April 22, 2016 Daniel A. Lovato Acting Forest Supervisor Plumas National Forest 159 Lawrence Street Quincy, California 95971 Sent via email to: comments-pacificsouthwest-plumas-featherrvr@fs.fed.us Re: Objection on the Environmental Assessment for the Forbestown Community Protection Fuels Reduction Project Dear Mr. Lovato: Sierra Forest Legacy hereby submits this objection to the Forest Service’s selection of the proposed action of the Forbestown Community Protection and Fuels Reduction Project Environmental Assessment (Forbestown Project). The Forbestown Project is proposed on the Feather River Ranger District of the Plumas National Forest. The responsible official is Randall J. Gould, District Ranger, Feather River Ranger District. The reviewing officer has been identified as Daniel A. Lovato, Acting Forest Supervisor, Plumas National Forest. The Finding of No Significant Impact Environmental Assessment for the Forbstown Project failed to adequately address and respond to the comments we submitted. In addition, the decision violates law, regulation, or policy, and our settlement agreement with the Forest Service, as our Statement of Reasons outlines. Attached to this cover letter, we provide a Statement of Reasons that presents specific reasons for the objection to the proposed decision, the related evidence and rationale on why the decision violates applicable laws and regulations, and the specific relief requested in response to our concerns. As required by 36 CFR 218.8(d), the objector is: Ben Solvesky Wildlife Ecologist Sierra Forest Legacy PO Box 244 Garden Valley, CA 95633 Phone: 928/221-6102

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Statement of Reason

Our concerns about the Forbestown Project are described in detail below. In general, the agency’s responses to our comments on the draft environmental assessment (EA) did not justify the need to reduce canopy cover in spotted owl habitat for fuels purposes and did not use the best available science to analyze the effects of the selected alternative on spotted owls. Outside of strategic areas identified for direct attack (e.g., ridges) or along essential community escape routes, we ask that the project avoid converting CWHR 5D and 6 habitat to a lower canopy cover classes within spotted owl territories by focusing on the removal of surface and ladder fuels and implementing a 20 inch diameter limit within these CWHR classes, except in extreme cases where it can be justified that the removal of a tree larger than 20 inches dbh is justifiable from a ladder fuel perspective. Such a general upper diameter limit would undoubtedly meet the purpose and need of the proposed action by providing for the removal of all ladder fuels within project units and would help reduce the likelihood of spotted owl territory abandonment within the project area. I. Best Available Science on California Spotted Owl and Mechanical Thinning and Violation of our Settlement Agreement As a general matter, the EA relies on approaches to assessing habitat and the impacts of treatments on such habitat that have been found by experts to be inadequate and not supported by the best available science. Forest thinning conducted under the standards and guidelines of the 2004 Sierra Nevada Forest Plan Amendment (2004 Amendment) has contributed to the precipitous decline of spotted owls on Forest Service-managed lands throughout the Sierra Nevada. As we reported in our comments on the EA (Appendix A), mechanical thinning that reduces canopy cover within spotted owl territories increases the probability of territory abandonment (Seamans and Gutiérrez 2007); increases home range size (Gallagher 2014) and extinction probability; and reduces reproductive output, colonization rates, and survival (Tempel et al. 2014); negatively affecting habitat suitability for more than 30 years (SNAMP 2015). It is also predicted that climate change will negatively affect the species and increasing or maintaining canopy cover will be the only way to mitigate the effects (Jones et al. 2016). The information contained in these and other papers was used by Forest Service scientists to develop the Interim Recommendations for the Management of California Spotted Owl Habitat on National Forest System Lands (IRs) on May 29, 2015 (included in Appendix A). The Plumas National Forest received the IR release letter from the Regional Forester on August 20, 2015 (Appendix B), prior to the closing of the Forbestown scoping comment period. Therefore, the project had not been “scoped” and the IRs were undoubtedly available to the Plumas National Forest to consider during NEPA analysis and should have been included as an alternative in the EA. Not only does the EA fail to consider the best available science in analyzing the effects of the proposed action, the failure to consider an IR alternative is a clear violation of our settlement agreement with the Forest Service. Although the District has made it clear they do not intend to consider the IRs for the Forbestown Project, we consider this transgression a reflection of the Forest Service’s overall commitment to adhere to the spirit and intent of our mutually agreed upon settlement.

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The IRs were created and designed to arrest the ongoing decline occurring on all Forest Service-managed lands throughout the Sierra Nevada as a result of management activities conducted under the 2004 Amendment. Even if the Forest Service chose not to select the IR alternative, the analysis framework presented in the IRs represents the best available science on the effects of timber harvest to the species. We are particularly concerned about the effects of the proposed action to CWHR 6 and 5D. According to the forest plan and virtually all literature on the subject, CWHR 5D and 6 are the highest quality spotted owl habitat available. Based on information provided by the Ranger District (Table 1), BU078 will lose approximately 40 percent (about 150 acres) of the CWHR 6 habitat within the HRCA (including the PAC). While it would appear the HRCAs include enough dense forest habitat to support the species (see EA Table 7), the forest plan infers that forest stands not considered high quality habitat (e.g., CWHR 3D) may be designated as HRCA-habitat if higher quality habitat is not available. We are not aware of any scientific literature supporting the idea that CWHR 3D habitat provides anything but less than marginal foraging habitat. Yet, the combined area of the two HRCAs (including PAC-acres) are composed of approximately 22 percent (about 380 acres) of CWHR 3D pre-treatment, including 73 acres of PAC. It could be inferred from this that in order to create an approximately 1,000-acre HRCA, the wildlife biologist had to make up for a lack of higher quality habitat available to these spotted owls by designating large amounts of CWHR 3D as HRCA. One could also conclude that prior to treatment each of the HRCAs are already significantly short on high quality dense forest habitat near the territory center (i.e., where it is most important, see Seamans and Gutiérrez 2007) and the treatment effects will only contribute to the further loss high quality habitat (see section II). It is also worth noting that of the 381-acres of CWHR 3D habitat included within the HRCAs pre-treatment (381 acres), only 44 acres (12 percent) are proposed for treatment under the proposed action. Arguably, CWHR 3D is a forest vegetation structure that is, by definition, almost entirely composed of ladder fuels and for which treatment would have a significant effect on reducing fire hazard and have little to no effect on spotted owl habitat.

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Table 1. Loss of dense forest habitat within HRCA YU008 and BU078 as a result of Forbestown, Slapjack, and the Lumpkin Fire. Assumes Lumkin Fire Effects Resulted in Canopy Cover Reduction. HRCA does not include PAC-acres. YU008

CWHR PAC HRCA Pre-Treatment HRCAPost-Treatment 3D 12 154 132 4D 86 316 238 5D 0 0 0 6 184 119 76

Total 282 589 446 Total - 3D 270 435 314

BU078

CWHR PAC HRCA Pre-Treatment HRCAPost-Treatment 3D 61 154 132 4D 94 274 197 5D 0 9 9 6 110 158 53

Total 265 595 391 Total - 3D 204 441 259

YU008 + BU078 PAC HRCA Pre HRCAPost

Total 547 1184 837 Total - 3D 474 876 573

II. Compliance with 2004 Sierra Nevada Forest Plan Amendment The project does not follow direction in the forest plan, i.e., the 2004 Amendment, in several ways. First, according to the 2004 Amendment, a management intent of spotted owl HRCAs is to: “Arrange treatment patterns and design treatment prescriptions to avoid the highest quality habitat (CWHR types 5M, 5D, and 6) wherever possible.” Clearly this was not done for the Forbestown Project. According to Table 11 in the Forebestown Silviculture Report, approximately 71 percent (326 of 459 acres) of CWHR class 5D (we assume the EA and supporting documents are using CWHR 5D and 6 interchangeably) within the project area will be eliminated under the selected alternative. The Forbestown project appears to be focusing commercial harvest treatments (i.e., not hand-thinning) on CWHR class 5D and 6, with 53 percent (326 of 621 acres) of all project acres consisting of CWHR 5D habitat to be converted to another CWHR type. Based on Table 1, 66 percent of CWHR 6 will be converted to a lower canopy cover class within HRCA BU078 (not including the PAC-acres) and 36 percent will be lost in YU008. How then can it be justified that this project was designed to avoid the highest quality spotted owl habitat in HRCAs wherever possible? Second, the forest plan also states that, “Where existing vegetation conditions permit, design projects to retain at least 50 percent canopy cover averaged within the treatment unit. Exceptions are allowed in limited situations where additional trees must be removed to adequately reduce ladder fuels, provide sufficient spacing for equipment operations, or minimize re-entry. Where 50 percent canopy cover retention cannot be met for reasons described above, retain at least 40

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percent canopy cover averaged within the treatment unit.” However, according to the EA, “The proposed treatments would reduce 224.9 acres of suitable habitat, within HRCA to an average of a 40% canopy cover.” We were not able to locate any rationale in the EA for dropping canopy cover in HRCAs to less than 50 percent. However, the Forbestown Silviculture Report suggests that, “Some CWHR 4 and 5 stands adjacent to roads would receive heavier thinning (removal of more trees and thin down to 40% canopy cover) to create open canopy stands and enhance diameter growth of residual trees.” These are not legitimate justifications to reduce canopy cover in an HRCA to less than 50 percent adjacent to or away from roadsides. III. Justifying Canopy Cover Modifications in Owl Territories In our project comments, we asked that the Forest Service justify the reduction of canopy cover in each treatment unit that violates the IRs. Although it appears the Forbestown EA attempted to bolster the discussion on the relationship between forest canopy parameters and fuels treatment, none of the studies cited were designed to test the effectiveness of treating surface and ladder fuels only versus the treatment of surface, ladder, and crown fuels. Such a study design is required to determine the degree to which canopy cover contributes to wildfire threat. The first study the EA cites is Agee et al. (2000), stating, “Treatments to create defensible space that increases firefighter safety, transportation safety, and increases suppression efficiency is designed within buffers surrounding roads and structures. These treatments alter surface fuels, increase the height to the base of the live crown, and open the canopy by removing trees (Agee et al. 2000).” Agee et al. (2000) is a paper that discusses the use and effectiveness of shaded fuel breaks. In citing the Agee et al. (2000), the Forbestown EA has essentially described a shaded fuel break. Shaded fuel breaks are designed to be resistant to wildfire (as opposed to resilient) and to provide firefighters with safe areas to implement direct attack. Agee et al. (2000) does not justify landscape reductions in canopy cover outside of strategic locations. Therefore, Agee et al. (2000) does not justify carte blanche reductions in canopy cover. We must note that the EA does not actually list Agee et al. (2000) in the references section, so we are assuming the Agee et al. (2000) cited in the EA is the same paper we list in our references section. The EA also suggests that opening canopy cover is needed to increase the effectiveness of aerial suppression. Such an idea is also a concept that does not support landscape reductions in canopy cover. For this purpose, reductions in canopy cover would only be justified in strategic locations, similar to shaded fuel breaks. Justifying thinning to reduce canopy cover on any acre across the general forest matrix to increase the effectiveness of aerial suppression, outside of strategic areas necessary for direct attack, is not helpful from a management perspective and would cause significant ecological harm if all of the WUI were thinned with such a goal in mind. Thinning for such a purpose clearly requires site-specific rationale, something the Forbestown EA has not attempted to provide. In reference to Agee and Skinner (2005), the Frobestown EA states, “Treatments are designed as low thinning, where all small trees are removed, and cutting of successively larger trees continues until the criterion is reached: 40% - 50% canopy cover (Agee and Skinner 2005).” However, such a statement does not support the idea that it is necessary to reduce canopy cover to affect fire hazard. Agee and Skinner (2005) are clear on this point, since they find that (page 9): “Some effective fuelbreaks had only surface fuels and ladder fuels treated, with residual

