CHAPTER 2. ALTERNATIVES, INCLUDING THE PROPOSED ACTION

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1 CHAPTER 2. ALTERNATIVES, INCLUDING THE PROPOSED ACTION Introduction This chapter describes the process used to develop alternatives for the Rustler Vegetation Management Project. It includes a description and map of each alternative considered, a summary of project design criteria, mitigation measures to be applied to minimize environmental effects, and describes the monitoring applicable to the Action Alternatives. This chapter presents the alternatives in comparative form, sharply defining the differences between each and providing a clear basis for choice among options for the deciding official and the public. Some of the information used to compare the alternatives is based upon the design of the alternative (i.e., cable logging versus the use of skidders on skid trails) and some of the information is based upon the environmental, social and economic effects of implementing each alternative (i.e., the amount of erosion caused by cable logging versus skidding). Development of Alternatives Development of alternatives began with the Proposed Action briefly described in Chapter 1. This proposal was driven by the Purposes and Needs for action discussed there. Following scoping and the identification of Key Issues (Chapter 1) the interdisciplinary team developed alternatives to the Proposed Action that were designed to address those issues in meaningful yet distinct ways. The resulting range of alternatives is intended to: a) fulfill the purposes and needs for action, b) respond to management direction, including the Northwest Forest Plan, c) address the Key Issues raised in response to scoping on the Proposed Action, and d) provide clear choices for the deciding official. Note that there is not a detailed description of a No Action alternative. Development of this alternative is no longer required (36 CFR 220.7(b)(ii)). However, the consequences of taking no management action are compared against the Action Alternatives and are described in Chapter 3 of this Environmental Assessment. Assumptions Common to All Alternatives Under NEPA, there is a need to accurately estimate the maximum extent of treatments, their locations, and the resulting environmental effect. This Rustler environmental analysis process estimates this level of effect to identify the tolerable or acceptable limits or thresholds of effects for specific resource concerns under this decision. These thresholds set the boundaries for implementation of the decision under NEPA. The obligation of those implementing this decision is to monitor closely to ensure that implementation actions do not exceed the level of effects disclosed here. Under the Action Alternatives, treatments and amounts of acres with specific design criteria or limitations are proposed. These implementation specifics are intended to address specific on-theground conditions. It is inherent in each alternative that these on-the-ground conditions be identified and validated at the time of, and throughout, implementation. Some conditions may have changed between decision and implementation. Some mismatches between predicted and actual conditions and prescriptions are expected, though they should be uncommon, and Introduction Silvicultural Treatments II-1

2 necessary adjustments within the limits of the effects described in this EA are intended to be applied. Development of specific projects (including timber sales, service contracts, stewardship contracts, etc.) may require specialist field review and recommendations for more detailed, site-specific, application of treatments and mitigating measures. Concurrent monitoring would ensure that the effects of implementing any decision are no greater than those documented in this EA. Treatment Elements Applicable To Action Alternatives The following is a brief description of the treatments that are included in the Proposed Action and the alternatives. A detailed silvicultural prescription would be developed for each selected unit (during implementation) that specifically describes the size and species of trees that would be removed from that unit, as well as trees to be left and subsequent post-harvest treatments. Silvicultural Treatments Overstory Treatments This treatment typically involves the removal of overstory trees in a series of two or more harvests. Traditionally, this is designed to establish (regenerate) a new crop of trees prior to removal of the last of the overstory. Establishment of the new stand occurs under the cover of a partial forest canopy or shelter. A final harvest may remove the trees providing shelter which permits the new stand to develop in the open, or the remaining overstory trees could be left to serve as wildlife trees (future snags), or structure for uneven-aged stand management such as would be the goal in LSR, riparian, big game winter range, and other land allocations. In many cases, the establishment of natural seedlings is augmented with artificial planting to fill in any gaps in stocking. In the Rustler Planning Area there are two types of treatments that are proposed relating to overstory treatment. They include: Shelterwood Final Removal This treatment is the final stage of a shelterwood harvest and includes the removal of