contacted in June 2015 and there is no new information that would trigger the need to reassess the project or implement seasonal restrictions outlined above (personal communication with BLMs District Wildlife Biologist).

BLACK BACKED WOODPECKER (BBWO)

Comment 20: • Why are surveys are being conducted when there is no management direction to survey for the black-backed woodpecker (BBWO)? • It appears that nest trees would receive buffers; does that mean that nesting is the only form of occupancy that the RMP mandates protection for? • Why is the chosen buffer radius 0.40 miles? Where was this value derived from? We cannot find it in the RMP or EIS. Was it derived from a piece of peer reviewed literature on the BBWO; and if so which piece of literature was it?

Response: While surveys are not required, it is within the discretion of the BLM to survey for BBWO. BLM Special Status policy are to conserve and/or recover ESA-listed species and the habitats on which they depend so that ESA protections are no longer required and to implement proactive conservation measures to reduce the likelihood of the need for listing species under ESA (Final EA, p. 1-10).

The Ashland Resource Area is applying the best available science on this species as guided by the Northwest Forest Plan, Survey and Manage Record of Decisions, and other available literature and information. The 1994 Standards and Guidelines in the Northwest Forest Plan and the 2001 Survey and Management ROD management recommendations for the BBWO provide guidance to maintain baseline populations in “green” forests. The required Project Design Feature to buffer 0.4 miles around active nest sites (Final EA, p. 3-67) was derived from the California Conservation Strategy (Bond et. al 2012) as developed by The Institute for Bird Populations and California Partners in Flight.

Comment 21: The Lakeview BLM District may implement the conservation plan developed by Partners in Flight concerning post-fire snag retention for BBWO while the Ashland BLM salvage proposal will not. The cumulative and synergistic impacts of these potentially differing approaches that may affect the viability of the species must be disclosed and analyzed in an EIS.

Oregon Gulch Fire Salvage Recovery Project A-14 Response to Comments

The Lakeview District BLM acknowledges that the post-fire BBWO source population requires 3-5 years of habitat retention. As a result, the Ashland Resource Area would be precluding the nesting and reproductive needs of this sensitive species between 2-4 years.

The Lakeview BLM salvage EA concludes that “fire based periodic populations may be critical to maintaining the population in the region” (p.51), “without enough acreage in high quality recently burned forest habitat this species may not be able to persist in this region (p. 50)”, and “the burned forest [within the Oregon Gulch fire area] is a source habitat essential to the long term persistence of the regional population or species as a whole (p. 61).” By not applying the Partners in Flight conservation strategy, the Ashland Resource Area may cause BBWO populations to decline to the point where the species is listed under ESA.

Response: The Final EA notes (p. 3-66), the Medford District RMP provides for management of 100 percent of the potential population levels of BBWO in Matrix by adding an additional amount of snag retention in timber harvest units which is intended for unburned forests (RMP, p. 48).

Neither the 1994 Standards and Guidelines in the Northwest Forest Plan nor the 2001 Survey and Management ROD management recommendations for the BBWO require management for 100 percent population potential in burned areas. The intent of the guidance in both documents is to maintain baseline populations in “green” forests. The 2001 ROD encourages application of current science to inform project planning, though it does not require population outcomes or management standards for burned areas to be greater than those described for general management purposes.

The BLM is also a cooperator in The Partners in Flight (PIF) Habitat Conservation program. PIF recommends providing for 40 percent retention of post-fire BBWO habitat in old-growth lodgepole pine, but does not provide BBWO recommendations for other habitat types such as those present in the Oregon Gulch Fire area. While PIF documents provide valuable information, they are not regulatory requirements and do not represent the policies of any agency or organization. The BLM uses PIF information along with all other scientific literature to inform the effects of harvest of burned forest on the BBWO.

Using current scientific literature, BLM developed criteria for the project design that balances the needs for the BBWO with the project purpose and need, as well as other social, ecological, and economic concerns. Application of conservation strategies are project specific and will vary from project to project depending on variables on the landscape such as ownership patterns, densities and sizes of burned trees, block size of unburned and burned habitat, and distance of burned habitat to unburned habitat. Hence, the differences in variables between Klamath Falls Resource Area and the Ashland Resource Area are properly vetted in the different approaches being taken.