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canopy cover exceeding 60–70% (Fig. 8). Even though canopy bulk density was insignificantly reduced, fire severity was significantly reduced, suggesting that reductions in canopy bulk density are not always needed to reduce wildfire severity.” Despite our comments on your misleading and unsubstantiated portrayal Fites et al. (2007), Fule et al. (2006), and Safford et al. (2009), it is disturbing the EA has maintained its portrayal of these papers. We ask that you locate and directly cite the specific portion of Fites et al. (2007) where the report discusses the effectiveness of hand thinning. Again, we reiterate that Fule et al. (2006) is irrelevant to the Forbestown project because it relied on a 5 inch diameter limit, half the diameter limit proposed in the Forbestown project and Fule et al. (2006) found that prescribed fire, an activity proposed throughout most of the Forbestown project area, was effective at reducing fuels. We also note, again, that the four hand-thinned stands in Safford et al. (2009) are fraught with too many caveats to apply the effects to any treatment or condition outside of the study area (see Appendix A). In contrast to these inappropriately applied citations, Collins et al. (2011) actually conducted a study that compared the effectiveness of three different diameter limits on flame length across a landscape over a 30 year period (Figure 1). Figure 1. “Mean conditional burn probabilities across the Last Chance landscape for which simulated flame lengths are >2 m. Three diameter-limited thinning scenarios along with a no treatment scenario are reported. Each scenario was modeled into the future based on output from the Forest Vegetation Simulator, using our 2007 field inventory plot data as a baseline. Probabilities are based on 5,000 randomly placed ignitions simulated using RANDIG (see Methods for explanation). Note that the three thinning scenarios are nearly indistinguishable, with the exception of a slight departure for the 30.5-cm scenario in 2037.” (From Collins et al. 2011). Collins et al. (2011) is a more rigorous and relevant study on the influence of canopy cover on fire severity than anything cited in the Forbestown EA. The Forbestown EA also supports this idea in stating, “By treating surface and ladder fuels, that generate greater flame lengths, passive and active crown fire is mitigated.” We fully agree with this statement. We also note that North et al. (2009, a.k.a. GTR 220), a study endorsed in the Forbestown EA, affirms Collins et al. (2011), stating:

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“What is achieved by thinning intermediate sized (20- to 30-in d.b.h.) trees? Some research suggests that for managing fuels, most of the reduction in fire severity is achieved by reducing surface fuels and thinning smaller ladder-fuel trees (see summaries in Agee et al. 2000, Agee and Skinner 2005, Stephens et al. 2009). What is considered a ladder fuel differs from stand to stand, but typically these are trees in the 10- to 16-in d.b.h. classes. If trees larger than this are thinned, it is important to provide reasons other than for ladder-fuel treatment.”

The idea that open canopied forests are somehow more resilient to wildfire is simply unsupported. In fact, open canopied forests with high shrub cover can be, and often are, less resilient to wildfire than closed canopied forests. For example, Thompson and Spies (2009) stated that in the Biscuit Fire, “Open tree canopies with high levels of shrub-stratum cover were associated with the highest levels of tree crown damage, while closed canopy forests with high levels of large conifer cover were associated with the lowest levels of tree crown damage.” We also note that evidence from recent large wildfires on the west-side of the Pacific Crest on the Plumas National Forest do not support the idea that open canopy forests are somehow more resilient to wildfire than closed canopied forests. According to data provided by the Forest Service (http://www.fs.fed.us/postfirevegcondition/index.shtml), for two of the three largest fires on the Plumas National Forest since 20081 (i.e., BTU Lightning Complex, Chips, and Canyon Complex), outside of wilderness and within Forest Service boundaries, more evergreen open canopy forest burned at high severity than evergreen closed canopy forest. On the BTU Lightning Complex Fire, 12 percent more evergreen open canopy forest burned at high severity than closed and on the Chips fire that figure was 2 percent. In the Canyon Complex Fire, 6 percent more evergreen closed canopy forest burned at high severity than open. The threat of high severity wildfire is not caused by canopy cover or trees much larger than 12 inches, it is caused by fire exclusion and the buildup of surface and ladder fuels over a 10 to 20 year period in all forest canopy cover classes. 5S, 5P, 5M, or 5D, it does not matter; more than 10 years between surface and ladder fuel treatments and the probability of high severity fire are similar and increase similarly. IV. Conclusion We find that the District has inappropriately presented information in the Forbestown EA in an effort to justify the removal of large trees for economic purposes. This perpetuates unsubstantiated and disproven conventional wisdom (i.e., observations that are contrary to findings of scientific study design) about the influence of canopy cover on fire severity. We understand there are many constraints to increasing the pace and scale of prescribed fire to treat fuels, constraints we are tirelessly working to help remove. We are also aware that economics are a significant driver of the Forest Service’s management abilities and inadequate budgets to treat surface and ladder fuels drive the agency to design projects to log large trees to generate timber revenue to pay for the fuel treatments. We ask that you provide a transparent economic and ecological cost-benefit analysis and explicitly identify the extent to which logging is being proposed to create revenue to off-set the cost of removing surface and ladder fuels. As is demonstrated by Figure 1, it does not take long 1 Data was only available from 2008 through 2015.

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for wildfire hazard to return to pre-treatment levels, regardless which of the three diameter limits is being implemented. However, it is our experience that many Ranger Districts in the Sierra Nevada are running out of economically viable timber projects capable of offsetting the cost of expensive hand thinning treatments. It is only a matter of time before this reality reveals itself. Regardless of the canopy cover treated or retained from this project today, in 10 to 20 years from now the treatment units will have returned to pre-treatment fuels conditions, and where will the larger trees come from to pay for the removal of the surface and ladder fuels that will represent a wildfire hazard to the community? The Forbestown Project does not meet the management intent of the forest plan regarding spotted owl management in HRCAs. This is of particular concern because the ability of the forest plan to provide for spotted owl viability has been shown to be wholly inadequate. Spotted owls are declining on all Forest Service-managed lands and the decline is associated with reductions in canopy cover from logging. The IRs represent the best available science to ensure species viability. The effects of the project should have been judged in comparison to the protections provided by the IRs. Again, outside of strategic areas identified for direct attack (e.g., ridges) or essential community escape routes, we ask that the project avoid converting CWHR 5D and 6 habitat to a lower canopy cover classes within spotted owl territories by implementing a 20-inch diameter limit within these CWHR classes, except in extreme cases where it can be justified that the removal of a tree larger than 20 inches dbh is justifiable from a ladder fuel perspective. Such a strategy would still meet the purpose and need of the proposed action. Thank you for your time and attention. Please direct any questions or comments to Ben Solvesky (ben@sierraforestlegacy.org; 928-221-6102). Sincerely, Ben Solvesky, Wildlife Ecologist Sierra Forest Legacy PO Box 244 Garden Valley, CA 95633 Attachments Appendix A: SFL Comments on the Forbestown Project EA. February 8, 2016. Appendix B: August 20, 2015, Memo from Randy Moore to Forest Supervisors on the California Spotted Owl Interim Recommendations for Management (File Code 1950; 2670).

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References Agee, J.K., Berni, B., M.A. Finney, P.N Omi, D.B. Sapsis, C.N. Skinner, JW. Van Wagtendonk, and C.P. Weatherspoon. 2000. The use of shaded fuelbreaks in landscape fire management. Forest Ecology and Management 127:55-66. Agee, J.K. and C.N. Skinner. 2005. Basic principles of forest fuel reduction treatments. Forest Ecology and Management. 211: 83-96. Collins, B.M., S.L. Stephens, G.B. Roller, and J.J. Battles. 2011. Simulating fire and forest dynamics for a landscape fuel treatment project in the Sierra Nevada. Forest Science 57:77-88. Fites, J., M. Campbell, A. Reiner and T. Decker. 2007. Fire behavior and effects relating to suppression, fuel treatments, and protected areas on the Antelope Complex Wheeler Fire. Fule, P.Z., W.W. Covington, M.T. Stoddard and D. Bertolette. 2006. Minimal-impact restoration treatments have limited effects on forest structure and fuels at Grand Canyon, USA. Restor. Ecol. 14: 357-368. Gallagher, C.V. 2010. Spotted owl home range and foraging patterns following fuels-reduction treatments in the northern Sierra Nevada, California. M.S. Thesis, University of California Davis. Jones, G.M., R.J. Gutiérrez, D.J. Tempel, B Zuckerberg, and M.Z. Peery. Using dynamic occupancy models to inform climate change adaptation strategies for California spotted owls. Journal of Applied Ecology doi: 10.1111/1365-2664.12600. North, M., P. Stine, K. O’Hara, W. Zielinski, and S. Stephens. 2009. An ecosystem management strategy for Sierra mixed conifer forests. USDA Forest Service, General Technical Report PSW-GTR-220. Pacific Southwest Research Station, Albany, California. Safford, H.D., D.A. Schmidt, and C.H. Carlson. 2009. Effects of fuel treatments on fire severity in an area of wildland-urban interface, Angora Fire, Lake Tahoe Basin, California. Forest Ecology and Management. 258: 773-787. Seamans M.E., and R.J. Gutiérrez. 2007. Habitat selection in a changing environment: the relationship between habitat alteration and spotted owl territory occupancy and breeding dispersal. The Condor 109:566-576. SNAMP (Sierra Nevada Adaptive Management Program). 2015. Draft Sierra Nevada Adaptive Management Program Final Report: Appendix C. California Spotted Owl Team Report. Tempel, D.J., R.J. Gutiérrez, S.A. Whitmore, M.J. Reetz, R.E. Stoelting, W.J. Berigan, M.E. Seamans, and M.Z. Peery. 2014. Effects of forest management on California spotted owls: implications for reducing wildfire risk in fire-prone forests. Ecological Applications 24:2089-2106.

Appendix A

February 8, 2016 Randall J. Gould District Ranger 875 Mitchell Avenue Oroville, California 95965 Sent via email to: comments-pacificsouthwest-plumas-featherrvr@fs.fed.us Re: Comments on the Forbestown Community Protection Fuels Reduction Project Dear Randall: We have reviewed the proposed Forbestown Community Protection and Fuels Reduction Project Environmental Assessment and other relevant project documents. Based on our review of these documents, the proposed action has the potential to cause the abandonment of two California spotted owl territories. Due to serious concerns for the long-term persistence and viability of the species throughout the Sierra Nevada, the Forest Service finalized the Interim Recommendations for the Management of California Spotted Owl Habitat on National Forest System Lands (IRs) on May 29, 2015 (Appendix A). The IRs should be considered the best available science to maintain species viability when designing and implementing timber harvest and fuels reduction projects after May 2015. Furthermore, since the IRs were completed well in advance of project scoping, we believe that the lack of an IR alternative constitutes a violation of our settlement agreement with the Forest Service on litigation over 2004 Sierra Nevada Forest Plan Amendment (Appendix B). The failure of the Environmental Assessment to develop an IR-based alternative and the failure of the Biological Evaluation (BE) to analyze the effects of the proposed action using the IR-framework raises significant concerns about the Forest Service’s commitment to our settlement agreement and using the best available science to ensuring species viability within the unit. Community protection and forest resilience to fire are goals that do not require significant degradation of spotted owl habitat. 1) Violation of the 2004 Amendment Settlement Agreement Our settlement agreement states the following (California Spotted Owl, paragraph 7):

“The Forest Service agrees that any environmental impact statement or environmental assessment prepared for a site-specific, vegetation management project within the range of the California spotted owl in the Sierra Nevada National Forests, for which public notice of scoping is published after receipt of the recommendations described in paragraph 4, shall include and analyze an alternative consistent with (a) the recommendations described in paragraph 4 or (b) the final CASPO strategy.”

