Final Environmental Impact Statement for the Green Diamond ... for the Green Diamond FH… · Green Diamond will apply for a Scientific Collection Permit for barred owl research and

A P P E N D I C E S

Final Environmental Impact Statement for the Green Diamond Forest Habitat Conservation Plan

March 2019

Prepared by the U.S. Department of the Interior; Fish and Wildlife Service

Estimated EIS Preparation Costs:

Consultant contract : $1.2 million

Fish and Wildlife Service staff: $480,000

Appendix A Figures

Appendix B Additional Tables

APPENDIX B ADDITIONAL TABLES

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Table 1-1. Summary of Laws and Regulations Applicable to Timber Harvest within the Action Area

Requirement Applicability How Conformance is Achieved

Federal

ESA, Section 10(a)(1)(B) Authorizes the Services to issue permits to non-Federal entities allowing incidental take of species listed under Section 4 of the ESA as endangered or threatened. Incidental take authorization may be extended to unlisted species, should they become listed during the term of the FHCP.

Green Diamond has submitted an ITP application to the Service. See “Decisions to be Made” in Chapter 1 of the EIS.

ESA, Section 7(a)(2) Authorizes the Services to allow take of endangered or threatened species by Federal entities, including the Service, for activities that a Federal agency may conduct, fund, or permit.

The Service will conduct an intra-agency Section 7 consultation on the proposed Federal action to issue an ITP, and will produce of Biological Opinion of its findings.

Migratory Bird Treaty Act In accordance with United States treaties, makes it unlawful to pursue, hunt, capture, kill, or possess migratory birds (as defined by the MBTA).

An ITP for the northern spotted owl can constitute a need for a Special Purpose Permit under the Migratory Bird Treaty Act. Barred owl removal on Green Diamond lands, as described under the FHCP (see AFWO website) will require a MBTA Special Purpose Permit.

NEPA Requires agency (Service) decision to be based on an EIS for “major Federal actions significantly affecting the quality of the human environment.”

This EIS has been prepared to comply with NEPA for the proposed federal action of issuing the requested ITP.

Federal Coastal Zone Management Act

Requires consistency determination for Federal actions that could affect resources or land use within the coastal zone.

The California Coastal Commission will have the opportunity to review the FHCP and EIS during the public review period.

National Historic Preservation Act

Requires Federal agencies to consider the effects of a proposed undertaking on cultural resources listed or eligible for listing on the NRHP.

The Service will take account of effects on historic properties, if any, in accordance with NEPA.

Clean Water Act Established and protects water quality standards through individual permits or by watershed standards called TMDLs.

General compliance with FPRs and Waste Discharge Requirements approved by the North Coast RWQCB.

CAA The CAA established national ambient air quality standards for several pollutants that represent the safest levels for each contaminant. EPA, through the CAA, also regulates emissions of certain greenhouse gases through its stationary source emission regulations.

Section 309 authorizes EPA to review and comment on the environmental impact of major Federal actions.

NEPA review.

Bald and Golden Eagle Protection Act

Prohibits the take, possession, sale, or transport of bald or golden eagles within U.S. jurisdiction.

Green Diamond will remain subject to all requirements of the Bald and Golden Eagle Protection Act.


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State

California Forest Practice Act and FPRs

The primary regulations controlling timber operations on private lands in California.

Green Diamond will continue to conduct timber operations consistent with the FPRs except where superseded by the ITP or where rules allow exemptions with an approved HCP.

CEQA Requires analysis of the environmental impacts of any State or local agency’s discretionary actions, focusing on a project’s significant effects on the environment, alternatives to the project, and the way significant environmental effects can be mitigated or avoided.

Timber harvest plans prepared consistent with the FPRs are “functionally equivalent” to CEQA documents.

California Fish and Game Code – Scientific Collection Permits

A Scientific Collection Permit is required for the take of wildlife and marine plants for bona fide scientific, educational, or propagation purposes.

Green Diamond will apply for a Scientific Collection Permit for barred owl research and management purposes.

California Fish and Game Code – Streambed Alteration

Activities within streams and lakes are subject to authorization by CDFW. Based on the conservation commitments in the AHCP,a CDFW provided Green Diamond with long-term authorization for all stream crossing work on Green Diamond Property under a MATO approved in 2010.

CESA Provides regulatory authority for CDFW to protect species that are candidates for listing or are listed as rare, threatened, or endangered under the CESA.

CDFW will continue to participate in the timber harvest planning and review process. Green Diamond will also seek a consistency determination from CDFW for NSO, and for other Covered Species if listed under both the ESA and the CESA.

Native Plant Protection Act

Provides regulatory authority to CDFW to designate native plants as rare or endangered.

Green Diamond will notify CDFW at least 10 days prior to disturbance to allow for salvage of rare or endangered native plants. Noticed by submittal of a timber harvest plan.

Porter-Cologne Water Quality Control Act

Authorizes RWQCBs to establish water quality objectives to protect beneficial uses of water.

The North Coast RWQCB will continue to participate in timber harvest planning and review. In 2010, the North Coast RWQCB approved a waste discharge requirement for all discharges from Green Diamond’s forest roads to waters of the State within the AHCP/CCAA plan area based on the road management requirements of the AHCP/CCAA. In 2012, the North Coast RWQCB approved a waste discharge requirement for all discharges from Green Diamond’s forest management activities to waters of the State within the AHCP/CCAA Plan Area.

California Coastal Act Coastal Development Permits required for actions that result in coastal zone land use changes.

Timber operations are exempt from California Coastal Act per provisions of the Z’berg-Nejedly Forest Practice Act of 1973.

California Timberland Productivity Act

Establishes timber production zone. Nearly all Plan Area lands are zoned as timber production zone.

Establishes a condition of land versus a compliance provision.


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a Green Diamond Resource Company. 2007. Aquatic Habitat Conservation Plan and Candidate Conservation Agreement with Assurances. (AHCP/CCAA).

Notes:

AFWO = Arcata Fish and Wildlife Office

AHCP = Aquatic Habitat Conservation Plan

CAA = Clean Air Act

CCAA = Candidate Conservation Agreement with Assurances

CDFW = California Department of Fish and Wildlife

CEQA = California Environmental Quality Act

CESA = California Endangered Species Act

EIS = Environmental Impact Statement

EPA = U.S. Environmental Agency

ESA = Federal Endangered Species Act

FHCP = Forest Habitat Conservation Plan

FPR = Forest Practice Rule

Green Diamond = Green Diamond Resource Company

ITP = incidental take permit

MATO = Master Agreement for Timber Operations

MBTA = Migratory Bird Treaty Act

NEPA = National Environmental Policy Act

NRHP = National Register of Historic Places

NSO = Northern Spotted Owl

RWQCB = Regional Water Quality Control Board

TMDL = total maximum daily load


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Table 3-9. Special-status Plant Species Occurring or Potentially Occurring within the Action Area Scientific Name Common Name ESA/CESA CRPR Habitat Associations Potential for Occurrence in Action Area

Non-Vascular Plants

Bryoria spiralifera twisted horsehair lichen --/-- 1B.1 North Coast (immediate) coniferous forest. Moderate. Suitable habitat present. Calicium adspersum spiral-spored gilded-head pin

lichen --/-- 2B.2 North Coast coniferous forest, lower montane

coniferous forest Moderate. Suitable habitat present.

Discelium nudum Naked flag-moss --/-- 2B.2 Coastal bluff scrub, on clay banks Unlikely. Suitable habitat not present.

Fissidens pauperculus Minute pocket moss --/-- 1B.2 North coast coniferous forest Moderate. Suitable habitat present. Ramalina thrausta Angel’s hair lichen --/-- 2B.1 North Coast coniferous forest Moderate. Suitable habitat present. Trichodon cylindricus Cylindrical trichodon --/-- 2B.2 Broad-leafed upland forest, meadows and

seeps, upper montane coniferous forest. Moderate. Suitable habitat present.

Triquetrella californica Coastal triquetrella --/-- 1B.2 Coastal bluff scrub, coastal scrub Unlikely. Suitable habitat uncommon.

Vascular Plants

Abronia umbellata ssp. breviflora

Pink sand-verbena --/-- 1B.1 Coastal dunes Unlikely. Suitable habitat not present.

Arabis aculeolata Waldo rock-cress --/-- 2B.2 Broad-leafed upland forest, lower and upper montane coniferous forest

Moderate. Suitable habitat present.

Boechera koehleri Koehler’s stipitate rock-cress --/-- 1B.3 Chaparral, lower montane coniferous forest Moderate. Suitable habitat present. Arabis mcdonaldiana McDonald’s rock-cress FE/SE 1B.1 Lower and upper montane coniferous forest Moderate. Suitable habitat present. Anthoxanthum nitens ssp. nitens

Vanilla-grass --/-- 2B.3 Meadows and seeps Moderate. Some habitat is present.

Asarum marmoratum Marbled wild ginger --/-- 2B.3 Lower montane coniferous forest Moderate. Suitable habitat present. Astragalus umbraticus Bald Mountain milk-vetch --/-- 2B.3 Cismontane woodland, lower montane

coniferous forest Occurs. Known from Green Diamond property.

Bensoniella oregano Bensoniella --/-- 1B.1 Stream banks, meadows, bogs, fens lower montane coniferous forest

Occurs. Known from Green Diamond property.

Calamagrostis foliosa Leafy reed grass --/SR 4.2 Coastal bluff scrub, north coast coniferous forest

Moderate. Suitable habitat is present.

Calamagrostis crassiglumis Thurber’s reed grass --/-- 2B.1 Coastal scrub, marshes and swamps Unlikely. Suitable habitat uncommon.


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Cardamine angulata Seaside bittercress --/-- 2B.1 Wet areas and streambanks in lower montane coniferous forest and North Coast coniferous forest.

Moderate. Suitable habitat is present.

Carex arcta Northern clustered sedge --/-- 2B.2 Bogs and fens, moist places in north coast coniferous forest


Carex lenticularis var. limnophila

Lagoon sedge --/-- 2B.2 Wetlands, meadows Unlikely. Suitable habitat not present.

Carex leptalea Flaccid sedge --/-- 2B.2 Meadows, bogs, fens, marshes and swamps Occurs. Known from Green Diamond property.

Carex lyngbyei Lyngbye’s sedge --/-- 2B.2 Coastal salt marsh Unlikely. Suitable habitat not present. Carex praticola Meadow sedge --/-- 2B.2 Moist to wet meadows Occurs. Known from Green Diamond

property.

Carex saliniformis Deceiving sedge --/-- 1B.2 Coastal prairie, coastal scrub, meadows and

seeps, marshes and swamps Moderate. Some habitat present.

Carex serpenticola Serpentine sedge --/-- 2B.3 Meadows and seeps, serpentinite Moderate. Some habitat present; not known on Green Diamond property.

Carex viridula var. viridula Green sedge --/-- 2B.3 Meadows, bogs, fens, marshes and swamps Unlikely. Suitable habitat uncommon. Cascadia nuttallii Nuttall’s saxifrage --/-- 2B.1 North Coast coniferous forest Moderate. Some habitat present. Castilleja litoralis Oregon coast paintbrush --/-- 2B.2 Coastal bluff scrub, Coastal dunes, Coastal scrub Unlikely. Suitable habitat uncommon. Castilleja ambigua ssp. humboldtiensis

Humboldt Bay owl’s-clover --/-- 1B.2 Coastal salt marsh Unlikely. Suitable habitat not present.

Castilleja elata Siskiyou paintbrush --/-- 2B.2 Bogs and fens, lower montane coniferous forest Moderate. Some habitat is present. Chloropyron maritimum ssp. palustre

Point Reyes bird’s-beak --/-- 1B.2 Marshes and swamps Unlikely. Suitable habitat not present.

Clarkia amoena ssp. whitneyi Whitney’s farewell-to-spring --/-- 1B.1 Coastal bluff scrub, coastal scrub Unlikely. Suitable habitat not present. Cornus canadensis bunchberry --/-- 2B.2 Bogs and fens, meadows and seeps, North Coast

coniferous forest Moderate. Some habitat is present.

Empetrum nigrum --/-- 2B.2 Coastal bluff scrub, coastal prairie Unlikely. Suitable habitat not present.


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Epilobium oreganum Oregon fireweed --/-- 1B.2 Bogs, fens, meadows, montane coniferous forest

Moderate. Some habitat present; not known on Green Diamond property.

Eriastrum tracyi Tracy’s eriastrum --/SR 33.2 Chaparral, cismontane woodland Moderate. Some habitat is present.

Erigeron bloomeri var. nudatus Waldo daisy --/-- 2B.3 Lower and upper montane coniferous forest Moderate. Some habitat is present.

Erigeron maniopotamicus Mad River fleabane daisy --/-- 1B.2 Meadows and seeps, open disturbed areas (road cuts); rocky areas

Moderate. Some habitat is present.

Eriogonum nudum var. paralinum

Del Norte buckwheat --/-- 2B.2 Coastal Prairie, Northern Coastal Scrub Moderate. Some habitat is present.

Eriogonum pendulum Waldo wild buckwheat --/-- 2B.2 Lower and upper montane coniferous forest Unlikely. Suitable habitat uncommon.

Erythranthe trinitiensis Pink-margined monkeyflower --/-- 1B.3 Serpentinite and roadsides in cismontane woodland, lower montane coniferous forest, meadows and seeps, upper montane coniferous forest


Erythronium hendersonii Henderson’s fawn lily --/-- 2B.3 Lower montane coniferous forests High. Suitable habitat present. Erythronium howellii Howell’s fawn lily --/-- 1B.3 Lower montane coniferous forest, North Coast

coniferous forest High. Suitable habitat present.

Erythronium oregonum Giant fawn lily --/-- 2B.2 Cismontane woodland, meadows and seeps Occurs. Known from Green Diamond property.

Erythronium revolutum Coast fawn lily --/-- 2B.2 Moist areas and streambanks within bogs and fens


Gilia capitata ssp. pacifica Pacific gilia --/-- 1B.2 Coastal bluff scrub, Chaparral, coastal prairie Valley and foothill grassland


Gilia millefoliata Dark-eyed gilia --/-- 1B.2 Coastal dunes Unlikely. Suitable habitat not present. Glyceria grandis American manna grass --/-- 2B.3 Bogs and fens, meadows and seeps, marshes

and swamps High. Suitable habitat present.

Hesperevax sparsiflora var. brevifolia

Short-leaved evax --/-- 1B.2 Coastal bluff scrub, coastal dunes Unlikely. Suitable habitat not present.

Hosackia yollabolliensis Yolla Bolly Mtns. bird's-foot trefoil

--/-- 1B.2 Dry, barren, exposed slopes, often gravelly. In meadows and seeps, and upper montane coniferous forest openings



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Iliamna latibracteata California globe mallow --/-- 1B.2 Chaparral, lower montane coniferous forest, north coast coniferous forest, riparian scrub


Juncus nevadensis var. inventus Sierra rush --/-- 2B.2 Bogs and fens Unlikely. Suitable habitat uncommon. Kopsiopsis hookeri Small groundcone --/-- 2B.3 North Coast coniferous forest Occurs. Known from Green Diamond

property. Lasthenia californica ssp. macrantha

Perennial goldfields --/-- 1B.2 Coastal bluff scrub, Coastal dunes, coastal scrub

Unlikely. Suitable habitat not present.

Lathyrus japonicus Seaside pea --/-- 2B.1 Coastal dunes Unlikely. No suitable habitat. Lathyrus palustris Marsh pea --/-- 2B.2 Coastal prairie, coastal scrub, bogs, fens,

marshes, swamps, lower montane coniferous forests


Layia carnosa Beach layia FE/SE 1B.1 Coastal dunes Unlikely. Suitable habitat not present. Lewisia cotyledon var. heckneri Heckner’s lewisia --/-- 1B.2 Rocky areas in lower montane coniferous

forest Moderate. Some habitat is present.

Lewisia oppositifolia Opposite-leaved lewisia --/-- 2B.2 Lower montane coniferous forest Moderate. Some habitat is present. Lilium occidentale Western lily FE/SE 1B.1 Early successional bogs, fens, coastal scrub, and

prairie, on poorly-drained soils, within about 4 miles of coast

Moderate. Some habitat present; no specimens found during THP surveys.

Lupinus elmeri South Fork Mountain lupine --/-- 1B.2 Lower montane coniferous forest Occurs. Known from Green Diamond property.

Lycopodiella inundata Inundated bog-clubmoss --/-- 2B.2 Bogs and fens, marshes and swamps, lower montane coniferous forest Unlikely. Suitable habitat uncommon.

Microseris borealis Northern microseris --/-- 2B.1 Bogs and fens, meadows and seeps, lower montane coniferous forest

Unlikely. Suitable habitat uncommon.

Sabulina howellii Howell’s sandwort --/-- 1B.3 Chaparral, Jeffrey-pine/oak woodland, serpentine


Monotropa uniflora Ghost-pipe --/-- 2B.2 Broad-leafed upland forest and north coast coniferous forest, often associated with redwoods and western hemlock



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Montia howellii Howell’s montia --/-- 2B.2 Vernally wet sites, meadows, northeast coniferous forest


Noccaea fendleri ssp. californica

Kneeland Prairie pennycress FE/-- 1B.1 Serpentine soils in Kneeland Prairie, near Kneeland Airport

Unlikely. Limited distribution and limited habitat availability.

Oenothera wolfii Wolf’s evening-primrose --/-- 1B.1 Coastal bluff scrub, coastal dunes, coastal prairie, lower montane coniferous forest


Packera bolanderi var. bolanderi

Seacoast ragwort --/-- 2B.2 Coastal scrub, North Coast coniferous forest Occurs. Known from Green Diamond property.

Phacelia argentea Sand dune phacelia --/-- 1B.1 Coastal dunes Unlikely. No suitable habitat. Pinguicula macroceras Horned butterwort --/-- 2B.2 Bogs and fens Moderate. Some habitat is present. Piperia candida White-flowered rein orchid --/-- 1B.2 Coniferous and mixed evergreen forest Occurs. Known from Green Diamond

property. Polemonium carneum Oregon polemonneum --/-- 2B.2 Coastal prairie, coastal scrub, lower montane

coniferous forest Moderate. Some habitat is present.

Prosartes parvifolia Siskiyou bells --/-- 1B.2 Roadsides, disturbed areas, and burned areas in lower and upper montane coniferous forest


Pyrrocoma racemosa var. congesta

Del Norte pyrrocoma --/-- 2B.3 Chaparral, lower montane coniferous forest Moderate. Some habitat is present.

Romanzoffia tracyi Tracy’s romanzoffia --/-- 2B.3 Ocean bluffs Unlikely. Suitable habitat not present. Rosa gymnocarpa var. serpentina

Gasquet rose --/-- 1B.3 Serpentinite, along roadsides, and sometimes ridges, streambanks, and openings within chaparral and cismontane woodland.


Sanguisorba officinalis Great burnet --/-- 2B.2 Marshes, swamps, bogs, fens, seeps, riparian areas, meadows, broad-leaved upland forest, north coast coniferous forest


Schoenoplectus subterminalis Water bulrush --/-- 2B.3 Bogs and fens, marshes and swamps Unlikely. Suitable habitat uncommon. Sedum citrinum Blue Creek stonecrop --/-- 1B.2 Serpentinite; rocky, talus, scree, or boulder

crevices; sometimes roadsides. North Coast coniferous forest



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Sidalcea malviflora ssp. patula Siskiyou checkerbloom --/-- 1B.2 Coastal bluff scrub, coastal prairie, and North Coast coniferous forest


Sidalcea oregana ssp. eximia Coast sidalcea --/-- 1B.2 Endemic to Humboldt County. Gravely soils in meadows and seeps. North coast coniferous and lower montane coniferous forests


Silene serpenticola Serpentine catchfly --/-- 1B.2 Chaparral, lower montane coniferous forest, serpentinite openings; gravelly or rocky

Moderate. Some habitat present; not known on Green Diamond property.

Spergularia canadensis var. occidentalis

Western sand-spurrey --/-- 2B.1 Marshes and swamps Unlikely. Suitable habitat not present.