The Proposed Action would retain 257 acres (32%) of the suitable BBWO habitat (Final EA, p. 3-75). The remaining habitat after salvage would be scattered between six stands encompassed in an approximate two square mile area. It is unknown if this remaining habitat would support successful BBWO fledgling of young. If it would not, the potential loss to the BBWO regional population could represent 28 individuals, which is based on the potential number of birds not bred. This number would likely be lower because the loss of habitat from salvage would not preclude adult BBWOs from breeding in other fire areas, green stands, or bug-kill areas the following seasons such as burned areas of the Cascade-Siskiyou National Monument. The protection of all active nest sites would provide BBWO one full breeding season (2 if some areas are not salvaged by the end of 2015) in all acres of BBWO habitat in the Wildlife Analysis Area on the Medford District. Post-salvage, 32% of BBWO habitat in the Wildlife Analysis Area on the Medford District would remain for use by this species.

Oregon Gulch Fire Salvage Recovery Project A-15 Response to Comments

Current research indicates the most appropriate scale to study impacts to migratory birds is at the eco regional scale (California Partners in Flight 2002), which is the Cascade and Klamath Mountains in this area. When looking at the wide range and distribution (see Map 3-5, Final EA, p. 3-66) of BBWO, this loss of habitat and the potential reduction of 28 individuals into the population, the Proposed Action would not have a substantial effect to the species’ regional persistence and it would not contribute to the need to list the species under ESA.

It is worth noting the statements quoted by the commenter from the Lakeview District’s EA (p.50 and 51) and as verified by the Klamath Falls Resource Area wildlife biologist are at the regional scale and do not make conclusions regarding effects from the Ashland Resource Area project.

Comment 22: The risks associated with logging in BBWO nesting habitat cannot be known because surveys will not be completed until May. Hence the analysis about the effects of logging approximately 87% [64% based on recent protest resolution of the Lakeview District’s fire salvage decision] of BBWO nesting habitat on BLM lands is speculative and hypothetical. No information is provided regarding the timing, or results, of BBWO surveys on public lands managed by the Lakeview BLM for woodpeckers that may also use post-fire stands in the Medford District portion of the fire perimeter.

Response: As stated earlier, the BLM is managing the BBWO through the application of the Medford District RMP, standards and guidelines for retention of snag habitat (p.45, 48). While there is no requirement for the BLM to conduct pre-implementation surveys for this species, the Ashland Resource Area has opted to do so to minimize direct negative effects of nesting disturbance or the loss of individual birds from cutting an active nest tree. No salvage would occur until surveys for BBWO have been completed. The protection of all active nest sites on BLM-managed land of the Medford District would provide the BBWO one full breeding season (two if some areas are not salvaged by the end of 2015) in all acres of BBWO habitat in the Oregon Gulch fire. Post-salvage, 32% of BBWO habitat in the Wildlife Analysis Area on the Medford District would remain for use by this species (Final EA, p. 3-75). Since the EA was released, BBWO surveys were completed. No nest sites were located within the project area. A female was located on three different locations on three different site visits, but did not exhibit territorial behavior that would be expected of a nesting BBWO (Final EA, p. 3-76).

It is anticipated that 36% retention, the local BBWO population would be expected to expand above baseline levels and thus above levels anticipated if no fire had occurred (Final EA, p. 3-77). It is also worth noting that the Oregon Gulch Fire was not the only fire to occur in 2014 in the proposed Oregon Cascades/California Distinct Population Segment (DPS) for this species. “The 790 Fire burned more than 2,000 acres of conifer forest in 2014 in the bounds of the Sky Lakes Wilderness (approximately 40 miles north of the Oregon Gulch fire area). No salvage will take place in the wilderness. This and other burned areas that receive no salvage treatment will provide areas scattered across the Oregon Cascades for BBWO nesting and population growth. Thus, when the effects to BBWO from implementing Alternative 2 are added cumulatively with the other projects in the Analysis Area, salvage in the Oregon Gulch project is not anticipated to have a substantial effect on the species regional persistence (Oregon Cascades/California DPS) and would not contribute to the need to list the species under the ESA” (Final EA, p. 3-77).