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Paragraph 4 of the settlement agreement pertains to the development of the IRs and the final CASPO strategy has yet to be completed. The IRs are dated May 2015; almost two months before the Forbestown scoping notice was published. Therefore, we believe that the Forbestown environmental assessment must develop a project alternative based on the IRs, in compliance with the settlement agreement. 2) Providing Forest Resilience, Community Protection, and Maintaining Spotted Owl Viability We strongly support minimizing the threat of wildfire to communities. The protection of life and property is often foremost in the minds of those who live and work in the Sierra Nevada. However, it is the responsibility of the community as a whole to provide for a fire-safe environment. It is the responsibility of the Forest Service to provide fire resilient forest conditions, prioritizing areas in close proximity to communities and along important emergency egress routes. We ask that you demonstrate that it is necessary for community fire protection and fire resiliency to reduce canopy cover to 40 percent and remove trees 20 to 30 inches dbh within each unit in a spotted owl territory (i.e., significantly increase the likelihood of territory abandonment) rather than to remove only surface and ladder fuels within spotted owl territories as recommended by the IRs (i.e., minimize the likelihood of territory abandonment). It is our understanding that the primary cause of passive and active crown fire and high fire spread rates are surface and ladder fuels, not canopy cover. We are not aware of any data that suggests that decreasing canopy cover throughout a stand to 30 to 40 percent is necessary to increase resilience to fire and reduce torching. There is rarely a need to remove trees greater than 12-inches dbh (Collins et al. 2011) or trees 16- to 20-inches dbh (North et al. 2009) for fuels purposes. In fact, Fry et al. (2015) found that the higher canopy cover forests of the Sugar Pine study were more resilient to fire than the lower canopy cover forests of the Last Chance study area. It is also worth noting that decreasing canopy cover can increase average wind speeds and thereby increase fire spread rates and severity. For instance, the only spotted owl territory treated in SNAMP (2015) was modeled to have more area burn at high severity post-treatment than pre-treatment. The EA contends that hand thinning is less effective than mechanical removal based on the following (page 11):

“Based on observations on the 2006 Bolder Fire, the 2007 Antelope Complex Fire (Fites et al. 2007), and recent scientific literature (Fule et al. 2006; Safford et al. 2009), lighter intensity, hand thinning treatments may not be as effective as mechanical treatments in modifying ladder and crown fuels and resulting fire behavior or tree mortality, dependent on individual stand conditions. Consequently, hand thinning treatments are prescribed for specific stand conditions where removal of smaller diameter material alone may be effective, for example riparian areas.”

We found this to be extremely misleading and contrary to the results of larger studies designed to test such inferences (Collins et al. 2011 and Fry et al. 2015). First, we were unable to find any mention of hand thinning treatments or the effectiveness of such treatments in Fites et al. (2007). Second, it is inappropriate to compare the effectiveness of the 5-inch diameter limit hand

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thinning treatments used in Fule et al. (2006) to the 10-inch diameter limit hand thinning treatments proposed in the EA. Fule et al. (2006) also found that prescribed fire alone was effective at treating fuels, a management tool proposed to be used throughout much of the Forbestown project area. Third, the four hand thinning units in Safford et al. (2009) are fraught with caveats that make it inappropriate to make broad generalizations on the effectiveness of hand thinning on fire behavior: (1) two of the units were on slopes too steep to allow ground-based mechanical treatments, (2) the hand piles on one of the units had not been burned and remained onsite, and (3) one of the units was a follow-up treatment to a salvage of beetle-killed trees. Finally, if there are units within the Forbestown project area that require the removal of trees larger than 10 inches for ladder fuels purposes within spotted owl HRCAs or territories, then remove trees larger than 10 inches. However, the number of trees larger than 10 inches that should be removed to increase fire resilience is likely very few and all trees greater than 16 inches chosen for removal should be defendable from a ladder fuels perspective. According to the EA, the purposes of the proposed project are:

• Remove hazard trees along roadways to make these areas safer and increase roadside viewing distances for motorists, local residents, recreationists, and other forest users;

• Thin vegetation to create defensible spaces along roads and ridgetops to create safe conditions for wildland firefighters; thinning would be more aggressive near roads and taper off at greater distances from the roads;

• Reduce ground, ladder, and crown fuels by thinning trees and brush, thereby decreasing the likelihood of a severe wildfire spreading to private lands and structures;

• Utilize removed material – timber and smaller trees – to create an economic benefit locally and generate partial funding for the required noncommercial thinning and burning fuel treatments;

• Remove invasive plants from the project area. Limiting the removal of trees to surface and ladder fuels (i.e., trees generally less than 16 inches dbh) within spotted owl territories that do not contain sufficient high canopy cover forest would still allow the project to meet all of these purposes, considering some units would be outside of spotted owl territories, not all acres within a territory are off-limits to treatment or the harvest of trees less than 30 inches dbh under the IRs, and commercial-sized trees generally begin at around 12 inches dbh. 3) Forest Service-wide California Spotted Owl Decline The U.S. Fish and Wildlife Service’s (Service) 2006 finding that the California spotted owl did not warrant ESA protections relied heavily on a draft demographic meta-analysis conducted by Blakesley et al. (2006). Since 2006, several long-term demographic studies have been published that suggest the statistical methods of Franklin et al. (2004) and Blakesley et al. (2006 and 2010) lacked the statistical power to detect the ongoing declines and that such statistical methods are inherently biased toward not detecting decline when a decline has occurred (Conner et al. 2013). These new studies affirm that declines have occurred on all Forest Service-managed lands with long-term survey data over the past 20-plus years, and the only stable or increasing population is in Sequoia-Kings Canyon National Park where logging does not occur and fire is the primary management tool used to reduce fuel loading. Specifically, between 1990 and 2012, the spotted

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owl population declined by 50 percent in the Eldorado demographic study area (Tempel et al. 2014b). From 1993 to 2010, spotted owl occupancy declined by 30 percent, territory extinction increased over time, and colonization rates were insufficient to maintain occupancy at its initial level on the Eldorado study area (Tempel and Gutiérrez 2013). Over the 18-year study period, the population declined by 21 to 22 percent on the Lassen-Plumas and 11 to 16 percent on the Sierra demographic study areas, and increased by 16 to 27 percent in the Sequoia-Kings Canyon National Park demographic study area (Conner et al. 2013). It is important to note that from the early 1990s through 2012 there was very little to no high severity wildfire activity within the four demographic study areas, suggesting that these observed declines were unrelated to the effects of wildfire or post-fire salvage logging. 4) Effects of Thinning on Spotted Owl Habitat In the Service’s 2006 finding that the species did not warrant protections under the ESA, the agency contended that high severity fire represented the greatest threat to the species and Forest Service thinning treatments were a short-term threat that ameliorated the long-term threat of high severity fire. We now know that spotted owls use forests that burn at all severities for foraging (Bond et al. 2009) and forests that burn at low and moderate severity have no effect on spotted owl occupancy and retain essential habitat characteristics (Roberts et al. 2011). In addition, recently published research has consistently documented a correlation between mechanical reductions in canopy cover and adverse effects to California spotted owl:

• Alteration of 50 acres or more of mature conifer forest (conifer forest with greater than 70 percent canopy cover dominated by medium and large trees) within a spotted owl territory increased dispersal probability (Seamans and Gutiérrez 2007).

• Home range size increased with the amount of fuels treatment within the home range (Gallagher 2010).

• Medium-intensity timber harvests, characteristic of proposed fuel treatments, were negatively related to reproduction of spotted owls, with reproduction appearing sensitive to modest amounts of medium-intensity harvests (Tempel et al. 2014a).

• Reductions in canopy cover were associated with reductions in spotted owl survival and territory colonization rates, as well as increases in territory extinction rates (Tempel et al. 2014a).

• Greater than 90% of medium intensity harvests converted high-canopy forests into lower-canopy vegetation classes, suggesting that landscape-scale fuel treatments could have negative impacts on populations of California spotted owls (Tempel et al. 2014a).

• The effects of implementing medium intensity timber harvests immediately decreased average habitat suitability, with a difference still present after 30 years of simulated forest growth (SNAMP 2015).

• Jones et al. (2016) found that declines in occupancy were expected under climate change when the amount of closed-canopy forest was constant over the modelling period, as well as in most cases when the amount of closed-canopy forest increased; however, increases in the amount of closed-canopy forest always moderated declines in occupancy.

SFL Scoping Comments on Forbestown 5

5) Trend to Federal Listing On September 18, 2015, the Service issued a positive 90-day finding on a petition to list the California spotted owl. A positive 90-day finding indicates that the Service believes that substantial scientific or commercial information was provided by the petitioner and that the petitioned action may be warranted. It is clear that the foundation of the Service’s 2006 not warranted determination has been eroded by the best available science and cannot again be used to justify not listing. It is scientifically baseless that the Forest Service can continue implementing thinning projects in spotted owl habitat that reduce canopy cover beyond thresholds known to increase the probability of territory abandonment and still claim that the agency is providing for species viability. The 1982 planning rule and the 2012 planning rule require that species viability be maintained in the planning area. FSM 2670.1 states that sensitive species of native plant and animal species must receive special management emphasis to ensure their viability and to preclude trends toward endangerment that would result in the need for Federal listing. As stated in the IRs, “These recommendations constitute a suite of measures that individually hold promise and support in scientific literature pertaining to owls and forest ecology.” The best available science suggests that modifying canopy cover in a manner or to an extent not recommended by the IRs may significantly increase the probability of territory abandonment and reduce the probability of colonization and successful reproduction and perpetuate a trend to federal listing. Conclusion Thinning trees greater than 12-20 inches dbh and reducing canopy cover cannot continue to occur in spotted owl territories at the levels observed over the last 20 years without continuing to push the species toward extinction throughout much of the Sierra Nevada and compromising viability within many of the National Forests. The U.S. Fish and Wildlife Service will soon commence another 12-month status review on the species. Unlike the last 12-month status review, there is now conclusive evidence of a Forest Service-wide decline and mounting scientific evidence that the decline is being caused by reductions in high canopy cover forest from logging. It is also apparent that the removal of canopy cover in spotted owl territories is being done almost entirely for economic purposes, not fuels purposes. Designing projects that meet or exceed the habitat protections afforded by the IRs is the only scientifically defensible way to justify that an activity does not result in a trend to federal listing. We ask that you adhere to our settlement agreement and develop an alternative based on the IRs and resubmit the Forbestown EA for public comment. We have translated and summarized the IRs for the central Sierra Nevada (Appendix C). This translation is adapted from one prepared by Region 5 for the forest plan revision process in the southern Sierra Nevada.