the uppermost layer of a forest stand, from which most trees had already been removed in the first entry decades ago. This treatment is usually associated with a previous shelterwood treatment but may occur in natural stands with similar characteristics. A portion of the overstory is typically removed, with some trees left to provide for canopy structure, future large snags, and future coarse woody material. Some units may be below Forest Plan Standards and Guidelines for snags and coarse wood, and such retention would be essential to meet LRMP standards and guidelines for these features. Where disease is a threat to meeting our objectives and there are insufficient trees to provide snags, coarse wood, and an economically viable harvest treatment; some trees may be girdled or topped rather than removed to reduce the spread of disease. Green-tree retention (the saving of individual green trees or patches of green trees for species habitat needs) would be implemented where necessary as outlined in the Standards and Guidelines from the NWFP. It is expected, however, that post-project conditions following the treatments proposed here will provide for these needs without having to apply this standard and guideline. Treatment Elements Applicable To Action Alternatives Silvicultural Treatments II-2

3 Variable Density Management Rustler Vegetation Management Project Environmental Assessment This treatment involves the selective removal (thinning) of some trees within a stand to reduce moisture or nutrient stress in overcrowded stands, allow for reintroduction of low intensity fire in the understory, and increase growth in the remaining trees. Stands receiving this treatment are often even-aged. This form of treatment is generally referred to as commercial thinning and favors retention of the healthiest trees that best meet structural and compositional goals. The anticipated treatment for many of the forest stands within the Planning Area would be a combination of density management, small group selection, and sanitation. Due to the variability of vegetation conditions within these units, the relative percentage of each treatment will be determined through very site-specific field exams during implementation. The stands proposed for treatment by this method within the Rustler Planning Area generally have trees that average between inches in diameter. Legacy trees (such as very large old trees) are to be left for structural diversity. Density management in young stands (20-40 years old) offers the best opportunity for developing the conditions most suitable for future development of old growth characteristics and makes them less vulnerable to wildfire effects. Density management in older stands is primarily driven by the need to reduce stress, increase species diversity, and increase the forest s ability to survive the inevitable exposure to large-scale wildfire, insects, and disease. Although the Standards and Guidelines from the Northwest Forest Plan do not call for the leaving of green tree retention areas in young, even-aged stands, some of the stands proposed for density management contain older trees. Where this situation occurs, GTR areas would be retained to prevent the loss of old growth trees as was intended by the green tree retention guidelines, unless the silvicultural prescription retains them. The following treatments would also likely occur within density management units: Sanitation - This treatment includes the removal of insect-attacked or diseased trees in order to maintain the health of a stand and capture the value of trees before it is lost (Daniel, Helms, and Baker 1979, page 434). For this Planning Area, this treatment is proposed to reduce the spread of damaging organisms to healthy trees in the rest of the stand. It is proposed primarily to prevent Douglas-fir dwarf mistletoe and root disease from spreading to susceptible trees nearby. This treatment is only being proposed in areas where the current levels of pathogens are a threat to the goal of maintaining good stocking of healthy trees, snags, and replacement snags. The purpose here is for the removal of threatening disease conditions; this is not an operation for simply increasing the timber volume yield from the project. Dwarf mistletoe is probably the most damaging disease of Douglas-fir in southern Oregon. Infection causes growth loss and mortality. Douglas-fir dwarf mistletoe is mainly a concern in the Rustler Planning Area where an infection in the overstory threatens to prevent a susceptible understory from reaching maturity. Laminated root rot spreads by root contact. The fungus can survive for decades in stumps and roots, preventing susceptible species from ever reaching maturity. The susceptible species in the Rustler Planning Area of concern include Douglas-fir, Shasta red fir, and white fir. Trees infected with laminated root rot do not make good wildlife snags because the disease reduces root strength, causing the trees to fall down before cavity nesting species can make good use of them. While these fallen diseased trees provide good coarse woody debris, the disease creates them in large numbers and high concentrations well in Treatment Elements Applicable To Action Alternatives Silvicultural Treatments II-3

