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Gap Landscape Restoration Project Ochoco NF

Objection Resolution Meeting June 1, 2016

Introductions --Regional Office Participants Becki Heath, Deputy Regional Forester and Objection Reviewing Officer Debbie Anderson, Regional Objection Review Coordinator Heidi Hopkins, Administrative Review Program Specialist Lawson Fite, American Forest Resource Council (AFRC) (Objector) Tyler Eastman, American Forest Resource Council (AFRC) (Objector) -- Ochoco SO Participants Stacey Forson, Forest Supervisor and Responsible Official Gary Asbridge, District Ranger Marci Anderson, Forest Environmental Coordinator Robbie Piehl, Wildlife Biologist and Team Leader Lauren DuRocher, NEPA Planner Karen Coulter, Blue Mountain Biodiversity Project (BMBP) (Objector) -- Call in Participants Irene Jerome, American Forest Resource Council (AFRC) (Objector) Meeting Rules - Debbie Anderson The Objection Reviewing Officer is most interested in listening to the objectors options for resolution, with the intent that there may be follow up meetings with the Responsible Official if there are further areas of resolution that can be explored. The meeting will be facilitated and notes will be kept. Time limits are 15 minutes per objector, but we will be flexible if needed. Opening Remarks by the Objection Reviewing Officer – Becki Heath

• Good morning and thanks for participating and continuing to work with the Forest Service on the Gap Landscape Restoration Project on the Ochoco National Forest.

• Becki recognized the time and energy that it takes and is grateful for participant’s interest and involvement.

• Becki asked that dialogue with the eligible objectors focus on opportunities to resolve any of the issues.

• It is important to note that Stacey Forson, as the Forest Supervisor on the Ochoco National Forest, is the Decision Maker – not Becki. Becki serves as the Reviewing Official and will facilitate additional discussion to search for resolution.

• Anyone who has interests or concerns about objection resolution changes or choices is encouraged to meet with Stacy Forson, as she will be balancing the ability to meet the purpose and needs with the changes that may ensure this project’s success.

• To be clear – this is not a hearing. • Becki’s role is to review the plan and hear the objections, and again, to facilitate dialogue about

the objections with the eligible objectors and Responsible Official. Objector’s highlighted issues and potential points of resolution

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• Irene Jerome spoke for American Forest Resource Council (AFRC). Irene stated that AFRC has worked with the Forest Service for 15 years. AFRC has just a few main issues, which Irene articulated.

• The AFRC believes that by not managing in old growth forest the Forest isn’t meeting the purpose and need of the Gap project. By not managing trees over 21” (white fir) the Forest isn’t meeting the ecological need of the forest. The Forest needs to move to an old forest single story instead of an old forest multi story. AFRC encourages the Forest to amend Forest Plan to be able to log trees over 21”. Becki then asked if AFRC would clarify their thoughts and reasoning behind the 21” rule. Lawson answered that the National Forest Management Act (NFMA) provides that a Forest Plan can “be amended in any manner whatsoever.” 16 U.S.C. § 1604(f)(4). This allows the Forest Service to carve out exceptions to the Eastside Screens where necessary to achieve the desired condition within a specific area. AFRC is aware that the Snow Basin decision rejected site-specific amendments because of a lack of unique site characteristics. However, the Snow Basin decision recognized that the combination of unique site characteristics and Forest Service expertise would be sufficient for site-specific amendments to be upheld. On the Gap Project there is a biological need to remove trees over 21” dbh and there is legal justification for amending the Forest Plan accordingly. Irene then stated they were concerned that the Forest is working hard to save legacy pine and they are dying off as a result. In many of these areas AFRC feels that site specific amendments could be utilized to manage the forest.

• AFRC also wanted to know why the Forest did not analyze cable logging in several areas of the Gap project. She stated that there are several individuals or contractors in the region that have the ability to do this kind of logging and the Forest should be analyzing its effects so they have the ability to use it in the future if they want to.