Comment 23: The analysis of the Oregon Gulch EA arbitrarily shifts between the Medford BLM project area, the Medford BLM fire perimeter, and the entire fire perimeter. Unlike most of the analysis in the EA, the section on BBWO defines the scale of effects analysis as the entire 35,000-acre fire perimeter. Page 3-72 of the EA states a total of 87% [64% based on recent protest resolution of the Lakeview District’s fire salvage decision] of the available BBWO nesting habitat within the fire perimeter may be removed. The scale of this habitat removal and the BLM’s decision to look at impacts across the fire area

Oregon Gulch Fire Salvage Recovery Project A-16 Response to Comments

show the need for an EIS to disclose the significant cumulative impacts associated with removing nearly 90% [64%] of the habitat for this at-risk species.

The EA overlooks foreseeable cumulative effects to BBWO that may result from the proposed action concurrent with undisclosed effects of post-fire logging on adjacent federal actions and private lands in the Oregon Gulch fire area.

Response: As described earlier in the response to comments (1, 2, 11 and 21), the scales for environmental effects analysis were selected at the level for which the adverse or beneficial effects of the Oregon Gulch Fire Salvage Recovery Project could be detected. The effects scale for the BBWO included the entire boundary of the Oregon Gulch fire (35,302 acres) since this species is dependent on forest stand disturbance such as high severity wildfires. The Final EA included the effects on the BBWO from foreseeable activities on private and federal lands within this boundary.

The Final EA (p. 3-77) anticipated that private lands are not expected to provide high quality habitat for cavity nesting species since they are managed intensively for timber production, were early successional stands, or had low tree density conditions before the fire.

Please see response to Comment 21, regarding the context of the potential removal of 64% of available BBWO nesting habitat. Thus, when the effects to BBWO from implementing Alternative 2 are added cumulatively with the other projects in the Analysis Area is not anticipated to have a substantial effect on the species regional persistence (Oregon Cascades/California DPS) and would not contribute to the need to list the species under the ESA” (Final EA, p. 3-76). Therefore, the evidence does not support the assumption that there would be significant impacts to the species or the need for analysis in an environmental impact statement.

BATS

Comment 24: Bats find favorable habitat in burned areas with abundant and diverse snags and abundant and diverse flying insects. Salvage logging will remove potential roost sites, and food sources (Bat Conservation International (2013)).

Response: The Final EA considered the potential effects to bat species known or suspected in the Planning Area for this project. Pallid bats have not been confirmed in the Project Area, but they could be present and there is a single fringed myotis bat documented in the Planning Area (p. 3-65).

“The Proposed Action is not expected to adversely affect local bat populations or long-term population viability of any bat species in the Planning Area. Live trees killed by the fire would be expected to be harvested prior to developing the loose bark or cavity character most utilized by bats for roosting. In addition, on Medford BLM land in the Planning Area that experienced moderate to severe fire intensity in forest stands, 32% would be retained and unharvested (Final EA, p. 3-75) as well as 2 snags per acre would be marked for retention and an additional 120 linear feet of fire killed trees would be retained. Existing non-hazardous older decay class snags would be retained where available and protected to the greatest extent possible from disturbance. Because adequate habitat would remain post-harvest, the Proposed Action would have minimal negative effects and no negative cumulative effects are expected for these species that would increase the need to list as threatened (EA, p. 3-75).”

Additionally, there are 1,028 acres of BLM land in the Medford District that burned at moderate and high severity during the Oregon Gulch Fire that will not be salvage harvested and 2,000 acres of the Sky Lake Wilderness from the 790 Fire that burned in 2014 that will also provide habitat for these bats species in areas where snags were created. Since bats are not dependent solely of fire-killed snags, natural

Oregon Gulch Fire Salvage Recovery Project A-17 Response to Comments

undisturbed areas provide habitat throughout the Cascade-Siskiyou National Monument and Soda Mountain Wilderness. Snags would also be retained at the landscape scale in unharvested Riparian Reserves and the green tree retention areas in the Planning Area.