4 excess of desired amounts and well over the numbers required by standards and guidelines. To treat infected pockets, openings up to 2 acres in size (depending on the alternative) would be created. Under this proposal, trees susceptible to the pathogen would be removed. Trees not susceptible to the disease, such as pine and cedar, would be retained, and the created openings would be re-planted with disease resistant species. Sufficient numbers of wildlife snags and replacement snags would be designated to remain on the site, prior to any sanitation treatment. Group Selection - Group selection is a silvicultural treatment that harvests groups of trees within a stand in order to create regeneration openings. Generally, openings are between ½ and ¾ acre but have the potential to be larger in size depending on site-specific objectives. The area regenerated within each unit would not exceed 20% of the total unit area unless disease conditions require larger areas to be regenerated (see sanitation). Group selection is intended to introduce structural diversity in an otherwise large homogeneous stand by mimicking the effects of a variety of natural disturbance processes (fire, wind, disease, etc.) that are essential for maintaining a healthy ecosystem. Each opening is regenerated through natural seeding and planting to insure that the desired mix of species is obtained. Though the regeneration in the small groups matures under even-aged conditions, the ½ acre or larger openings permit establishment of shade intolerant species such as ponderosa pine, and the result is a larger uneven-aged, more species-diverse forest. Group selection allows stands and landscapes to stay continuously forested while regeneration of each stand takes place over a long period of time with periodic entries. Pre-Commercial Thinning This is a reforestation and restoration action where the objective of treatment is to control the density and species composition of immature stands. This is commonly labeled timber stand improvement. It is designed to maintain or improve growth rates and reduces undesirable levels of mortality from suppression (from larger, healthier trees), insects, and disease. The trees that would be treated are generally less than five inches in diameter, although trees up to ten inches in diameter may be cut. The result of this treatment usually concentrates growth in those trees with the most desirable characteristics. The proposed units would be treated manually with individual trees being cut by chainsaw. There are several possible by-products that could be realized as a result of these treatments. These potential products include firewood, poles, posts, chips, biomass or Christmas trees. Utilization of these products would depend on the size and species of trees and market conditions. What can t be utilized may be subject to fuels treatment upon review. Snags and Down Wood Retention and Creation Down Wood and Snags are critical components of a fully functioning forest. In some locations within the planning area, past natural processes and human forest management activities have reduced snag levels below amounts recognized as being within the normal range of natural forest systems in southwestern Oregon. Data from analysis by Hochhalter (2010) was used to identify these normal range amounts of down wood and snags. The amounts were then used to develop guidelines for amounts to be left, or created after management activities, to ensure adequate Treatment Elements Applicable To Action Alternatives Silvicultural Treatments II-4

5 numbers are available following management actions. Table 2.2 and Appendix 3 contain a table of recommended amounts of snags and down wood to be in place following management activities. During logging and burning operations, snags will be protected to the degree safety considerations allow. Where large snags and logs are deficit (according to the guidelines in Table 2.2) in areas to be underburned, additional care will be applied to those that remain (raking duff and fuel from around rare large soft snags and logs) to better ensure retention. Following all management activities, if snags and logs are still deficit, they may be created from live trees left within the unit. Snags can be created through girdling, topping the trees with chain saws, blasting, or inoculation with heart rot fungi. These methods open the trunk to development of a hollow core used by woodpeckers and a variety of other birds, mammals, and other wildlife. Release This treatment removes competing vegetation from around selected trees to maintain and enhance the health and vigor of the remaining trees. Release is a manual treatment accomplished by cutting the competing vegetation by mechanical methods, usually chainsaws, within a radius around each tree usually equivalent to the radius of the tree s crown, plus 25 feet. Meadow Restoration After decades of fire suppression, brush, hardwoods and conifers are encroaching upon the Blue Rock meadows (and many other meadows across the High Cascades Ranger district). This treatment removes the encroaching vegetation through cutting and possibly burning to maintain the native grasses and forbs normally found in meadow habitats. Enlarging this meadow to its historic conditions will assist in control of future wildfires meeting the Purpose and Need to reduce risk of