SFL Scoping Comments on Forbestown 6

Thank you for your time and attention. Please direct any questions or comments to Ben Solvesky (ben@sierraforestlegacy.org; 928-221-6102). Sincerely, Ben Solvesky, Wildlife Ecologist Sierra Forest Legacy PO Box 244 Garden Valley, CA 95633 Attachments Appendix A: Interim Recommendations for the Management of California Spotted Owl Habitat on National Forest System Lands. May 29, 2015. Appendix B: Settlement Agreement between Sierra Forest Legacy and the U.S. Forest Service on Litigation over the adoption of the 2004 Sierra Nevada Forest Plan Amendment. October 9, 2014. Appendix C: Summarized Description of the Forest Plan Components Consistent with the 29 May 2015 California Spotted Owl Interim Recommendations

SFL Scoping Comments on Forbestown 7

References Blakesley, J.A., M.E. Seamans, M.M. Conner, A.B. Franklin, G.C. White, R.J. Gutiérrez, J.E. Hines, J.D. Nichols, T.E. Munton, D.W.H. Shaw, J.J. Keane, G.N. Steger, B.R. Noon, T.L. McDonald, and S. Britting. 2006. Demography of the California spotted owl in the Sierra Nevada: report to the U.S. Fish and Wildlife Service on the January 2006 meta-analysis. February 21, 2006. Blakesley, J.A., M.E. Seamans, M.M. Conner, A.B. Franklin, G.C. White, R.J. Gutiérrez, J.E. Hines, J.D. Nichols, T.E. Munton, D.W.H. Shaw, J.J. Keane, G.N. Steger, and T.L. McDonald. 2010. Population dynamics of spotted owls in the Sierra Nevada, California. Wildlife Monographs 174:1-36. Bond, M.L., D.E. Lee, R.B. Siegel, and J.P. Ward. 2009. Habitat use and selection by California spotted owls in a postfire landscape. Journal of Wildlife Management 73:1116-1124. Collins, B.M., S.L. Stephens, G.B. Roller, and J.J. Battles. 2011. Simulating fire and forest dynamics for a landscape fuel treatment project in the Sierra Nevada. Forest Science 57:77-88. Conner, M.M., J.J. Keane, C.V. Gallagher, G. Jehle, T.E. Munton, P.A. Shaklee, R.A. Gerrard. 2013. Realized population change for long-term monitoring: California spotted owl case study. Journal of Wildlife Management 77:1449-1458. Franklin A.B., R.J. Gutiérrez, J.D. Nichols, M.E. Seamans, G.C. White, G.S. Zimmerman, J.E. Hines, T.E. Munton, W.S. LaHaye, J.A. Blakesley, G.N. Steger, B.R. Noon, D.W.H. Shaw, J.J. Keane, T.L. McDonald, and S. Britting. 2004. Population dynamics of the California spotted owls (Strix occidentalis occidentalis): a meta-analysis. Ornithological Monographs No. 54. Fry, D.L., J.J. Battles, B.M. Collins, and S.L. Stephens. 2015. Sierra Nevada Adaptive Management Project. Appendix A: Fire and Forest Ecosystem Health Team Final Report. August 31, 2015. Jones, G.M., R.J. Gutiérrez, D.J. Tempel, B Zuckerberg, and M.Z. Peery. Using dynamic occupancy models to inform climate change adaptation strategies for California spotted owls. Journal of Applied Ecology doi: 10.1111/1365-2664.12600. North, M., P. Stine, K. O’Hara, W. Zielinski, and S. Stephens. 2009. An ecosystem management strategy for Sierra mixed conifer forests. USDA Forest Service, General Technical Report PSW-GTR-220. Pacific Southwest Research Station, Albany, California. North, M., A. Brough, J. Long, B. Collins, P. Bowden, D. Yasuda, J. Miller, and N. Sugihara. 2015. Constraints on mechanized treatment significantly limit mechanical fuels reduction extent in the Sierra Nevada. Journal of Forestry 113:40-48. Roberts S.L., J.W. van Wagtendonk, A.K. Miles, and D.A. Kelt. 2011. Effects of fire on spotted owl site occupancy in a late-successional forest. Biological Conservation 144:610-619.

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SNAMP (Sierra Nevada Adaptive Management Program). 2015. Draft Sierra Nevada Adaptive Management Program Final Report: Appendix C. California Spotted Owl Team Report. Tempel, D.J., and R.J. Gutiérrez. 2013. Relation between occupancy and abundance for a territorial species, the California spotted owl. Conservation Biology 27:1087-1095. Tempel, D.J., M.Z. Peery, and R.J. Gutierrez. 2014a. Using integrated population models to improve conservation monitoring: California spotted owls as a case study. Ecological Monitoring 289:86-95. Tempel, D.J., R.J. Gutiérrez, S.A. Whitmore, M.J. Reetz, R.E. Stoelting, W.J. Berigan, M.E. Seamans, and M.Z. Peery. 2014b. Effects of forest management on California spotted owls: implications for reducing wildfire risk in fire-prone forests. Ecological Applications 24:2089-2106. USDA Forest Service. 2015. Draft Environmental Impact Statement, King Fire Restoration Project Volume 1. USDA Forest Service R5-MB-292. May 2015. Verner, J., K.S. McKelvey, B.R. Noon, R.J. Gutierres, G.I. Gould, Jr., and T.W. Beck. 1992. The California spotted owl: a technical assessment of its current status. USDA Forest Service, General Technical Report PSW-GTR-133. Pacific Southwest Research Station, Albany, California.

Appendix A

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Draft Interim Recommendations for the Management of California Spotted Owl Habitat on National Forest System Lands

29 May 2015

Overview

Region 5 is in the process of developing a new conservation strategy for the California spotted owl throughout its range in California. A science team was assembled to first develop a Conservation Assessment for the owl that summarizes current scientific information regarding the biology, population status, habitat use, forest conditions, and threats. The Conservation Assessment will be completed in mid-2015, and it is intended to serve as the primary scientific foundation for the Conservation Strategy, which Region 5 anticipates to be completed by March 31, 2016. In the intervening time period, the Region asked the leading experts in the California spotted owl, forest ecology, and fire ecology in the Sierra Nevada associated with the Conservation Assessment to provide interim recommendations on changes to forest management prior to the development of the Conservation Strategy.

Significant challenges and uncertainty face the management of habitat to support viable

populations of the California spotted owl – the risk of high intensity fire, loss of habitat from stand-replacing fire, impacts of mechanical treatments to habitat suitability, and declining populations - there are no simple solutions. The Conservation Assessment and the Conservation Strategy to follow it will provide the strongest foundation of scientific information and its application to the challenge of managing habitat for the spotted owl in the Sierra Nevada. The measures recommended in this document are intended to inform changes to existing management that are likely to reduce risks to the California spotted owl and could be considered important interim measures to enhance management’s ability to meet current goals for the conservation of the species until a more comprehensive conservation strategy can be developed and implemented. This charge cannot be accomplished through simple measures such as increasing the amount or quality of suitable habitat set aside for the owl because of the risk that fire poses to habitat loss, particularly in dense-canopied forests associated with owl occupancy and productivity.

The recommended conservation measures provided here are based on the findings of the draft

Conservation Assessment (May 2015), and represent a first approximation of actions available for consideration in the interim period between the development of the Conservation Assessment and implementation of a Conservation Strategy for the owl. These recommendations constitute a suite of measures that individually hold promise and support in scientific literature pertaining to owls and forest ecology, but they have not been field tested as a composite set of conservation measures. Thus, we cannot offer any certainty in terms of their benefits, only the potential for benefits based on the best available science in the form of the draft Conservation Assessment. Final interim recommendations may be issued once the draft Conservation Assessment is reviewed and finalized. The bulk of the work of reconciling the challenges that face the conservation of old forest ecosystems in the Sierra Nevada will fall to the Conservation Strategy.

Contributors

The following individuals made contributions to the development of these interim guideline recommendations: John Keane, Patricia Manley, Peter Stine, Malcolm North, Dawn Lipton, and Dana

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Walsh of the US Forest Service; Brandon Collins, Scott Stephens, and Mark Schwartz of the University of California, and Zach Peery of the University of Wisconsin. These individuals were also primary authors of the draft Conservation Assessment.

Summary of Interim Recommendations

The recommended conservation measures summarized here are intended to provide options to reduce risk to the California spotted owl in the short-term relative to the degree of risk associated with current standards and guidelines (Table 1). The recommended conservation measures pertain to each of four scales relevant to spotted owl habitat management: protected activity center (PAC), territory, home range, and landscape (Fig. 1). There is no single approach that can eliminate risk to the spotted owl population given the complex nature of the current situation: declining population trends, severe drought, fire suppressed forests, and high risks of high intensity wildfire. These recommendations are intended to provide a balance of conserving existing high quality habitat, enhancing habitat conditions through management, and reducing the risk of habitat loss through high intensity fire. These conservation measures are not expected to be appropriate or ideal for every situation – their greatest value is in prompting managers to consider these additional protections, and possibly others, in the process of planning and implementation. Table 1. Summary of interim recommendations for conservation measures for the California spotted owl as they pertain to land allocations and their associated current management direction.

Habitat Scale Current Direction Recommended Conservation Measures

PAC:

Acres of habitat 300 ac No change

Characteristics Best available > 70% canopy cover or best available

Mechanical treatment Allowed – retain >30” dbh trees and >40% canopy cover

(cc)

Not allowed, unless needed to improve habitat suitability

Other treatments Allowed – retain >30” dbh trees and > 40% cc

Allowed, if treatment improves habitat suitability; retain >30” dbh trees

Territory:

Acres of habitat -- 700 ac, to enhance habitat retention close to activity center

Characteristics -- 400 ac > 70% cc (including any such habitat within PAC); remaining acres >

50% cc

Mechanical treatment in designated habitat

(see home range) Not allowed, unless needed to improve habitat suitability

Other treatments in designated habitat

(see home range) Allowed, if treatment improves habitat suitability; retain >30” dbh trees

Treatment of undesignated habitat area

Maintain > 40% cc Manage for habitat heterogeneity and fine-scale mosaic

Prescribed fire -- Encouraged as mgt tool

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Habitat Scale Current Direction Recommended Conservation Measures

Home Range:

Acres of habitat 700 ac 300 ac (majority of acres are close to activity center)

Characteristics > 40% cc Best available

Minimum acres of designated habitat

1000 ac No change

Target acres of suitable habitat

1000 ac ~1500 ac

Mechanical treatment in designated habitat

Allowed Not allowed, unless needed to improve habitat quality

Other treatments in designated habitat

Allowed Allowed, if they improve habitat quality

Treatment of remaining home range

Manage to 40% cc Manage for habitat heterogeneity and fine-scale mosaic

Prescribed fire -- Encouraged as mgt tool

Landscape:

Target conditions Manage to 40% cc Manage for integrated desired conditions: territory quality, home range

quality, forest resilience

Figure 1. Nested spotted owl management areas.

Home Range(4,400 acres)

Territory Circle(1,000 acres)

Owl PAC300 acres)

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Management Guidelines Not Addressed

Old Forest Ecosystem and Associated Species Management Goals The long-term viability of the California spotted owl will depend on producing pine and mixed-conifer forests that are resilient to disturbances such as fire, tree-killing insects, and drought. Essential to this resilience is supporting regeneration and mortality patterns consistent with historic forest processes adapted to these perturbations. The overall strategy for old forest ecosystems was not evaluated, nor did the team evaluate the degree to which our recommendations affect the overall network of land allocations. We do not offer recommendations regarding the old forest ecosystem strategy or the Northern goshawk, per se. Although we do offer recommendations on conditions that are likely to confer resilience, we do not address landscape-scale forest resiliency. Given the broad geographic range of the California spotted owl across the Sierra Nevada, we suggest that the Region consider an integrated old forest ecosystem management strategy for old forests and associated species across the Sierra Nevada, including specific considerations for the California spotted owl, Northern Goshawk, Pacific fisher, American marten, and possibly other sensitive old forest associated species. Any conservation strategy for old forest associated species will need to reconcile how to manage for a sufficient quality, quantity, and distribution of suitable habitat to maintain viable populations of associated species while working to reduce the risk of extensive high severity fire and to improve prospects for the use of fire as a management tool.

Maintenance of PACs Regardless of Occupancy Status

In reference to the maintenance of PACs regardless of occupancy, the allocation of fixed patches of habitat established around California spotted owl locations regardless of their occupancy status over long periods of time presents a potential barrier to managing resilient landscapes that are essential to a long-term strategy for maintaining old forest conditions. Clearly, occupancy is not the only criterion for consideration in determining the value of retaining suitable habitat in a given location, but absent a landscape-wide evaluation of population dynamics and persistence, there is no firm foundation to determine the desired number and relative value of territory and home range locations across landscapes and over time. We suggest that the current static representation of the forest and of owl occupancy be revisited in the conservation strategy to strive for a balance between providing a sufficient amount and distribution of suitable habitat to support a viable population of owls, and the ability to manage dynamic landscape conditions over time.