Streptanthus howellii Howell’s jewel flower --/-- 1B.2 Lower montane coniferous forests, associated with serpentine


Thermopsis robusta Robust false lupine --/-- 1B.2 North coast coniferous forest, broad-leaved upland forest


Vaccinium scoparium Little-leaved huckleberry --/-- 2B.2 Subalpine coniferous forest Unlikely. Suitable habitat uncommon. Viola palustris Marsh violet --/-- 2.2 Coastal scrub, bogs and fens Unlikely. No suitable habitat. Viola primulifolia ssp. occidentalis

Western white bog violet --/-- 1B.2 Bogs and fens, marshes and swamps Moderate. Some habitat is present.

Notes: CESA = California Endangered Species Act CRPR = California Rare Plant Ranks ESA = Federal Endangered Species Act Green Diamond = Green Diamond Resource Company USFWS = U.S. Fish and Wildlife Service ESA (USFWS) Listing Categories: FE = Federal Endangered CESA (California) Listing Categories: SE = California Endangered SR = California Rare (plants only)

California Rare Plant Ranks (CRPR): Rank 1B = Rare, threatened, or endangered in California and elsewhere Rank 2B = Rare, threatened, or endangered in California, but more common elsewhere Threat Rank of 0.1 = Seriously threatened in California Threat Rank of 0.2 = Moderately threatened in California Threat Rank of 0.3 = Not very threatened in California


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Table 3-10. Special-Status Non-aquatic Wildlife Species Potentially Occurring within the Green Diamond Action Area

Scientific Name Common Name ESA/CESA Other Habitat Associations Potential for Occurrence in Action Area

Birds

Accipiter gentilis Northern goshawk --/-- CSC, USFS-S, CDF-S

Nests in mature and old-growth coniferous forests with sparse ground cover

Unlikely. Rare or absent from the Green Diamond ownership. Known to nest in eastern Humboldt County.

Agelaius tricolor Tricolored blackbird --/SC CSC Highly colonial species, largely endemic to California. Requires open water with protected areas for nesting

Moderate. Most numerous in the Central Valley. Rare, local breeder in Humboldt County.

Aquila chrysaetos Golden eagle --/-- C-FP, CDF-S

Rolling foothills and open mountain terrain in oak woodlands and most major forested habitats.

Occurs. Occasionally seen in the open woodlands of the eastern portion of the Green Diamond ownership, but no nests documented. Low potential for occurrence in other areas.

Ardea alba Great egret --/-- CDF-S Colonial nester in large trees near marshes, tidal flats, rivers and lakes

Moderate. Some foraging habitat is present.

Ardea herodias Great blue heron --/-- CDF-S Colonial nester in large trees near wet meadows, marshes, lake margins, rivers and streams and tidal flats

Occurs. Foraging known to occur on Green Diamond property. Two rookeries known (Eel River and Klamath River). Moderate potential for occurrence in other areas.

Asio flammeus Short-eared owl --/-- CSC Marshlands, grasslands, and forest clearings Occurs. Seen at several sites throughout the ownership, but no known breeding sites.

Athene cunicularia Western burrowing owl --/-- CSC Grasslands and shrublands Unlikely. Limited habitat present. Seen in winter at the old office site in the Arcata “bottoms,” and along the Bald Hill Road. No known breeding sites.

Brachyramphus marmoratus Marbled murrelet FT/SE CDF-S Late seral conifer forest and marine waters Occurs. Known to occur in multiple residual old-growth stands in the Klamath region and one-second growth stand with residual structure in the Maple Creek drainage. Low potential for occurrence in other areas.

Chaetura vauxi Vaux’s swift --/-- CSC Conifer forest with large snags Moderate. Frequently observed flying over Green Diamond’s timberlands. Nests and/or roost sites documented in Klamath and Korbel.


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Charadrius alexandrinus nivosus

Western snowy plover FT/-- CSC Sandy beaches, salt ponds and levees, gravel bars along coastal rivers

Unlikely. None have been recorded on Green Diamond lands.

Circus cyaneus Northern harrier --/-- CSC Open habitats including grasslands, scrublands, and wetlands

Occurs. Observed occasionally in non-forested areas of ownership.

Contopus borealis Olive-sided flycatcher --/-- CSC Forest and woodland riparian zones Moderate. Commonly seen throughout the Green Diamond ownership; confirmed nest sites.

Coturnicops noveboracensis Yellow rail --/-- CSC, USFS-S

Densely vegetated marshes or wet meadows Unlikely. Limited habitat availability.

Cypseloides niger Black swift --/-- CSC Breeds in small colonies adjacent to waterfalls in deep canyons and coastal bluffs, forages widely

Unlikely. Limited habitat availability.

Elanus leucurus White-tailed kite --/-- C-FP Nests along rivers and marshes associated with oak woodlands in foothills and valley margins, forages in open meadows and grasslands


Empidonax traillii brewsteri Little willow flycatcher --/SE Riparian areas with extensive willow vegetation

Occurs. One breeding site known in the Klamath region. Low potential for occurrence in other areas.

Falco peregrinus anatum American peregrine falcon

--/-- C-FP, CDF-S

Breeds on high cliffs near wetlands, lakes, and rivers.

Occurs. Known to occupy and reproduce within Green Diamond property (two active tree nests and one active cliff nest as of 2011).

Fratercula cirrhata Tufted puffin --/-- CSC Breed on offshore rocks or shore cliffs. Unlikely. Habitat not present.

Haliaeetus leucocephalus Bald eagle --/SE C-FP, USFS-S, CDF-S

Nests in large old-growth trees near the ocean shore, lakes, and rivers.

Occurs. Regular winter inhabitant; 12 nest sites known on/adjacent to ownership (Salmon Creek, Jacoby Creek, Mad River, Big Lagoon and Klamath River; moderate potential for occurrence in other areas; some habitat present).

Icteria virens Yellow-breasted chat --/-- CSC Riparian thickets and early seral forest Unlikely. Some habitat present. Rare occurrences in the Mad River area in 1996.

Oceanodroma furcata Forked-tailed storm petrel

--/-- CSC Breed on offshore rocks and islands Unlikely. Habitat not present.


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Pandion haliaetus Osprey --/-- CDF-S Freshwater lakes, bays, ocean shore, large streams

Occurs. Known to occupy and reproduce within Green Diamond property (Ah Pah Ridge, Arcata South, Fields Landing, McWhinney Creek, Requa). Moderate potential for occurrence in other areas.

Progne subis Purple martin --/-- CSC Forest and woodland with cavity trees and riparian zones

Occurs. Occasionally seen throughout the ownership and several nest sites known in Korbel tract. Moderate potential for occurrence in other areas.

Riparia Bank swallow --/ST Colonial nester in riparian area with vertical sandy banks composed of fine soils

Moderate. Some habitat present; no individuals observed.

Setophaga petechia Yellow warbler --/-- CSC Riparian woodland Moderate. Seen commonly throughout Green Diamond’s ownership, but no work done to confirm nest sites.

Mammals

Antrozous pallidus Pallid bat --/-- CSC, USFS-S

Roosts in trees, caves, crevices, and buildings; feeds in a variety of open habitats

Moderate. Occurs throughout the region, roosting sites include trees, caves and rock crevices.

Arborimus albipes White-footed vole --/-- CSC Mature conifer forests, small streams with dense alder and shrub cover

Unlikely. May occur within the ownership, but their presence has not been confirmed.

Corynorhinus townsendii Townsend’s big-eared bat --/-- CSC, USFS-S

Humid coastal regions of central and Northern California, southern Oregon

Moderate. May occur within the ownership, but their presence has not been confirmed.

Martes caurina humboldtensis

Humboldt marten --/SC CSC, USFS-S

Mesic coniferous forests Occurs. Documented on Green Diamond lands.

Myotis thysanodes Fringed myotis --/-- USFS-S Wide variety of habitats. Roosts in caves, buildings, and mines.

Unlikely. Roosting habitat uncommon.

Invertebrates

Bombus occidentalis Western bumble bee --/-- USFS-S Generalist pollinators of a wide variety of flowering plants and crops

?

Polites mardon Mardon skipper --/-- USFS-S Prairies and meadows, particularly in mesic serpentine soils

Unlikely. Known from two locations in Del Norte County.


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Speyeria zerene hippolyta Oregon silverspot butterfly

FT/-- Coastal meadows in Del Norte County. The larvae feed only on the foliage of violets, primarily the western dog violet (Viola adunca)

Unlikely. Apparently extirpated from a site north of Smith River near Highway 101, outside of Action Area. Extant population known near Lake Earl.

Speyeria zerene behrensii Behren’s silverspot butterfly

FE/-- Coastal terrace prairie habitat from Mendocino County south to Sonoma County.

Does not occur. Out of range

Source: California Department of Fish and Wildlife. 2017. California Natural Diversity Database. Action Area query conducted on December 28, 2017. Notes:




Green Diamond = Green Diamond Resource Company

USFWS = U.S. Fish and Wildlife Service

ESA (USFWS) and CESA Status: FE = Federal Endangered FT = Federal Threatened SE = California Endangered ST = California Threatened SC = California Candidate for Listing Other Status: CDF-S = California Department of Forestry and Fire Protection Sensitive Species C-FP = California Fully Protected Species CSC = California Species of Special Concern (CDFW) USFS-S = US Forest Service Sensitive Species


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Table 3-11. Special-status Aquatic Species with Potential to Occur in the Green Diamond Action Area

Scientific Name Species ESA/ CESA

Other Status Range/Habitat Associations Potential for Occurrence in Action Area

Fish Acipenser medirostris Green sturgeon, northern DPS --/-- CSC Coastal watersheds north of the Eel River. Known to

spawn in the Klamath River (California) and Rogue River (Oregon).

Moderate. Known from the lower Klamath River.

Entosphenus tridentatus Pacific lamprey --/-- CSC, USFS-S

Coastal watersheds from Hokkaido Island, Japan, and along the Pacific Rim, including Alaska, Canada, Washington, Oregon, Idaho, and California to Punta Canoas, Baja California, Mexico.

Occurs in all 11 HPAs within the Action Area

Eucyclogobius newberryi Tidewater goby FE/-- CSC Coastal drainages from Agua Hedionda Lagoon, in San Diego County, north to the mouth of the Smith River in Del Norte County.

Occurs in 6 of 11 HPAs within the Action Area

Oncorhynchus clarki Coast cutthroat trout --/-- CSC, USFS-S

Coastal drainages from the Eel River to Prince William Sound in Alaska


Oncorhynchus kisutch coho salmon, Southern Oregon/ Northern California Coast ESU

FT/ST Coastal drainages from Cape Blanco, Oregon to Punta Gorda, California


Oncorhynchus mykiss Steelhead, Klamath Mountains Province DPS

--/-- CSC, USFS-S

Elk River in Oregon to the Klamath and Trinity Rivers in California, inclusive

Occurs in 4 of the 11 HPAs within the Action Area

Oncorhynchus mykiss Steelhead, Northern California DPS

FT/-- All naturally spawned anadromous O. mykiss (steelhead) populations below natural and manmade impassable barriers in California coastal river basins from Redwood Creek southward to, but not including, the Russian River


Oncorhynchus tshawytscha Chinook salmon, California Coastal ESU

FT/-- Coastal drainages from Redwood Creek in Humboldt County to the Russian River in Sonoma County


Oncorhynchus tshawytscha Chinook salmon, Klamath-Trinity Rivers ESU

--/-- CSC, USFS-S

Klamath River Basin upstream from the confluence of the Klamath and Trinity Rivers


Oncorhynchus tshawytscha Chinook salmon, Southern Oregon/Northern California Coastal ESU

CSC Coastal drainages from Cape Blanco, Oregon to the Lower Klamath River (inclusive)



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Table 3-11. Special-status Aquatic Species with Potential to Occur in the Green Diamond Action Area

Scientific Name Species ESA/ CESA

Other Status Range/Habitat Associations Potential for Occurrence in Action Area

Source: California Department of Fish and Wildlife (CDFW). 2017. California Natural Diversity Database. Action Area query conducted on December 28, 2017. Notes:


DPS = Distinct Population Segment



ESU = Evolutionary Significant Unit

HPA = Hydrographic Planning Area

USFWS = U.S. Fish and Wildlife Service

ESA (USFWS) and CESA Status: FE = Federal Endangered FT = Federal Threatened SE = California Endangered ST = California Threatened SC = California Candidate for Listing Other Status: CDF-S = California Department of Forestry and Fire Protection Sensitive Species C-FP = California Fully Protected Species CSC = California Species of Special Concern (CDFW) USFS-S = US Forest Service Sensitive Species

http://encyclopedia.thefreedictionary.com/Evolutionary+Significant+Unit


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Table 3-12. Del Norte and Humboldt Counties Population, January 1991 to 2015

Year Del Norte Humboldt

1991 25,488 120,404

1992 26,915 122,410

1993 27,427 124,028

1994 27,707 124,569

1995 27,843 124,721

1996 27,823 125,161

1997 28,214 125,847

1998 28,309 125,907

1999 27,742 125,926

2000 27,514 126,858

2001 27,595 127,448

2002 27,912 128,841

2003 28,254 130,097

2004 28,679 131,142

2005 28,955 131,655

2006 28,995 131,996

2007 29,260 132,172

2008 29,428 132,795

2009 29,500 133,269

2010 28,544 134,663

2011 28,498 135,218

2012 28,359 134,923

2013 28,225 134,698

2014 28,219 134,609

2015 27,254 135,727

Source: California Employment Development Department. 2018. Labor and market info – Population Data Search Tool. Accessed February 9, 2018. http://www.labormarketinfo.edd.ca.gov/data/labor-market-data-library.html.


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Table 3-13. Del Norte and Humboldt Counties Employment by Industry, 2015

Industry

Del Norte County Humboldt County

Jobs % Jobs %

Labor Force

Civilian Employment 9,030 91.5 58,970 94.6

Civilian Unemployment 840 8.5 3,480 5.6

Total Labor Force 9,870 62,450

All Industries

Nonfarm

Total Private 3,980 44.1 30,800 50.6

Goods Producing 230 2.5 4,090 6.9

Manufacturing 80 0.9 2,030 3.4

Service Providing 7,360 83.9 43,680 74.1

Private Service Producing 3,750 41.5 29,720 50.4

Trade, Transportation and Utilities 1,010 11.2 9,380 15.9

Information 80 0.9 500 0.8

Financial Activities 190 2.1 1,630 2.8

Professional and Business Services 210 2.3 2,700 4.6

Educational and Health Services 1,400 15.5 8,110 13.8

Leisure and Hospitality 760 8.4 5,570 9.4

Other Services 100 1.1 1,880 3.2

Government 3,830 42.4 13,950 23.7

Federal Government 150 1.7 750 1.3

State and Local Government 3,690 40.9 13,190 22.4

State Government 1,570 17.4 2,130 5.9

Local Government 2,120 23.5 9,720 16.5

Total Nonfarm 7,820 86.6 47,760 81.0

Total Farm 290 3.4 870 1.5

Total, all Industries 8,120 89.9 48,630 82.5

Source: California Employment Development Department. 2017. Labor Market Information. Accessed February 9, 2018. http://www.labormarketinfo.edd.ca.gov. Notes: Percentages are based on Civilian Employment.

Numbers have been rounded.

Appendix C Rationale for Excluding Alternative

Barred Owl Management Approaches

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Rationale for Excluding Alternative Barred Owl Management Approaches In developing the alternatives for the Proposed Action, the U.S. Fish and Wildlife Service (Service) considered several additional approaches to barred owl management under the Forest Habitat Conservation Plan (FHCP). Some approaches have been considered in the scientific literature (Johnson et al., 2008) as potentially feasible means to study the effects the barred owl may have on the Northern Spotted Owl (NSO). These approaches and the reasons for not analyzing them in detail as alternatives are provided below.

Alternative Scales of Barred Owl Removal Under the Proposed Action, the scale and period of removal would transition from the limited extent and number that occurred under the completed Phase 1 experiment to a potentially broader scale under a new experiment that would continue for the full term of the FHCP. Under this proposal, barred owl removal would be scaled back to reduce the total area and number subject to removal. While developing the action alternatives, the Service considered several other options that would rely on other removal scales and study formats, and other removal methods. After much consideration, the Service chose not to consider these different approaches in detail. The following subsections provide reasons for not pursuing their full analysis.

Site-specific Removal of Barred Owls This approach would remove barred owls around individual NSO sites and would research and evaluate barred owl effects at multiple sites. Barred owl removal could be implemented at some or all currently occupied NSO sites in the Plan Area. Barred owls would not be removed in areas where no occupied or recently occupied NSO sites occur. With a sufficient sample size, data from individual sites could be pooled to evaluate the effectiveness of barred owl removal on NSO conservation in the plan area.

After careful consideration, the Service identified the following logistical and biological difficulties in implementing this approach:

• Substantial logistical limitations would occur. The large perimeter-to-area ratio of the relatively small treatment areas around each NSO site allows for extensive and rapid reoccupancy of the site by barred owls. Barred owls that currently occupy forest stands not near occupied NSO sites would continue to live and reproduce and their offspring would likely disperse into stands near spotted owl sites where other barred owls have already been removed. This makes it more difficult to maintain spotted owl territories free of barred owls for a substantial period and would not relieve most spotted owls from barred owl competition or aggressive encounters for a full breeding season, substantially reducing the effectiveness of the research.

• Barred owls must be removed from an area around each spotted owl site of sufficient size to include the full annual home range of the spotted owl pair, and maintained for the years of spotted owl occupancy, to ensure adequate nesting opportunities and determine the effect of removal. Removal of barred owls on a site-by-site basis requires a very large removal effort in relation to the information gained.

• This approach does not provide information, or result in spotted owl conservation, that would not otherwise occur in a more effective and efficient manner under one or more of the action alternatives already being considered.

APPENDIX C RATIONALE FOR EXCLUDING ALTERNATIVE BARRED OWL MANAGEMENT APPROACHES

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• The influence of confounding biotic and abiotic factors is greater than under removal strategies considered in the FHCP due to the scattered nature of the NSO sites. The large and scattered spatial scale adopted under this approach would unnecessarily limit the interpretation of turnover rates and provides a low ability to detect differences (i.e., reduced strength of inference), which limits the effectiveness of this approach as an Adaptive Management tool.

This approach was not considered for detailed analysis because it does not result in an analytical method not already available under one or more other action alternatives, would be costlier to implement, and is anticipated to result in a higher number of barred owls to be removed during the full term of the Habitat Conservation Plan.

Partial Removal of Barred Owls Under this approach, rather than remove all barred owls within the Plan Area or a significant portion of it, Green Diamond Resource Company (Green Diamond) would remove a predetermined proportion of the barred owl population in the Plan Area, or reduce barred owl numbers to a specific density, and track the effects on NSOs. If enough experiments were conducted in the Plan Area, with different levels of barred owl removal, Green Diamond might be able to determine the threshold level at which barred owls begin to adversely affect NSOs and their population within the Plan Area.

This experimental approach was dismissed from detailed analysis for the following reasons:

• This approach was already considered in principle under the completed Phase 1 experiment. During Phase 1, Green Diamond studied and evaluated the response of spotted owl survival and reproduction, and compared it to trends estimated from similar data collected prior to removal of barred owls and from other data within the region. Under this proposal, barred owl removal in the Plan Area would be relaxed. During the FHCP’s Phase 3, Green Diamond already has the flexibility to explore the feasibility of coexistence between barred owls and spotted owls by testing different densities of barred owls within the spotted owl landscape, while still ensuring sufficient numbers of spotted owls to fully meet Green Diamond’s conservation commitments.

• The Service anticipates that testing and documenting the thresholds at which barred owl densities would have minimal adverse effects on spotted owl populations in the Plan Area would require several to many years of research, under a variety of experimental conditions. The Service believes this research is best deferred until other ecological effects of barred owls are better understood, and is not an appropriate approach for initial implementation of the FHCP or other action alternative.

Invasion Study This demography-type approach (Johnson et al., 2008) can only be conducted in areas where barred owls are just beginning to invade. The basic concept is fundamentally different than a removal study in that it prevents barred owls from colonizing a previously unoccupied landscape by removing them as they invade, while allowing the invasion to proceed with no removal at a comparable experimental control area. This approach determines the effect of barred owls on NSOs by comparing the response of spotted owls in the invasion area to those in an area where barred owls are not allowed to invade.

This approach was dismissed from detailed analysis in the Environmental Impact Statement (EIS) for the following reasons:

• It is limited to very specific conditions at the leading edge of the barred owl range expansion or other locations where barred owl populations are currently very low or nonexistent, but are anticipated to substantially increase within a few years.


