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Conservation Strategy Boise National July 2010 What is the Strategy? The Boise National Forest is developing a Wildlife Conservation Strategy (WCS) in accordance with its and Management Plan (Forest Plan). The WCS will prioritize the types of activities that should be undertaken to help maintain or restore for wildlife in greatest need of conservation. The WCS will also identify where these actions are most needed. Assessing 300 wildlife species and their on the planning unit is very complex. To reduce this complexity, the WCS and associated Forest Plan amendments will be completed in four phases over the next 4–5 years, based on four major biological communities: ♦ Phase 1: Forested Biological Community ♦ Phase 2: Biological Community ♦ Phase 3: Unique Combinations of Forested and Rangeland Communities ♦ Phase 4: Riparian and Wetland Communities The Forest Service completed Phase 1 of the WCS in July 2010. Location of the Boise National Forest Why did the Forest Undertake Development of a WCS? In 2003, the Boise National Forest revised its 1990 Forest Plan. During Forest Plan revision, wildlife habitat families that had declined from historical conditions were identified and management direction was developed for these families based on identified and restoration needs. However, a comprehensive strategy that prioritized areas for wildlife habitat maintenance and restoration was not included in the 2003 Forest Plan update. Instead, the revised Forest Plan contained a wildlife objective (WIOB03) that called for developing such a strategy—the WCS. Work began in 2005 to meet this wildlife objective by developing a strategy that prioritizes areas for treatments to improve the health and of and associated wildlife habitat. A strategic approach will allow the Forest Service to focus its limited in areas where the greatest benefits may be realized. The long-term goal of the WCS will be to maintain or restore a representative, resilient, and redundant network of wildlife habitats across the Boise National Forest that will provide for a diversity of terrestrial species and be consistent with overall multiple-use objectives. The short-term emphasis will be placed on prioritizing and restoring habitats associated with species believed to be of greatest conservation concern. Only those portions of the Forest Plan needed to integrate the WCS will be amended through this forest planning process. The remaining portions of the Forest Plan that address other multiple-use management goals and objectives will not be changed. Old-forest ponderosa pine habitat

1 WCS Phase 1 Decision Alternative B (the Proposed Action) has been selected by the Responsible Official, Forest Supervisor Cecilia R. Seesholtz. The rationale for making this decision can be found in the Record of Decision (ROD) issued in July 2010. This decision is subject to the optional appeal procedures available during the planning rule transition period pursuant to 36 CFR 219.35(b) provisions of the 2000 Planning Rule (65 FR 67514) and 2001 interpretative rule (66 FR 1864). The ROD contains direction on filing appeals. A brief overview of the WCS assumptions, foundational conservation principles, alternatives assessed in the supporting Environmental Impact Statement (EIS), and their anticipated effects are presented below. For detailed alternative discussions and effects disclosure, refer to the Final Environmental Impact Statement (FEIS). Underlying Assumptions for Developing the WCS Historical range of variability increases as habitat departure from ♦ Using the HRV to guide (HRV) concepts have been used as the HRV increases. management implies managing for an underlying foundation to this ♦ Strategies using the HRV remain a range of conditions, not a single amendment process. Using HRV useful in light of evidence of condition. concepts to guide forest planning first climatic change because historical ♦ Managing within the range of the came from a committee of scientists. forests were likely more resilient HRV allows greater latitude and While the HRV has limitations, it and resistant to , insect requires greater flexibility than continues to be used as a tool to pathogens, and severe wildfire. many traditional management develop management strategies. The ♦ Using the concept of the HRV strategies. following are underlying assumptions does not mean taking ♦ To provide for the variety of in using the HRV: back to a pre-Columbian condition multiple uses from the Boise or that human uses should be National Forest, managing for a ♦ The risk of losing species, precluded from the . subset of HRV rather than the full processes, or genetic range was deemed appropriate. diversity within populations Six Conservation Principles To ensure the WCS is based on the 3. Large blocks of habitat containing best available science, it draws upon large populations of species are a variety of scientifically accepted superior to small blocks of conservation concepts that were habitat containing small converted into six conservation populations. principles to guide the development of 4. Blocks of habitat close together are Forest Plan strategies. The principles better than blocks far apart. and indicators generated by the 5. Interconnected blocks of fragmented interdisciplinary team provided habitat are better than isolated blocks, the framework for developing the and dispersing individuals travel more Proposed Action: readily through habitat resembling that 1. Species well distributed across preferred by the species in question. their range are less susceptible to 6. Blocks of habitat that are in areas than species confined to where the direct or indirect effects small portions of their range. of human disturbance are low are 2. Habitat in contiguous blocks is more likely to provide all elements