high-intensity large-scale wildfire. Trees of commercial value will be removed from within the meadow meeting the purpose and need for timber volume while restoring the meadow to its historic meadow condition. Harvest (Logging) Systems Within the Rustler Planning Area, logging system options include ground-based systems and skyline cable systems. Other systems, such as aerial systems (helicopter), may be utilized provided they meet the project design criteria and project objectives. Ground-based Systems This refers to a group of logging methods that are considered ground-based, and may also include mechanized harvesting equipment. Typically, logs are harvested using mechanized heavy equipment to skid the logs to a landing area, where they would be loaded onto a truck. These ground-based systems are usually utilized on terrain where slopes are less than 35%. Tractor - In this system, a cutter will fall (cut down the tree), then limb (cut off the limbs) and buck (cut into lengths) the tree in the bed where it landed when it was felled. Choker cables are attached to the logs and a tractor equipped with a winch uses a bull line to pull the logs from their beds into the pre-designated skid trail. When a group of logs is assembled into a turn (a group of logs that will be dragged at one time), Treatment Elements Applicable To Action Alternatives Harvest (Logging) Systems II-5

6 the chokers are gathered together, the leading ends of the logs are suspended above the ground behind the tractor by way of an integral arch or similar apparatus, and the trailing end of the logs drag along the ground on the way back to the landing. At the landing, a front-end or a knuckle-boom loader is used to load logs decked (piled) at the landing onto log trucks. Rubber-tired Skidder - This system is essentially the same as tractor logging in technique, although the skidding equipment has some operational and functional differences. While most tractors have a rigid frame and steel tracks with cleats that run along a rigid rail and tend to churn up some soil when it turns, rubber-tired skidders have no tracks (hence rubber-tired ), are often articulated in their middle instead of having a rigid frame, and they displace somewhat less topsoil than a tractor would when they turn. Both types of equipment have their advantages, depending on the situation. Harvester Forwarder - A harvester and forwarder are two separate pieces of equipment. The harvester (while traveling on pre-designated harvester trails) reaches its boom out to cut the tree, and lays it down approximately perpendicular to the axis of the skid trail. Rollers on the cutting head then pull the tree through cutting knives, which drop the limbs in the harvester trail in front of the harvester as they are severed. As each pre-determined length of log has been fed through the de-limbing knives, logs are bucked from the tree and allowed to fall into a stack of uniform length logs alongside the harvester trail. As the harvester travels through the unit, it rides on the bed of limbs that act as a cushion to help minimize soil compaction. Later, a forwarder uses the same trails to pick up the logs, load them onto its bunk, and transport the logs to the landing, completely free of the ground instead of dragging them behind the machine. Because the logs are transported free of the ground and the weight is evenly distributed over all of the forwarder s wheels, and the resulting ground pressure is less than that of other groundbased systems. This method not only minimizes soil compaction, but it virtually eliminates any exposure of subsoil so there is rarely any detrimental displacement or erosion. These machines are often used to pre-bunch logs throughout a harvest unit for later yarding to the landing by a skidder or cable system. Such pre-bunching is economically efficient, but practically limited in areas such as the Rustler planning area where soil compaction constraints limit machines to existing skid roads. These machines can only reach so far, and there are generally areas between designated skid roads that cannot be reached by these machines. Designated Skid Roads Designated skid roads is a concept referred to throughout this document. Its use is routinely prescribed to minimize compaction of soils by heavy equipment. In the early days of logging, equipment was allowed to operate everywhere within timber cutting units, and broad-scale soil compaction resulted when such practice occurred when soils were wet. Preventing additional compaction and restoring soil permeability in areas compacted in the past is a primary objective of this project, and designated skid trails is the practice envisioned. That primary objective, however, can be met in other ways, and those other ways are equally acceptable and considered equivalent to designation of skid roads during implementation. The objective to be met (minimizing additional compaction with Treatment Elements Applicable To Action Alternatives Harvest (Logging) Systems II-6