PR0105180936SAC C-3

• An invasion-type study is already considered in the FHCP’s proposed Phase 3 experiment, described in the EIS, albeit under the third phase of research into barred owl effects.

Alternative Methods of Studying Northern Spotted Owl/Barred Owl Interactions Removal of barred owls under the FHCP would be solely by lethal means, and would be conducted according to the protocol adopted by Green Diamond during the completed Phase 1 experiment. The Service considered several means of conducting barred owl/NSO research, including non-lethal removal, but found each to be infeasible or not consistent with the Purpose and Need and decided to not include any for detailed review. The alternative approaches to lethal removal that were considered, and the reasons for not bringing them forward for detailed analysis, are described in the following subsections.

Reproductive Interference This approach to reducing the number of barred owls in the Plan Area would reduce the productivity of territorial barred owls by removing eggs from nests, rendering eggs unviable (e.g., oiling eggs), conducting surgical sterilization, or using immuno-contraceptive vaccines. Reducing productivity of barred owls would hypothetically limit the number of barred owls being produced within the Plan Area to the point of maintaining a reduced population and limiting barred owl competition with NSOs.

After careful consideration, the Service identified the following logistical and biological difficulties in implementing this approach:

• Barred owl reproduction lost in the Plan Area as a result of implementing reproductive interference measures would simply be replaced by dispersers entering the Plan Area from other, unmanaged populations. This approach would, therefore, not significantly reduce barred owl conflicts with spotted owls.

• Finding nests and removing eggs would require that nests are located early in the nesting season each year within a very narrow seasonal period and that re-nesting efforts are tracked, procedures that would be extremely labor intensive and costly. Finding barred owl nests is difficult and missing even a few would provide replacements (in addition to immigrating dispersers) for older barred owls that die, resulting in few or no empty sites for spotted owls to colonize. It would be nearly impossible to substantially reduce barred owl influences on enough spotted owl pairs to adequately test any hypothesis.

• The process of conducting the surveys and nest locating would substantially affect any NSO breeding in the area because spotted owls show strong evidence of reduced calling and inhibited breeding behavior when confronted with barred owl territorial behavior. That is, the intensive and extensive calling surveys for barred owls, and associated nest location efforts, would inadvertently result in reduced breeding success of spotted owls, which typically reduce their own territorial and breeding behaviors to avoid adverse confrontations with barred owls.

• The implications of having non-nesting barred owls in the same area where spotted owls attempt to breed are not fully understood. It is entirely possible that barred owls that abandon their nesting attempt due to our reproductive interference may increase their daily use of habitat near spotted owl nest trees. This may increase their aggressive encounters with spotted owls, because they are no longer bound to their own nest sites.

This approach to barred owl removal research was not brought forward in the EIS under a separate action alternative because the logistics of researching reproductive interference to reduce barred owl/NSO conflicts are currently not considered to be feasible and show only limited potential for future


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implementation. In addition, this approach does not meet the Purpose and Need of the Proposed Action.

Studies of Species Interactions without Removal This approach focuses on observational studies of barred owl and spotted owl ecology and interactions between the two species. This approach would rely on direct and indirect observation of interspecies encounters and interactions to determine specific mechanisms of conflict and competition and the conditions under which coexistence could occur.

After careful consideration, the following limitations of this approach were noted:

• Although observations may provide information on potential underlying mechanisms, such an experiment would have limited ability to directly test the impact of barred owls on NSOs and their population. There would be only limited ability to include a barred-owl-free control in such an observational study.

• Some studies and monitoring efforts, including data collected under separate Migratory Bird Treaty Act permits in the Plan Area (Phase 1), already suggest that spotted owl numbers and territories decline where barred owls invade. Other observational studies provide anecdotal and correlational evidence of this phenomenon. However, stakeholder groups and other public entities have indicated that data from designed studies, where a clear cause and effect relationship can be demonstrated, is preferred. While observational studies can establish an association between barred owl presence and spotted owl declines, they cannot unambiguously determine barred owls as the cause of the declines, because other factors such as weather or habitat differences are very difficult to account for under this approach.

• This study approach would not test the effects of barred owl removal on spotted owl populations or provide information on the effectiveness of removals in stemming spotted owl population declines.

• No readily apparent, feasible Adaptive Management response is evident that could be implemented from a successful completion of this research because information to support a management response, including future removal, would not result from an observational study.

• The cost of observational studies is anticipated to be exceedingly high, resulting from the need to have numerous trained individuals available to conduct such observations as locating such potential encounters is difficult.

This approach does not meet the Purpose and Need of the Proposed Action for the following reasons:

• Would not provide an unambiguous conclusion regarding the barred owl role in declines of NSOs

• Would not lead to a clear Adaptive Management response to the decline

• Would be unacceptably costly to implement for information to be gained

This approach to barred owl research without removal was not brought forward in the EIS under a separate action alternative because it would not meet the Purpose and Need of the Proposed Action, would be costly to implement, and would not directly address questions on the effects of barred owls on the NSO population.

Remove Food Competition with Supplemental Feeding The Service considered two potential methods to reduce competition between barred owls and NSOs through supplemental feeding: (1) feed spotted owls to reduce food stress and meet their energetic demands and (2) feed barred owls to reduce competition with spotted owls for native prey.


PR0105180936SAC C-5

After careful consideration, the Service determined that this approach has the following insurmountable logistic difficulties, as well as adverse biological implications, in its application: • Supplemental feeding of barred owls or NSOs would be an extremely labor-intensive activity,

requiring potentially daily feeding attempts at 100 or more owl sites or nests, and would need to continue indefinitely. The costs and operational difficulties of daily supplemental feeding of dozens to hundreds of spotted owls or barred owls would be logistically infeasible and extremely costly.

• This approach assumes that food competition is the sole or primary mechanism by which barred owls affect NSOs, rather than competition for space (territory) or aggressive encounters. It also assumes that a reduction in food competition would allow the two species to coexist. Although competition for food may occur, current information indicates that competition for space, and aggressive interactions, are more likely causes of adverse effects by barred owls on spotted owls and their populations.

• Artificial feeding of NSOs could have unintended future consequences, such as dependence on food supplementation, that results in reduced survival and fitness.

• This approach would be contrary to the stated intent of the Federal Endangered Species Act (ESA) to conserve listed species “…and the ecosystems upon which they depend.” The Service anticipates that habitat management aspects of the FHCP and other action alternatives would provide an abundance of prey, especially woodrats and voles, sufficient to support a viable population of NSOs in the Plan Area. Artificial feeding of either species would create a reliance of spotted owls on continued human interactions that would be contrary to any future decision to delist the species as a result of its recovery in its native habitat.

This approach would not meet the Purpose and Need of the Proposed Action, would not address the underlying causes of competition between the two species, would not be consistent with the stated intent of the ESA, and would not be economically practicable or feasible. Hence, this approach was not brought forward in the EIS as an action alternative for detailed consideration.

Forest or Habitat Management to Favor Northern Spotted Owls or Hinder Barred Owls This approach would rely on focused research into NSO and barred owl habitat use, their responses to various forest structural conditions, and feasible silvicultural methods that could be employed to promote habitat conditions disproportionately favorable to NSOs. If successful, this research would determine whether specific habitat conditions could be promoted that would favor NSO over barred owls and result in coexistence of both species in the Plan Area.

Although this approach may show some promise as a long-term strategy for forest management, the Service determined that it suffers from the following limitations in the short term:

• This approach assumes that forest conditions exist, or can be created, under which NSO have a substantial competitive advantage over barred owls and that forests can feasibly be managed on a commercial basis for these conditions. To date, barred owls have been shown to be capable of occupying, at high densities, virtually all types of habitat used by NSOs, including a broad range of seral conditions ranging from mid-seral to old growth. No clear differentiation of habitat conditions disproportionately favorable to NSOs has yet been identified despite attempts in some studies to examine potential differentiation of habitat use between the two species.

• Although barred owls have not displaced NSO as rapidly in some areas and under some conditions, there are no substantially large areas within the range of the NSO where barred owls are not present, or will not be present within the next few years, including throughout the Plan Area and in


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the most ancient old growth coast redwood forest in the adjacent Redwood National and State Parks.

• Managing habitat to be beneficial to NSOs and simultaneously unfavorable to barred owls, if found to be feasible, would require a long period of time to develop and test at a large scale. Such habitat fixes could not be implemented in less than the several decades necessary for forest structural conditions to develop.

• Long-term monitoring of a portion of the NSO population, as already prescribed in the action alternatives, in combination with ongoing research and limited reinvasion of the Plan Area by barred owls under Phase 3 may provide additional opportunities to determine forest conditions conducive to NSO viability. In this sense, a forest habitat research approach is already built into the action alternatives, including the FHCP. However, at the present time, the Service is unaware of forest management or silvicultural treatments with substantial promise to avoid an unacceptable decline in the NSO population in the short term.

• During the time required to manage forests for changed habitat conditions and possibly detecting a NSO response, barred owl populations would continue to increase and expand, resulting in an anticipated substantial decline or elimination of the NSO population in the Plan Area. Such a decline would result in a severe reduction in the amount of take allowable under the FHCP, substantially reducing or precluding Green Diamond’s ability to continue as a viable corporation.

This approach was not brought forward in the EIS under a separate action alternative because it would not meet the Purpose and Need of the Proposed Action and would not directly address questions on the effects of barred owls on NSOs. In addition, this approach is already considered in a similar fashion in Phase 2 of the FHCP.

Northern Spotted Owl Captive Propagation This approach would consider captive propagation of NSOs for release into the Plan Area to bolster wild populations as a means of conserving the NSO in the Plan Area without having to rely on barred owl removal.

After careful consideration, the Service identified the following substantial and insurmountable limitations to this approach:

• A substantial investment of time and money would be needed to develop an initial population of breeding NSOs, as well as facilities and trained individuals to care for and handle the animals, before actual release into the wild could occur. Establishing such facilities, and developing the techniques to promote successful release of spotted owls into the wild with some assurance of their successful establishment at this scale, would require several years to decades to develop with no assurance that it would be successful in reestablishing or maintaining spotted owls in the Plan Area.

• Captive-reared and released NSOs likely would not survive and reproduce because barred owl competition and aggressive encounters that result in loss of spotted owls or failure to establish nest sites would not have been addressed.

• If captive propagation proved successful, and spotted owls could be successfully released into the wild, it would not result in conservation of the spotted owl or be an effective long-term management tool consistent with the issuance criteria of the permits.

• This approach would be contrary to the stated intent of the ESA to conserve listed species “… and the ecosystems upon which they depend.” The FHCP is anticipated to provide an abundance of prey, especially woodrats and voles, in close proximity to suitable nesting habitat sufficient to support a viable population of NSOs in the Plan Area. Artificial propagation would create a reliance on


PR0105180936SAC C-7

continued human interactions that would be contrary to any future decision to delist the NSO as a result of recovery within its native habitat.

This approach was not brought forward in the EIS under a separate action alternative because it would not address the underlying issue of conserving NSOs and the ecosystems upon which they depend in the Plan Area consistent with the issuance criteria for the permits and, therefore, would not meet the Purpose and Need.

Non-lethal Removal Methods This method would consider live capture and transport of barred owls out of the Plan Area and relocation to other favorable habitat. Non-lethal removal is only possible to the extent that Green Diamond could find permanent locations ready to accept the captured birds. In its EIS for barred owl removal experiments (USFWS, 2013), the Service examined several placement options based on two general approaches: translocation and release to the wild, or permanent captivity.

To avoid spreading the barred owl more quickly outside of its native range, the Service would limit translocation to the historical (pre-1900) range of the northern barred owl (Strix varia varia), the subspecies that has expanded its range into southern Canada and the western U.S. The Service will not consider translocation of barred owls anywhere outside of this historical range to avoid conflicts with other native species, similar to the effects that barred owls already appear to have on the NSO and possibly a wide range of other native fauna.

Translocations of barred owls are most likely to be successful and not result in the death of the animal where populations do not already saturate the available habitat. As part of the development of the experimental removal project (USFWS, 2013), the Service contacted states within the historical range of the northern barred owl (the subspecies of barred owl that is the most likely source population of the invasion into the western U.S.) to determine if they were interested in receiving barred owls for relocation or reintroduction. No responding states expressed interest in receiving any captured barred owls. The primary reason was a lack of empty, suitable habitat. In addition, concerns over transmission of western diseases and genetic changes were expressed as reasons for not considering translocation. Therefore, translocation is not a viable option.

The Service considered the option of permanent captivity of live-captured barred owls. Based on a preliminary survey of zoos, zoological parks, and related facilities as part of the development and environmental review of the barred owl experimental removal project (USFWS, 2013), the Service found little interest in the potential placement of barred owls, resulting in requests for only five individual birds. These requests will be filled as part of the implementation of that project. No placement of barred owls would be needed from Green Diamond under this Alternative in the foreseeable future. Therefore, the Service does not believe a requirement for live placement is a viable approach to consider in this EIS. However, nothing in the Proposed Action would preclude future live capture of barred owls for permanent placement in educational and scientific institutions, should a larger need arise. The Service anticipates that future requests for live barred owls can be met through other opportunities on Federal lands, if research conducted under this and other efforts indicate that barred owl removal on Federal lands is a feasible and effective means of conserving the NSO.

The FHCP proposes to remove more than 1,000 barred owls. If limited to non-lethal removal methods, Green Diamond could not capture barred owls without a location ready to accept them, greatly hindering or precluding their ability to remove enough barred owls in the Plan Area to effectively achieve conservation of the NSO. This would be a direct conflict with their commitment to spotted owl conservation and ability to meet the issuance criteria of the permits. Therefore, an alternative based solely on non-lethal removal methods would not meet the Purpose and Need, and was not brought forward in the EIS for additional review and analysis.


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Considering the lack of opportunities to place barred owls captured in the Plan Area, and other limitations described above for translocation or long-term retention of live-captured barred owls, such methods would not meet the Purpose and Need of the Proposed Action, would be extremely difficult and costly to implement, and would not provide the information necessary for long-term conservation of the NSO. Therefore, these approaches were not brought forward in the EIS under a separate action alternative.

References Johnson, D. H., G. C. White, A. B. Franklin, L. V. Diller, I. Blackburn, D. J. Pierce, G. S. Olson, J. B. Buchanan, J. Thrailkill, B. Woodbridge, and M. Ostwald. 2008. Study design for barred owl removal experiments to evaluate potential effects on northern spotted owls. Report prepared for the U.S. Fish and Wildlife Service, Lacey, Washington, and Yreka, California. Washington Department of Fish and Wildlife, Olympia, Washington. 32p.

U.S. Fish and Wildlife Service (USFWS). 2013. Experimental Removal of Barred Owls to Benefit Threatened Northern Spotted Owls. Final Environmental Impact Statement. Notice of Availability. Federal Register 78:44855-44589.

Appendix D References

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References Abatzoglou, J.T., K.T. Redmond, and L.M. Edwards. 2009. “Classification of regional climate variability in the State of California.” Journal of Applied Meteorology and Climatology 48: 1527-1541.

Ager, A.A., M.A. Finney, B.K. Kerns, and H. Maffei. 2007. “Modeling wildfire risk to northern spotted owl (Strix occidentalis caurina) habitat in central Oregon, USA.” Forest Ecology and Management 246 (2007) 45-56.

American Veterinary Medical Association (AVMA). 2013. AVMA Guidelines for the Euthanasia of Animals. https://www.avma.org/KB/Policies/Documents/euthanasia.pdf.

Anderson, M.A. 2009. The State of Climate Change Science for Water Resources Operations, Planning, and Management. Public Review Draft. California Department of Water Resources, CA. 41pp. https://water.ca.gov/LegacyFiles/waterplan/docs/cwpu2009/0310final/v4c02a16_cwp2009.pdf.

Anthony, R.G., M.C. Hansen, K.A. Swindle, and A.M. Ellingson. 2000. Demographic Characteristics of Northern Spotted Owls on Lands Managed by the Oregon Department of Forestry. Final Research Report to the Oregon Department of Forestry. Oregon Cooperative Fish and Wildlife Research Unit, Department of Fisheries and Wildlife, Oregon State University, Corvallis, Oregon.

Anthony, R.G., G.S. Olson, S. Ackers, E. Forsman, W.J. Ripple, and E.M. Glenn. 2002. Predicting Abundance and Demographic Performance of Northern Spotted Owls from Vegetative Characteristics: Report on Results of Western Oregon Cascades - H.J. Andrews Experimental Forest. As Part of The Northern Spotted Owl Effectiveness Monitoring Plan for The Northwest Forest Plan. Unpublished Annual Report. Oregon Cooperative Fish and Wildlife Research Unit, Department of Fisheries and Wildlife, Oregon State University, Corvallis, Oregon.

Anthony, R.G, E.D. Forsman, A.B. Franklin, D.R. Anderson, K.P. Burnham, G.C. White, C.J. Schwarz, J.D. Nichols, J.E. Hines, G.S. Olson, S.H. Ackers, L.S. Andrews, B.L. Biswell, P.C. Carlson, L.V. Diller, K.M. Dugger, K.E. Fehring, T.L. Fleming, R.P. Gerhardt, S.A. Gremel, R.J. Gutiérrez, P.J. Happe, D.R. Herter, J.M. Higley, R.B. Horn, L.L. Irwin, P.J. Loschl, J.A. Reid, and S.G. Sovern. 2006. “Status and Trends in Demography of Northern Spotted Owls, 1985 2003.” Wildlife Monographs. Vol. 163. pp. 1-48.

Aubry, K.B., and D.B. Houston. 1992. “Distribution and status of the fisher (Martes pennanti) in Washington.” Northwest Naturalist. Vol. 73. pp. 69-79.

Aubry, K.B., and J.C. Lewis. 2003. “Extirpation and reintroduction of fishers (Martes pennanti) in Oregon: implications for their conservation in the Pacific states.” Biological Conservation. Vol. 114. pp. 79-90.

Aubry, K.B., and C.M. Raley. 2006. Ecological Characteristics of Fishers (Martes Pennanti) in the Southern Oregon Cascade Range. 31. USDA Forest Service, Pacific Northwest Research Station, Olympia Forestry Sciences Laboratory, 3625 93rd Ave. SW, Olympia, Washington 98512.

Aubry, K.B., M.J. Crites, and S.D. West. 1991. “Regional patterns of small mammal abundance and community composition in Oregon and Washington.” Wildlife and Vegetation of Unmanaged Douglas-fir Forests. Ruggiero, L.F., K.B. Aubry, A.B. Carey, and M.G. Huff, technical coordinators. USDA Forest Service, GTRPNW- 285.

Aubry, K.B., C.M. Raley, T.J. Catton, and G.W. Tomb. 2002. Ecological characteristics of fishers in the southern Oregon Cascade Range: final progress report: 1 June, 2002. USDA Forest Service, Pacific Northwest Research Station, Olympia, WA.

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Zielinski, W.J., and N.P. Duncan. 2004. “Diets of sympatric populations of American martens (Martes americana) and fishers (Martes pennanti) in California.” Journal of Mammalogy. Vol. 85. pp. 470-477.

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Appendix E Responses to Comments

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JeanPublic 1

I am totally opposed to killing barred owls under the FHCP.

Comment noted.

EPA 1

EPA rated the Proposed Action as “Lack of Objections.”

Comment noted.

EPA 2

EPA suggests that the Final EIS (FEIS) disclose whether any project activities would be subject to the requirements of Section 404 of the Clean Water Act (CWA), and the status of any consultation with the Army Corps of Engineers regarding the Proposed Action.

Issuance of an ITP under Section 10 of the ESA does not obviate the need to comply with the CWA. Green Diamond is required to comply with CWA requirements, in the same manner, with or without the FHCP. For that reason, the Army Corps of Engineers is not a participant in the FHCP process.

Aquatic species and their associated habitats are the focus of the Aquatic Habitat Conservation Plan/Candidate Species Agreement with Assurances (AHCP/CCAA), which was approved in July 2007. Some elements of the AHCP/CCAA will likely contribute towards the achievement of beneficial uses. The AHCP/CCAA measures, and the environmental effects of those measures, were described in the AHCP/CCAA EIS (NMFS and USFWS, 2007). As described in Section 4.2.4 of this EIS, implementation of the FHCP may have a positive benefit as it extends the aquatic protections and protections for unstable geologic areas from the AHCP/CCAA.

EPA 3

EPA suggests the FEIS provide additional detail specifying how proposed activities would comply with state and federal industrial storm water regulations.