1. Land Allocation Background

Two scales are recognized in the existing direction - activity (300 ac) and home range (4400 ac). There is no formal recognition of a territory scale or landscape scale in the current management direction. However, the territory scale serves an important ecological function in that it represents the core habitat and area requirements to support a single or paired owls, and as such it is typically defended and not shared between pairs of the same species. Similarly, the landscape scale is the scale at which population dynamics and long-term persistence (viability) are expressed. Species conservation approaches most effectively start with population-level objectives and approaches, followed by habitat and management approaches at the home range and territory scales.

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The activity center, territory, and home range can be conceptualized as a nested set of

concentric management areas (Fig. 1). The territory scale has an important ecological function in that it is, in principle, the area of the home range that is not shared (i.e., defended) between adjacent owl pairs. Thus, it is the area within the home range that the owl pair depends upon the most. It is commonly estimated as ½ of the nearest neighbor distance. Given that home ranges tend to be larger in the northern Sierra and smaller in the southern Sierra, adjustments to territory sizes in northern (Hat Creek and Eagle Lake Ranger Districts of the Lassen National Forest) and southern (Sequoia and Sierra National Forests) locations are recommended. Conservation Measures

1a. We recommend that habitat conservation for California spotted owls be addressed at four scales – activity center, territory, home range, and landscape. We provide specific recommended conservation measures for the activity center, territory, and home range scales in this document. We do not provide any recommendations for the landscape scale because guidelines at this scale will require detailed analysis and policy discussions regarding population and forest resilience parameters that were not possible to develop as part of this effort.

1b. In the central Sierra Nevada, we recommend a 1000-acre circle (0.7 mi radius) as a

reasonable representation of a territory. In the southern Sierra (Sierra and Sequoia NF), estimated territory size would be 800 acres (0.6 mi radius). In the northeastern portion of the range on the Lassen, estimated territory size would be 2400 acres (1.25 mi radius).

2. CASPO PAC Designation and Desired Condition Background

Current direction for PAC establishment provides guidance on where and how to establish 300 acres of suitable habitat in response to the discovery of territorial owls, and the duration of the habitat designation. Primary concerns regarding existing habitat designation (acres specifically identified as contributing toward minimum habitat requirements) and desired conditions for PACs pertain primarily to minimum canopy cover conditions and how canopy cover is measured and modeled. The current direction of “at least 60-70% canopy cover” is vague and contrary to other guidelines that specify “at least 70% tree canopy cover”. We suggest a more consistent designation of target minimum canopy cover of ≥ 70% for PAC habitat.

Current management direction also specifies the duration of the land allocations. PACs are to be

maintained regardless of California spotted owl occupancy status. However, after a stand-replacing event, guidelines specify to “identify opportunities for re-mapping the PA C within a 1.5-mile radius around the activity center, and if there is insufficient suitable habitat for designating a PAC within the 1.5-mile radius, the PAC may be removed from the network.” See background text and recommendations in the salvage section below, given that high-intensity fire currently is the primary source of stand-replacing events in the Sierra Nevada.

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The specific existing criteria for designating habitat for individual PACs are pasted below for reference.

“PACs are delineated to: (1) include known and suspected nest stands and (2) encompass the best available 300 acres of habitat in as compact a unit as possible. The best available habitat is selected for California spotted owl PACs to include: (1) two or more tree canopy layers; (2) trees in the dominant and co-dominant crown classes averaging 24 inches dbh or greater; (3) at least 70 percent tree canopy cover (including hardwoods); and (4) in descending order of priority, CWHR classes 6, 5D, 5M, 4D, and 4M and other stands with at least 50 percent canopy cover (including hardwoods). Aerial photography interpretation and field verification are used as needed to delineate PACs. “ “Stands in each PAC have: (1) at least two tree canopy layers; (2) dominant and co-dominant trees with average diameters of at least 24 inches dbh; (3) at least 60 to70 percent canopy cover; (4) some very large snags (greater than 45 inches dbh); and (5) snag and down woody material levels that are higher than average. “

Conservation Measures

2a. In reference to the desired condition criteria for suitable habitat, we recommend that the description and measurement of canopy cover be standardized across the Region. Chapter 14 in PSW-GTR-237 provides clarification of the terms “canopy cover” and canopy closure”, and how each is measured. We also recommend that field measurements of canopy cover using a densitometer (or similarly accurate and precise measure) be used to characterize pre- and post-treatment canopy cover conditions where treatments are proposed within designated owl habitat (also see page 6 of these guidelines).

2b. We recommend that target canopy cover conditions for PAC habitat be set specifically at ≥

70%. Further, we recommend that all snags, 15 inches and above, be retained in PACs, unless they represent a safety hazard.

3. CASPO Territory Habitat Designation

Background Recent research, primarily in the central Sierra Nevada, indicates that successful territories (i.e., sustained survival and occupancy of a territory) have more than the 300 acres of high quality nesting/roosting habitat (defined as ≥ 70% canopy cover) in the vicinity of the activity center. We assume this new information is relevant and thus applicable to all locations in the Sierra. Two criteria for habitat designation and management at the territory scale are indicated: a minimum amount of habitat with ≥ 70% canopy cover, and total amount of habitat with ≥ 50% canopy cover (including the minimum ≥ 70% canopy cover) (Fig. 2). Research from the central Sierra Nevada has provided strong evidence that maintaining 375 acres or more of habitat with ≥ 70% canopy cover within the territory has significant benefits in terms of occupancy and site fidelity. The total amount of habitat with >50% canopy cover has a less certain target condition, but it appears that greater concentrations (i.e., more acreage) of >50% canopy cover forests in proximity to the nesting area (i.e., within the territory) are associated with higher performing territories (i.e., higher occupancy rates, lower extinction rates). However, some habitat heterogeneity at the territory scale is likely to be a beneficial attribute

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for foraging based on multiple studies that indicate that owls forage frequently along habitat edges, particularly high contrast edges. Thus, concentrating habitat designations within the territory while providing some opportunity for habitat heterogeneity is expected to improve habitat quality and territory performance. Research findings pertaining to minimum patch sizes and spatial distribution criteria for habitat use are limited; this is a key information gap to be addressed in the short term, ideally in time to inform the Conservation Strategy.

Figure 2. Graphic example of nested spotted owl management areas with designated habitat. Conservation Measures 3a. We recommend that the desired condition at the territory scale is the maintenance of a minimum of 400 acres of high quality nesting/roosting habitat (≥ 70% tree canopy cover), ideally in the vicinity of the activity center, an increase of 100 acres over current guidelines. 3b. The same designation criteria would apply at the territory scale as for PACs, and as they are specified in the existing guidelines,“ the best available habitat is to include: (1) two or more tree canopy layers; (2) trees in the dominant and co-dominant crown classes averaging 24 inches dbh or greater; (3) ≥ 70% tree canopy cover (including hardwoods); and (4) in descending order of priority, CWHR classes 6, 5D, 5M, 4D, and 4M and if not available, substitute stands with ≥ 50 % canopy cover (including hardwoods).”

> 70% canopy cover

> 50% canopy cover

PAC

Home Range(4,400 acres)

Territory Circle(1,000 acres)

> 1000 acres total designated habitat within home range:• remaining 350 acres outside the

territory circle

> 650 acres total designated habitat within owl territory:

• 400 acres >70% canopy cover• 250 acres >50% canopy cover

Owl PAC300 acres)

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3c. We recommend that a minimum of 70% (700 acres) of the 1000-acre territory be maintained in a canopy cover condition of ≥ 50%. Where territories lack 700 acres of suitable habitat, the shortfall would be located within the home range as close to the habitat within the territory as possible. 3d. Designated habitat patches or stands ideally are large enough to provide interior stand conditions (1-2 tree heights from edge) to minimize edge effects, particularly for the acres with > 70% canopy cover. 3e. All habitat that is designated as meeting the minimum habitat requirements to support an owl territory are located on NFS lands.

4. CASPO Territory Desired Condition Background

Given the current emphasis on retaining very high canopy cover for core nesting and roosting habitat, foraging habitat values as well as options to reduce the risk of high intensity fire will rest on forest conditions outside of designated habitat (acres specifically identified as contributing to minimum habitat requirements). As owls select habitat at larger scales and for different activities, from nest stand to core area to foraging habitat, there is greater variability in the habitat characteristics, which suggests greater flexibility in selection. Heterogeneity within the owl territory is likely to support higher prey populations that homogeneous habitat conditions across the entire territory, and is also likely to enhance resiliency to disturbance. Therefore, within the remaining 300 acres of the territory circle, some habitat heterogeneity is desired. The enhancement of habitat heterogeneity without fragmenting existing mature closed-canopy forest represents a challenge in forest management, but is currently being envisioned by forest ecologists as a mosaic of forest clumps and small openings (0.03 to 2.0 acres).

Current habitat maps generated for the National Forests have variable minimum mapping units, depending on the age and source of the remotely-sensed data. Most Forests now have maps that have 1-acre minimum mapping unit. Ideally these maps would be available for characterizing territories (and home ranges) both in terms of suitable habitat and the character and extent of more open habitat types and conditions.

A potential barrier to successful implementation of these recommendations is how canopy cover is

measured and modeled. Vegetation maps used for forest and initial project planning are derived from satellite imagery, generated by Region 5 Remote Sensing Lab, and commonly referred to as the “e-veg” layer. This is the source of information used to identify and designate habitat for wildlife, including the California spotted owl. Detailed project planning for forest management commonly employs the use of Forest Vegetation Simulator (FVS) to estimate pre- and post-treatment canopy cover conditions for proposed treatments. The ability of FVS to model changes in canopy cover in a manner that adequately reflects habitat suitability for the spotted owl is limited. Within designated habitat, particularly within the territory circle, field-based measurements are suggested to ensure characterizations of habitat conditions are accurate (see section 6 below, Forest Management within Designated CASPO Habitat).

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Conservation Measures 4a. Desired conditions are to create or maintain fine-scale gaps associated with shrubs, meadows, or low tree and canopy densities within a matrix of higher density forests. This recommendation represents a change in the forest-wide standard to maintain canopy cover of >50% (see mechanical thinning section below) at the stand (unit) scale. 4b. Existing open habitat conditions (early seral forests, shrub fields, plantations, meadows) within territories count toward this goal of some heterogeneity within the territory. It is expected that most territories already have areas of low canopy forest or other non-forest vegetation types. Ideally vegetation is mapped at 1 ac (or less) minimum mapping units so that small gaps can be identified and counted toward desired conditions. 4c. The remaining acres within the territory (< 300 acres in a 1000-ac territory) ideally are managed to create a fine-scale mosaic (gaps and patches of 0.03-2.0 acres) of low, moderate, and high canopy cover that create heterogeneous conditions, that are in turn conducive to supporting suitable foraging habitat, an abundance of prey, and a reduced risk of high intensity fire. Treatments outside of designated CASPO habitat within territories, however, should avoid creating uniform low tree density and bare understory conditions, as these conditions are not conducive to habitat quality or enhanced prey availability. A reduction in hazardous fire potential may still be achieved while producing a more variable spatial forest structure consistent with supporting a diverse and resilient forest ecosystem (see forest thinning section below). 4d. Desired conditions for a 1000-ac territory are the following:

≥ 40% (400 ac) with >70% canopy cover (or best available – see recommendation 3b)

Additional minimum of 300 acres (30%) with > 50% canopy cover

The remaining area (< 300 acres) should represent fine-scale mosaic (gaps and patches of 0.03-2.0 acres) of low, moderate, and high canopy cover that create heterogeneous conditions, that are in turn conducive to supporting suitable foraging habitat and an abundance of prey

The condition of the territory is a function of all lands that occur within the territory circle. Minimum habitat requirements all need to be met on NFS lands, but evaluations of the condition and quality of territories include all lands.