7 post-activity restoration through subsoiling) is the primary consideration, not the means envisioned for doing so. To that end, pre-bunching in unreachable areas between designated skid roads as discussed above can be considered if such action occurs only when soils are frozen or sufficiently dry to prevent compaction, and adequate slash is available to effectively cushion such operations to prevent compaction. The end result of any soil protection method must be the same: no net increase in detrimental soil compaction consistent with LRMP allowances. Skyline-Cable Systems This method for transporting logs from stumps to landings utilizes a wire rope cable that is suspended between two high points. This cable (or skyline) functions as an overhead track for a load-carrying carriage. Cables, or other devices attached to the carriage, lift logs and pull them into a skyline corridor. The carriage is then pulled to the landing by a mainline powered by a yarder. The skyline provides vertical lift so that the logs have their leading end suspended above the ground during inhaul. In some cases, the entire log may be suspended above the ground. Aerial Systems Though not specifically planned for this project, heavy-lift helicopters could be used to transfer the logs from where they are cut to a landing where they are loaded on trucks for haul to a mill. Helicopters are divided into three classes, depending on their lift capabilities. Helicopters have high operating costs and are usually utilized where there are specific concerns for ground disturbance, retaining visual quality, or where road building is not desired. Road Access The following discussion includes the basis for proposals for reconstruction of existing roads and construction of temporary roads. While a majority of the Rustler Planning Area has an existing network of roads and landings from previous harvests, there would still be some additional areas where access would be necessary to carry out the prescribed treatment. These would primarily occur in areas not previously entered, or sometimes to facilitate a change in logging systems (e.g., where skyline logging is now prescribed in areas that were previously tractor logged). Road Reconstruction Reconstruction involves maintenance and improvements to existing system roads, to make them suitable for logging equipment and harvest treatment access. The work typically involves clearing the roadway of vegetation and grading the surface. It may include widening and replacement of surface rock. Proposed system road reconstruction would be accomplished by the purchaser/contractor for the various potential timber sales prior to any commercial timber haul. Treatment Elements Applicable To Action Alternatives Road Access II-7

8 Temporary Roads Rustler Vegetation Management Project Environmental Assessment Temporary roads are generally proposed where single entry access is needed as part of a timber sale, for access to harvest units. They typically have a lower planning, design, and initial development cost than permanent system roads. They do not add to the forest s road maintenance costs since all costs associated with the development, use, and obliteration of these roads are covered by the associated Timber Sale. Temporary roads are generally shorter than system roads and are open only during use and/or the life of the timber sale contract. These roads cannot be compared to engineered roads (permanent system roads), as they generally are not surveyed or designed for multiple uses or long-term resource protection (e.g., all-weather maintenance). Temporary Roads have also been defined in 36 CFR as Roads authorized by contract, permit, lease, other written authorization, or emergency operation not intended to be part of the forest transportation system and not necessary for long-term resource management. Temporary roads associated with this project would be built and removed by the timber operator as part of the Forest Service timber sale contract. In many cases, these temporary roads are merely an extension of a landing (a few hundred feet), or could actually be a travelway of more than ¼ mile. Temporary roads, just like any other roads, are included as part of the affected (detrimental) soil conditions under the Soil Quality Standards and Guidelines. Forest Service regulations (36 CFR ) also require temporary roads to be revegetated within ten years. In order to prevent continued low level casual use, and to minimize resource impacts, such roads and landings would be obliterated at the completion of their intended use. The Forest Service Sale Administrator, with agreement by the purchaser, will determine temporary road and landing locations and stabilization measures. The Sale Administrator will request the advice of a watershed specialist in determining the most appropriate location and stabilization measures to be required. Unclassified or Unauthorized Roads Unclassified roads are roads on National Forest System lands that are not managed as part of the National Forest s transportation system, such as unplanned roads, abandoned travel ways, and off-road vehicle tracks that have not been designated and managed as a trail; and those roads that were once under permit or other authorization and were not decommissioned upon the termination of the authorization. Since they do exist, it is preferable to re-use these existing roads and trails rather than to construct new temporary roads whenever feasible. Regarding soils, the area within these existing traveled ways has already been adversely impacted. Re-using them does not contribute any additional areas being compacted or displaced, whereas not re-using them in favor or constructing new roads will obviously create new and additional adverse impacts. Re-using existing unclassified roads also gives the Forest Service a mechanism to rehabilitate them during harvest operations, so a measure of soil restoration can be done under the contract. Decommissioning Roads Road decommissioning means to un-build, deactivate, or dismantle a road; the denial of use, elimination of travel way functionality, and removal of the road from the Forest Development Road system, and return of the road corridor to resource production by natural or designed Treatment Elements Applicable To Action Alternatives Road Access II-8