See response to EPA 2. The Proposed Action is the issuance of an ITP and is not intended to serve as a TMDL compliance document, Report of Waste Discharge, Stormwater Notice of Intent, or other compliance documents related to Federal stormwater regulations. Issuance of an ITP under Section 10 of the ESA does not obviate the need to comply with these regulations.

EPA 4

EPA suggests that the Service review the science and analysis included in the Synthesis of Science to Inform Land Management within the Northwest Forest Plan Area, and evaluate in the FEIS whether its key findings could inform the conservation and management actions in the FHCP.

Much of the information contained in the Synthesis of Science to Inform Land Management within the Northwest Forest Plan (NWFP) Area, and other NWFP-related documents, were considered and incorporated into the EIS and FHCP.

COMBINED DRAFT RESPONSES TO DEIS FOR GD FHCP PUBLIC COMMENTS 12/10/2018

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CDFW 1 and 2

In Comment Section 1, CDFW reviewed the relevant scientific literature concerning Habitat Fitness Potential (HFP) modeling for Northern Spotted Owls (NSOs). CDFW also reviewed a letter from Dr. Alan Franklin (who developed this modeling approach) to the Service (see Attachment 3), regarding the appropriate application and interpretation of HFP modeling for NSOs. The FEIS should evaluate the appropriateness of using territory-scale HFP modeling as a basis for large-scale conservation planning in the FHCP. The Service should consult with a third-party quantitative NSO ecologist (such as a principle investigator of an NSO demographic study) on HFP modeling to inform the FEIS evaluation of this technically complex information.

The FEIS should evaluate the appropriateness of comparing modeled projections of future HFP to trends in estimated abundance for monitoring the effectiveness of the FHCP’s conservation strategy.

The Service was engaged in the 10-year review of the 1992 NSO HCP and we contracted with Dr. Alan Franklin as an independent technical reviewer for that process and review of the 1992 NSO HCP 10-year report. Therefore, we did consult with an independent quantitative NSO ecologist regarding evaluation of NSO habitat, modeling of fecundity, survival and development of the NSO habitat fitness model for Green Diamond ownership, and predictions of habitat fitness on the Green Diamond ownership (Appendix C, C-3, Chapter 2 of the FHCP). Please note that Dr. Franklin’s involvement in review of the 10-year report was occurring simultaneously with development of the Draft Recovery Plan for the Northern Spotted Owl, and Dr. Franklin’s comments on the Green Diamond 10-year report occurred after his 2007 memo that was included in the CDFW comments. Dr. Franklin’s comments in the 2007 memo were specific to his work and the Service’s application of those findings on habitat fitness into the Draft Recovery Plan and not to Green Diamond’s modeling of habitat fitness.

Green Diamond predicted habitat fitness in the Plan Area using the complete final model (the top ranked model with the full suite of covariates). Dr. Franklin pointed out flaws in application of his habitat fitness model in the Draft Recovery Plan, which included selective use of a single covariate to explain NSO habitat rather than the multiple covariates that explained habitat fitness. Green Diamond used multiple covariates in all submodels of the habitat fitness model. This multiple covariate approach is a key difference between Green Diamond’s model and the single covariate approach in the Draft Recovery Plan. In addition, the study by Franklin et al. 2000 was in an intensive demographic study area located in northern California. The Draft Recovery Plan extrapolated results from Franklin et al. 2000 to other parts of the NSO range. Therefore, because the study of Franklin et al. 2000 was not part of a probability sample (i.e., random sample) of potential study areas from within the range of the NSO, it is questionable and problematic to extrapolate results from that study to make inferences about habitat over the entire range of the NSO (i.e., the Pacific Northwest). Green Diamond interpolated habitat fitness to the Plan Area, the same area where data were collected.

CDFG 3

The FEIS should evaluate the HFP modeling’s implications for conservation of NSOs in the Plan Area additional to the importance of habitat edge; for example, in regard to the size,


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shape, and clustering of nesting/roosting habitat patches associated with high survival and fitness.

The Resource Selection Functions (Sections 4.3.1.4 and Appendix C of the FHCP) and models of NSO survival, fecundity, and habitat fitness included a suite of habitat covariates, weather covariates, management related covariates (e.g., take, set aside), and various spatial scales into the model selection process (see Appendix C, Tables 2.4, 2.8 and 4 of the FHCP). The modeling procedures also included spatially explicit covariates of habitat within various buffers, so spatial arrangements of habitat were incorporated into the model selection process (see Appendix C of the FHCP). This analysis has been completed and incorporated the results into development of the FHCP.

CDFW 4 and 5

The FEIS should evaluate the FHCP’s conservation strategy (e.g., “dendritic” habitat retention) and mitigation for take (DCAs, rather than set-asides) in light of GDRCo research showing the importance of set-asides to NSOs in the Plan Area.

The FHCP should be amended to state that set-asides will be retained for NSOs until the HFP modeling is appropriately validated.

As part of the 10-year review, Green Diamond conducted NSO survival and fitness analyses in which the position of NSO nest sites or activity centers relative to set-asides was included as a covariate (Section 4.4.1; Appendix C of FHCP). Specifically, NSO sites were characterized as being within, adjacent to (<0.5 mile) or outside of (>0.5 mile) set-asides. With respect to survival, NSO at sites that were adjacent to set-asides had the highest survival, followed by those within and those outside set-asides. With respect to fecundity, NSOs adjacent to set-asides had the highest fecundity, followed by those outside and those within set-asides. These results suggest NSOs within or near set-asides have the highest fecundity, and those outside have the lowest fecundity.

The fundamental premise of the FHCP is that a mosaic of high quality habitat will be maintained for the NSO and other Covered Species within the term of the permit through retention of some habitat elements and regrowth of other habitat components temporarily lost due to timber harvest. This central conservation strategy is augmented by specific landscape commitments and through measures that mitigate potential impacts to Covered Species. The primary mitigation strategy for NSO under this FHCP is establishment of DCAs as the highest priority and level of protection for the most productive NSO sites distributed throughout the Plan Area. DCAs are intended to be dynamic and adaptive within this FHCP’s managed landscape. This is in contrast to the static reserve concept of set-asides established under the NSO HCP. The new approach is based on knowledge gained from monitoring and research conducted during 23 years of implementation of the NSO HCP (Green Diamond, 1992). As noted in FHCP Section 4.4.1.3, the value of set-asides under the NSO HCP (Green Diamond, 1992) varied such that some contributed to both NSO survival and fecundity and others were never occupied by NSOs. The DCAs will provide a greater biological benefit to NSO than the set asides as measured by NSO occupancy and fecundity and by prohibiting take of NSO in these areas.

Upon FHCP approval, all set-aside areas defined in the NSO HCP (Green Diamond, 1992) that are not included in a newly designated DCA will be available for timber harvest. However,


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Green Diamond will plan and implement harvesting of these former set-asides within the Plan Area to maximize the persistence of any existing NSO sites. Green Diamond will do this using a pattern of harvest unit layouts that will avoid the core nesting area until the final harvest unit(s) within that set-aside. Depending on the size of the former set-aside area, the actual displacement of an NSO site will not occur for 5 to 15 years following FHCP approval. The importance of this lag in harvesting in or near NSO sites within former set-asides is that it will allow the NSO sites to be replaced with new DCAs that are projected to develop in the Plan Area.

CDFW 6 and 7

The FEIS should evaluate the appropriateness of 89 acres of nesting/roosting habitat and 233 acres of suitable habitat (foraging + some nesting/roosting) as thresholds for reporting take and for protecting DCAs. These thresholds were selected from the lower end of the distribution of habitat conditions (mean -1SD) in a single study (Folliard 1993) and are not congruent with the findings of numerous research studies conducted since 1992.

If one or both of the habitat thresholds identified for DCA retention (89 and 233 acres) is/are not supported by the best available science, the FHCP should be amended to change the threshold(s) to one(s) that is/are supported.

The definition of NSO habitat as defined in the FHCP is based on the site-specific study conducted by Folliard (1993). The information in Folliard (1993) is the best scientific information available and is supported by additional studies conducted by Green Diamond over several decades of implementing the 1992 NSO HCP. The Revised Recovery Plan, suggests that to the extent possible using local habitat definitions when the info is available is the best approach. Therefore, site-specific studies by Green Diamond on lands to be covered by the FHCP, support use of these thresholds and thus should be used. Studies that have supported the guidance provided in NSO guidance in Attachment A, is a more broad one-size fits all approach for take and no take.

CDFW 8 and 9

CDFW recommends the FEIS evaluate whether additional habitat categories should be used in the FHCP for reporting take and protecting DCAs.

If additional categories should be used in the FHCP for reporting take and protecting DCAs, the FHCP should be amended to reflect that.

NSO habitat definitions should be based on local conditions when possible. Green Diamond had over two decades of data and analysis regarding NSO habitat characteristics on Covered Lands. The Service considers the habitat definitions in the FHCP to be adequate because structural characteristics are strongly correlated with stand age. The age categories result in comparable tree sizes and basal areas. The number and types of NSO habitat described in the FHCP (e.g., nesting/roosting and foraging) are the same as those used by the Service and others in the redwood region; therefore, additional categories are unnecessary. In addition, stand age is a more streamlined metric for management and monitoring purposes. Also, see response to EPIC 10.


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CDFW 10, 12 and 14

CDFW recommends the FHCP be revised to include enforceable language to prioritize the retention of the highest scoring trees (Appendix E, page 11, Live Tree Retention Scorecard and Definitions) when selectively harvesting in RMZs.

CDFW recommends revising the FHCP to make it an enforceable standard to prioritize the highest scoring trees (Appendix E, page 11 Live Tree Retention Scorecard and Definitions) when choosing green tree retention (HRA’s, tree clumps, or scattered trees).

CDFW recommends the FEIS compare the kinds of structural retention supported by researchers on GDRCo’s ownership and elsewhere with the FHCP's requirements for retention of targeted habitat elements (i.e., TREE).

The TREE document (Appendix E) provides guidelines for tree retention within harvest units. These guidelines were developed based on data collected by Green Diamond and in collaboration with CDFW. Green Diamond is proposing to include the TREE document in the FHCP. Once the FHCP is approved, all Green Diamond timber harvest plans will be submitted under 14 CCR 919.9 (d) and all provisions in the FHCP and ITP issued by the Service will become enforceable.

The TREE document does prioritize the retention of the highest scoring trees within harvest units; this includes selectively harvesting in RMZs, Habitat Retention Area (HRA) placement, and Green Tree retention. The Live Tree Retention Scorecard (Section E.1.9.1) provides a system for ranking of the relative value of habitat elements that should be preferentially retained. The rankings are not absolutes because the forester need also consider the ability to protect the trees to be retained during operations, the likelihood that it will be destroyed by natural processes, and safety.

The TREE document and Scorecard also emphasize retention of residuals over non-residuals as evidence by the ‘Unit Scarcity Factor’, which assigns additional points for residuals based on the total number of residuals within a harvest unit. The definition of a residual in the TREE document is based on estimated age from visible features. The goal of the Scorecard is to prioritize retention of trees with the highest wildlife value, which is determined by structural complexity and rarity on the landscape.

The importance of the structures defined and included in the TREE document are well documented and supported by research conducted on Green Diamond lands and elsewhere. Green Diamond and others have documented that NSO primarily nest on naturally occurring platforms (i.e. broken tops, large lateral limbs, and other complex limb features) and in cavities. See Appendix C, Chapter 3 and B.2.3 in the FHCP for specific habitat requirements for NSO with literature references. Similarly, Green Diamond and others have documented the importance of cavities for denning fisher. As stated above, the Scorecard provides a system for ranking the relative value of habitat elements based on their importance to the covered species, rarity on a managed landscape, and distribution and abundance within the harvest unit. Large cavities (i.e. cavities large enough to support nesting by NSO or denning by fisher) receive the most points compared to other structural elements. See B.3.4 in the FHCP for more information on the habitat requirements of fisher complete with literature references. As described in FHCP B.5.4, tree voles are almost exclusively arboreal and generally associated with coniferous forest habitats, including both mature and immature forests (Taylor, 1915; Howell, 1926; Benson and


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Borrel, 1931; Maser, 1966; Thompson and Diller, 2002; Forsman et al., 2009). Nests are found in a variety of tree species within the live canopy of the tree on larger branches in older trees, a whorl of branches in younger trees, or other structural deformities like ‘candelabra’ tops (B.5.4 and E.1.2). In addition to prioritizing the retention of trees with the highest wildlife value (structural complexity), the TREE document also emphasizes the retention of trees containing an active or remnant tree vole nest by assigning additional points to those trees (“vole nest factor” in FHCP E.1.9.1 III-D).

CDFW 11

FHCP Appendix E (page 16) for Candidate Tree Selection states “retain trees with the average diameter equal to or greater than the average diameter of trees in the THP area.” CDFW recommends defining “THP area” in the FHCP or delete “area” from this sentence.

The candidate tree selection criteria are assessed at the harvest unit level and do not include areas outside of the unit boundary. The sentence was modified to replace “area” with “unit.”

CDFW 13

CDFW recommends the Service revise to FHCP to state that “if a nest is found, the nest tree will be marked and retained.”

All NSO nest trees are retained under Forest Practice Regulations and will continue to be retained (new and historical) under the FHCP. This sentence was modified to include the phrase “and retained.”

CDFW 15

CDFW recommends the FEIS use estimates of snags and residual trees in timber harvesting plans in the annual report for the 1992 NSO Plan (Simpson 1992, page 202) to analyze the rate of loss of residual trees in THPs since the TREE program’s implementation in order to evaluate the effectiveness of the TREE program in retaining this critical element for NSOs under the FHCP.

Green Diamond’s use of the term residual is not necessarily the same across various documents that were developed over the course of several decades. Therefore, historical and current estimates of residual trees are not comparable across study years. Additionally, annual reporting criteria also changed over time to include pre- and post- estimates of Scorecard Trees, which as described in the response to CDFW Recommendations #10, 12, and 14, include both residual and non-residual trees and were not identified in the 1992 NSO HCP. Therefore, an evaluation of the rate of loss of residual trees is not possible due to changes in the definition of residual trees and how these trees are reported in annual reports. Additionally, there is no way to estimate loss of residual trees based on what CDFW proposes. In the annual reports, residual trees retained under the NSO HCP are lumped within the general category of green tree retention and may occur as a component of scattered, clumped, or HRA retention. The concept of a scorecard tree was developed nearly a decade into implementation of the NSO HCP and was not a concept of the NSO HCP. The precursor to the TREE, Green Diamond’s Terrestrial Deadwood Management Plan was implemented for nearly a decade prior to development of the TREE under the FHCP.


7

CDFW 16

CDFW recommends adding enforceable language to the FHCP for GDRCo to monitor for the effectiveness of the tree retention standards (e.g., TREE program) for FHCP Goal Two and report the results to the Service.

The FHCP includes commitments to monitor the effectiveness of the tree retention along with other habitat management based on the response of the covered species over time and not just a compliance count of trees retained. The reporting of retention from a compliance standpoint is also included in reporting commitments. This is a long-term monitoring goal because it will take decades to regenerate the stands around the retained elements in order to see how Covered Species use these habitat elements in the future. Therefore, the FHCP includes monitoring objectives to assess population trends for the covered species, and adaptive management (5.3.6.1) could be triggered by population declines and not a count of retained trees or tree use. A potential response under Adaptive Management could be modifications to tree retention (Section 5.3.6).

CDFW 17 and 18

Revise the FHCP’s initial set of DCAs so that every initial DCA has recently high occupancy and fecundity, as defined by the FHCP’s criteria for selecting replacement DCAs.

CDFW recommends the FHCP be revised so that the initial set of DCAs is better distributed (e.g., in the Plan Area, among OMUs, and in relation to the current distribution of active NSO sites).

The FHCP initial DCA selection criteria included a combination of recent and historical biological performance, barred owl impacts, spatial distribution, and prior ‘take’ designations. As described in Section 4.3.1.6, barred owls have a direct, negative influence on the biological performance of NSO as measured via various demographic parameters. Barred owl numbers have steadily increased across Green Diamond’s ownership for more than a decade. Consequently, the number of NSO sites that meet the biological performance criteria described for DCA sites is greatly influenced by barred owls within the Plan Area. In fact, some OMUs lack occupied NSO sites or sites that meet the performance criteria. In order to maintain a spatial distribution of DCAs across the ownership, some NSO sites were designated as DCAs if the site exhibited high performance in the past but low performance in recent years due to the negative influence of barred owls. The goal of the FHCP is to designate DCA sites based largely on performance in the absence of the barred owl threat, and following a minimum of 5 years after initiation of Phase 2 of the barred owl experiment to allow NSO to select sites based more on habitat quality rather than competition from barred owls.

CDFW 19

CDFW recommends the FHCP be amended to state that replacement DCAs can be selected from adjacent OMUs, regardless of whether the DCA being replaced is near the OMU boundary.


8

The FHCP section describing the replacement criteria has been modified to allow DCA replacement between adjacent OMUs regardless of the proximity of the site to the OMU boundary.

CDFW 20 and 21

Revise the FHCP’s initial set of DCAs, and/or redraw the core habitat polygon within currently selected DCAs, so that every DCA has a core habitat polygon that is at least as large as the FHCP’s take avoidance threshold for nesting/roosting habitat (currently, >89 ac).

Revise the FHCP’s initial set of DCAs so that every DCA has a core nesting/roosting habitat patch that is at least as large as the FHCP’s take avoidance threshold for nesting/roosting habitat (currently, >89 ac).

As described in FHCP 5.3.1.4.1, Green Diamond designated the minimum size DCA core by calculating the area occupied by all nests (1990 through 2007 for sites with at least 3 nest years) using a 95% kernel estimator. The 80th percentile was used as the cutoff to describe the core area size around nests since this captured all sites where birds exhibited typical site fidelity and eliminated ‘outliers’ where birds made uncharacteristic shifts in nest sites. The 80th percentile nest core area for these 94 NSO territories was estimated at 76 acres. 76 acres of nesting habitat (stands equal to or greater than 46 years) is the minimum criteria used in the FHCP to designate the initial set of DCAs (not 89 acres). However, some NSO sites/territories designated as DCAs (see DCA criteria in FHCP 5.3.1.4.4) were nesting in areas with less than 76 acres of nesting habitat. As a result, the initial set of DCAs includes 11 core areas smaller than 76 acres. Additionally, DCA boundaries were drawn around actual nest locations using logical topographic boundaries (roads, streams, ridges, etc.) to allow for accurate mapping and on the ground delineation. As a result, 33 of the initial DCAs are larger than the 76 acres. The average size of the initial set of DCAs is 86 acres (range 56 – 130.2 acres). Going forward, all new DCAs will be a minimum of 89 acres in order to be consistent with the no-take standard of maintaining a minimum of 89 acres of nesting habitat. Since DCA boundaries will still be drawn around actual nests using logical topographic boundaries, some DCAs will be larger than 89 acres. Therefore, the average size DCA going forward will always be greater than 89 acres.

CDFW 22

Amend the FHCP so that it is more clear whether the no-take standard will be applied: (a) within 0.5 mile of the center of the DCA (including protection of 233 acres of forest >31 years), (b) the Activity Center, which may or may not be located in or nearby the DCA with which it is associated, or (c) both.

The DCA polygon is no-harvest, and the no-take habitat standards are applied to the activity center or nest site of the NSO territory associated with the DCA. DCA polygons were drawn around actual nests for a given NSO territory. Therefore, when the DCAs were designated, all nest sites were located within the boundary of the DCA. Due to displacement of NSO by barred owls, some of the activity centers associated with the DCAs are currently located adjacent to the DCA boundary. Additionally, future nests may be located outside the initial boundary of a DCA for reasons not related to competition with barred owls. Regardless of the reason, if activity centers or nest sites are located outside of the DCA boundary, the site center and the 0.5 mile


9

buffer will be managed as no-take (FHCP 6.2.4.1) and the DCA will still be managed as no-harvest. FHCP 5.3.1.4.1 has been modified to provide clarity for the no-take designation for NSO sites associated with the DCAs.

CDFW 23 and 24

Amend the FHCP so that is clear whether DCAs can be selected within 0.5 mile of GDRCo property boundaries, and if so, how they are protected from take associated with off-property activities.

The FEIS should evaluate whether DCAs located nearby property boundaries are adequately protected from off-property activities. If they are inadequately protected, the initial set of DCAs should be revised to only include NSO sites >0.5 mile from a property boundary.

