FORESTS ON THE HORIZON by Michelle Berditschevsky

Like dark pines on the bright expanse of snow, forest issues shadow the winter landscape. We are concerned about the Bush administration's rollbacks of forest protection policies and public process that appear to feed the timber industry's appetite for ever more trees. In order to determine if the changes are necessary adjustments or mere accommodations of industry demands, we're looking deeper into questions raised by recent changes in policies and regulations

Northwest Forest Plan Reconsidered
In the summer of 2003, the Forest Service decided to review of the Northwest Forest Plan (NWFP). The Plan, implemented in 1994 under the Clinton administration, encompasses seven national forests and BLM land, including our local Shasta-Trinity National Forest.

Decision Imminent on Critical Survey & Manage Rule
The review led to a supplemental EIS with a preferred alternative to eliminate requirements to survey and manage 300+ at risk species before projects can be implemented. A final decision on which alternative will be selected is expected as we go to print.

Implications
Proponents say that the Survey & Manage requirement creates unnecessary work and expense, hampering the Forest Service in carrying out essential functions, such as fire-preventative thinning, salvaging dead and dying timber, and legitimate timber sales. On the other hand, opponents of the change claim that the NWFP was a compromise hammered out over a decade, giving at-risk species a fair chance of surviving, and that environmentalists would lose a valuable protection tool.

Recently, the USFS announced its final policy on three new categories of small, "low-impact" timber harvest activities that are now considered as "categorical exclusions" from full review under NEPA: 1) Harvest of up to 70 acres of live trees, as long as it doesn't involve clearcutting or other even-aged regeneration activities; 2) Salvage of dead and dying trees on sites up to 250 acres; 3) Harvest of live, dead or dying trees on sites up to 250 acres in order to control damaging insects and/or diseases.

Coupled with these exclusions, the elimination of NWFP Survey & Manage standards will make closer scrutiny of Forest Service actions imperative and also harder, as the criteria will not be as obvious. Judgment calls will be left to forest managers (as in the days before the NWFP) and will be more difficult to assess by the public than compliance with clear Survey and Manage standards.

DISTRICT RANGER MIKE HUPP ON
ELIMINATION OF SURVEY & MANAGE STANDARDS

Eco Echo: As our readers know, over time and many battles we've developed good communications with the local Forest Service. There is more understanding all around about natural and cultural values that are important to those who live and visit the Mount Shasta area. We questioned Mount Shasta District Ranger Mike Hupp on how removal of the NWFP Survey and Manage standards would affect forests in the Mount Shasta area.

Q) Why are the BLM and the Forest Service (agencies) proposing to remove the Survey and Manage Standards and Guidelines?

The impacts and costs of implementing Survey and Manage have been greater than anticipated in the 1994 NWFP. The Survey and Manage Standards and Guidelines are preventing many NWFP timber sales from moving forward and restricting forest health treatments such as hazardous fuels reduction and restoration projects.
The decision to prepare a supplemental environmental impact statement (SEIS) came as a result of the settlement that was reached between the Department of the Interior, the Department of Agriculture and the Douglas Timber Operators regarding a lawsuit. Douglas Timber Operators alleged the Survey and Manage provisions were excessive and unwarranted because they violate the Oregon and California Lands Act and are beyond the authorities or intent of the National Forest Management Act, the Federal Land Policy and Management Act, the National Environmental Policy Act, and the Endangered Species Act. In particular, Douglas Timber Operators claimed that the protection of every species site amounted to the creation of additional "reserves" without going through the NEPA process and in violation of Oregon and California Lands Act.

Q) If you remove the Survey and Manage Standards and Guidelines, how will the Survey and Manage species be managed?

Survey and Manage species that qualify will be added to the agencies' Special Status Species Programs. These programs are based on national policies and seek to further the objectives of the Endangered Species Act by avoiding federal action that may contribute to future listings of species as threatened or endangered. They require coordination with state and other federal agencies to achieve conservation goals of species. The objectives of the Forest Service' program also include compliance with National Forest Management Act regulations requiring diversity of plant and animal communities, and requiring habitat to be managed to maintain viable populations of existing native and desired nonnative vertebrate species in the planning area.

Q) How are Survey and Manage and Special Status Species Programs different?

Survey and Manage is a mitigation measure adopted in the NWFP Record of Decision in 1994. The objective of Survey and Manage is to conserve rare and little known species that were thought to be associated with Late-Successional and Old-Growth forests in the NWFP area.

The Special Status Species Programs are national policies adopted in the 1980s. They apply to all lands managed by the agencies and include any species that qualify, not just those associated with Late-Successional and Old-Growth forests. Specialists at field offices determine what species a project might effect, what information is needed to determine impact to a species, and document potential impacts and affirm that the action will not contribute to the need to list the species under the Endangered Species Act.

Q) How do species become Special Status Species?

The primary basis for adding species is information obtained from State Natural Heritage Programs and State Agencies responsible for wildlife and botanical resources. The decision to add a species is made by the Regional Forester or State Director and is also based on factors that include the agency's capability to significantly affect the conservation status of the species and whether there is sufficient information on habitat relationships and life history to evaluate potential effects.

Q) What are the agencies required to do for Special Status Species?

The Environmental Assessment or decision for a project must state that the project will not contribute to a listing as threatened or endangered under the Endangered Species Act. Information about the species in the project area must be gathered and analyzed in an Environmental Assessment or Biological Evaluation. These sites are then managed for the benefit of the species if it is determined that management of the site will reduce the likelihood of the species being listed.

Q) Will the preferred alternative reduce protection for rare species?

The preferred alternative would somewhat reduce protection since not all of the species are fully included in the Special Status Species Programs or they were not included in all of their range. This is due to the fact that there are different criteria for including species in Survey and Manage versus Special Status Species Programs. As a result, analysis shows that there may be insufficient habitat to support stable populations in all or part of their range in the NWFP area for 57 species under the preferred alternative. This analysis is based on known information. Much of the information has been gathered through surveys conducted in the matrix area of the NWFP. However, only a small fraction of late-successional habitat has been surveyed and it is reasonable to assume that species habitat would occur in the same proportions in late-successional forest stands in the Reserves as occurs in the Matrix lands.

Q) Will the preferred alternative result in harvest of old growth forests?

The preferred alternative does not authorize any timber harvest. It is anticipated that the action would improve the agencies' ability to meet all the objectives of the NWFP. One of those objectives is to ensure a sustainable supply of timber from federal forests. Since 1994 on average, the agencies' annual timber sale offerings have been 60% of the amount predicted in the NWFP.

Under the NWFP, approximately 86% of late-successional forest (6.9 million out of 8 million acres) is in reserves. The remaining late-successional forest (approximately 1.1 million acres) is located in the Matrix and Adaptive Management Area Land Use Allocations and is available for timber harvest. The preferred alternative does not change these allocations.