9 means 1. Roads proposed for decommissioning were identified using an interdisciplinary team which assessed the existing road system, access needs for the watershed, and resource impacts from roads for the planning area for this project. Activity and Natural Fuels Treatments Activity Fuels Activity fuels treatment refers to the slash and accumulated fuels loading resulting from the proposed commercial harvest or service contract action. While there may be some slash from previous harvesting or from natural conditions, the majority of material would be generated through treatments at this time. There are several techniques available to accomplish reduction of activity fuels, when resulting levels are predicted to be greater than that which equates to an acceptable fuels risk and fire hazard. All available fuel treatments are considered viable until Pre and Post-Harvest reviews are conducted, at that time fuels treatments will be identified and documented in prescribed burn plans. Activity fuels treatments proposed for this project include only those that are predicted to be necessary to achieve an acceptable fuels/fire risk. It is estimated that there would be 9,100 acres of activity fuels treatments under the Proposed Action. Several methods of activity fuels treatment are being proposed, and include the following: Lop and Scatter is a method of slash reduction where accumulations and concentrations are broken up (usually with chain saws) and dispersed away from dense locations. Leave Tops Attached is a method that effectively reduces fuel loading within units and would transfer most of the slash to landings, where it would be treated. This practice is just what its name indicates: a tree, or the last bucked log, is yarded to the landing without cutting off the unmerchantable top and leaving it in the forest, as is usual practice. These tops are then piled at the landing for hauling away as biomass or disposal though burning. Whole Tree Yarding is a method similar to the one above except that the entire tree is yarded to the landing. This is usually applied only where trees are relatively small. Hand pile, with subsequent burning of piles is a fuels treatment where accumulated harvest activity slash is piled by hand; the resulting piles are burned at a time of year when the risk of escaped fire has subsided (typically in winter) and resulting smoke production can be managed in conjunction with favorable weather conditions. Underburning is a term for prescribed ignition and burning of continuous activity fuels under a forest canopy across a larger area, usually a large landscape. Burn patterns are continuous and are expected to treat percent of the area. Jackpot burning is a term for prescribed ignition and burning of concentrations of activity slash and fuels. It is a technique used where concentrations of slash are higher than that over much of the area, but typically not continuous. Only the heaviest concentrations of fuels are ignited. Burn patterns would not be continuous, nor expected to affect more than percent on an activity area. This method emulates conditions 1 Guide for Road Closure and Obliteration In The Forest Service, Technology and Development Program, 7700 Engineering, June 1996 Treatment Elements Applicable To Action Alternatives Activity and Natural Fuels Treatments II-9

10 often found under natural regimes where fire has been a part of the ecosystem and resulting burns are light and incomplete. Natural Fuels Although treatment of natural accumulations of fuel to reduce fuel loading and to lower the Fire Regime Condition Class (FRCC) 2 is usually accomplished by prescribed fire, there are many other methods that maybe considered for fuels reduction to change the condition class. These methods include: underburning, handpiling and burning piles, pruning ladder fuels, lop and scatter, thinning, chipping, brushing, whole tree yarding, and yard with tops attached. It may take more than one treatment to effectively lower the condition class. Approximately 3,500 acres (most of which are coincident with vegetation treatment areas) within the Planning Area have been proposed for natural fuels reduction treatments. Portions of the Rustler Planning Area have been proposed for Fuel Modification Zones as defined below: Fuel Modification Zone (FMZ) A zone in which fuel quantity has been reduced or altered to provide a position from which suppression forces can effectively fight wildfire. FMZ s are designed or constructed before an outbreak of a fire. FMZ s may consist of one or a combination of the following: natural