FHCP 5.3.1.4.1 states that DCAs will be designated in the Plan Area. There are no stipulations listed that require DCAs to be located greater than 0.5 mile from non-FHCP covered lands. Green Diamond calculates the on-property and off-property habitat within the 0.5-mile buffer of an NSO site when assessing take. For DCA-associated sites, harvest within the 0.5-mile buffer would only be allowed if the combined on- and off-property habitat amounts remained above the take thresholds. Green Diamond is not in control of activities that occur on adjacent lands, but all sites located on Green Diamond ownership are reported annually to the State NSO database (CNDDB) making the locations available to neighboring landowners. Off-property protections are in place through the requirements applied to non-HCP lands (FPRs and other State or Federal regulations).

CDFW 25

The FEIS should evaluate whether comparison with the Willow Creek Study Area is an appropriate benchmark for completion of Phase 2 of the Barred Owl experiment, when there is no guarantee that the Willow Creek Study will continue throughout Phase 2.

The Willow Creek Demography Study (WCDS) is a long-term study that predated the Service’s barred owl removal study (which is also taking place within the WCDS study area), and does not have a projected end date. The Service’s barred owl removal study uses the Willow Creek NSO population as a control to compare to Hoopa Valley Tribal Reservation’s NSO population where barred owls are being removed. The Service’s barred owl removal study will end in a few years; however, the underlying demography project at Willow Creek is expected to continue and be available as a control for comparison to Green Diamond’s NSO data. The reliance of the FHCP on data from the WCDS actually increases the likelihood that this long-term research project will continue, because this added utility of the project may increase funding opportunities.

CDFW 26

The FEIS should evaluate whether validation of the HFP modeling is an appropriate benchmark for completion of Phase 2 of the Barred Owl experiment, given concerns about the potential inappropriateness of using that modeling as a basis for the FHCP’s conservation strategy (also see CDFW Comment Section 1).

Neither the Barred Owl strategy nor the HFP modeling are dependent on the other. However, barred owls need to be removed for about 10 years before the HFP model can be evaluated. The


10

completion of Phase 2 of the barred owl experiment and validation of the habitat fitness model are not directly linked to each other. The validation of the habitat fitness model is achieved based on an analysis of trends in the NSO population and trends in habitat fitness as described in FHCP Section 5.3.5.1.1. Green Diamond will conduct the Phase 2 experiment until a statistically significant trend is detected in the parameters of interest (e.g., survival, fecundity, lambda) between Green Diamond and the WCDS. In other words, the barred owl experiment may take more or less time than model validation, and it is evaluated based on different metrics.

CDFW 27, 28, and 29

The FEIS should more clearly describe and evaluate the value of the Barred Owl experiment as mitigation for take, in light of the relatively short timeframe within which Barred Owls will be completely removed from the Plan Area (i.e., Phase 2) versus undetermined portions of the Plan Area (i.e., Phase 3).

The FEIS and FHCP should include more detailed descriptions of Barred Owl experiment Phases 2 and 3.

The FHCP should be amended to include a statement that a scientific panel will be consulted for input on the best locations for treatment and control areas during Barred Owl experiment Phase 3. This will help ensure that the experiment’s scientific value is maximized and that areas with high densities of NSO territories and habitat are protected from Barred Owl impacts.

The FHCP provides basic details on the concepts of the Phase 2 and 3 experiments. Phase 2 is removal of barred owls from throughout the Plan Area, similar to what was done in the treatment area of Phase 1, except that another NSO study area (e.g., Willow Creek) is used as a control in the BACI (Before-After-Control-Impact) design. The actual timeframe for Phase 2 is not known, but it is anticipated that it will take approximately 10 years based on the results in Diller et al. 2016.

Additional detail was added to the FHCP to describe how Phase 3 may be implemented in the Plan Area. Barred owl research commitment three requires review and concurrence by the Service prior to implementing Phase 3. This may include review by an independent researcher with knowledge and experience designing and implementing these types of field experiments on NSO and barred owls. Also see CDFW 2 and 3.

CDFW 30

The FEIS should evaluate the FHCP’s method for “returning” displacements (take) based on occupancy, which may inadequately reflect negative impacts of take on a taken site’s original occupants, and which could inaccurately reflect habitat quality in the site.

The FHCP establishes habitat thresholds for potential incidental take of NSOs. If harvest reduces habitat within a NSO site below the habitat thresholds, then the site will be evaluated (monitored) to determine if a take (biological impact) has occurred. Take is evaluated based on a combination of occupancy and reproductive criteria (FHCP 6.2.4.2). Take is assessed at the site level and not assessed for individual NSO. Collecting information on individual owl occupancy and reproduction requires obtaining 100% accurate resights of the owl’s leg band. If the original occupant relocates (temporarily or permanently), then continuing to gather information to


11

monitor occupancy and reproduction would require Green Diamond to find the bird in the new location and accurately resight the leg band. There are no absolutes that the bird will be found each year, remain in the study area, or that surveyors will resight the leg band if the bird is found. NSO relocate or vacate sites for a variety of reasons unrelated to habitat removal. Green Diamond evaluated the biological impacts of take on individual NSOs, and there was no significant effect of take on NSO apparent survival (Appendix C). If a potential take site remains occupied and owls continue to reproduce, then the site in the modified state (reduced habitat amounts) is still capable of supporting occupancy and reproduction regardless of which NSO occupies the site.

CDFW 31 and 32

The FEIS should determine if the FHCP’s habitat thresholds for reporting take are appropriate in light of the best available science and, if they are not, whether the FHCP accurately estimates the annual rate of take and cumulative take during the Plan’s term.

The FEIS should determine if the FHCP’s habitat categories (forest >31 years and >46 yrs) for reporting take are appropriate in light of the best available science and, if they are not, whether the FHCP accurately estimates both the annual rate of take and cumulative take during the Plan’s term.

The habitat thresholds in the FHCP for evaluating and reporting take are based on the best available science. More specifically, habitat thresholds are based on site-specific information collected over a decade or more; however, this is not the case on most/all USFS or other lands. The thresholds were established and studied for 27 years under the 1992 NSO HCP. Green Diamond conducted long-term, ownership-wide NSO demographic surveys and assessed the response of NSO pre- and post-harvest. As described in FHCP Appendix C – Chapter 1 and FHCP 6.2.2.1, the habitat thresholds triggering and evaluation of take are conservative and do not always result in an actual displacement of NSO or alteration of their normal behaviors.

CDFW 33

The FEIS should evaluate whether changes to the conservation strategy and mitigation measures in the FHCP compared with the 1992 HCP could lead to changes in the rate of take. For example, whether the risk of take differs with retention of nesting/roosting habitat in narrow, “dendritic” RMZs compared with the past: (a) retention of patches with more interior forest, (b) association with relatively large, no-take set-asides, and (c) association with residual older trees outside RMZs. In light of these findings, the FEIS should evaluate whether the FHCP accurately estimates the annual rate of take and cumulative take during the Plan’s term.

The retention of NSO habitat in the RMZs and Geologically Unstable Areas as well as other forms of habitat retention (DCAs, HRAs, TREE, etc.) are in addition to the take/no-take habitat threshold standards. As a result of the no-take standards, no harvest is allowed within 500 feet of a NSO site, and Green Diamond must maintain a minimum of 233 acres of NSO habitat (stands greater than 30 years) with at least 89 acres of nesting habitat (stands greater than 45 years) within a 0.5-mile radius buffer of the NSO site. Additionally, the dendritic network of RMZs are not isolated on the Green Diamond ownership nor surrounded by non-habitat. The Green Diamond landscape is dynamic and harvest complies with the FPRs that restrict the timing and


12

rate of harvest. Therefore, the dendritic network of RMZs (typically greater than 90 years) is situated adjacent to a variety of other stand sizes and ages ranging from 0 to 90 years. As described in the FHCP (Section 4.3.1.2) Green Diamond’s demographic monitoring documented several instances of NSO colonizing and reproducing successfully in young stands (stands less than 30 years) that were harvested prior to implementation of the current FPRs, the 1992 NSO HCP, and the AHCP/CCAA, which provide increased habitat protection and retention requirements compared to historic practices. Green Diamond evaluated interior habitat in the development of the Nesting Resource Selection Function, and this covariate was not a component of the top model or competing models (Appendix C). See also CDFW 4 and 10-16.

CDFW 34 and 35

CDFW recommends FHCP Section 6.2.4.7 be amended to clearly state seasonal disturbance buffers shall be applied to nesting NSOs affected by any Covered Activity that may lead to a disruption of breeding behaviors that could result in death of young or eggs. The 2006 USFWS guidelines would be the appropriate source for determination of activities that may have such an effect.

The FHCP should disclose and evaluate the estimated level of take that would occur from noise and visual disturbance

The Service and Green Diamond have agreed to seasonal disturbance buffers as specified in the FHCP. The estimated level of take from all Covered Activities is described in Section 6.2.3 in the FHCP, and considerations for noise disturbance is addressed in Section 6.2.4.7 in the FHCP. As described in FHCP Appendix C – Chapter 1 and FHCP 6.2.2.1, the habitat thresholds triggering and evaluation of take are conservative and do not always result in an actual displacement of NSO or alteration of their normal behaviors.

CDFW 36 and 37

CDFW recommends the FEIS include a discussion on the potential effects to NSOs currently located within the 339,667-acre Adjustment Area if these sites are added to the Plan Area and subsequently available for take under the FHCP.

CDFW recommends FHCP Section 1.4.7.2.3 incorporate a discussion of NSO activity sites within the Adjustment Area including a provision for assessing DCA additions within the new area.

Lands in the adjustment area are similar to Covered Lands with respect to the distribution and amounts of NSO habitat and the density of NSO. Accordingly, if similar management is applied, similar results should be expected. Therefore, the effects to NSO in the Adjustment Area are expected to be generally the same as in the initial Covered Lands.

The Service and Green Diamond agree with this comment, and the FHCP and FEIS have been edited to reflect that for every 8,000 acres added to Covered Lands, one additional DCA will be added. However, when lands are removed from Covered Lands, the number of DCAs will not fall below 44.


13

CDFW 38

CDFW recommends additional information relevant to the FHCP covered species for lands added to the Plan Area (as required by FHCP Section 1.4.7.2.3) include information related to NSOs, other Covered Species, and their habitat. The current language states the additional information including water temperature, channel and habitat type, large woody debris inventory, and estuarine conditions shall be submitted to the Service. Terrestrial habitat information is not mentioned, and thus appears to be an oversight retained from the Aquatic HCP.

See CDFW 36 and 37

The FHCP has been edited.

CDFW 39

The FHCP and FEIS should use a standardized detection probability analysis to establish the estimated number of nesting birds that may be directly affected as a result of the survey methodology, which would account for the probability of missing nesting during surveys, rather than the probability of physically seeing birds after missing nesting.

As stated in 6.2.2.2.1 of the FHCP, since Green Diamond began pre-harvest surveys in 1990, there is not a single known instance of harvesting an occupied nest stand that pre-harvest surveys had concluded was unoccupied by NSO. The detection probability approach recommended by CDFW would not account for the specific circumstances that would result in direct harm and would therefore be an overestimation. For example, a 95% detection probability results in the potential for NSO to be undetected 5% of the time if present. However, this represents the probability of missing NSO somewhere within 0.5 mile of a proposed harvest unit. It does not reflect the probability of missing a territorial nesting NSO that has a nest site in or directly adjacent to a harvest unit and where harvest operations are initiated prior to young being fledged. The estimate described in the FHCP is a conservative estimate but a more appropriate approach for estimating the potential for direct harm.

CDFW 40

CDFW recommends the FEIS provide an analysis estimating the intended population size and number of occupied NSO sites required to ensure a stable, sustainable population of NSOs within the Plan Area, including the potential Adjustment Area. This evaluation should also include consideration of the potential for numbers of individuals or sites to continue to decline during an undetermined number of years (e.g., >5 years) after adaptive management is triggered.

The FHCP is a habitat-based conservation strategy, and the strategy does not include a “minimum sustainable population size” per se, but does include that a minimum of 44 DCAs will be maintained on Covered Lands. Information on the number of NSO on Covered Lands is provided in the FHCP in Tables 5-1 and G-1.

If triggered, it is unknown exactly which measures, or how long, any adaptive management measures would be in place. The measures could be in in place for the remainder of the permit term. However, such measures would be implemented with the express intent of maintaining


14

and enhancing the NSO population. If the measures do not correct the problems, and the number of active NSO sites falls below 47, then take of NSO would be prohibited.

CDFW 41

To ensure successful implementation of the Adaptive Management’s Scientific Review Panel (FHCP Section 5.3.6.1), CDFW recommends adding a statement that if the Service and GDRCo cannot come to agreement on the members of the scientific review panel, then the Service and GDRCo will each choose one member and agree on the third.

The FHCP has been so amended. See pg. 5-62

CDFW 42

Because other landscapes or ownerships may not have the same objectives or habitat conditions as the plan area, comparing fecundity estimates to a “comparable region” is an uncertain measure (Adaptive Management commitment Two [Objective 5C]). CDFW recommends the FHCP identify a mean fecundity rate based on what is intended for the plan area.

Despite different land management objectives (Green Diamond is private managed forest and the WCDS is located on U.S. Forest Service lands) and vegetation types, demographic parameters of NSO have been very similar over time. In the future, a comparable region may also be the Hoopa Valley Tribal Reservation Study Area. The idea is to compare fecundity estimates from Green Diamond to another study area to assess temporal variation. Designating a target fecundity rate is problematic because it would not consider large scale variation in reproduction due to weather and other factors.

CDFW 43

FHCP 5.3.6.2 establishes an Adaptive Management Reserve Account (AMRA) to create habitat adjustments during the life of the FHCP. The AMRA appears to limit no more than 1,068 acres added during the life of the FHCP. CDFW recommends the FHCP not identify an upper limit on habitat mitigation measures, but rely on the outcomes of the scientific review panel.

The Service agreed that 1,068 acres was an adequate amount to credit the AMRA for expansion of existing DCAs or creation of additional DCAs if adaptive management is triggered.

CDFW 44

CDFW recommends revising the FHCP Implementation Commitments to include, “The Service may require annual meetings or the submittal of additional information as necessary to determine compliance with the FHCP at any time.”

Beginning approximately 1 year after issuance of the ITP, an annual meeting between the Service and Green Diamond will be scheduled for the first 5 years of the permit term to discuss issues that may arise with implementation of the FHCP. Additionally, upon approval of the FHCP, Green Diamond will establish an FHCP Compliance Team that will consist of a Plan Coordinator working in conjunction with Green Diamond’s internal forestry and wildlife staff. At any time during the term of the permit, the Service can conduct pre-harvest spot checks or


15

audits of THPs to ensure that they are compliant with the measures in the FHCP, request data, and/or schedule meetings.

CDFW 45 and 46

Because there is no requirement in the FHCP to disclose FHCP requirements/mitigations within the THP, CDFW recommends the FEIS evaluate how the Service will monitor for compliance the FHCP mitigations including the TREE program, NSO disturbance buffers, and incidental take in a timely matter (i.e., before timber is harvested) and on a site-specific basis.

CDFW recommends that specific information be included within the THP on (1) the TREE program; and (2) disturbance buffers and take.

The DEIS was edited to reflect that the Service will periodically conduct pre-harvest spot checks or audits of THPs to ensure they are compliant with the measures in the FHCP. Green Diamond is required to notify the Service about THP submission. Annual reports and meetings also provide an opportunity to monitor compliance with FHCP provisions. Compliance monitoring will occur through the annual reporting process and through periodic audits and field inspections conducted by the Service.

The reporting requirements for the FHCP agreed to by Green Diamond and the Service are found in FHCP Section 5.3.7. Much of the information related to items listed in CDFW’s Recommendation 46 are found in various sections of each THP and is available to CDFW during the THP review process. Information related to NSO activity centers is found in annual reports that will be submitted to the Service in compliance with the permit. Green Diamond is responsible for implementation and reporting requirements as specified in the FHCP.

CDFW 47

CDFW recommends the FHCP for Annual Reports (Chapter 5, page 70) be revised to include specific information on NSO monitoring, site occupancy, reproductive success, survey results, maps/spatial data, and other information in the annual report content for full disclosure and compliance monitoring.

The FHCP includes reporting commitments to provide spatial data for all active NSO sites and includes a summary of the site occupancy results. In order to maintain the Federal banding permits required for conducting the demographic monitoring work, Green Diamond will also be required to obtain the appropriate State permits. One provision of Green Diamond’s NSO banding MOU with CDFW requires that Green Diamond submit annual NSO site history information to the CNDDB spotted owl database. Although not a direct requirement in the FHCP, Green Diamond will be required to comply with State permit requirements (submittal to the State database) in order to obtain a Federal permit. Therefore, Green Diamond will continue to submit annual site status information to the State database. Green Diamond will also include the state ID (master owl number) for each NSO site where referenced in the FHCP annual report.

The FHCP does include reporting requirements for reproductive success.

FHCP surveys cover more than 400,000 acres of the Green Diamond ownership on an annual basis. Pre-harvest surveys are conducted for more than 600 THP units annually. Green Diamond conducts annual demographic surveys for more than 380 known NSO sites and property-wide


16

surveys at more than 500 fixed survey stations. Conservatively, this would result in reporting on more than 7,200 individual surveys each year. All survey information is maintained by Green Diamond and available for review by the Service. Additionally, the FHCP includes commitments to report the summary results of the various surveys listed above for both NSO and barred owl. Individual detailed survey data will be available upon request through the auditing process described in the response to CDFW recommendation #44.

The FHCP includes annual reporting commitments to provide spatial data for active NSO sites, current and proposed DCAs and associated sites, and pre- and post-harvest habitat within 0.5-mile buffers for potential take sites.

For a detailed list of the FHCP reporting commitments please refer to 5.3.7 of the FHCP.

CDFW 48

“Continuous” harvest refers to timber falling and operations that are initiated on or before February 21 and continue into the breeding season without a substantial break (generally a week or less) (FHCP F.2.1.15). There are different survey requirements (level of intensity) in the FHCP dependent on the amount of contiguous timber and if the harvest is continuous. CDFW is concerned that NSO may move into a THP unit during a gap in operations, and operations could begin again next to a new nest site. CDFW recommends the number of days timber operations can be stopped without requiring protocol surveys should reanalyzed, disclosed, and mitigated as potential take.

NSO may defend territories and show courting behavior 2-3 weeks before nesting (Forsman et al. 1984). The earliest documented nest on the Green Diamond ownership was March 12, but the majority of NSO initiate nesting (incubation) the last week in March through the first week in April. Therefore, we expect NSO on the Green Diamond ownership will initiate courting behaviors and begin to exhibit territorial responses in late-February. Continuous operations are initiated on or before February 21 and continue into the breeding season without a substantial break. Continuous operations only occur in THP units surveyed and cleared for harvest in the previous breeding season, and surveys are conducted concurrent (once per week) with continuous operations. The goal of the concurrent surveys is to document a colonization event or a long-distance shift in a known site activity center, and to detect NSO under these conditions with a minimum 95% detection probability. See response to CDFW recommendation #49 for more information regarding the detection probability analyses.

CDFW 49

CDFW recommends the FEIS evaluate all of the survey requirements in FHCP F.2.1.15 (Additional Spot Calling and Second Year Surveys) for their ability to achieve a detection probability of 95%.

As described in Appendix H, Green Diamond conducted a series of analyses in 2012 to update the 1992 NSO HCP survey protocol to ensure surveys achieve a minimum 95% probability of detecting NSO if present. Green Diamond consulted with a PhD statistician with Western EcoSystems Technology, Inc (West Inc.) to design and conduct the analyses. The analytical methods were similar to Dugger et al. (2009) to inform the revisions to the Service’s NSO survey protocol (USFWS, 2011) except that Green Diamond used ownership-specific data for the analyses and evaluated their site visit survey data (survey for known spotted owl sites) separately


17

from their pre-harvest NSO survey data. This allowed for Green Diamond to estimate detection probabilities for both site visits and THP surveys, where the latter were unavailable to Dugger et al. The analyses conducted in 2012 allowed Green Diamond to update the 1992 NSO HCP with the number of surveys required to achieve a 95% detection probability for pre-harvest surveys and surveys for known spotted owl sites while accounting for presence of barred owls. The pre-harvest survey detection probability results are applicable to the “THP Surveys” described in FHCP F.2.1.9.1, and the detection probability results for NSO site visit surveys are applicable to “Known or Historical NSO Sites” described in F.2.1.9.2. Once a NSO is detected during a pre-harvest survey, the “Follow-up Visits” follow the same field methods as described for surveys of “Known or Historical NSO Sites”. Therefore, the site visit survey detection probability analysis is also applicable to “Follow-up Visits” described in F.2.1.11.