YELLOW-BILLED CUCKOO

Comment 25: The possibility of yellow-billed cuckoo presence in riparian areas that may be affected by road construction and salvage logging is not considered.

Response: The yellow-billed cuckoo is not a Bureau Special Status species, U.S. Fish and Wildlife Service Bird of Conservation Concern or a species with any other federal management status. It is not known or suspected to occur within the Planning Area (Table 3-4, Final EA, p. 3-58). Additionally, activities within Riparian Reserves will be very limited and the proposed temporary road construction is less than 0.1 miles.

BIRDS

Comment 26: In the northwestern United States, a number of bird species thought to be strongly associated with early-seral broadleaf habitat have declined and are considered conservation priorities; Altman (1999), U.S. Fish and Wildlife Service (2002). “Because the Pacific Northwest represents a substantial portion of the ranges of these species, loss of quality early-seral habitat could increase risk of extinction”; M.G. Betts, J.C. Hagar, J.W. Rivers, J.D. Alexander, K. McGarigal, and B.C. McComb (2010).

Response: The Oregon Gulch Fire Salvage Recovery Project proposes salvaging fire-killed conifers, not removing broadleaf vegetation (Final EA, p. 2-22). Additionally, of the 2,425 acres of public land consumed by the fire on the Medford District, only 863 acres are proposed for salvage harvest. The remaining 1,562 acres of unsalvaged burn area will provide additional hardwood/broadleaf habitat within the Planning Area. There are approximately 97 acres of Riparian Reserves within the proposed harvest units that were previously forested. Due to the severity of the fire, they may not currently contain broadleaf habitat, but may in the future as the vegetation recovers.

The BLM manages for bird species that use broadleaf habitat through the Migratory Bird Treaty Act and Executive Order (EO) 13186. Both the Act and the EO promote the conservation of migratory bird populations. There are two lists prepared by the U.S. Fish and Wildlife Service in determining which species are to receive special attention in land management activities; the lists are Bird Species of Conservation Concern (BCC) found in various Bird Conservation Regions (analysis area is in BCR 5) and Game Birds Below Desired Condition (GBBDC). The Final EA (Table 3-4, p. 3-58) lists which species are likely or known to be present in the Wildlife Analysis Area. Current research indicates the most appropriate scale to study impacts to migratory birds is at the eco-regional scale (California Partners in Flight 2002).

The effects of fire has increased open to semi-open forests, stand edges, and brush fields, and this type of habitat for these species is expected to increase across the fire landscape. The proposed removal of 683 acres fire-injured or fire-killed trees would still result in a net increase of these types of habitats in untreated areas, therefore, no negative cumulative effects are expected for these species (Final EA, p. 3 78).

Oregon Gulch Fire Salvage Recovery Project A-18 Response to Comments

IMPACTS TO GREEN TREES

Comment 27: Page 2-1 of the EA further indicates that “some live trees would be felled and removed incidentally to facilitate salvage operations.” The impacts, amount, and location of green tree logging in the project area are not analyzed or disclosed.

Response: The felling of live trees would be a rare occurrence that would largely be tied to safety reasons where it would be left onsite to provide for coarse woody material or extracted for yarding corridors, skid trails, landing and road construction, or road renovation. However, this would be minimized to reduce effects to live trees. While the exact number of green trees to be logged is not necessary for a reasonable analysis of the effects of the project, all potential yarding corridors and skid trails were factored into the effects to habitat for each unit (Final EA, p. 2-15 and 2-20). The Final EA analyzed the effects of constructing a 320 ft. designated skid trail in the 20-acre green tree retention area (p. 3-26 to 3-27, 3-32, and 3-45). Removing green trees to facilitate logging operations is not in violation of the RMP.

STAND RE-STOCKING AND NATURAL FOREST STANDS REGENERATION

Comment 28: Since proposed salvage Units 25-3 and 25-4 are directly adjacent to a 20 acres green tree retention area, is there really “a lack of green trees able to produce a viable cone crop” (EA, p. 3-6). Quantify the acreage of proposed salvage logging and replanting that is closer, or farther, than this ¼ mile distance.