barriers, constructed fuel breaks, and human-made barriers (such as roads). This treatment consists of commercial and noncommercial treatments such as thinning, pruning, handpiling and burning up to 300 feet in width in strategic locations utilizing roads and ridge tops to slow an advancing fire front to create a defensible space for fire suppression personnel in the event of a large fire. It also provides opportunities for introducing prescribed fire to large areas on the landscape. There are approximately 660 acres proposed for FMZ under the Proposed Action and 717 acres in Alternative Three. Post-Harvest Treatments Following completion of the prescribed silvicultural treatments, many of the proposed units would require follow-up treatments. Options include soil restoration or reforestation (described below), or animal damage control activities. Most post-harvest treatments are funded under the provisions of the Knutson-Vandenberg (KV) Act of 1930, as amended by the National Forest Management Act of Purchasers of National Forest timber make deposits to finance sale-area improvement activities needed to protect and improve the future productivity of the renewable resources of forest lands on timber sale areas. This act requires development of a Sale Area Improvement (SAI) plan. 2 Fire Regime Condition Class, referred to generally as condition class, is a classification system used to characterize the relative fire risk to vegetative conditions. It is defined in terms of departure from the historic fire regime, as determined by the number of missed fire return intervals with respect to (1) the historic fire return interval, and (2) the current structure and composition of the system resulting from alterations to the disturbance regime. Three Condition Classes are used, with Condition Class 1 being most resistant to adverse impact from fire and Condition Class 3 likely to result in adverse changes well outside the historic norm. The goal in fuels treatment is generally spoken of as reducing condition class, that is, reducing it from a Class 3 to a Class 2 or 1. A more detailed discussion of condition class may be found at Treatment Elements Applicable To Action Alternatives Post-Harvest Treatments II-10

11 Planting Rustler Vegetation Management Project Environmental Assessment This is a reforestation practice used to establish vegetation, mainly trees, lost during treatment or insect or disease infestations. The density and species mix is variable depending on site-specific conditions. Planting prescriptions are developed specifically for each site. Animal damage control methods such as netting or tubing of seedlings are likely to be applied. Soil Restoration This is a practice designed to fracture a compacted layer of soil without plowing or turning over surface soil layers. The following section on subsoiling was adapted from the guidelines included in a report by Geist and Froehlich (Appendix 6). Routine application of these guidelines across the Pacific Northwest Region in the past couple of decades have demonstrated that even severely compacted landings can be loosened to restore a large proportion of its growth potential if sufficient soil remains. To meet this objective, specialized subsoilers must be used. Traditional rock-rippers or various types of disks are not capable of adequately alleviating the compaction problem. The characteristics of adequate tillage prescribed here includes 1) the ability to fracture the full depth of the compacted layer, 2) an ability to fracture soil without plowing or turning over the surface and subsurface soil layers, and 3) the capability of tilling the full width of typical skid trails in a single pass. A towed winged subsoiler meets these goals. The key to subsoiling is the fracturing of the compacted layer of soil by drawing a set of wings through the soil just below the compacted layer. As the wings slice through the soil, the compacted layer is lifted slightly and fractures as it flows over the back edge of the wings. The wings are mounted at the base of the curved, sharpened shank. Ideally, the wings should be adjustable to meet the wide variety of soil conditions encountered. The wings are up to 20-inches wide and mounted on the moveable shanks. To be effective when tilling among stumps, boulders, etc., the shanks need to be equipped with a hydraulic tripping mechanism that automatically releases each shank individually when it encounters an obstacle. Areas with excessive slash, especially large debris, are difficult to subsoil, but the long shanks (up to 3 ft.) and wide spacing (up to 4 feet) make it possible to subsoil most skid trails without slash piling. When a crawler tractor equipped with a brush rake draws the subsoiler, occasional large debris accumulations can be piled during the tillage operation. While subsoiling has proven to be effective in restoring a high level of tilth to compacted soils, there are conditions where it may not be appropriate. Subsoiling is not usually effective where there is dense surface vegetation as masses of root-bound soil tend to be torn into large chunks. Shallow soils above a stony layer and sites with numerous large boulders can be tilled but it is generally ineffective. Subsoiling should be limited to slopes less than 40%. However, when tilling with a subsoiler on steep skid trails, the tractor may turn off of the skid trail at intervals to create effective water diversions. After creating a water diversion or water bar, the equipment is positioned several feet down the skid trail from the water bar and begins tilling again. This discontinuous tillage helps to assure that water cannot be routed down a steep section of skid trail to create an erosion problem. It is especially important to subsoil completely through the compacted layers to allow water to infiltrate into the slope rather than be concentrated on an impermeable compacted layer. Treatment Elements Applicable To Action Alternatives Post-Harvest Treatments II-11