The analyses conducted in 2012 also calculated a colonization rate for NSO on the Green Diamond ownership. In 2014 Green Diamond consulted with West Inc. to determine if the second-year survey protocol and the concurrent survey protocol for continuous operations being implemented under the 1992 NSO HCP also achieve the 95% detection probability. The purpose of the second-year surveys and concurrent surveys conducted for continuous operations (F.2.1.15) is to document a colonization event since these surveys only apply to areas surveyed during the prior breeding season without NSO detections. Based on the detection probability estimates for pre-harvest surveys and the colonization rate, West Inc. concluded that both of these surveys achieve a 95% probability of detecting a colonization event.

CDFW 50

Determining if an NSO site is influenced by Barred Owl based on Barred Owls being “repeatedly seen or heard at the site” (FHCP Section 6.2.4.9) is a vague requirement. CDFW recommends the FHCP include spatial and temporal requirements for determining if a NSO site is influenced by Barred Owls.

Green Diamond’s FHCP includes pre-harvest surveys, annual surveys for all known (active and vacant) NSO sites, and annual property-wide surveys conducted across the ownership at fixed survey locations. All of the surveys listed above include surveys for both NSO and barred owls. Additional barred owl surveys will also be conducted in association with the barred owl research proposed in the FHCP. Given the intensity of surveys being conducted annually, we expect that Green Diamond biologists will have an accurate assessment of where barred owls are located. The FHCP includes spatial criteria for describing NSO sites and establishing new territories (FHCP 6.2.4.3), which will provide the spatial limits for assessing barred owl influence. Additional details have been added to FHCP 6.2.4.8 for determining when a NSO site is influenced by a barred owl.

CDFW 51

CDFW recommend the FEIS provide an assessment of the origin and validity of using this set of criteria found in FHCP Section 6.2.4.4 for establishing new ACs that differs from the standards in the Protocol

Green Diamond has conducted full demographic surveys annually for 27 years under the 1992 NSO HCP. The definitions for establishing new activity centers (new sites) and the permanence of those sites were developed by Green Diamond and the Service in 1995. Between 1990 and


18

1995, Green Diamond analyzed the occupancy rates for newly colonized sites based on status (single or paired) and detections. Based on these initial findings, Green Diamond and the Service developed the definitions currently in use under the 1992 NSO HCP and proposed in the FHCP to distinguish between ‘floater’ (i.e., non-territorial) and resident territorial NSO.

In addition to the presence of ‘floater’ owls, Green Diamond has documented banded NSO miles from their core nesting territories during the breeding season. Given the intensity of annual surveys being conducted on Green Diamond’s ownership, it is important for the FHCP protocol to distinguish floater and roaming resident owls (detected but not resighted) from NSO attempting to establish a new territory. As described in the response to CDFW recommendation 49, Green Diamond’s survey protocol results in a 95% detection probability. When an NSO is detected during a nighttime survey, a minimum of three follow-up (daytime searches) surveys are conducted in combination with additional nighttime surveys, and the follow-up survey protocol also achieves a 95% detection probability for detecting the NSO.

The definitions used in the 1992 NSO HCP are being proposed in the FHCP since they are based on ownership-specific data collected through long-term ownership-wide demographic monitoring and have been in use for 27 years.

CDFW 52

Since the relationships between NSOs and habitat post-fire is complex, depending on where the fire burned and it’s severity, post-fire salvage logging in DCAs should be evaluated on a site-by-site basis. CDFW recommends revision of the FHCP to state that Green Diamond consult with the Service prior to post-salvage harvest operations in functional DCAs.

The suggested edit to the FHCP has been made, see page 5-78.

CDFW 53

Green Diamond data indicate larger trees with cavities are the most important habitat element for fisher. However, the FHCP and FEIS lacks an assessment as to whether only retaining larger trees with cavities is enough habitat on the landscape to support a viable fisher population. Currently, fisher are using smaller trees with cavities, and the effect of removing smaller trees with cavities may have negative implications for fisher populations. Increase the number of points in the live scorecard for internal hollow or large cavity from 4 to 5. This will increase the number of smaller trees (<30 inches DBH) on the landscape with large cavities, providing recruitment for the larger trees where they are scarce.

The TREE scorecard was developed based on Green Diamond scientific research that supports the objectives of the TREE and score card. The diameter criteria is a mechanism for identifying larger residual trees on the landscape that likely possess the features (e.g., cavities) that require more time to develop due to periodic wildlife events, scarification and breakage from other falling trees and spread of disease and fungi that create internal decay. Larger trees are generally older, and older trees generally possess features like fire scars and internal rot that may only develop over several decades. The TREE and the score also emphasize retention of other smaller diameter trees with structures, such as cavities, that will benefit the denning habits of fishers. Green Diamond in the FHCP and the Service in the DEIS have recognized the amount of potential denning, resting and foraging habitat that will develop within the Plan Area as a result of the retention and continual aging of forest stands in the extensive riparian and geological


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zones approximating 25% of the Plan Area. In addition, the regrowth of forest stands outside of the these areas along with the retention of scattered individual and clumped retention to accelerate the development and function of these stands will occur over an approximate 50 year growth and harvest cycle on the remainder of the Plan Area. The amount of older forest within the Plan Area is expected to increase through time therefore providing an increasing amount of potential denning habitat for fisher (Section 5.2.2.1).

CDFW 54

In conifer-dominated harvest areas with RMZ retention, if the unit is lacking hardwoods to meet minimum retention standards (two trees per clearcut acre), conifers should be retained to meet this requirement.

The goal of tree retention is to retain hardwoods in conifer dominated areas because they are likely a minor stand component and important to maintaining tree species diversity within those stands and for providing vertical structural diversity within the regenerating stand. Hardwoods also offer opportunities for roosting, denning, and nesting by the Covered Species and through mast production as a food source for various small mammal species that could be prey for Covered Species. It is not a goal to retain additional conifer trees that do not possess important wildlife structure (as defined in TREE and the scorecard) within conifer dominated stands. Where conifer trees with structure exist within conifer dominated stands, those trees will be retained as defined in the TREE and scorecard. Millions of conifer trees will be retained across the landscape in RMZs, geological zones, and in the regenerating forests that are harvested over an approximately 50-year cycle. There is no need to retain additional conifer trees for the Covered Species unless they meet the criteria in the TREE.

CDFW 55 and 56

Tree voles are arboreal, have extremely limited movement capabilities for foraging and dispersing, and are highly associated with defective (e.g., forked or broken-top) trees on GDRCo land. The FHCP should be revised to ensure greater retention of tree vole nest and foraging trees.

The FHCP should be revised to ensure that green tree retention prioritizes trees with the structure (see CDFW Recommendations 10 and 12). For tree voles, the FHCP should specifically include prioritization of defective trees for tree vole nests; for example, broken-top or forked top trees.

The TREE scorecard does prioritize retention of trees with structure. Trees retained trees may provide current and future habitat for tree voles. In addition, potential tree vole nests identified in RMZs are prioritized for retention through the TREE scorecard. Potential foraging trees for tree voles could be any whitewood tree. Tree voles are not known to select trees with structural deformities for foraging. Therefore, retention of structural trees for potential nesting is the greatest priority. Millions of potential foraging trees will be retained within the Plan Area around nest trees. In addition, Green Diamond’s research has shown that persistence of tree vole nests is relatively brief (generally < 60 months, Appendix C). The FHCP identifies the most beneficial aspect of tree retention for tree voles in Section 5.3.3.3.


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CDFW 57

The FEIS should evaluate whether GDRCo will collect a sufficiently large and well distributed sample of NSO pellets to rigorously monitor tree vole populations in the Plan Area (e.g., for triggering adaptive management).

It is the goal of the FHCP and monitoring commitments for tree voles to collect a sufficient number of NSO pellets to reliably estimate tree vole occupancy and potential changes in tree vole occupancy within the Plan Area. The FHCP’s tree vole monitoring commitment (Section 5.3.5.3) is designed to address this recommendation.

EPIC 1

The HCP Fails to Take “Hard Look” at Other Species.

Take will only be permitted under the proposed FHCP for the Covered Species. No take will be permitted for federally listed species not covered under the FHCP (e.g., marbled murrelet). The MAMU is the only federally listed species occurring on GDRCo lands that is not a covered species. As with their existing HCP, there is no take of MAMU under the new FHCP. Old-growth stands (i.e., MAMU habitat) on GDRCo property are not subject to harvest and will not be affected by the ‘project’.

EPIC 2

The HCP Provides Weaker Habitat Protections than No Action Alternative.

The No Action Alternative does not include barred owl management, and is therefore inferior to the No Action Alternative. Also see responses to EPIC 13 and FOA 1.

The FHCP proposes to use the same habitat definitions and take thresholds established in the 1992 NSO HCP. These definitions and thresholds have been in place and studied for more than two decades and are specific to Green Diamond managed lands.

EPIC 3

Location of DCAs Minimizes Conservation Benefit.

The location of DCAs within RMZs and other areas protected under the AHCP/CCAA does not minimize the conservation value of the DCAs for NSO simply because they may overlap with areas protected for different (e.g., aquatic) resources. As for overlap, some DCAs are not near AHCP/CCAA RMZs or Geological Unstable Area (GUA), and those that are typically extend outside of the preexisting RMZ or GUAs. The DEIS and FHCP were edited to include data on the overlap of DCAs with areas previously protected under the AHCP/CCAA (see section 2.1.2.7 and Table 2-2 in the FEIS). DCAs were chosen based on productivity, so it should be expected that many of them will overlap with RMZs or GUAs. Because Green Diamond’s GIS data is considered proprietary and sensitive commercial information, it is unlikely the company will release these data to the public.

EPIC 4

Use of Outdated Information.


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Data was frozen at 2015 in order to allow time for analysis to occur during the development of the proposed FHCP and the DEIS. See response to HOFF 6.

EPIC 5

Lack of Assurances for Other Required Barred Owl Permits.

Any successful application for a MBTA permit will be compliant with all laws and regulations, or the permit will not be issued. The Service continues to work with Green Diamond to ensure that their permit application is adequate for permit issuance. It is the Service's understanding, through the FHCP, that Green Diamond is committed to Barred Owl Research measures throughout the term of the FHCP, as discussed in Section 5.3.4. If Green Diamond fails to obtain a MBTA permit or cannot maintain a permit, or if the Service cannot issue the MBTA permit, the FHCP contains processes that will be followed to determine whether and when the need for permit amendment is necessary. Please see FHCP Sections 5.3.7, 5.4.9, and 5.4.12 for further details. See the response to HOFF 5 and FOA 2.

EPIC 6

The DEIS and HCP Applies an Illegal “Take” Definition.

Under the FHCP, a take assessment is triggered when habitat retention guidelines or disturbance minimization measures are not fully implemented. However, actual biological take can be difficult to determine. NSO do not breed or occupy the same nest site each year, so temporary absence or non-breeding at a former nest site may not indicate that biological take has actually occurred. Pursuant to the FHCP, biological take is considered to have occurred if the NSO site is unoccupied and no nesting has occurred during a 3-year post-harvest period. This type of take assessment is possible in the context of the FHCP given the extensive monitoring that will be conducted, and may not be possible in most other situations. Thus, take is not being reversed or undone; rather it simply takes a period of time after timber management activities have occurred before we can be reasonably confident that biological take has actually occurred.

EPIC 7

The Definition of “Active” and “Vacant” Sites is Contrary to Existing Policy and Science.

The definitions of “Active” and “Vacant” used in the FHCP are specific to the FHCP and only applicable to the Plan Area. These definitions were developed based on data collected by Green Diamond through implementation of the 1992 NSO HCP and full demographic monitoring since 1990. After the 2008 memo referenced in EPIC’s comment, the Service updated the NSO survey protocol (2011 revision) to account for reduced detection rates for NSO in areas with barred owls. The goal of the revised survey protocol was to ensure that surveys detect NSO with a 95% detection probability. In 2012, Green Diamond also conducted a series of analyses to update the 1992 NSO HCP survey protocol to ensure surveys achieve a 95% probability of detecting NSO. Green Diamond consulted with a PhD statistician with West Inc. to design and conduct the analyses. The analytical methods were similar to Dugger et al. (2009) that informed the revisions to the Service’s NSO survey protocol, except that Green Diamond used ownership-specific data for the analyses and evaluated their site visit survey data (survey for known spotted owl sites) separately from their pre-harvest NSO survey data. This allowed Green Diamond to estimate detection probabilities for both site visits and THP surveys, where the latter were unavailable to


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Dugger et al. The analyses conducted in 2012 allowed Green Diamond to update the 1992 NSO HCP with the number of surveys required to achieve a 95% detection probability for pre-harvest surveys and surveys for known spotted owl sites while accounting for the presence of barred owls. The FHCP has incorporated the results of these analyses in the proposed survey protocols (See Appendices H and F).

Green Diamond conducts annual pre-harvest surveys, demographic surveys for all known sites (active and vacant), and property-wide surveys at a series (>500) of fixed survey locations. All surveys include species-specific protocols for NSO and barred owls. FHCP F.2.1.5 requires that historical NSO sites within the influence of barred owls (FHCP F.2.1.12) receive one stand search on or after 1 June to increase the probability of locating evidence of roost sites or elicit juvenile NSO begging calls. The barred owl research program incorporating barred owl removal experiments proposed in the FHCP should keep barred owl presence within the Plan Area at a low level. However, FHCP F.2.1.17.4 requires that NSO sites influenced by barred owls must remain unoccupied for 5 years before being designated as “vacant.”

Additionally, Green Diamond analyzed the rate of recolonization at sites designated as “Vacant” (sites unoccupied by NSO for three consecutive years) under the 1992 NSO HCP and found that it takes a minimum of 10 years for recolonization at sites unoccupied for three consecutive years (FHCP 6.2.4.3). However, the majority of sites unoccupied for three consecutive years were not recolonized for 18 years or longer. Site vacancy is not the same as site “abandonment,” as the term is currently used by the Service, and the FHCP assumes that sites designated as “vacant” will eventually be recolonized by NSO given the dynamic nature of managed lands. A provision of the FHCP allows harvest within sites designated as vacant without the potential for take since NSO sites may remain vacant for reasons unrelated to harvest.

EPIC 8

The DEIS Confuses Ongoing Management Activities with Action Alternatives. Many of the mitigation measures are activities that GD is already doing as part of a separate permitting program and should be considered part of the no action alternative. While GD is free to incorporate these activities into their HCP, the DEIS should in no way rely on these to find and improvement in baseline management practices and cannot take credit that these measures are additional mitigation/minimization measures.

The purpose of a Habitat Conservation Plan is to authorize incidental take, as well as to integrate non-Federal development and land-use activities with conservation goals, resolve conflicts between protection of listed species and economic activities on non-Federal lands, and create a climate of partnership and cooperation (2016 HCP Handbook pg. 1-2). Ongoing actions are part of the No Action Alternative as well as the FHCP. Having multiple resource protection needs met in the same areas is good planning, and should be encouraged. Also, see response to EPIC 3.

EPIC 9

Failure to Consider a Reasonable Range of Alternatives

The commenter (and several other commenters) have recommended inclusion of lethal barred owl removal as a component of all project alternatives. As pointed out by the commenters, barred owl removal (and the prerequisite issuance of an MBTA permit) is included in the Proposed Action but is not included in Alternative A or Alternative B.


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EPIC correctly points out several of the essential rules for developing a reasonable range of NEPA alternatives, including the focus on providing decision-makers with sufficient options to allow a reasoned choice. Habitat conservation planning requires crafting dozens of diverse conservation measures, compiled into a functional HCP. Any of those measures can be adjusted to form different alternatives – the challenge is to develop a reasonable range among many possible combinations. For this EIS, the Service chose to focus on high-level approaches to NSO conservation using static reserves (Alternative A) and uneven-aged management (Alternative B). Most other actions were held constant, but the Service decided that including the same barred owl management actions in all alternatives was not necessary to provide a reasonable range of alternatives that allows for comparison and contrast of habitat outcomes under different silvicultural methods.

In the EIS, the Service compares and considers the landscape-specific impacts for NSO habitat under the proposed FHCP, static reserves, and uneven-aged management which are unaffected by barred owl management experiments. The Service found that, with or without barred owl management, the proposed FHCP was superior to Alternatives A and B as a means to increase habitat quality supported by 25 years of research on the NSO population response to management on Green Diamond timberlands. Adding barred owl management experiments to all of the alternatives would certainly be consistent with the Revised Recovery Plan for NSO and therefore contribute to NSO recovery, but it would not alter the relative habitat outcomes and benefits under the range of alternatives.

Furthermore, adding the barred owl management experiments to any HCP alternative is an additional program with added costs for the applicant. The EIS acknowledges that alternatives A and B would entail greater economic sacrifice by the applicant, but the EIS also finds that greater habitat benefits are not likely to result from alternatives A or B. Accordingly, it is reasonable for the Service to omit a program of barred owl management experiments with additional costs from Alternatives A and B that are included to test the premise that NSO conservation would be better served by more tree retention and less intensive harvest. The EIS finds that this premise of more retention or less intensive harvest does not provide better habitat quality. The addition of barred owl management experiments to these alternatives does not alter that finding. Alternatives A and B provide information about how NSO are likely to respond to an ITP in the absence of barred owl management, which helps provide a reasonable range of alternatives for consideration.

The Service also notes that barred owl removal is not simply another type of forest management prescription applied to use of property – it requires an applicant that will dedicate resources and expertise to develop and implement a complex and controversial research program to deal with interspecies competition. The Service has found that many landowners do not have the capacity or are unwilling or reluctant to become involved in barred owl management. Such a program requires a separate Service action (i.e., the issuance of a MBTA permit) that is costly and controversial for social and ethical reasons. Including barred owl removal in all alternatives as a “given” would be problematic, in the Service’s judgment, because it fails to recognize this added cost and controversy.

The distinct inclusion of barred owl management experiments in the proposed FHCP alternative is warranted because Green Diamond has pioneered barred owl management experiments on its California Timberlands and its scientific stepping-stones have been useful to the Service in implementing its own barred owl management experiments. The barred owl management


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experiments proposed in the FHCP are a unique contribution by Green Diamond and outgrowth of implementation and adaptive management under the NSO HCP (1992). Green Diamond is not currently conducting any barred owl experiments on their property (and has not for about 2-3 years), so not Baseline. However, results of their former experiments were the basis for encouraging them to conduct future experiments. We do not consider it reasonable to expect the applicant to simply take a complex long-term scientific experiment that was commenced under an existing HCP and silvicultural regime and apply it to any silvilcultural alternative that the Service may want to consider, especially when it is an added program and cost and not merely a condition on use of property.

Note also that the Service considered alternative barred owl management approaches (e.g., non-lethal removal). For the reasons explained in EIS Appendix C, those alternatives were not carried forward for detailed consideration.

EPIC 10

The HCP and DEIS rely on inappropriate habitat definitions

The FHCP proposes to use the same habitat definitions and take thresholds established in the 1992 NSO HCP. These definitions and thresholds have been in place and studied for more than two decades and are specific to Green Diamond managed lands. Since Green Diamond will be operating under an ITP associated with the FHCP, habitat protection measures are designed to assess “take/no take” standards as opposed to ‘take avoidance,’ which is applied to lands not covered by HCP ITPs. The Service’s guidance for take-avoidance for the California Coast Forest District (2011 “Attachment A” document) includes definitions for NSO foraging habitat and nesting/roosting habitat. According to those definitions, foraging habitat contains ≥40% canopy cover of trees (hardwood or conifer) that are ≥ 11-in. dbh and have a basal area ≥75 square feet per acre of trees ≥ 11-in. dbh. Nesting/Roosting habitat contains ≥60% canopy cover of trees (hardwood or conifer) that are ≥11-in. dbh and have a basal area ≥100 square feet per acre of trees ≥ 11-in. dbh. The habitat definitions in the FHCP are described in terms of stand age (i.e. ≥ 31 years = foraging with some opportunities for roosting and nesting and ≥46 years = nesting/roosting); however, the age categories result in comparable tree size and basal area standards but generally greater canopy cover standards compared to standards in the Service’s guidance document. The FHCP proposes to use stand age since this is consistent with the 1992 NSO HCP, and stand age is a more streamlined metric to use for management and monitoring purposes.