better than fragmented habitat. of species’ source environments than Pileated , a Forest Plan Management Indicator Species (MIS) areas that are not. 2 The Role of Fire Historically, wildfire disturbance helped shape forested landscapes across the Boise National Forest. However, decades of fire exclusion, , wildfires, insect outbreaks, and other factors have substantially altered the structure of forests, especially in the low- to mid-elevation ponderosa pine forest that comprise about 52% of the forested acres on the Boise National Forest. While fire frequency has remained relatively stable, ongoing drought, severe weather conditions, and in some cases, altered forest structure have contributed to a dramatic increase in the number of acres affected by wildfire over the last two decades. In addition, past forest management—which actively suppressed most wildfires and favored harvesting large, economically desirable ponderosa pine and other fire-resistant species—helped create undesirable conditions that vary from historical conditions.

These same influences have directly and indirectly affected wildlife habitat quality, quantity, and distribution, especially within the low- to mid‑elevation ponderosa pine forests. Moreover, the updated multi‑scale assessment indicates that most terrestrial wildlife species of concern associated with the forested biological community are linked to habitats found in the low- to mid-elevation ponderosa pine forests.

Total acres burned between 1952 and 2007

Historically, many low-elevation forests in southern As wildfires were excluded over the last century, Idaho were “single-storied,” characterized by old, many warm, dry forests in southern Idaho developed large ponderosa pine (below). multiple “stories,” or canopies, with smaller trees filling in below and between large, old trees (right).

3 Current Forest Conditions Compared to Historical Conditions Compared to historical conditions (i.e., HRV), an updated assessment by the Boise National Forest found or projected the following trends: The Historical Range ♦ Substantial reductions in the abundance and extent of the large tree of Variability (HRV) is size class and old-forest habitat, especially in the low- to mid-elevation defined for this analysis ponderosa pine forests1 as the vegetation ♦ Substantial reductions in the abundance of legacy ponderosa pine, western conditions that existed larch trees, and large snags in managed areas. This reduction is believed to more than 100 years result from substantial reductions in the large tree size class and old‑forest ago. Researchers assume habitat, snag removal levels in historic salvage operations, and greater that if a variety of removal of products where road access is extensive. historically functioning ♦ Substantial increases in tree densities and ladder fuels within stands, across resulting in reduced habitat quality and increased risks for habitat loss from the landscape can be future uncharacteristic wildfire or insect events in the low- to mid-elevation produced or mimicked, ponderosa pine forests then much of the habitat for native flora and ♦ Reductions in habitat quality due to increases in climax tree species fauna should be present. (e.g., Douglas-fir and grand fir) that historically would not have been as widespread within the low- to mid-elevation ponderosa pine forests ♦ Reductions in forest cover from uncharacteristic wildfire and/or insect and disease events, all of which have become more extensive and severe with changes in tree species composition and increases in tree density and continuous ladder fuels, combined with ongoing drought and extreme weather events ♦ Reductions in habitat quantity and quality due to historic and/or continued increases in human use across forested landscapes—increased human use has reduced and fragmented habitat through forest management, recreation, and residential development 1 The low- to mid-elevation ponderosa pine forests fall within what is referred to as the nonlethal and mixed1 fire regimes. These forests were typically maintained through fires that burned every 5–75 years. Forest fires in these fire regimes historically resulted in low-to-moderate levels of tree mortality. Today, these forests are experiencing substantially greater levels of mortality due to changed conditions.

Need to Change the Forest Plan In response to these findings, the Forest Service identified the following needs to change its Forest Plan: 1. The need to develop a more comprehensive and diverse strategy for wildlife conservation that relies on scientifically accepted conservation concepts (FEIS Appendix 1) and associated principles. 2. The need to shift from a commodity production emphasis to a restoration emphasis in certain areas, including reintroducing fire in these areas where it can be done safely. 3. The need to emphasize retention of most forest stands that meet the definitions of old-forest habitat or large tree size class. 4. The need to focus restoration to promote desired old-forest habitat or large tree stand conditions and reduce hazards and risks to these habitats. 5. The need to emphasize retention of large snags while balancing other objectives associated with a given management prescription.