Percentages are slightly different with the smaller 800-ac territory in the southern Sierra

Nevada, as follows:

≥ 50% (400 ac) with >70% canopy cover (or best available)

Additional minimum of 100 acres with > 50% canopy cover

The remaining area (< 100 ac) should represent heterogeneous conditions that are conducive to supporting suitable foraging habitat and an abundance of prey (see section 6 below). Percentages are also slightly different with the larger 2400-ac territory in the northern Sierra

Nevada, as follows:

≥ 17% (400 ac) with >70% canopy cover (or best available)

Additional minimum of 1000 acres with > 50% canopy cover

The remaining area (< 1000 ac) should represent heterogeneous conditions that are conducive to supporting suitable foraging habitat and an abundance of prey (see section 6 below).

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5. CASPO Home Range Habitat Designation and Desired Condition Background

First, we suggest clarifying language regarding habitat retention within home ranges. It is a source of confusion for many that Home Range Core Areas pertain to designated habitat acres, not to the home range area itself. Our recommendations are to simply refer to the home range area, which is approximated by a 1.5-mi circle around the center of activity for the territory, most commonly represented by the center of the PAC.

Insufficient new information exist to update the minimum amount of suitable habitat to be

retained within a given owl home range, so we have no suggested changes to the minimum amount of habitat. However, we do recommend that the outer home range area (outside of territory circles) have a different desired condition than current direction specifies. Recommended desired conditions are to promote or maintain a heterogeneous mosaic of forest conditions that would provide additional acres of suitable habitat beyond the specified minimum acres, as well as variable forest canopy conditions that currently cannot be created outside of limited circumstances. However, the outcome of managing for fine-scale heterogeneity across the home range is expected to yield a total of around 1500 acres of suitable habitat across the home range.

Mosaic conditions are known to be important to providing overall suitable habitat for foraging and fitness. In the Sierra Nevada, California spotted owls select edge habitat for foraging, suggesting that owls exploit a heterogeneous forest matrix when foraging, which is consistent with observations that small mammal diversity is enhanced by increased structural heterogeneity at large spatial scales, as well as greater development of mature forest structure. However, it is difficult to determine a threshold of heterogeneity and finding a balance between habitat heterogeneity and minimizing fragmentation. Similarly, structural heterogeneity in forests can confer a greater resilience to disturbance, particularly fire. Given concerns about the growing risk of loss of forests to high intensity fire, fire resilience is a high priority for forest management. Fire resilient landscapes that contain contiguous patches of closed-canopy mature forest embedded with smaller forest openings and variable forest structure and composition (e.g., presence of large oaks) may represent our best option for sustaining habitat and populations of spotted owls.

We provide target proportions of the home range area in various canopy cover conditions. The

intent of these target percentages of various canopy cover conditions is to serve as a measurable guide to a heterogeneous, mosaic condition that we believe will provide high quality suitable habitat for the California spotted owl while moving toward landscapes that better reflect a natural disturbance regime and are more resilient to fire and other disturbances. The desired condition recommendations are expected to exceed the current habitat minimums required by existing direction (1000 acres of suitable habitat) within the home range by an estimated 50% (i.e., ~1500), but at the same time promote habitat heterogeneity across the home range by relaxing canopy cover minimums on the remaining acres within the home range. Calculations of these desired conditions over a full home range reveal that by attaining canopy cover levels within the 1000-ac territory and levels within the remaining 3400 acres, as outlined above, the goal of a landscape-scale average of 40% canopy cover outside the 1000-ac territory would be consistent with improved desired conditions for the owl.

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The recommendation to have some portions of the home range in shrub, meadow, and/or low canopy cover forests would be a change to the current forest-wide management direction for forest thinning (see forest thinning section below for more details). By specifying a home range-wide average canopy cover condition, as opposed to a stand- or unit-scale minimum, landscapes can be managed to create heterogeneous habitat conditions that are favorable for foraging as well as for old forest resilience. These recommendations are based on empirical data that suggest that habitat management needs to move away from a modal condition of 40-50% canopy cover in forests with reduced vertical and horizontal complexity, to a more divergent and heterogeneous condition including a greater amount of high canopy cover habitat and fine-scale mosaics (gaps and patches of 0.03-2.0 acres) of low, moderate, and high canopy cover. Some acres would be managed to support or create high quality owl habitat; the remaining acres would be managed to meet other forest restoration objectives that would result in openings and a mosaic condition.

Landscapes where known owl locations are at a density where there are significant overlaps in home ranges, and perhaps even overlaps in territory circles, present a special challenge to designating habitat for the spotted owl and creating habitat heterogeneity. We suggest that each territory circle is managed as an independent unit in this interim period, but where overlap among home ranges is high, we suggest habitat management be determined at the subwatershed scale (10,000-30,000 acres) such that the resulting landscape supports territory and home range conditions for each owl, with the composite result being a mosaic of heterogeneous forest conditions that has high foraging habitat quality and reduced risk of high intensity fire.

Conservation Measures

5a. We recommend adopting the simplified term of HRA – Home Range Area – the area that pertains to the 1.5-mi radius circle around activity centers.

5b. The desired condition for a 1000-ac territory calls for > 700 acres of suitable habitat with >

50% canopy cover, with the remaining of 300 acres of suitable habitat occurring in the home range area outside the territory circle (see Table 1 and 2 for all geographic zones). All habitat designations to meet minimum habitat requirements are on NFS lands.

5c. We recommend that each territory be managed to retain at least the minimum designated

habitat acres (e.g., 700 of the 1000 acres in the territory circle), but home range habitat acres may be shared where overlap in home range is significant.

5d. We recommend that the area outside the territory circle and within any given home range

area be managed to maintain an average of 40% canopy cover across the entire home range area (not at the stand scale), with conditions ranging from < 25% to > 70% canopy cover across a fine-scale mosaic of heterogeneous conditions. The average condition is intended to serve as a guide in balancing a wide range of stand-scale canopy cover conditions across the home range area toward creating heterogeneous forest conditions.

5e. Habitat heterogeneity is the desired condition in the 3400 acres of the home range area

outside the territory circle. The recommendations provided below reflect general parameters of historical forest conditions that, if used to guide forest management in the home range area outside

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the territory, are likely serve to enhance forest resilience to fire while maintaining or increasing quality foraging habitat conditions for the spotted owl. In implementation, discourage uniform, homogeneous treatments, but rather create a mosaic of conditions within and among stands (see Forest Thinning sections below for recommendations on condition measures and prescriptions):

Low and high density forest interspersed across the home range for a target total of ~1500 acres of suitable spotted owl habitat.

< 25% (~850 ac) with ≤ 25% canopy cover as consistent with topographic, edaphic, and site condition influences (including non-forested and low canopy cover forests at the smallest detectable size).

> 10% (~350 ac) with > 70% canopy cover

> 15% (~500 ac) with > 40% canopy cover

~50% fine-scale forest mosaic

Home range conditions are a function of all lands occurring within the home range circle regardless of land ownership. 5f. Given that specific target values and implementation specifics are not well known or

understood, we recommend that projects that propose to treat forests in territories commit to monitoring of owl occupancy pre- and post-treatment to understand and learn from these tactics.

5g. We recommend that landscape designs and associated silvicultural prescriptions integrate

topography, soils, and aspect into desired conditions so they are consistent with the ecological patterning that would occur across the landscape under a natural disturbance regime. For example, disturbances such as fire tend to be more frequent on ridge tops and south facing slopes, creating younger and/or more open conditions, as opposed to lower slope, north facing, and ravines, where vegetation conditions would be likely to be more dense and multi-layered.

5h. We recommend developing variable density treatments to create heterogeneity at multiple

scales to create spatial discontinuity in forest fuels and create openings for regeneration of pines and oaks.

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Summary Tables and Figures

Table 2 summarizes the recommended amount and spatial distribution of habitat conditions at the activity center, territory, and home range scales at each of the three preciously established geographic zones within the Sierra Nevada. Territory specifications for the central Sierra Nevada are based on substantial empirical data, however specifications for the northern and southern zones are an extrapolation of observations from the central Sierra Nevada. Further, the Home Range Area is the 1.5-mile radius circle in the current guidelines, however in the southern Sierra Nevada, the radius of the home range area containing the final 100 acres could be smaller (600 ac is 20% of 3000 ac territory), with potentially beneficial results for the owl.

Table 2. Recommended minimum acres of suitable habitat to be maintained at each of three nested scales, and the total expected total acres of suitable habitat for individual the California spotted owls across the three geographic zones currently recognized for the owl in the Sierra Nevada.

Northeast SN (Hat Creek and Eagle

Lake RD)

Central SN (all other Forests*)

Southern SN (Sequoia and Sierra NF)

Scale Area (ac)

Amount of designated habitat (ac)

Area (ac)

Amount of designed

habitat (ac)

Area (ac)

Amount of designated habitat (ac)

PAC – min 300 300 300 300 300 300

Territory – min >70%cc 2400 400 1000 400 800 400

Territory – min > 50% cc

2400 1400 1000 700 800 500

Home Range - min 4400 2400 4400 1000 4400** 600

Home Range - expected >2400 `>1500 >900

* Modoc, Inyo, Humboldt-Toiyabe, Plumas, Tahoe, Eldorado, Lake Tahoe Basin Management Unit and Stanislaus National Forests

** Could potentially be reduced to 3000 acres

Table 3 below summarizes the recommended desired conditions for territories and home ranges in the central Sierra Nevada (acres for northern and southern zones would need to be adjusted as per recommendations in Table 2).

Figure 3 reflects two home range conditions from the Sierra Nevada: one with limited

availability of suitable habitat (3A), and one with an abundance of suitable habitat (3B). These figures illustrate how varied the distribution and abundance of suitable habitat can be within a territory circle and home range area. Figure 4 depicts a small landscape with multiple home ranges. This figure illustrates a situation where there is a high density of known owl territories. The overlap in territory circles is expected to be low, as shown here, but the overlap in home range areas can be high.

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Table 3. Summary of desired conditions for activity centers, territories and home ranges in the central Sierra Nevada.

DESIGNATION SIZE DESCRIPTION OF KEY FEATURES DESCRIPTION OF REMAINDER OF AREA

PACs 300 acres Minimum of 300 acres of high quality nesting and roosting habitat (≥ 70% canopy cover or best available as per section 3b) as close to the activity center as possible

Territories 1,000 acres

Measured as a 0.7 mile radius circle around the activity center. Minimum of 400 acres of high quality habitat (≥ 70% canopy cover, including acres of this habitat in the PAC) plus at least 300 acres of suitable foraging habitat (≥ 50% canopy cover) for a total of 700 acres within the territory

300 acres in a fine-scale mosaic forest structure designed to achieve heterogeneous forest cover and stand density

Home Ranges 4,400 acres

Minimum of 1,000 acres of designated suitable habitat; including the minimum 700 acres within the territory circle. Recommended criteria for heterogeneous mosaic conditions in the home range area outside of the territory are expected to yield an additional 700-800 acres of suitable habitat with > 50% canopy cover, for a total acreage exceeding 1500 acres.

3400 acres comprised of: - Low and high density

forest interspersed across the home range

- > 10% (~350 ac) with > 70% canopy cover

- > 15% (~500 ac) with > 40% canopy cover

- < 25% (~850 ac) with ≤ 25% canopy cover as consistent with topographic, edaphic, and site condition influences

- ~50% fine-scale forest mosaic

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A)

B)

Figure 3. Home range conditions from actual locations in the Sierra Nevada. A) Home range with limited suitable habitat. B) Home range with an abundance of suitable habitat.