Green trees will be removed to establish a skid trail through a retention area to access 9 acres of the 683 timber sale. How is this necessary to assure successful regeneration?

Response: It is possible that the green tree retention area would provide adequate seed to reforest the 9 acre unit. “Dispersal distances from the few remaining green trees are inadequate to establish regeneration across the Project Area. The majority of Douglas-fir seed is dispersed within 330 feet of parent trees. Douglas-fir seed is produced approximately every eight years. Ponderosa pine has large, heavy seeds with relatively small wings that disperse fairly close to parent trees (1 to 1.5 times tree height). Ponderosa pine seed is produced almost every year, with abundant crops every two to five years (Boldt and Van Deusen 1974).” However, studies on the Biscuit and Timbered Rock Fires have shown that post-fire natural regeneration was highly variable in density and strongly dominated by single species (USDA/USDI 2014) (Final EA, p. 3-6).

The ability to successfully establish regeneration of conifer species and put Matrix land on a trajectory to produce a sustainable supply of timber and other forest commodities (RMP, p. 73) is not the only reason to harvest the 9 acres adjacent to the green tree retention area. The purpose and need identified on pages 1-7 through 1-9 include the need to provide for salvage of timber killed by wildfire (RMP, p. 72), harvest only mortality above the level needed to for snag retention and other habitat goals (RMP, p.186), permit salvage volume from stands following partial or complete stand mortality provided structural objectives are met (RMP, p. 193), and provide a sustainable supply of timber to provide jobs and contribute to community stability.

Comment 29: Let the forests regenerate naturally after the fire and tolerate conifer re-establishment over longer periods of time. The BLM should not rely on the outdated RMP to justify salvage logging and replanting. There is significant new information on the value of natural disturbances that are not salvaged and not replanted. A plan amendment and reconsideration in a programmatic EIS of BLM’s salvage

Oregon Gulch Fire Salvage Recovery Project A-19 Response to Comments logging program is required that considers the effects of salvage logging on young complex forests and the development of complex older forests.

Response: While Medford District RMP is currently under revision, the BLM is required to follow the 1995 RMP as it is the current direction for managing BLM lands on the Medford District. Hence, the project follows the standards and guidelines of the RMP. The revision will determine whether any changes in management direction need to occur.

DEVELOPING AND MAINTAINING DIVERSE EARLY SERAL HABITAT

Comment 30: Allow high quality early seral habitat to develop and reduce the need to log rare mature forest elsewhere.

Response: Alternative 1 (No Action) analyzed the effects of allowing early seral habitat to develop for each of the affected resources (Final EA). The primary land use allocation of this project is Matrix, which is to restore timber productivity on these lands and meet reforestation objectives as defined by the 1995 RMP. The Final EA explains (p. 1-1), “There is a need to remove the dead and dying trees and provide for a site that can support sustainable forest management in addition to conserving habitat elements as defined by the RMP. Salvaging dead or dying trees would allow the BLM to retrieve some economic value from these trees while retaining levels of coarse wood and standing snags needed to meet RMP standards and guidelines.”

The project does not propose establishing conditions typically seen in single species, even spaced plantations. “Due to the natural variation of planting sites that includes rocky and/or shallow soils, fallen snags, and coarse woody debris, tree spacing will be inherently heterogeneous. Natural mortality would further contribute to variable spacing…Salvage harvesting would expedite tree planting and ensure that more fire-resilient species become established and protected from future fire (Tappeiner et al. 2007; 289, 256), (Final EA, p. 3-13).” Management intervention, such as the proposed scalping or grubbing of sites 3 to 5 years after tree planting, and brushing every 3 to 5 years after that, would accelerate development of large fire-resilient tree structure by many decades, (Final EA, p. 3-13).

The Oregon Gulch Fire burned across 2,425 acres of Medford District BLM-administered lands, of which 683 acres are proposed for salvage. Forested stands within the 1,742 acres that isn’t proposed for salvage may provide for early seral habitat development on BLM-managed lands within the fire perimeter.