4 Need to Change the Forest Plan (cont.) 6. The need to prioritize vegetative and wildlife habitat restoration treatments to increase the overall probability of restoration success. 7. The need to identify the location of priority or key habitat areas for wide-ranging carnivore species, such as the wolverine, retain linkages between these habitats, and identify where potential conflicts between this species and human use may exist and warrant further review. 8. The need to balance wildlife habitat restoration needs with multiple-use objectives, the exercise of existing rights, and other public needs. Amendments to the Forest Plan that Address the Needs for Change The Forest Service proposed the following changes to the 2003 Forest Plan (i.e., the Proposed Action): ♦ Develop a diverse strategy for wildlife conservation that relies on scientifically accepted conservation concepts (FEIS Appendix 1) and associated principles ♦ Reallocate 400,000 acres from a commodity production prescription (Management Prescription Category [MPC] 5.2) to a restoration emphasis prescription (MPC 5.1) so that all acres would have a desired condition that falls within the HRV (see maps on pages 6 and 7) ♦ Add Forest Plan direction that emphasizes retaining most forest stands that meet the definition of old-forest habitat or large tree size class ♦ Add Forest Plan direction to focus restoration that promotes desired old-forest habitat or large tree stand conditions, and reduces hazards and risks to these habitats ♦ Add Forest Plan direction that emphasizes retaining large snags while balancing other objectives associated with a given management prescription emphasis ♦ Add a spatial strategy to prioritize vegetative and wildlife habitat restoration treatments in one area over another to increase the overall probability of restoration success ♦ Identify the location of priority or key habitat areas for wide-ranging carnivore species, such as the wolverine; retain linkages between these habitats; and identify where conflicts between this species and human use may exist and warrant further review ♦ Balance wildlife habitat restoration needs with multiple-use objectives, such as handling emergencies (including wildfire); reducing hazardous fuel in the wildland-urban interface (WUI); providing for public health and safety; exercising prior existing and Native American rights; and addressing other statutory requirements, such as the Act. Examples of before and after hazardous fuels treatments near Warm Lake, which was affected by the 2007 Cascade Complex Wildfire. In 2008, the Forest, in cooperation with the Rocky Mountain Research Station, assessed the effectiveness of the fuels treatments.

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shaded brown). The Forest Service uses the most current and complete data available. GIS data and product accuracy may vary. Using GIS products for purposes " Mountain Home other than those intended may yield inaccurate or misleading results. Map produced by: B.Geesey, Sawtooth NF, 08/2009

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V 2.2 3.1 Management Prescription Categories (MPC) 2.2 3.1 5.1 1.1 Existing Wilderness " Donnelly 3.2 1.2 1.2 Recommended Wilderness 2.2 Research Natural Area Y E L 2.4 Boise Basin Experimental Forest 4.1c 3.2 L R 3.1 Passive Restoration and Maintenance of Aquatic, 5.1 3.2 A E 3.2 4.2 V T Terrestrial, and Hydrologic Resources S 4.1c U 3.2 Active Restoration and Maintenance of Aquatic, C 3.1 Terrestrial, and Hydrologic Resources 4.1a Undeveloped Recreation: Maintain Inventoried Roadless Area 4.1c 4.1c Undeveloped Recreation: Maintain Unroaded Character 5.1 1.1 with Allowance for Restoration Activities 5.1 " 3.1 Cascade 2.2 3.1 4.2 Roaded Recreation 5.1 Restoration and Maintenance Emphasis within Forest Landscapes 6.1 Restoration and Maintenance Emphasis within Shrubland and Grassland Landscapes 3.2 1.1 4.1c Non-Forest System Lands 4.1c 4.1c 5.1 3.1 Wild & Scenic River Classification 5.1 2.2 5.1 Recreation (R) 5.1 3.1 ¬«21 Scenic (S) 3.2 1.2 Wild (W) 3.2 4.2 Suitable Wild & Scenic River 5.1 5.1 4.1c 5.1 4.1c 5.1 1.2 " 4.1c Stanley 5.1 3.2 1.2 3.2 2.2 5.1 4.1c 5.1 3.2 4.1c 5.1 4.1c " Lowman " Banks 3.2 1.2 ¬«75 5.1 4.1c 5.1 1.2 ¬«55 5.1 5.1