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Figure 4. Example of a landscape with multiple territories in close proximity. Points indicate the center of the territory, blue indicates the 300 ac PAC, solid black circle indicates the 1000-ac territory circle, and dashed circle indicates the 4,400 ac home range area. The dark green color represents suitable habitat with >70% canopy cover; the light green color represents suitable habitat with 50-70% canopy cover.

6. Forest Management Within Designated CASPO Habitat

Background

The acres of suitable habitat within PACs, territories, and home ranges that are identified as meeting the habitat requirement guidelines for the California spotted owl are explicitly identified and designated on each Forest. Fuel reduction treatments that are consistent with habitat enhancement are likely to be very modest (e.g., removal of smaller diameter trees in dense stand, prescribed fires), given that the highest priority for these acres in the short term is to maintain or enhance habitat quality for spotted owls. Thinning within designated habitat could be accomplished with mechanical thinning, hand thinning, or prescribed fire (where feasible). Prescribed fire is a valuable management tool and is increasingly important for reintroducing fire as an essential ecosystem process. Barriers to implementing prescribed fire are many, but its increased use will be essential to creating and maintaining forest resilience. Tree retention standards for trees ≥ 30-in diameter remain in place within home ranges, given that these larger diameter trees make significant contributions to canopy cover, as well as providing a diversity of other habitat values.

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Conservation Measures 6a. We recommend that no mechanical treatment occur within the designated habitat acres for the spotted owl (e.g., 1000 acres per home range in the central Sierra Nevada) unless it is intended to maintain or improve habitat conditions for the spotted owl in the short-term (1-5 years). Key features of desired conditions (i.e., multi-layered structure, diversity of diameter classes, moderate to high tree canopy cover) are retained or enhanced as a result of forest management actions. This is likely to limit treatments to the removal of small diameter woody material through hand thinning or prescribed fire.

6b. We recommend that no overstory trees be removed with PACs and rarely within the remaining designated habitat, including the retention of trees ≥ 30-in diameter except in circumstances where public safety is at risk as a result of tree fall.

6c. We recommend the use of prescribed fire as a valuable and essential forest management tool in instances where fire can be used to create desired conditions and improve habitat quality in the short-term.

6d. In instances where mechanical thinning in designated habitat is warranted, we recommend that silvicultural prescriptions be informed by and follow to the degree possible the concepts in GTR-220 and 237, and parameters described for non-designated habitat (below) while being consistent with the objective of short-term habitat improvement for the spotted owl . Given the likelihood of prescriptions being limited to the removal of small diameter material, hand thinning may be a more feasible and effective approach.

6e. We recommend that pre- and post-thinning canopy cover conditions be measured in the field using a densitometer using standard forest measurement sampling designs whenever possible to obtain a sufficiently precise estimate of average canopy cover and within-stand variability pre- and post-thinning. For example, a 25-pt densitometer grid could be added to the measurements taken at each stand exam plot location and a sufficient number of stand exams.

6f. We recommend the use of fixed-plot methods be used for project planning and effectiveness monitoring whenever possible when treatments are planned within designated habitat in territories.

7. Salvage within Designated CASPO Habitat Background

The value of burned forests as habitat or as landscape components within a territory or home range is not clear. Some research suggests that burned forests can enhance the foraging opportunities for California spotted owl, other research suggests that burned forests themselves provide suitable foraging habitat, while still other studies show limited value of large areas of burned forests and a negative impact as burned forest becomes the predominant condition within a territory. The number of studies, their associated samples size, and their divergent findings create uncertainty about appropriate management direction regarding burned forests as habitat for the spotted owl. The entire issue of the effects of salvage on spotted owls remains unclear and should be carefully revisited in the conservation strategy. Promoting and supporting research directed at understanding the habitat value of burned forests would greatly enhance the ability of the conservation strategy to identify appropriate management guidelines for the treatment of burned forests.

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Conservation Measures

7a. We recommend that PAC habitat (designated 300 acres) burned at any intensity be retained

as unsalvaged, and PAC acres burned at high intensity (> 75% mortality) be augmented by unburned forest within the territory where it exists. In cases where multiple PACs are located in close proximity, this recommendation could be reconsidered in light of potential ecological impacts of leaving large areas of unsalvaged intensively burned forest.

8. Forest Management in Home Range Areas Outside of Designated CASPO Habitat Background An overarching point of concern that surfaced through the course of developing tthese interim recommendations was the existing forest-wide standards and guidelines that targeted 40-50% average canopy cover at the “unit” scale (i.e., stand scale), which at this small scale translates in the field to a minimum canopy cover. The outcome has been is that stands with higher canopy cover and variable canopy conditions can be treated to reduce canopy cover down to near 40% and simplify vertical structure by removing ladder fuels. These treatments create more homogeneous conditions within stands and across landscapes that meet the minimum criteria for suitable habitat, but provide low quality habitat for owls. These stands do not necessarily benefit the owl or other old forest associated species and can present barriers to managing for forest resilience.

Forest restoration that positively affects spotted owl habitat ideally starts at scales larger than the home range, and then scales down to the home range and territory scales, in order to ensure that the analysis encompasses the entirety (or at least the majority) of home ranges within the targeted treatment area. We suggest subwatersheds as a minimum planning unit size for restoration projects. The subwatershed scale ranges roughly from 10,000 to 30,000 acres, and is reasonably approximated by sixth-level hydrologic units [HU] (as enumerated with 12-digit codes). This is the scale at which landscape heterogeneity begins to be expressed, and planning restoration treatments across multiple subwatersheds would be ideal given the large size of recent wildfires (e.g., 2013 Rim Fire, 2014 King Fire) and the area burned in extreme single burn periods within these fires (30,000-50,000 ac). This step already is commonly employed to identify target treatments, but it may not be explicitly documented as part the project file or explicitly target home range conditions as part of project objectives. Ideally, planning and analysis would occur at even larger scales commensurate with the scale of major disturbances (100,000 – 200,000-ac range), but that scale of analysis and desired conditions is beyond the scope of these recommendations. We suggest that the conservation strategy for old forests and associated species outline desired conditions and associated measures at multiple scales, including large landscapes in this 100,000 to 200,000-ac scale.

Within subwatersheds, we suggest that forest conditions could be evaluated at three scales:

stand, home range, and subwatershed-wide. We are considering stands as a scale unit of roughly 5-40 ac and not the silvicultural definition (“a spatially contiguous group of trees and associated vegetation having similar structures” [Oliver and Larson 1996]) because that definition emphasizes identifying relatively homogeneous areas. The home range scale is 4400 acres, and subwatershed is 10,000-30,000 acres, as described earlier.

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Specific treatments that will move forest conditions toward desired conditions will be better informed by field data. Field assessments a typically take the form of common stand exams conducted in a systematic manner across the proposed treatment area. We suggest that restoration projects will benefit from conducting field assessments across one or more entire territories and home ranges in order to determine where and what type of stand-scale treatments will move the landscape to a more desired condition. For example, larger-scale analysis may lead planners to propose treatments in stands that have been recently mechanically treated to reduce fuels, as well as in stands that have not been treated recently. Fixed plot methods would also provide additional valuable information, but may only be warranted or feasible across smaller areas and would be most valuable in instances where designated habitat is targeted for treatment (see section below).

At the stand scale, we suggest that forest conditions be characterized using the three

elements consistently found in frequent-fire forests: individual trees, clumps of trees and openings (ICO) (see Larson and Churchill 2012). The ICO concept and approach is relatively new in its application to designing resilient forests in dry forest ecosystems of the Sierra Nevada, so its implementation will be a learning process. Project planners will be challenged with how to gather and interpret field data gathered as part of initial stand exam efforts in a manner that enables them to assess current and potential future conditions in terms of ICO parameters to assess heterogeneity and in terms of stand-scale canopy conditions to assess owl habitat suitability. The ICO parameters provided in the recommendations are intended to serve as a starting point based on the limited empirical information currently available (Lyderson et al. 2013, Fry et al, 2014).

Canopy cover, as a stand- or landscape-level average, does not adequately describe or quantify

the desired variability in canopy cover and tree density, particularly if it is based on e-veg or standard FVS calculations. Also, neither of these sources accounts for tree spatial patterns, which is a central feature of forest restoration for fire resilience (see PSW-GTR-220). Chapter 9 of PSW-GTR-237 (North and Sherlock 2012) provides some suggested tools and techniques that can be used to interpret stand exam data to assess forest heterogeneity, including ways in which FVS can be used to assess variability in canopy conditions. Field measurements using a densitometer (i.e., a sighting tube) are the recommended method to characterize canopy cover conditions because they provide an accurate and precise measure of canopy cover conditions (overall average and variability) and it is more consistent with measures of canopy cover used to determine spotted owl habitat associations.

Tree retention standard for trees ≥ 30-in diameter would remain in place throughout the home range area, including the PAC, territory, and outer home range area. The 30-inch diameter limit serves an important function outside of designated habitat, namely the retention and recruitment of large trees. We acknowledge that there is a deficit of large trees across the landscape, especially larger trees with structure (i.e. cavities, platforms, etc.) for nesting or roosting use. Based on conversations with District and Forest silviculturists, the > 30-in diameter retention standard is not expected to be a significant limiting factor in achieving heterogeneous forest conditions. However, the 30-in diameter limit outside the California spotted owl home range areas could present an impediment in certain circumstances where there are high densities of white fir trees in this size class, and retaining all of them could be counter-productive to objectives for maintaining/restoring heterogeneity. We encourage the conservation strategy to reevaluate the broad applicability of the 30-inch diameter limit and identify circumstances under which the 30-inch diameter limit may be counter-productive to meeting habitat conservation objectives for the spotted owl. Close monitoring of projects that propose treatments throughout territories and home range areas will provide valuable insights into these assumptions (and others).

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Conservation Measures

8a. We recommend the subwatershed scale (10,000-30,000 ac) as a target for the broad-scale analysis for project planning. Boundaries can be defined by HUC boundaries or other relevant topographic features that represent a meaningful ecological unit.

8b. Within the subwatershed planning unit, we recommend evaluating among-stand

heterogeneity across the landscape based on e-veg, other sources of satellite imagery, and information on management history. Project planners can use these data to evaluate existing conditions for each territory and home range within the planning subwatershed: location of designated CASPO habitat, amount of suitable habitat, proportion of the area occupied by each canopy cover condition, diversity of canopy cover conditions, and average canopy cover. The results of this analysis can be used to identify territories and home ranges that do not currently meet desired conditions, and where and how treatments could be applied to move them closer to desired conditions.

8c. We recommend that project planning include stand exams that are distributed across entire territories or home ranges as needed to characterize existing stand-scale structures and inform where treatments will be directed and toward what change in condition. If FVS is used to model forest structure, consider using alternative approaches (re: GTR-237) that can be used to assess canopy variability.

8d. We recommend that densitometer readings be added to stand exam measurements in order for canopy cover and structure to be accurately assessed. We recommend that pre- and post-thinning canopy cover conditions be measured in the field using a densitometer as part of the standard forest measurement sampling designs to obtain a sufficiently precise estimate of average canopy cover and within-stand variability pre- and post-thinning. For example, a 25-pt densitometer grid could be added to the measurements taken at each stand exam plot location and a sufficient number of stand exams.

8e. ICO parameters for stand-scale heterogeneity are recommended for use in evaluating existing and desired future forest heterogeneity, recognizing that they are a work in progress and may be updated as new information becomes available. Project planners can assess current and potential future conditions in terms of ICO parameters to assess heterogeneity and in terms of stand-scale canopy conditions to assess owl habitat suitability, extent (acres) and spatial distribution.

A clump is any group of adjacent trees with touching or overlapping crowns, with tree groups generally ranging from 2-50 trees.

A gap is a forest opening roughly equivalent to or greater than the area occupied by the canopy of a dominant, overstory tree (e.g., an overstory tree with 20-ft crown radius would have a canopy area of 1250 ft2 or about 0.03 ac) generally ranging from 0.03 to 2 ac, but greater variability in clumps and gaps is valuable and recommended.