EPIC 11

Failure to account for impacts to dispersal habitat and potential dispersal-related “take”

Under the NSO critical habitat rule (77 FR 71907), the Service considers NSO dispersal habitat in redwood habitats to include, but are not limited to, trees with at least 11-in. dbh and minimum 40% canopy cover. Areas considered to be suitable for nesting, roosting, and foraging are also considered suitable dispersal habitat. Accordingly, the Service considers that dispersal habitat is widespread and not limiting on Covered Lands. Like many species, dispersing NSO experience high mortality, but given the widespread use of even-age harvest on both private and public lands in northwestern California, and that NSO are known to successfully disperse throughout these landscape, the Service does not think impacts to dispersal habitat will result in increased take.


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During section 7 consultation with the U.S. Forest Service, when NSO take is analyzed, dispersal habitat is not part of that analysis. In addition, being a younger age class with smaller trees, dispersal-only habitats are not typically subjected to harvest under FHCP management.

EPIC 12

Failure to Cultivate Public Involvement

The NOA published in the FR for public viewing on July 23, 2018. A press release was sent out to the Humboldt Insider, Mad River Union, Crescent City Times, Times-Standard, North Coast Journal, Lost Coast Outpost, and the Redwood Times on July 25. In addition, a public meeting was held on August 28, 2018.

EPIC 13

From my review of the HCP, I find elements of the plan deficient and likely to contribute to ongoing regional and local NSO declines.

There may be adverse effects to NSO including take under the FHCP; however, without barred owl management, NSO will likely be extirpated from Covered Lands. The FHCP is expected to help stabilize the NSO population on Covered Lands, not contribute to the ongoing regional and local NSO declines. Also see the responses to EPIC 2 and FOA 1.

EPIC 14

Certainly, the company can do more to contribute to recovery of the owl by maintaining all historic nest sites, particularly in light of the alarming range wide declines in owl populations, including on Green Diamond lands (Dugger et al. 2016).

The purpose of the proposed FHCP is not to recover listed species, but rather to authorize incidental take, as well as to integrate non-Federal development and land-use activities with conservation goals, resolve conflicts between protection of listed species and economic activities on non-Federal lands, and create a climate of partnership and cooperation (2016 HCP Handbook pg. 1-2). However, several of the Revised Recovery Plan Actions are considered in the FHCP, and the barred owl control effort is expected to at least stabilize the declining NSO population. Also see responses to EPIC 13 and FOA 1.

EPIC 15

Green Diamond provides only limited assurances that after six years of monitoring its logging activities in owl habitat it will enter into “adaptive management” with the Service if the approach is ineffective at stemming NSO declines. That is a risky and unclear proposition given that if populations continue to decline, declines may not be linear or reversible in time. (EPIC Attachment #2; page 1).

One of the triggers under adaptive management for NSO (FHCP 5.3.6.1) is to assess population trends. Six years is proposed because it is the minimum number of years needed to estimate a population trend (i.e., estimate lambda). Additionally, adaptive management will also be implemented if the trend in mean fecundity estimate from the Plan Area is statistically lower (p ≤ 0.05) than a comparable regional mean (FHCP 5.3.6.1).


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EPIC 16

Green Diamond also proposes to limit harvest within 0.5 miles radius surrounding owl activity centers (with numerous stipulations). The Service needs to examine the efficacy of this narrow buffer in relation to Recovery Action 10. (EPIC Attachment #2; page 2)

The 0.5-mile circular radius buffer is the equivalent of a NSO home range on the Green Diamond Ownership. The Service’s guidance for take avoidance for the California Coast Forest District (2011 “Attachment A” document) uses a 0.7-mile circular radius habitat buffer around NSO sites. The 0.5-mile circular radius habitat buffer proposed in the FHCP is based on ownership-specific data and was extensively studied over the past 27 years during implementation of the 1992 NSO HCP. Green Diamond has conducted pre- and post-harvest full demographic monitoring for all known NSO sites. The habitat buffer and take/no-take thresholds are specific to the Green Diamond ownership. For more information on the results of the NSO displacement studies, see FHCP Appendix C, Chapter 1. Also, see the response to EPIC 17.

EPIC 17

It appears that Green Diamond’s HCP violates Recovery Action 10 by proposing to log unoccupied sites and by providing insufficient buffering (e.g., out to the provincial home range radius of 1.3 mi) from logging.

The prioritization factors outlined in Recovery Action 10 were considered during the FHCP development process and the DCAs were chosen based on those criteria. Recovery Actions are not regulations and furthermore, using over 20 years of demographic data, the DCAs were chosen based on high levels of occupancy and fecundity while also considering spatial distribution and barred owl influences. Thus the Service assessed all conservation actions provided by the FHCP and the followed suggested recovery actions in the Recovery Plan, for instance Recovery Action 10 is met through retaining habitat around existing productive NSO sites as a priority (i.e., DCAs).

Section 10 of the ESA does not require recovery of the species, but rather is to authorize incidental take, as well as to integrate non-Federal development and land-use activities with conservation goals, resolve conflicts between protection of listed species and economic activities on non-Federal lands, and create a climate of partnership and cooperation (2016 HCP Handbook pg. 1-2).

EPIC 18

If the habitat model is wrong, or Barred Owl pressures intensify, it may be too late to reverse course on areas already logged under the HCP provisions of incidental take and the rather vague NRF and adaptive management “triggers” that may or may not result in mitigating timber harvest impacts.

The conservation program proposed under the FHCP is not based on the habitat model and the model does not determine management actions. Although there may be adverse effects to NSO including take under the FHCP, the conservation value of this plan, especially barred owl management, is expected to help stabilize regional and local NSO declines. If barred owl management is not implemented the NSO population will continue to decline under any management regime.


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In order to ensure that the conservation program is working properly, over the first 5 years of the proposed FHCP Green Diamond and the Service will hold annual meetings to discuss issues that might arise during initial implementation. Additionally, field reviews will be scheduled in the second and fourth year to allow for technical evaluation of the conservation measures that were implemented. Annual reports will be submitted and full demographic surveys will continue for the first 10 years of the FHCP. Adaptive management will be triggered if declines continue in years 6 and 10. The EIS was edited to state that if adaptive management is triggered, Green Diamond will implement one or more of the additional habitat protections outlined for NSO Adaptive Management on page 2-20 of the EIS.

EPIC 19

The Service also needs to take a hard look at the limited range of alternatives proposed by Green Diamond. An additional alternative that would better comply with NEPA and the recovery plan would be to include Barred Owl removal in all alternatives in conjunction with stronger NSO habitat protections by including: (1) all historic nest sites regardless of occupancy; (2) owl provincial home ranges (1.3-mile radius, instead of the 0.5-mile buffer); and (3) juvenile dispersal habitat that is functionally equivalent to NRF habitat (Sovern et al. 2015).

The range of alternatives carried forward in the EIS is a result of the Service’s determination of a reasonable range following extensive collaboration with Green Diamond over the course of the FHCP and EIS development process. The Service has determined that alternatives presented in the EIS represent a reasonable range. Also, see the responses to EPIC 9, HOFF 2, and HART 16.

EPIC 20

The multi-species HCP includes estimated fisher populations (n=335) and estimated tree vole populations (n=11,833) in the planning area with no supporting data or citations. Where did these numbers come from and can they be validated or were they inferred from habitat? (EPIC Attachment #2; page3)

FHCP 4.3.3.5 describes the details of the research that resulted in the population density estimates for fisher on the Green Diamond ownership. These ownership-specific density estimates were used to calculate the fisher population on Green Diamond. FHCP 6.3.2 states “The estimated population density of fishers on Green Diamond’s ownership based on two study areas and two estimation techniques was 0.23 fisher/km2 (sexes combined). Applying this average across the Plan Area, Green Diamond estimates a population of 335 fisher.”

FHCP 6.4.2 states “Green Diamond used data from field work conducted during 2001-2005 (Section 4.4.4) to estimate density of tree vole nests in suitable habitat on Green Diamond’s plan area… The Green Diamond data from 2001-2005 estimated an average density of 0.06 tree vole nests/acre in young stands (23 to 75 years). Using data from young stands in Swingle (2005), Green Diamond inflated estimates of vole nests by 100% to account for vole nests not visible from the ground and then divided the estimates of nest density by 2.2, which was the average number of nests used by tree voles in young stands in Oregon. Green Diamond applied this average to the average annual amount of vole habitat in the plan area from our habitat model (Section 4.4.4) and estimated a population of approximately 11,833 tree voles.”


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EPIC 21

Many of the mitigation actions are what the company is already doing. The HCP should include measures above the baseline status-quo management.

The Service considers it acceptable that permit applicants incorporate conservation measures they are already implementing in any newly developed plans. All management actions on the Covered Lands during the Term of the FHCP are considered for their direct, indirect, and cumulative benefits to the Covered Species just as the EIS considers all of the impacts. Section 10 of the ESA does not require that conservation measures benefiting Covered Species be distinct and exclusive from conservation measures and conditions that are beneficial to other resources and species that are not covered in a particular conservation plan. Under current management, Green Diamond is under no obligation to continue efforts to control barred owls, but they do have such a commitment under the FHCP. Also, see the response to EPIC 2, EPIC 3, EPIC 8, EPIC 13, and FOA 1.

EPIC 22

The discussion about GHG emissions is woefully inadequate and implies that the companies logging emissions are insignificant in the larger scope of emissions from other sources and the unproven notion that all forests they manage are currently acting as a sink.

As described in Section 3.7 of the DEIS, both the EPA (2005) and the California ARB (2011) agree that forestlands generally act as atmospheric carbon sinks whereby CO2 is captured from the atmosphere and fixed, through the process of photosynthesis, in wood fiber. It is a reasonable assumption that that forestlands in the Plan Area also act as carbon sinks. The primary management activities that release CO2 involve fossil fuel combustion during harvesting and transport of timber, and site preparation (e.g., prescribed burning). A life-cycle analysis that includes in-boundary and out-of-boundary emissions in relation to net sequestration and long-term carbon storage lost to logging, transport, and manufacture of wood products is speculative because Green Diamond has no control over the types of products and their fate. In addition, there is little difference between alternatives in terms of silviculture and harvest levels. As such, GHG emissions are not anticipated to differ greatly except under Alternative B where GHG emissions may be greater than under the other action alternatives due to uneven-aged silvicultural practices (as noted in Section 4.2.3 of the DEIS).

FOA 1

The DEIS and Draft FHCP inappropriately assume that barred owl removal is an effective strategy to mitigate harm to NSOs based on preliminary and inconclusive evidence.

The Service uses the best available information for making decisions. Although much is still unknown about the long-term efficacy of barred owl removal, there is site-specific data suggesting that it does maintain NSO occupancy. Because there are no other known or hypothesized techniques to prevent NSO extirpation because of barred owl invasion, removal is seen as the only presently available option. Given the unknowns, the Service considers barred owl removal an imperfect solution to this pressing problem. Waiting many years for all the science to be completed, or for another solution to appear, are not considered viable options since the situation only worsens as the years pass. Without management of barred owls, there is a high likelihood that NSO will ultimately be extirpated from Covered Lands, and that this


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extirpation will occur regardless of the amount and quality of NSO habitat present. Thus, barred owl control not only mitigates for the impacts of timber harvest, its prompt implementation is essential if there is to be any expectation that NSO will be remain extant on Covered Lands. In addition, implementation of barred owl control under the FHCP would increase our knowledge going forward about the efficacy of this activity.

FOA 2

The DEIS and Draft FHCP fail to demonstrate compliance with the MBTA and claim to use different and inconsistent regulatory provisions of the MBTA to authorize barred owl removal.

The Service’s NSO Revised Recovery Plan suggests a need for assessing barred owl control and the MBTA scientific collection permit process facilitates a way for barred owl control experiments. And, the U.S. Court of Appeals for the Ninth Circuit has held that MBTA permits may be used to control barred owls for the benefit of the northern spotted owl (Friends of Animals v U.S. Fish and Wildlife Serv. 879 F3rd 1000 [9th Cir 2018]). Any MBTA permit applications would need to demonstrate compliance with all applicable laws and regulations. It is the Service's understanding, through the FHCP, that Green Diamond is committed to Barred Owl Research measures throughout the term of the FHCP, as discussed in Section 5.3.4. If Green Diamond fails to obtain a MBTA permit or cannot maintain a permit, or if the Service cannot issue the MBTA permit, the FHCP contains processes that will be followed to determine whether and when the need for permit amendment is necessary. Please see FHCP Sections 5.3.7, 5.4.9, and 5.4.12 for further details. See responses to EPIC 5 and HOFF 5.

FOA 3

The FHCP fails to minimize and mitigate impacts to the northern spotted owl and significantly reduces the habitat protections of the NSO HCP.

The 1992 NSO HCP included 40 set-aside areas. As described in FHCP 4.4.1.3 and 5.3.1.4, NSO sites associated with the set-asides were not managed as “no-take” sites. The value of set-asides under the 1992 NSO HCP varied such that some contributed to both NSO survival and fecundity and others were never occupied by NSOs. The set-asides that appeared to be initially unoccupied in 1992 continued to be unoccupied by NSO throughout the elapsed years of the NSO HCP. The most important lessons learned from monitoring the set-asides since 1992 is that places selected by the NSO for roosting and nesting have special qualities that tend to result in repeated generations of NSO being tied to the same general location for their nest sites or activity centers. However, unoccupied locations that were selected because they appeared to have suitable habitat were very unlikely to ever be used by NSO. The DCAs will provide a greater biological benefit to NSO than the set asides as measured by NSO occupancy and fecundity.

The Service’s Recovery Plan for NSO has several Recovery Actions that are met by this proposed FHCP, for instance Recovery Action 10 suggests the need for retaining habitat around existing productive NSO sites, this is done through the DCAs of the FHCP. Recovery Actions around managing barred owl populations (e.g., Actions 22, 23, 24, 25) are also met through the preferred alternative and the FHCP. The Service’s analyses and conclusions are that the proposed minimization, mitigation, and adaptive management conservation measures in the FHCP


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effectively minimize and mitigate the effects of the proposed take. Also, see response to CDFW 4 and HOFF 7.

FOA 4

The DEIS fails to accurately describe and analyze the impacts of incidental takes authorized by the FHCP, and fails to take a hard look at the environmental impacts of the FHCP.

Section 4.2.1.1 of the EIS provides a detailed analysis of the consequences of the FHCP on NSO. Accordingly, the Service thinks that the EIS does take a hard look at the environmental impacts of the FHCP. See the response to CDFW 33.

FOA 5

Green Diamond’s monitoring activities under the FHCP are insufficient to ensure that northern spotted owl populations are not being appreciably harmed by the FHCP, and the DEIS fails to analyze this.

For the initial 10-year period of the FHCP, Green Diamond’s NSO monitoring includes pre-project surveys and a full demographic study where all individuals are uniquely marked, followed, and all NSO reproduction is quantified. We expect the full demographic study to generate information sufficient to adequately monitor the NSO population on Covered Lands. The occupancy model could be used in the future as a proxy for observed NSO occupancy, but only if the model is ultimately validated, which would occur, in part, using the data collected during the demography study. Post-validation of the model all DCAs and at least 12 additional sites will be monitored, at least 20% of potential take sites will be monitored annually, and site occupancy surveys will continue throughout the Plan Area.

GDRCo 1

Green Diamond's conservation partnership with the USFWS (introductory comment).

Comment noted

GDRCo 2

The unique and substantial scientific foundation for the Forest HCP.

Comment noted

GDRCo 3

The Nine-Year process for Development of the Forest HCP

The HCP process can be lengthy, especially when the property in question is large (i.e., several thousand acres), the species proposed for coverage are controversial (i.e., the northern spotted owl), and there is little information available regarding some of the species (i.e., red tree vole and Sonoma tree vole) proposed for coverage. In addition, during negotiations on the FHCP between Green Diamond and the Service, one of Green Diamond’s managers retired (who was substantially involved in FHCP development). In addition, the Arcata Field Office had two people retire who were lead Service representatives in the FHCP negotiations; therefore, work within the Arcata Field Office had to be reprioritized based on the remaining staff. In addition, in


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2013, shortly after one of the retirements, the Service was under ‘Sequestration’ and was unable to hire any new biologists to replace those who retired.

Furthermore, when Green Diamond submitted the FHCP to the Service’s Region 8 office in December of 2011, the Arcata Field Office did not consider the FHCP to have adequately minimized and mitigated the impacts to Covered Species to the maximum extent practicable. Consequently, the Arcata Field Office summarized our concerns regarding Green Diamond’s conservation strategy in a May 2012 letter to the company. At that time the Service’s concerns were unresolved, therefore further negotiations on the FHCP were necessary to resolve these issues. Furthermore, at that time after consulting with our solicitor, the Service determined that the draft EIS did not analyze a full range of alternatives, which necessitated further discussion with Green Diamond. Later in 2015, several questions and requests as part of an internal review were also discussed with the Applicant. These questions and requests resulted in additional clarifying edits to improve the understanding of the FHCP and the analyses of effects in the draft EIS. As a result of these efforts made in preparing the draft EIS and the analyses, the FHCP was improved.

GDRCo 4

The appearance and later removal of a DEIS action alternative based on inclusion of the marten as a covered species deserves some explanation.

During early negotiations on the FHCP, the Service determined that we did not have enough information about the species’ needs to be able to develop or evaluate a conservation strategy for the marten. Later, when more information about the species’ needs became available, we discussed mitigation measures with Green Diamond that the Service thought necessary for inclusion of the marten as a Covered Species in the FHCP; however, Green Diamond was unable to include those measures in the FHCP. Therefore, the marten was not included in the DEIS.

GDRCo 5

The essential role of barred owl control research in NSO conservation is beyond doubt and fully supported by FWS policy and authority under the ESA and MBTA.

We agree with Green Diamond that barred owl experiments are a key component of the conservation strategy of the FHCP. As discussed during FHCP negotiations, the Service anticipates that Green Diamond will conduct barred owl experiments through permits issued by the Service’s Migratory Bird Treaty Office.

GDRCo 6

The FHCP developed by Green Diamond in cooperation with the FWS over the past nine years and based on collaboration with the FWS over the past 25 years is a sound plan for continuing the conservation and recovery of NSO and other covered species on Green Diamond’s California Timberlands.

Comment noted.


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HOFF 1

The EIS fails to quantify owl site protections in Alternative B; i.e., in either size of ROCAs or number of same. Section 2.1.4.4 needs to be rewritten to allow for Alternative comparison and sufficient analysis under NEPA.

We incorporated the requested information into Alternative B of the FEIS. See section 2.1.4.4 of the FEIS.

HOFF 2

The EIS describes the practicality of Barred Owl removal then fails to explain why Barred Owl removal is not proposed in more Alternatives.

Under NEPA, alternatives need to provide a variety of approaches regarding strategy, timeframes, etc., so that the alternatives provide a range of different alternatives that can then be compared to one another. Not having barred owl control in all alternatives allows comparison with alternatives that do include barred owl control. Also, see the response to EPIC 9.

HOFF 3

Actions that the Service has documented would be likely to incidentally take NSO under Attachment A for everyone else, are not considered incidental take for Green Diamond (2.1.1.7)

Like northern spotted owl habitat definitions, criteria for other parameters such as habitat retention, are best developed on a landscape-specific basis if possible. The standard no-take guidelines in Attachment A that the Service uses are a one-size-fits-all to be used in a wide variety of situation across the region. However, the no-take standards in the FHCP were developed based on landscape-specific research and experience on Covered Lands (including under the 1992 NSO HCP), and are therefore different from the Attachment A no-take guidelines. Green Diamond’s current activities under the 1992 NSO HCP (which is in effect until 2022) are legal (i.e., authorized through their existing HCP). Once their existing 1992 HCP expires (and if they don’t get another HCP), then the Service would have to evaluate whether their activities would result in take of NSO. Although Attachment A represents the guidelines we recommend timber operators follow to avoid take, there are provisions in Attachment A for deviations.

HOFF 4

Section 2.1.1.5 lists the major activities associated with Green Diamond’s land management but does not describe any of them as being “Covered Activities” under the proposed FHCP.