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Alternative B— ELMORE 4.1c 6.1 Fairfield " The 400,000 acres of 6.1 National Forest System ¨¦§84 lands in MPC 5.2 under ¤£20 ¯ Alternative A are 0 5 10 15 20 Miles reallocated to MPC 5.1 The Forest Service uses the most current and complete data available. GIS data and product accuracy may vary. Using GIS products for purposes (areas shaded gold). " Mountain Home other than those intended may yield inaccurate or misleading results. Map produced by: B.Geesey, Sawtooth NF, 08/2009

7 EIS Highlights: Issues, Alternatives, and Effects Issues When developing the proposed Forest Plan amendments, the Forest Service used “scoping” to determine the issues with the Proposed Action to be addressed. As part of the scoping process, the Forest Service invited the public, American Indian Tribes, and other Governmental agencies to participate. Three major issues with the Proposed Action (i.e., Alternative B) were identified. Alternative C was developed to respond to issues with the Proposed Action as follows: Issue 1: Under the Proposed Action, acres in need of habitat restoration assigned to MPC 5.2 would continue to be designated as lands considered suitable for timber production when reassigned to MPC 5.1. Reallocating these acres to an active management MPC that still includes wood products objectives that contribute to the Forest Plan’s allowable sale quantity (ASQ) may further degrade wildlife habitat (or impede its restoration), regardless of whether or not commodity production is emphasized. Of specific concern are the low- to mid-elevation ponderosa pine forests, a forest type identified as one of greatest conservation concern. The WUI is defined as the Alternative C responds to this issue area where structures by reallocating MPC 5.2 acres to and other human MPC 3.2 (Active Restoration and development meet or Maintenance of Aquatic, Terrestrial, intermingle with wildland and Hydrologic Resources). This vegetation. reallocation reduces suited forestland acres by 50% across the forest, most of which is within the low- to mid‑elevation ponderosa pine forests. MPC 3.2 includes more stringent requirements for duration of effects, vegetation restoration, and road construction and reconstruction than found in MPC 5.1. Issue 2: Under the Proposed Action, activities within the WUI designed to reduce hazardous fuels are exempt from proposed Forest-wide standards concerning retention of large-tree stands, old-forest habitat, and large snags. This exemption may affect the Forest Service’s ability to restore old-forest habitats associated with some species of greatest conservation concern. Of specific concern are the remaining acres in or near an old-forest habitat condition that are within the low- to mid-elevation ponderosa pine forests. Alternative C responds to this issue by removing the WUI exemption, thereby retaining old-forest habitat, large tree forest, and large snags, regardless of whether or not they occur within the WUI. Issue 3: WCS assessments indicate that forested lands have fewer large trees than desired in most forest types. In many roaded areas, there are fewer large snags than desired. The Boise National Forest needs to retain all large trees and snags, especially in existing “old-growth” habitat, until habitat is restored. Alternative C responds to this issue by reallocating MPC 5.2 acres to MPC 3.2, thereby requiring the retention of all large snags on an additional 241,750 forestland acres, including during salvage sales.