• Lawson then stated that AFRC supports treatment of Old Growth Management Areas (classified MA-F6). These areas need to be managed to enable them to continue to meet the Forest Plan direction of providing habitat for wildlife species dependent on old growth stands. These stands have become over-stocked and need to be thinned to promote the health and sustainability of the old growth trees. Lawson stated that just because these areas are old growth does not mean they won’t catch on fire.

• Lawson then stated that AFRC is troubled by the Forest’s use of inventory in Area 52 (unroaded areas). He said should be done at the Plan level not the project level. He advised that the Forest add some language into the Record of Decision as a disclaimer about what kind of inventory was done. He noted that a good example of language on this topic can be found in the recent Goose EIS on the Willamette National Forest. Lawson thanked all for their time and Irene asked about the next steps.

• Becki asked Stacey to discuss the Area 52 concerns that AFRC has. Stacey stated that in the EIS they went into great detail about Area 52 and that this inventory was the only tool they had but they would like to not call it an inventory. The Forest will take another look at that section for clarification.

• Becki then asked Stacy about their reasoning for not analyzing cable logging. Stacey replied that they will take AFRC’s thoughts forward on cable logging. The Forest was not aware of anyone semi-local contractors who were able to cable log. Becki then thanked AFRC for their thoughts on the Snow Basin decision. She stated that the Forest has to weigh the risk with the amount of work that goes into each of these projects and how potential challenges to these projects really affect the agency. Becki stated that the Forest does not want to be constrained by the Snow Basin decision but needs to plan and step carefully. Lawson then stated that a landscape level project such as the Gap would be a great place to test the waters.

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• Karen Coulter then arrived at the meeting and Becki gave her a quick recap of the 30 minutes of the meeting that she missed and then Karen was given the opportunity to speak. Karen stated that BMBP opposes all of the points that AFRC has made.

• BMBP does not want logging of trees over 21” or in any old growth, no logging in Area 52 or unroaded areas, and no logging on steep slopes (where cable logging may be proposed).

• Karen then stated there was an inconsistency with the stated purpose and need of the project. She stated that the DEIS admits that the existing condition, whereby large and old trees are at a deficit across the landscape and late and old structure old growth forest types are below the historic range of variability for abundance was caused by similar management to what is proposed for this project on a landscape scale. Karen also noted that the purpose and need is overly narrow by assuming that density reduction is needed. They have historical evidence that there is no need to create early seral stands through logging.

• Logging in Area 52 is also inconsistent with the purpose and need. These areas are already close to HRV and need to keep the large tree structure.

• BMBP requests no removal of trees 21” or over, no logging of old growth grand fir or Douglas-fir, no logging in RHCAs, no logging in Area 52 or any potential wilderness.

• Karen stated that she has a summary sheet with a list of all of BMBP requested logging units to drop. She will provide a copy at the end of the meeting.

• BMBP listed viability concerns for Management Indicator Species, focal species, sensitive species and listed species, including American marten, goshawk, white headed woodpecker, black-backed woodpecker, Pileated woodpecker, Lewis’ woodpecker, redband trout, Columbia spotted frog, lynx, wolverine, wolves and fisher.

• On the survey sheets that BMBP provided with their objection they have noted the units that are high priority to be dropped and will provide us with the list at the end of the meeting. They noted goshawk fledglings in some units and request those units be dropped.

• BMBP also stated that widespread reduction of canopy closure in the Gap project area to less than 35-40% is the likely result of proposed commercial-size logging, and is highly detrimental to goshawk including such detrimental logging even in goshawk PFAs, which are essential areas for reproductive success. Goshawk viability cannot be ensured under such widespread heavy logging, including logging of PFAs, which could contribute to a trend toward uplisting.

• BMBP is opposed to management activities in lands with wilderness characteristics, as these could be degraded.