Areas identified as typically supporting higher tree density and/or canopy cover based on topographic position and aspect would be managed toward the upper end of clump size and lower end of gap size and frequency

Areas identified as typically supporting lower tree density and/or canopy cover based on topographic position and aspect would be managed toward the lower end of clump size and upper end of gap size and frequency.

Snag retention objectives can be achieved by variable densities that distribute snags throughout large areas consistent with the clumpy, variable nature of tree distribution.

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8f. Tree retention standards for trees ≥ 30-in diameter remain in place throughout the territory

and home range area. 8g. We recommend the use of prescribed fire whenever applicable and feasible as a valuable

and important management tool. It may be particularly effective in restoring resiliency and integrity across landscapes recently thinned to reduce fuels.

Appendix B

Appendix C

Translation of IRs into plan components for central SN (September 30, 2015) Page 1

Description of the forest plan components consistent with the 29 May 2015 California Spotted Owl (CSO) Interim Recommendations1.

Background:

Below is a translation of the CSO Interim Recommendations (IR) for the central Sierra Nevada into plan components to inform the design of a project. This translation is adapted from one prepared by Region 5 for the forest plan revision process in the southern Sierra Nevada. Information in brackets (i.e., [1a]) refers to the unique IR conservation measure (see Draft Interim Recommendations for the Management of California Spotted Owl Habitat on National Forest System Lands 29 May 2015) from which the plan component was derived. These plan components, as consistent with the 2012 Planning Rule, generally consist of (1) desired conditions, (2) standards or (3) guidelines consistent with the 2012 planning rule. They are defined as:

Desired Condition - a description of specific social, economic, and/or ecological characteristics of the plan area, or a portion of the plan area, toward which management of the land and resources should be directed. Desired conditions must be described in terms that are specific enough to allow progress toward their achievement to be determined, but do not include completion dates. Standards - A standard is a mandatory constraint on project and activity decision making, established to help achieve or maintain the desired condition or conditions, to avoid or mitigate undesirable effects, or to meet applicable legal requirements. Guidelines - A guideline is a constraint on project and activity decision making that allows for departure from its terms, so long as the purpose of the guideline is met. Guidelines are established to help achieve or maintain a desired condition or conditions, to avoid or mitigate undesirable effects, or to meet applicable legal requirements.

Other terminology associated describing plan content includes Management Approach; this is defined as describing the principal strategies and program priorities the Responsible Official intends to employ to carryout projects and activities developed under the plan. Management approaches should relate to desired conditions and may indicate the future course or direction of change.

Plan Components that incorporate the CSO IR:

General Plan Components:

• CSO direction changes from a strategy based on two zones (the Protected Activity Center and Home Range Core Area) to a strategy based on four zones: Protected Activity Center,

1 Draft Interim Recommendations for the Management of California Spotted Owl Habitat on National Forest System Lands 29 May 2015

Translation of IRs into plan components for central SN (September 30, 2015) Page 2

Territory, Home Range Area, and landscape [1a], with all designated habitat areas only on NFS lands [3e].

• No specific plan components are provided for the area outside the Home Range Area circle. However, a potential management approach would apply within the area mapped as the California spotted owl strategy area to manage within the vegetation desired conditions while considering the desired conditions for characteristics of Territory quality and Home Range quality consistent with improving forest resilience [table 1].

• A potential management approach would be added to evaluate California spotted owl habitat at the subwatershed scale (10,000 to 30,000 acres) [8a]. At this scale, designated spotted owl habitat is identified along with opportunities to improve the area towards desired conditions for the PAC, territory, and home range areas [8b].

• Where mechanical treatment is warranted, a standard would require that silvicultural prescriptions would follow the concepts of GTR-220 and 237 and consistent with short-term habitat improvement objectives [6d].

Plan Components within California spotted owl Protected Activity Center (PAC): • The size of a PAC remains 300 acres [table 2] and is designated using guidance in 2004

SNFPA

• A desired condition is added: canopy cover is ≥ 70% (increased from ≥ 60-70%) [2b] • The guideline would require retention of all snags greater than or equal to 15 inches, unless

they pose a safety hazard [2b]

• A guideline is added that provides that unless they are needed to maintain or improve habitat suitability in the short term (1 to 5 years), mechanical treatments are not allowed [6a]. Key features of desired conditions (i.e., multi-layered structure, diversity of diameter classes, moderate to high tree canopy cover) are retained or enhanced as a result of forest management actions. This is likely to limit treatments to the removal of small diameter woody material through hand thinning or prescribed fire. [6a] No exceptions for the WUI Defense or Threat Zones or long term habitat sustainability/resiliency are included.

• A guideline providing for the use of other treatments such as hand thinning of small diameter woody material or prescribed burning is changed to allow and encourage these activities if they maintain or improve key features of desired conditions (i.e. multi-layered structure, diversity of diameter classes, moderate- to high-tree canopy cover) in the short-term [6c].

• A standard is added to require that no overstory trees are removed [6b].

• A guideline is added to require that except where they pose a public safety risk, all trees greater than or equal to 30 inches diameter at breast height are retained [6b]. The existing exemption allowing removal of trees greater than or equal to 30 inches in diameter for equipment operability is not carried forward.

• A standard is changed to require retention of all PACs burned by wildfire in an unsalvaged condition regardless of the severity of fire effects and to augment the PAC to replace acres burned at high intensity (greater than 75 percent mortality) with unburned forest within the 0.6 mile territory circular area, where it exists [7a]. Salvage treatments can be considered in light of potential ecological impacts of leaving large areas of unsalvaged intensely burned forest where there are multiple PACs in close proximity.

Translation of IRs into plan components for central SN (September 30, 2015) Page 3

Plan Components within California spotted owl Territory:

• The Territory is an 1,000 acre circular area surrounding the activity center that is assumed to be used exclusively and is not shared with adjacent owls [table 2, 1b].

• The size of the designated habitat within the Territory is 700 acres [table 2], including the applicable acres within the PAC. Territory designated habitat must not include the PAC or designated territory area of adjacent owls.

• A desired condition is added: at least 400 acres within the entire Territory circle have at least 70 percent canopy cover and 300 acres have at least 50 percent canopy cover [Table 1, Table 2, 3c, 4d] and be in tree patches large enough to provide interior stand conditions, generally 1-2 tree heights from the edge [3d].

o If the territory circle does not contain sufficient suitable habitat, the shortfall is designated in the home range area as close to the habitat within the territory as possible.

• A desired condition is added that of the 700 acres above, at least 400 acres within the entire Territory circle are high quality nesting or roosting habitat defined as having at least 70 percent canopy cover (in descending order of priority, CWHR classes 6, 5D, and 4D) [3a, 3b, 4d]. This includes the applicable acres of the PAC and additional area with greater than 70 percent canopy cover outside of the PAC to meet the acreage target [table 1]. Patch sizes within this designated habitat should be large enough to minimize edge effects (large enough to provide interior stand conditions, generally 1-2 tree heights from the edge). The 400 acres of high quality nesting or roosting habitat should ideally be in the vicinity of the activity center [3a].

• A desired condition is added: territories include up to 300 acres in a fine-scale mosaic of low, moderate, and high canopy cover forest structure designed to achieve heterogeneous forest cover and stand density, defined as mosaics of habitats ranging from 0.03 to 2 acres in size that avoid uniform low tree density and bare understory conditions [4c].

• A potential management approach is added to monitor owl occupancy pre- and post-treatment in treated territories [5f].

• A guideline is added to manage up to 300 acres [4d]2 within the entire Territory circle to create or maintain fine-scale gaps associated with shrubs, meadows, or low tree and canopy densities with a matrix of higher density forests [4a].

• A guideline would be added that in the territory, except where it threatens public safety, all trees greater than or equal to 30 inches diameter at breast height are retained [6b, 8f].

• A guideline would be added that in acres of designated habitat that are within territory and outside of the PAC, except in rare cases (no examples of the ‘rarely removed’ situations given), all overstory trees are retained.

• A guideline is added that provides that unless they are needed to maintain or improve habitat suitability in the short term (1 to 5 years2), mechanical treatments are not allowed within the designated habitat within the territory [6a]. Key features of desired conditions

2 4d as applied to the southern Sierra Nevada 800-acre territories appears to include a typo suggesting that the ‘remaining acres (<100)’ be managed in this way, but after accounting for the 500 designated acres, there are 300 acres remaining, reflected here.

Translation of IRs into plan components for central SN (September 30, 2015) Page 4

(i.e., multi-layered structure, diversity of diameter classes, moderate to high tree canopy cover) are retained or enhanced as a result of forest management actions. This is likely to limit treatments to the removal of small diameter woody material through hand thinning or prescribed fire. [6a] No previous exceptions/allowances are carried forward.

• A guideline providing for the use of other treatments such as hand thinning of small diameter woody material or prescribed burning is changed to allow and encourage these activities in the designated habitat within the territory and outside of the PAC if they maintain or improve key features of desired conditions (i.e. multi-layered structure, diversity of diameter classes, moderate- to high-tree canopy cover) in the short-term [6c].

Plan Components within the California spotted owl Home Range Area:

• The Home Range Area is 4400 (or potentially 3000 acres [table 2]) within a 1.5 mile circle surrounding the activity center [5a].

• The size of the designated habitat within the Home Range Area is 1000-1500 acres [table 2], including the applicable acres within the PAC and the designated acres within the Territory [Table 1].

o Home range area for one owl may overlap with other home range areas of adjacent owls when there is significant overlap but must not include the PAC or territory designated area of any adjacent owls [5c].

• A desired condition is added for a minimum of 1000 acres and expected value of greater than 1500 acres within the entire Home Range Area circle have at least 50 percent canopy cover [table 2, 5b]. Patch sizes within this designated habitat should be large enough to minimize edge effects (large enough to provide interior stand conditions, generally 1-2 tree heights from the edge). This includes applicable acres in the PAC and designated Territory Habitat, and an additional 300-500 acres of designated habitat having greater than 50 percent canopy.

• A desired condition is added that the remaining area of the Home Range, outside of the Territory circle and outside the PAC or territory designated habitat of adjacent owls, contain an average of 40 percent canopy cover, and fine scale heterogeneity [5d].

• A desired condition is added to provide an approximate range of desired canopy covers in the Home Range outside the territory circle that reflects historical forest conditions. Percentages assume no overlap with adjacent owl PACs or territory designated areas [5e]:

o 25 percent or less with less than 25 percent canopy cover; o 10 percent or more with more than 70 percent canopy cover; o 15 percent or more with canopy from 40 to 70 percent canopy cover; o 50 percent is flexible in canopy cover with fine-scale mosaic.

• A guideline would require within the home range area, retention of all overstory trees and all trees greater than or equal to 30 inches diameter at breast height except where they pose a public safety risk [6b, 8f].

• A guideline is added that provides that unless they are needed to maintain or improve habitat suitability in the short term (1 to 5 years2) mechanical treatments are not allowed within the designated habitat within the home range [6a]. Key features of desired conditions (i.e., multi-layered structure, diversity of diameter classes, moderate to high tree canopy cover) are retained or enhanced as a result of forest management actions. This is

Translation of IRs into plan components for central SN (September 30, 2015) Page 5

likely to limit treatments to the removal of small diameter woody material through hand thinning or prescribed fire. [6a] No previous exceptions/allowances are carried forward.

• A guideline providing for the use of other treatments such as hand thinning of small diameter woody material or prescribed burning is changed to allow and encourage these activities in the designated habitat within the home range and outside of the Territory if they maintain or improve key features of desired conditions (i.e. multi-layered structure, diversity of diameter classes, moderate- to high-tree canopy cover) in the short-term [6c].

Appendix B