8 Alternatives: Summary of Key Differences Unlike Alternative A, Alternatives B and C do the following: ♦ Include a diverse wildlife strategy based on accepted conservation concepts and principles ♦ Add new direction to retain and conserve most forested stands that meet the definition of old-forest habitat and large tree size class forests and focus restoration that promotes desired old-forest habitat or large tree conditions within stands while reducing hazards and risks to these habitats ♦ Add new direction to retain all large snags on unsuitable forestland acres; Alternative A retains snag numbers within the range of desired conditions identified in the Forest Plan on all forested acres, regardless of suitability designation ♦ Provide a strategy that prioritizes restoration of one habitat over another. This strategy supports the conservation principles that emphasize increasing overall habitat patch size, reducing , and building connectivity between habitat patches using a strategic approach ♦ Prioritize monitoring of watersheds where winter recreational activities may be impacting species, such as the wolverine, and update the Forest Plan monitoring strategy to better track the implementation and effectiveness of vegetation and wildlife habitat conservation and restoration treatments ♦ Add a new management indicator species to address the effects of management activities on large snags, especially following wildfire events ♦ Do not directly change the existing road access or firewood collection areas from those currently available; however, include more specific direction to address road-related and firewood program fectsef on the conservation and restoration of wildlife habitat during plan implementation ♦ Provide an exemption to compliance with some proposed direction to respond to public health and safety during emergency events (e.g., wildfire); address other public health and safety issues (e.g., hazard trees in campgrounds); exercise prior existing rights and Native American rights; and address other statutory requirements (e.g., Endangered Species Act). Alternative B differs from Alternative C as follows: ♦ Alternative B reallocates the 400,000 acres currently allocated to MPC 5.2 (emphasis on commodity production) to MPC 5.1 (emphasis on overall forest restoration, including wildlife habitat); Alternative C reallocates these acres to MPC 3.2 (specific emphasis on the conservation and restoration of aquatic and terrestrial wildlife habitat). ♦ Alternative C retains all large snags on 241,750 more acres than Alternative B when these acres are moved from suitable forestland (MPC 5.1) to unsuitable forestland (MPC 3.2). ♦ Alternative B provides a compliance exemption to new direction for hazardous fuel reduction in the WUIs (e.g., old-forest habitat and large tree retention standards); Alternative C does not. ♦ Alternative B includes a guideline stating that while the Responsible Official has the discretion to exempt hazardous fuel reduction activities within the WUI, efforts should be made to meet both hazardous fuel reduction and wildlife habitat restoration objectives. Alternative C does not include this guideline because it does not include the WUI exemption discussed under Restoration activity within the Boise Experimental the previous bullet. Forest Effects: Alternative Highlights Alternatives A, B, and C were analyzed in detail in an EIS. The Draft Environmental Impact Statement (DEIS) was issued for a 90-day comment period in December 2009. In response to comments received on the DEIS, minor edits and corrections were made to disclosures, and new content was added to resource sections in the FEIS to improve clarity of disclosures. A summary comparing alternative effects disclosed in the FEIS is provided on page 10.

9 Effects: Alternative Highlights (cont.) ♦ Alternatives B and C move vegetative conditions within the low- to mid-elevation ponderosa pine forests toward the range of HRV substantially faster than Alternative A. Specifically, these alternatives result in about 70,000 acres more in the large tree, low canopy cover class condition that historically dominated these forests. Indicator Unit Alternative A Alternative B Alternative C Trend in the large tree Current acres 50,120 50,120 50,120 size class, low canopy Acres (decade 1) 58,240 67,330 66,810 cover class in low- to mid-elevation ponderosa Acres (decade 5) 127,370 174,940 174,270 pine forests Acres (decade 10) 175,710 247,240 245,420

♦ Alternative B results in slight increases in the large tree size class compared to Alternative C. However, large tree size class forests within WUIs under Alternative B may be more uniform and less dense in some cases. Thus, while habitat quality outside the WUI would be similar, habitat quality within the WUI may be lower under Alternative B where fuel reduction and habitat treatment objectives cannot be concurrently met. ♦ Alternatives B and C move macrovegetation conditions typical of historical old-forest habitat within the low- to mid-elevation ponderosa pine forests to within the HRV by decade 3 compared to decade 10 under Alternative A. As shown in the table below, by the 10th decade, Alternatives B and C are projected to have about 100,000 acres more than Alternative A, with slightly more in Alternative C. Similar old-forest habitat macrovegetation trends are projected across all forest types. Indicator Unit Alternative A Alternative B Alternative C Current acres 71,210 71,210 71,210 Trend in old-forest habitat macrovegetation within low- Acres (decade 1) 92,130 96,550 98,050 to mid-elevation ponderosa Acres (decade 5) 217,380 271,960 285,260 pine forests. Acres (decade 10) 251,980 341,270 357,480

♦ Most acres within the WUI fall in low- to mid-elevation ponderosa pine forests. The WUI exemption provided under Alternative B reduces the projected old-forest habitat acres in these forests compared to Alternative C (see table above). However, this does not change the overall sustainability outcome between these alternatives for species associated with low- to mid-elevation ponderosa pine forests in Family 1. ♦ Alternatives B and C move habitat features for white-headed woodpecker, a species associated with low- to mid‑elevation ponderosa pine forests, to within the HRV by decade 7 compared to decade 15 under Alternative A. This acceleration in habitat restoration is primarily why the sustainability outcome for this species improves under Alternatives B and C, but not Alternative A. ♦ Alternatives B and C move the historical mid- to upper-elevation habitat acres for pileated woodpecker to within the HRV by decade 6; Alternative A does not reach the HRV within the 150-year projection period. ♦ Alternatives vary in their wood product opportunities and the support they provide to local and regional communities. Changes in suited forestland acres, ASQ, total sale program quantity (TSPQ), and associated economics are below:

Indicator Alternative A Alternative B Alternative C Suited forestland 516,100 516,100 274,350 ASQ ceiling 45.1 mmbf 28.2 mmbf 12.0 mmbf TSPQ potential 58.2 mmbf 39.7 mmbf 41.2 mmbf Projected output per budget and 20.5 mmbf or less At least 20.5 mmbf, up to At least 20.5 mmbf, up to resource constraints (last 5-year average) 29.0 mmbf 30.6 mmbf Product quality Moderate to high Moderate Low to moderate Commercial sales vs. More commercial sales Similar mix commercial sales More stewardship than stewardship contracts than stewardship and stewardship commercial sales Community effects No change from current or Positive for all communities, Negative on two possibly negative possible increase over current communities, rest positive

10 Forest Plan Priorities for Restoration Included in 2010 Amendments Vegetative and wildlife habitat restoration priorities (full size maps are in the FEIS, Appendix 3)

Boise National Forest Vegetation and Widllife Habitat Restoration Strategy Yellow Pine 2009 " New Meadows " Administrative Boundary Non-Forest System Lands " Counties McCall Wildlife Habitat Short Term Priorities

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«¬21 An important species in Phase 1 of the WCS, the white-headed woodpecker «¬75 prefers warm, dry ponderosa pine forests that are relatively open. Active

" Stanley restoration using both mechanical and prescribed fire treatments will be needed to move stands back toward a more historical condition.

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¨¦§84 A collaborative approach involving all affected parties will be required to ¤£ effectively resolve conflicts between winter recreational uses and species such 20 as the wolverine. A study to address potential wolverine–human conflicts was started in southwest Idaho in 2009. This study has been supported by user Monitoring priorities to address potential " groups and Counties as a way to identify and resolve conflicts specific wolverine–humanMountain conflicts Home (full size maps are in the FEIS, to each location. Appendix 3)

11 How Phase 1 of the WCS and Forest Plan Amendments Might Affect You Implementation of the Phase 1 decision (ROD) may occur after the 7th calendar day following publication of the legal notice of decision in the newspaper of record, The Idaho Statesman. Forest Plan direction, as amended, will apply to all project decisions made on or after the ROD implementation date. These project decisions will be supported by their own site-specific analysis and appropriate documentation in compliance with the National Environmental Policy Act (NEPA). Management actions requiring decisions before the implementation date of this ROD were incorporated into the baseline analysis documented in the FEIS. The National Forest Management Act (NFMA) requires that “…permits, contracts, and other instruments for use and occupancy” of National Forest System lands be “consistent” with the Forest Plan (16 U.S.C. 1604(i)). In the context of a Forest Plan, NFMA specifically conditions this requirement in three ways: Working together on the Idaho City Ranger District to identify treatment needs. (1) only “when necessary,” (2) as “soon as practicable,” and (3) are “subject to valid existing rights.” The Responsible Official has made the following decisions: ♦ Not to modify existing timber sale contracts due to the Forest Plan as amended. These contracts will be executed according to their terms and these effects were included in the baseline conditions that informed disclosures in the FEIS. Existing timber sale contracts will, in most cases, be completed within 3 years. ♦ Review and determine whether or not to modify decisions authorizing timber sales not currently under contract on a case-by-case basis, documenting conclusions in a consistency review that will be included within the respective project record. ♦ Review other recent project decisions (other than timber sales) that have not yet been implemented and adjust them, if necessary, to meet Forest Plan direction as amended. ♦ No action is needed to bring Term Grazing Permits into compliance with this phase of the Forest Plan amendment process because Phase 1 specifically addresses forested vegetation, not rangeland vegetation where the majority of grazing occurs. ♦ Review other classes of “use and occupancy” agreements (e.g., special use permits) to determine whether or not they should be modified to comply with the Forest Plan as amended. The Responsible Official will make the determination on a case-by-case basis, documenting conclusions in a consistency review and/or letter to the project file as needed. The Responsible Official for a project or permit (i.e., Forest Supervisor or respective District Ranger) has the discretion, on a case-by-case basis, as to how and when to modify pre-existing authorizations to bring them into compliance with the standards and guidelines specified in the Forest Plan as amended.The statutory criteria of “when necessary,” “as soon as practicable,” and “ subject to valid existing rights” are used in exercising this discretion.

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