SNAGS AND COARSE WOODY DEBRIS

Comment 31: The two snags per acre to be retained could be felled for operational purposes, making it difficult to know if and where the BLM will retain snags at this level. Should all snags be removed from some logging units, the EA should analyze the effects on nutrient accumulation and cycling. The proposed retention level for the Ashland Resource Area will result in significantly less nutrient cycling and soil protection than the proposal of the Lakeview BLM District to retain 10 snags per acre. The Ashland Resource Area should analyze and disclose the significant differences in soil health and wildlife habitat between the reasonable alternative of retaining 10 snags per acre versus 2 snags per acre (averaged such that some units may in fact retain no snags at all).

Oregon Gulch Fire Salvage Recovery Project A-20 Response to Comments

As burned snags fall to the forest floor and with the absence of live trees to supply a future source of snags, a snag recruitment gap will be created (inability to maintain snag recruitment over time). Retain large snags now to mitigate this impact until stands can be re-established.

Response: The proposed project would meet the requirements of the Medford District RMP for snag and coarse woody debris retention, which is two snags per acre (RMP, p. 40 and Final EA, p. 2-22) and a minimum of 120 linear feet of coarse woody debris logs per acre greater than or equal to 16 inches in diameter (Final EA, p. 2-22). In addition to retaining 2 snags per acre, additional snags were marked to provide for adequate CWD requirements. For example, it takes 7.5 pieces of >16 inch diameter material 16 feet in length in decay class 1 or 2 to meet 120 linear feet of CWD. The number of trees marked for retention to meet this requirement would vary depending on the diameter and height of trees marked for retention. For one scenario, one tree 44 inches in diameter plus one tree 16 inches in diameter would be marked per acre to produce about 7.5 pieces 16 feet in length x 16 inches in diameter. In areas with smaller diameter trees, four 20-inch diameter trees or eight 16-inch diameter trees would need to be marked for retention to meet the CWD requirement. The BLM focused on retaining the largest available snags along with healthy green trees. Incidental felling of snags for safety during operations will help to get downed CWD restored to sites.

The following would also minimize impacts to snags and snag recruitment: • Proposed activities in Riparian Reserves would be limited to three temporary roads (totaling less than 0.1 miles) with no new landings in Riparian Reserves; about 97 acres of Riparian Reserves and a 20-acre green tree retention area remain in and around units that will be salvaged. These areas may also contribute to snag requirements consistent with RMP objectives (RMP, p. 75). • Cutting of healthy green trees would be limited to the rare occurrence needed for safety or operations reasons or for yarding corridors, skid trails, landing and road construction, or road renovation. • No activity would occur within 25 feet of a dry channel that borders Units 25-2, 25-3, 25-5A, and 25-5B, and passes through Unit 25-1. • The Oregon Gulch Fire burned across 2,425 acres of Medford District BLM-administered lands, of which 683 acres are proposed for salvage; the 1,742 acres that would not be salvaged includes areas that will provide for snag recruitment on BLM-managed lands within the fire perimeter.

This project is designed to meet management direction to, “harvest only mortality above the level needed to meet snag retention and other habitat goals and provide desired levels of coarse woody debris” (RMP, p.186; Final EA, p. 1-7). Large insect infestations are not expected and the reduction of host material for the insects would limit the potential damage and prolong the standing retention of snags (Final EA, p. 3 14).

To further assist with nutrient cycling, the tops and limbs of harvest trees would be left on site (Final EA, p. 3-27) along with non-merchantable snags (snags less than 10 inches diameter).

Coarse woody debris would be provided in a manner that meets the needs of species and provides for ecological functions per RMP requirements and snag retention would emphasize the largest trees available to ensure their longevity and to provide the unique structure and functions associated with these large trees (RMP, p. 39).