• Request dropping all commercial logging, non-commercial thinning, fuels reduction, tree felling and heavy equipment use, temporary road construction and reopening of closed roads, particularly in Area 52. This is a high priority area.

• BMBP requested an increased basal area retention with a minimum of 80 square feet of basal area at the low end of a basal area range and a 15" dbh limit for any remaining logging is also needed to support the retention of the next size class of trees to become large to provide large structure into the future in the form of live trees, snags, and logs for multiple species, including MIS and sensitive species, such as pileated woodpeckers, white-headed woodpeckers, Lewis' woodpeckers, Pacific fisher, American marten, and northern goshawk.

• BMBP requests that the Forest drop all temporary road construction or reconstruction within RHCAs and avoid log hauling on roads within RHCAs that are within the stream sediment contribution zone of 200-300 feet and the Forest needs to drop all planned logging and any planned road work in undeveloped lands and wildlife connectivity corridors.

• Also BMBP would like the Forest to drop all commercial logging, noncommercial size thinning and any associated road work in elk calving areas.

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• BMBP also stated that other Forest Plan violations include violating the intent of the Eastside Screens to protect northern goshawk viability; violation of INFISH goals and Riparian Management Objectives (RMOs); and inconsistency between Forest Plan direction and management goals for wildlife connectivity corridors and lands with wilderness characteristics; snag density requirements; road management goals; standards regarding detrimental soil impacts; with proposed Gap project logging and other management actions.

• The Forest failed to demonstrate that RHCA damage would not occur. BMBP is concerned about potential violation of the Forest Plan detrimental soil impact standards, especially considering the lack of 100% effectiveness of best management practices and project design criteria mitigations.

• For resolution to occur BMBP is asking that all sale units in goshawk habitat be dropped, no hauling or logging in RHCAs, no falling into streams because it decreases future wood recruitment. The Forest needs to drop all commercial logging in connectivity corridors. Shade removed from streams increases the temperature of the stream harming fish and aquatics. Please drop all logging in RHCAs.

• Karen stated that her list of sale units to drop is based on their survey sheets, logging history, MIS, and goshawk presence. Karen stated that BMBP field checks 95-100% of sale units.

• Becki thanks Karen for her comments and asked if Karen or her volunteers had talked to the staff on the district to understand there thinking about the design of the project. Karen said she had not and that in the past the staff has not been helpful in these types of discussions. Karen stated that she is not easily dissuaded from her opinion and she has over 25 years of experience. Becki then encouraged Karen to connect with the people on the Forest and in the field to help both parties understand their perspectives.

• Becki asked Karen is she was aware that the current proposed action does not cut trees 21” or over. Karen stated she was aware of this, but knew that AFRC had the opposite view and wanted to make sure all were aware that if that changed they would challenge.

• Becki then encouraged Karen and Stacey to meet to discuss resolution points. Stacey said she had two areas where she thought there was room for discussion an area where mixed moist conifer was a concern of BMBP and an area where the Silver-bordered Fritillary butterfly habitat was a concern. Karen stated that those areas where small and not her biggest concern. Karen stated that she would like the Forest to look hard at RHCA logging and Area 52 logging these were two of their greatest concerns. Karen said she would be available for the next 3 days while in Bend, but then she would be in the field for quite some time.

• Becki encouraged all parties to meet and try to find common ground. Becki asked that everyone keep her informed of any resolution points reached. AFRC then thanked Becki and for giving non objectors the opportunity to speak in these meetings.

Conclusion Debbie reminded everyone of the timeframe: the first 45 days ends July 5th and the review period can extend another 30 days to allow for continued dialogue, which is August 8th. If issues are resolved a formal resolution letter withdrawing the objection needs to be sent to the Regional Office and a formal letter will be sent to them as well, setting aside the objections because they were resolved. If not all issues are resolved then Becki will respond to unresolved issues in writing by August 8th. Meeting ended at 3:00pm.