Section 2.1.1 pertains to activities under the No Action alternative and describes the current land management activities covered by the 1992 NSO HCP, which would occur regardless of FHCP approval. Those activities and the additional activities described in Section 2.1.2.5 would be Covered Activities, with specific modifications, if the proposed FHCP is implemented. A full list of Covered Activities can be found in Section 2 of the FHCP.


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HOFF 5

Section 2.1.2.1 does not contain any assurance that the Migratory Bird Scientific Collecting Permit will be renewed after three years. Due to potential absence of barred owl permits, the description of the impacts of the FHCP Alternative is insufficient under NEPA.

It is the Service's understanding, through the FHCP, that Green Diamond is committed to Barred Owl Research measures throughout the term of the FHCP, as discussed in Section 5.3.4. If Green Diamond fails to obtain a MBTA permit or cannot maintain a permit, or if the Service cannot issue the MBTA permit, the FHCP contains processes that will be followed to determine whether and when the need for permit amendment is necessary. Please see FHCP Sections 5.3.7, 5.4.9, and 5.4.12 for further details. Regardless of the outcome of our analyses in the biological opinion, if the NSO population drops to 47 sites or below, take of NSO will not be authorized. The Service will work with Green Diamond to ensure that their permit application is adequate for permit issuance. Accordingly, the description of the FHCP Alternative impacts are sufficient. See responses to EPIC 5, City of Arcata 2, and FOA 2.

HOFF 6

Section 2.1.3.7 describes how the static reserves would protect 99 sites of which 67 were active in 2014. Is 2014 the most recent data used in the EIS? Why not 2017? Please provide the year of the data used throughout the EIS and an explanation as to why when the most recent data available is not used.

Development of the FHCP and FEIS spanned 8 years, and the data was updated several times. Both documents underwent lengthy reviews (several months) with each update. Therefore, in order to move forward with the process and avoid a continuous cycle of updates and reviews, the FHCP and FEIS present data through 2015. FEIS 2.1.3.7, Table 2-1, and associated information will be updated to reflect 2015 data instead of 2014 data.

HOFF 7

There is no effort made to explain why any measures are to the maximum extent practicable for Green Diamond. A reader is left to conclude that none of the Alternatives analyzed in the EIS for Green Diamond’s Forest Habitat Conservation Plan meet the issuance criteria for an incidental take permit. See Section 2.2.1 on Humboldt Marten alternative.

The minimization and mitigation measures incorporated into the FHCP are expected to be commensurate with the impacts to the species likely to result from the covered activities. Incorporation of adaptive management measures to increase monitoring, and conservation of the covered species, if populations decline during the permit term, are intended to ensure that populations are not jeopardized. The proposed minimization, mitigation, and adaptive management measures in the FHCP are expected to effectively minimize and mitigate the effects of the proposed take to the maximum extent practicable.

City of Arcata 1

Why is(n't) Barred Owl removal proposed in more Alternatives?


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NEPA alternatives need to provide a range of action so that they may be compared. See the responses to EPIC 9, EPIC 19, HOFF 2, and HART 16.

City of Arcata 2

Would Barred owl removal be allowed over the 50-year HCP permit period, or is it subject to other permit approvals?

Barred owl removal is subject to permits granted by CDFW and the MBTA division of the Service. The MBTA permit will initially be a Scientific Collection Permit, which has a limit of three years. Later, Green Diamond could apply for a Depredation Permit or Special Purpose Permit, which could have a longer duration. See HCP 1-20, 5-79. Also, see the responses to EPIC 5 and FOA 2.

City of Arcata 3

Would the No Action alternative analyzed in the EIS result in default operations under the USFWS Attachment A after the current permit expires in 2022?

Yes.

City of Arcata 4

A longstanding concern for the City is that public lands managed for timber do not assume disproportionate responsibility of habitat maintenance in watersheds with a mix of timberland ownership types.

Habitat management in watersheds with many landowners can be a complex and controversial issue. The condition of each ownership is a result of past management, and going forward, habitat condition is also affected by ongoing landowner management decisions. Therefore, each landowner does have an influence on habitat conditions. However, in all watersheds, whether there are HCPs in effect or not, there are no regulatory requirements for adjacent landowners to coordinate or agree on habitat management decisions. The Service has no ability to require such coordination or agreement.

HART 1

The public meeting was useless - poorly advertised with poor presentation materials echoing the poor quality of data presented in the EIS and HCP.

Public meetings are useful, but public participation is optional. The NOA was published in the Federal Register for public viewing on July 23, 2018. A press release was sent out to the Humboldt Insider, Mad River Union, Crescent City Times, Times-Standard, North Coast Journal, Lost Coast Outpost, and the Redwood Times on July 25, 2018.

HART 2

Was there even a meeting or hearing on the AHCP/AACC. Is this AHCP open for public comment since it is being extended for 12 years and part of the FHCP.

Some commitments included as part of the AHCP/CCAA are also incorporated into the FHCP; however, those commitments included as part of the AHCP/CCAA and included in the FHCP are


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independent and enforceable commitments under the FHCP. The term of the AHCP/CCAA is not being extended; therefore, there is no need to reopen the AHCP/CCAA for public comment.

HART 3

GD must not be allowed to reduce riparian tree age groups and only restore them at the end of the plan timeframe. It should be front loaded to allow all trees in the RMZ and unstable areas to get as large as possible (no harvest).

Management prescriptions for RMZs and GUA were agreed upon in the AHCP/CCAA, which was approved, by the Service and NMFS in 2007. The conservation of RMZs and GUA provides valuable habitat for NSO. Prescriptions in the AHCP/CCAA are incorporated into the FHCP. No changes to the management prescriptions of these areas are proposed in the FHCP.

HART 4

Leave trees and rain on snow events are laughable. (not discussion on the snow and ice storms that pin the tops of hardwood trees to the ground & I remember laffing out loud when I read Simpson has no rain on snow events in the AHCP) (Page 1).

The FHCP Appendix E (TREE document) provides guidelines for tree retention within harvest units. The document acknowledges the natural processes that may influence future retention like wind throw and other weather-related influences. For these reasons, the document prioritizes the placement of HRAs (clumps of retention instead of individual tree retention) and retention of wind-firm trees in areas susceptible to wind throw or other natural processes (FHCP E.1.3.3 and E.1.9.1).

HART 5

Discussion of history and origin of Green Diamond/Simpson.

Comments noted.

HART 6

Why verify samples of only 20% of take sites and not all of them?

The FHCP proposes to use advanced statistical modeling to predict and account for take after model validation. The model is built using 100% of the sites, but once the model is validated, then a sample of take sites will be ground-truthed to verify the continued validation of the model. If 100% of take sites are verified (ground-truthed), then it would no longer be a sample of sites and it would negate the need for model predictions. The FHCP also includes a provision that requires Green Diamond to resort to full monitoring at all NSO sites potentially displaced through timber harvest if Green Diamond and the Service determine that prediction of take using a model based approach is unreliable (FHCP 6.2.5).

HART 7

HCP and Jeopardy Determination

The Service issued a non-jeopardy biological opinion on the 1992 NSO HCP on September 14, 1992. The number of owls taken has not exceed the maximum allowed in the NSO HCP. A new permit is necessary because the 1992 NSO HCP will expire in 2022. See FEIS 2.1.


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HART 8

Prey and forging habitat must have been very limited before loggers started their third rotation harvest.

The Environmental Assessment prepared by the Service for the 1992 NSO HCP projected that suitable habitat for NSO would increase over time due to implementation of the NSO HCP. Suitable NSO habitat was projected to increase from 38% to 61% of the ownership between 1991 and 2011. The actual abundance of NSO suitable habitat was 60% of the Green Diamond ownership in 2010. Implementation of conservation measures included in the 1992 NSO HCP resulted in an increase in suitable NSO habitat during that time and it is projected that the proposed FHCP would have the same result.

HART 9

NSO numbers will continue to decline even with fancy model verification and habitat inprovements.

Although there may be adverse effects to NSO including take under the FHCP, the conservation value of this plan, especially barred owl management, is expected to help stabilize regional and local NSO declines. Also, see the response to EPIC 13.

HART 10

Fudged Math

From 1992 to 2008, timber harvest triggered reporting of 74 displacements but with follow up monitoring 30 of the displacements met the criteria to be "returned" and therefore only 45 were thought to have resulted in take. Displacements are considered "returned" if: after the third breeding season following displacement owls nested for at least 2 years or nested for 1 year and the site was occupied by at least one owl for 3 years; after the fourth breeding season owls nest for at least 2 years or at least one owl occupies the site for 4 years; or after the fifth breeding season at least one owl occupies the site 4 out of 5 years. Using these "return" criteria, through 2017, Green Diamond's harvest activities are thought to have displaced 55 owl pairs.

HART 11

Where is all the data on fledgling survival and new nests?

FHCP B.2.2 provides general information on NSO juvenile dispersal and mortality rates. FHCP Appendix C – Chapter 4 provides information on adult survival and fecundity in relation to take under the 1992 NSO HCP. FHCP 6.2.4.3 provides information on recolonization of take sites.

HART 12

Is the 5 year review period gone?

Beginning the first year after permit issuance of the proposed FHCP, Green Diamond and the Service will hold annual meetings over the first 5 years to discuss issues that may have arisen during initial implementation. Additionally, field reviews of conservation measures that might have been implemented would be scheduled in the second and fourth year to allow for technical evaluation.


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HART 13

Why is this FHCP not terminated at twenty years and renegotiated then.

Reasons for developing an HCP include generating long-term commitments to conserve listed and at-risk species and delivering regulatory assurances to project proponents (2016 HCP Handbook pg. 1-2). The 50-year permit term was chosen because that is the harvest rotation timeframe. There are adaptive management measures built into the FHCP that call for additional conservation and would be triggered if after 10 years following approval of the FHCP the NSO population in the Plan Area continues to decline relative to the NSO population at the initiation of barred owl removal. Additional conservation would also be triggered if the trend in mean NSO fecundity estimate from the Plan Area were lower than a comparable regional trend.

HART 14

No discussion on why ending clearcutting or even age management is or is not working for recovery of any species on GD property holdings.

The purpose of an HCP is to authorize incidental take, as well as to integrate non-Federal development and land-use activities with conservation goals, resolve conflicts between protection of listed species and economic activities on non-Federal lands, and create a climate of partnership and cooperation (2016 HCP Handbook pg. 1-2).

The landscape management commitments proposed in the FHCP would provide a dendritic network of intact older forests next to early seral stands creating high levels of habitat heterogeneity. The habitat suitability model developed by Green Diamond has indicated that proximity to foraging habitat (younger forests) and edge habitat is a key component of high quality habitat for NSOs in the Plan Area.

HART 15

Where set asides chosen as failures since inception of NSO listing to prove set asides do not work.

As part of the 10-year review, Green Diamond conducted NSO survival and fitness analyses in which the position of NSO nest sites or activity centers relative to set-asides was included as a covariate (Section 4.4.1; Appendix C). Specifically, NSO sites were characterized as being within, adjacent to (<0.5 mile) or outside of (>0.5 mile) set-asides. With respect to survival, NSO at sites that were adjacent to set-asides had the highest survival, followed by those within and finally those outside set-asides. With respect to fecundity, NSO adjacent to set-asides had the highest fecundity, followed by those outside and those within set-asides. This suggests NSO within or near set-asides have the highest fecundity, and those outside have the lowest.

Green Diamond’s data indicated that high quality foraging habitat occurs along the edge between young and mature forests (FHCP section 4.4.1 and Appendix C), which most commonly occurs in areas of active timber harvesting. Set-asides were areas of mature forests with no timber harvest that were selected primarily because the areas were being used for nesting and roosting by NSO. Therefore, Green Diamond found the primary biological value of the set-asides was related to providing a stable core area for roosting and nesting of NSO that were either in or adjacent to set-asides. The high site fidelity that NSO showed to occupied set-asides provided additional support for the hypothesis that NSO benefitted from stable core areas.


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As noted in FHCP Section 4.4.1.3, the value of set-asides under the NSO HCP (Green Diamond, 1992) varied such that some contributed to both NSO survival and fecundity and others were never occupied by NSOs. The set-asides that appeared to be initially unoccupied in 1992 continued to be unoccupied by NSO throughout the elapsed years of the NSO HCP. The most important lessons learned from monitoring the set-asides since 1992 is that places selected by the NSO for roosting and nesting have special qualities that tend to result in repeated generations of NSO being tied to the same general location for their nest sites or activity centers. However, unoccupied locations that were selected because they appeared to have suitable habitat were very unlikely to ever be used by NSO. The DCAs will provide a greater biological benefit to NSO than the set asides as measured by NSO occupancy and fecundity. Also, see response to CDFW 4 and CDFW 5.

HART 16

Can Alternative B and the Preffered Alternative all be chosen and continued toward recovery.

Under NEPA, alternatives need to provide a variety of approaches so that a range of alternatives can then be compared to one another. The alternatives cannot be combined at this point in the process, and only one alternative can be selected. Also, see the response to EPIC 9.

HART 17

More larger set asides not less in protected RMZ is better for all species.

A variety of species including fisher and NSO in the Plan Area require habitat heterogeneity (mix of stand ages, sizes, and compositions) in order to meet life cycle requirements such as reproduction and foraging (Appendix C – Chapter 2; 4.3.1.2; and 5.2.2.1). For example, both NSO and fisher require complex structures for reproduction, and these complex structures are most commonly associated with older stands or older trees (B.2.3; B.3.4; and 4.3.3.2). However, both of these species require younger stands for foraging since primary prey species such as the wood rat are located in these young, disturbed areas with an abundance of sun-loving shrub species and a low abundance of shade-tolerant shrub species (See B.2.2, B.3.3, Appendix C – Chapter 3, and 4.3.3.3). Also, see the response to CDFW 4 and CDFW 5.

HART 18

Fishers the left behind species will have its home logged " untill den is abandoned or kits have been moved over .25 miles." This is not justified in the lituature or in the FHCP. Who thaught that .25 miles is ok to limit take what of one mile or a half mile is more reasonable since they scatter in human presence rembering the hunters and trapers.

The Service considers the proposed protection of fisher den sites with a 0.25-mile-radius no-harvest buffer until the kits have dispersed or the den abandoned as adequate for avoiding direct take of denning adults and dependent young. Denning fishers should have adequate time to move dependent kits to an alternate den upon human approach, and adult females are known to move kits from their natal den to several maternal den locations before the kits are weaned (Service 2016). The 126-acre area (i.e. the area represented by a 0.25-mile radius circle) around a fisher den site represents approximately 7 percent of the mean year-round home range size for female fishers in northwestern California (Higley and Matthews, 2009). Therefore, denning female


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fishers should have adequate foraging habitat available outside the 0.25-mile circle and away from active timber operations to provide for dependent kits.

HART 19

In section 5.3 "if decline some adaptive management actions" will occur. One death of a fisher is a decline and GDH killed one or more in and open water tank. How many in a trend will have to be taken for a decline to exist? Decline needs definition and so do the adaptive management actions, ie the logging, road building and use will change how?

A statistically significant decrease in occupancy estimates for a major portion (approximately 50,000 acres) of the plan area at 5 years after the occupancy model is validated would trigger an occupancy survey during the next 5-year interval in that area (in addition to routine monitoring of half the Plan Area). If fisher occupancy estimates continue to decline in an area 10 years after the occupancy model is validated full adaptive management would be implemented. Full adaptive management for fisher could include: retention of additional trees with hollows and other structural features favorable to fishers; measures to promote the long-term development of those features such as topping to promote "candelabra" tops, introducing heart rot, or physically creating hollows; and promoting the development of a minimum of one hollow tree per 100 meters of stream for all Class 1 and 2 watercourses within RMZs or one hollow tree per hectare in geologically unstable areas.

HART 20

This FHCP is lacking in a discussion of how many road miles and densities around fisher detections will be allowed and when removal will occur. How many miles of roads are too many or the density of roads will allow for recovery to occur (clue look up Slausen or Zelinsky.).

Potential adverse effects of roads on fishers include roadkill mortality, increased vulnerability to predators, displacement due to noise and human activity, loss and fragmentation of habitat, and an increase in wildfire starts (Naney et al., 2012). Lewis (2014), Spencer et al., 2015, and Gabriel (2013) reported that all fisher roadkill mortalities in their study areas were on paved roads with fast vehicle speeds and high traffic volume. Existing roads in the Plan Area are unpaved and the speed limits are lower than for paved roads, suggesting fisher roadkill mortalities are unlikely in the Plan Area even with an increase in road density during the plan period. Slauson and Zielinski (2010) reported that fishers within the Redwood Region of northwestern California made little use of roads but potential fisher predators (such as cougars and bobcats) did, suggesting road density alone does not affect fisher predation rates. Green Diamond does not provide information on changes to road density in the Plan Area or how roads in general or changes in road density may directly affect the fisher. However, they do cite two papers (Dark, 1997; Carroll et al., 1999) that suggest fishers prefer habitat with a greater density of low use roads.

HART 21 and 22

You continue to allow roads to "fragment and provide corridors for preditors bobcat and cyote" to create deadly mischif. Let the shootiing of cyotes begin, eh!

Where is the discussion of road removal and GDH habitat cores for this species to connect link habitat buffers to other protected cores?


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See the response to HART 20.

HART 23

The FHCP is not a conservation planing document to keep fisher and martins from being listed or is it to keep them listed as job security. oh precluded so you cant do your job of protecting species before decline occurs more than it already has. The lack of declanation is your legacy.

Comment noted. See the response to HART 14.

HART 24

On p 55 (Buck 94, Truex 98) FWS admits that "timber harvest reduce fischer density and survival. Fischers need no cut buffers of their home range. Determin, what is the site specific home range for GDH plan area and this FHCP for the fisher and martin in the plan area.

Home range size for fisher have not been determined. Marten is not a covered species under the FHCP.

HART 25

Martins warrent listing in the plan area because they were "extrapated from 99% of their range and 38% of occupied land is elgable for harvest by GDH."

A proposed rule to list the coastal marten as threatened under the ESA was published in the Federal Register on October 9, 2018. Green Diamond proposed including the marten in the FHCP; however, the Service determined that the available data for the marten contained significant gaps regarding the species' distribution, population size, and habitat needs within the Plan Area, making long-term conservation commitments speculative. Additionally, the conservation that was proposed did not include measures to minimize take to maximum extent practicable. Therefore, the Humboldt marten is not a covered species in the proposed FHCP and no take is permitted.

HART 26

Voles can and must be studied with infrared cameras before harvest especialy in RMZ's.

Through the TREE program, Green Diamond will identify and retain, to the extent practicable, potential vole nesting trees. Green Diamond will avoid felling trees containing evident tree vole nests when conducting authorized harvesting and other covered activities within RMZs. Foresters will inspect potential harvest trees for tree vole nests prior to marking trees for harvest to avoid felling or damaging trees with active or remnant vole nests. Infrared cameras are used for vole research, however, no research of tree voles is proposed in the FHCP.

HART 27

Where are the proctions for marbled mureletts in the plan area.

Marbled murrelets are not a Covered Species under the proposed FHCP; therefore, take would not be permitted.


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HART 28

FWS, GDH, and everyone know that reducing the area, rate and volume of harvest is the only thing that will save the NSO and other covered species. Reduce the harvest to create recovery, please.

See the response to HART 14.

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Dugger, K.M., R. Anthony, and E.D. Forsman. 2009. Estimating northern spotted owl detection probabilities: updating the USFWS northern spotted owl survey protocol. Final report. Department of Fisheries and Wildlife, Oregon State University, Corvallis, OR.

Dugger, K.M., E.D. Forsman, A.B. Franklin, R.J. Davis, G.C. White, C.J. Schwarz, K.P. Bernham, J.D. Nicols, J.E. Hines, C.B. Yackulic, P.F. Doherty, Jr., L. Bailey, D.A. Clark, S.H. Ackers, L.S. Andrews, B. Augustine, B.L. Biswell, J. Blakesley, P.C. Carlson, M.J. Clement, L.V. Diller, E.M Glenn, A. Green, S.A. Gremel, D.R. Herter, J.M. Higley, J. Hobson, R.B. Horn, K.P. Huyvaert, C. McCafferty, T. McDonald, K. McDonnell, G.S. Olson, J.A. Reid, J. Rockweit, V. Ruiz, J. Sanz, and S.G. Sovern. 2016. The effects of habitat, climate, and


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