Oregon Gulch Fire Salvage Recovery Project A-21 Response to Comments

UTILIZE BEST AVAILABLE SCIENCE

Comment 32: Over 26 literature attachments were submitted with our (KS Wild’s) November 14, 2014 scoping comment letter that question many of the BLM’s assumptions concerning post-fire recovery, reforestation, fire hazard, and project impacts to wildlife, soils and watersheds, and the BLM did not respond to them.

Oregon Wild states, “The significant impact of salvage logging is a controversial issue and requires an EIS…Conflicts often exist between economic and ecological objectives…(Johnson and Franklin (2009).”

Response: The effects of this project are similar to those of many other projects that are implemented within the scope of the RMP and Northwest Forest Plan. There is a continuing full range of debate, findings and opinions about the potential effects of such land management activities as evidenced by public comments received regarding this project. Opposition to the project is not the same as “controversial effects.” The Ninth Circuit has held that a project is “highly controversial” if there is a “‘substantial dispute [about] the size, nature, or effect of the major Federal action rather than the existence of opposition to a use.’” Blue Mountains Biodiversity Project v. Blackwood, 161 F.3d 1208, 1212 (9th Cir. 1998) (quoting Sierra Club v. U.S. Forest Service, 843 F.2d 1190, 1193 (9th Cir. 1988)).

As required by NEPA and using the appropriate public involvement. The concerns and requests made in KS Wild’s scoping comment letter were considered by the interdisciplinary team and the Field Manager as described in the EA: Chapter 1 (Relevant Issues and Issues Considered but not Further Analyzed), Chapter 2 (Actions and Alternatives Considered But Eliminated from Detailed Analysis), and addressed in each of the affected resources in Chapter 3.

Each of the concerns and requests incorporated the literature references provided by KS Wild. The majority of the science revolves around ecological restoration, which is not the primary driving element in the purpose and need of this project. The BLM does not question the validity of the science submitted and in fact does reference and incorporate the science that is applicable to the purpose and need of the project. The majority of existing science on post-fire salvage activities is specific to ecological effects in terms of restoration, which does not fully apply to this project. The commenter does not describe how the Final EA is in error by not referencing all of the literature provided by the commenter during the scoping period.

CARBON AND CLIMATE CHANGE

Comment 33: Forgo salvage logging to retain more carbon on the landscape longer. Salvage logging will accelerate the transfer of carbon from the forest to the atmosphere and make global climate change worse. Large wood decays slowly, salvage logging will fragment large wood into smaller pieces that will decay more rapidly. Only a small fraction of the carbon from the forest will end up in long-term storage in wood products, most will be transferred to the atmosphere.

Response: The purpose and need for this forest management project is to provide for salvage harvest of timber killed or damaged by wildfire, harvesting only mortality above the level needed to meet snag retention and provide desired levels of coarse woody debris (Final EA, p. 1-7 to 1-8). A decision to not salvage to retain carbon on the landscape would not be consistent with the purpose and need for this project. Greenhouse gases and carbon storage analyses were done for recent projects such as the Howard Forest Management Project EA (2014) and the Heppsie Project EA (2012). These individual BLM proposed actions showed changes in greenhouse gas levels far too small to provide much meaningful information.

Oregon Gulch Fire Salvage Recovery Project A-22 Response to Comments

The effects to greenhouse gases and carbon storage from the Proposed Action are not expected to be different when compared to treatments of these other recent forest management projects that have had this analysis. Due to the similar scale of harvest we did not determine it was necessary to analyze greenhouse gases for this project. It is anticipated the proposed salvage would reduce carbon stores temporarily but would result in net increases over time as stands begin to be re-established.

Programmatic analysis of the effects on greenhouse gas levels would provide more meaningful information. To the extent possible, analysis of effects on greenhouse gas levels should be included in relevant programmatic analyses, such as resource management plan environmental impact statements. Such programmatic analyses could provide a basis for incorporation by reference and tiering for subsequent, project-specific NEPA documents. Greenhouse gas emissions will be an issue requiring analysis when the emissions would constitute a significant impact or when analysis is necessary to determine whether the impact would be significant (BLM Oregon/Washington State Office Instruction Memorandum No. OR-2010-012).

Oregon Gulch Fire Salvage Recovery Project A-23 Response to Comments