12 Project Design Criteria Applicable To Action Alternatives This sub-section discusses design criteria to be applied to the various treatment elements described above. These criteria are to be employed during layout of the project and are designed to ensure compliance with LRMP Standards and Guidelines or other guidance documents while attaining the Purposes and Needs. Other elements that manage consequences during actual operations that are beyond the protections provided by these design criteria are termed mitigation measures and are discussed later in this Chapter. Many design criteria and mitigation measures require site-specific recommendations from Forest Service resource professionals. This engagement of specialists in project layout and application of these criteria is in itself an overall design element to be applied where prescribed in the mitigation measures. Project Design Criteria for Silvicultural Treatments Density Management As previously discussed, the primary treatment being proposed for the Rustler planning area is density management. Implementation of this form of treatment is generally referred to as commercial thinning and favors retention of quality individual trees. To achieve the desired density, thinning would be applied across all size and age classes (with the exception of legacy trees as discussed above) until the desired objective is met. The goal is to increase structural and genetic diversity. This would hasten the development of the larger residual trees that are elements of habitat for a number of species while maintaining species diversity through planting and created openings. Riparian Reserves Density management/thinning treatments and/or commercial extraction would only be considered if needed to attainment or restore riparian forest conditions that meet Aquatic Conservation Strategy (ACS) objectives. Timber harvest is prohibited in Riparian Reserves, unless it is to acquire desired vegetation characteristics needed to attain ACS objectives or to mitigate damaging effects to Riparian Reserves from catastrophic events such as fire, flooding, volcanic, wind, or insect/disease damage (NWFP Standards and Guidelines, Timber Management, TM-1). Apply silvicultural practices for Riparian Reserves to control stocking, reestablish and manage stands, and acquire desired vegetation characteristics needed to attain Aquatic Conservation Strategy objectives (NWFP Standards and Guidelines, Timber Management, TM-1c). Situations in which timber harvest may be needed to attain ACS objectives include thinning in young forests in Riparian Reserves with a focus on recruitment of large trees for future in-stream wood and to improve height and size of trees for shade, to increase root strength, and to achieve other characteristics having to do with overall health and resilience of the stand against loss from insect, disease, or fire. This thinning will only be prescribed in dense young stands (generally under 40 years of age) where research indicates that in-stream wood benefits can be gained from such thinning (Beechie, et al, 2000). It will not be applied to dense mature stands of trees where research indicates that such thinning actually removes trees that might otherwise provide future mortality for snags, which then can become in-stream wood (Beechie, et al, 2000). Project Design Criteria Applicable To Action Alternatives Project Design Criteria for Silvicultural Treatments II-12

13 Field identification and delineation of Riparian Reserves and validation of fish-bearing status would be required before implementation of treatments within Riparian Reserves. An estimate of Riparian Reserve treatment acreage associated with the Action Alternatives has been made and is described in the alternatives section of this Chapter. Overall Project Design Criteria for Riparian Reserve Treatments Currently unmapped Riparian Reserves within the Planning Area, or within one site-potential tree (156 feet) of the Treatment Area Boundary, would be identified prior to implementation of any treatment. No new temporary roads or landings are proposed nor authorized within Riparian Reserves. The Stream Channel Protection Zone is defined as the area from the edge of the stream course up to 25 feet. No vegetation management would occur within 25 feet of perennial or intermittent stream channels. No hand piles would be located or burned within this zone. Within 100 feet horizontal distance of perennial streams (Restricted Riparian land allocation, MA 26) non-commercial thinning of smaller trees may be prescribed. No commercial timber harvest would occur within this zone under any action alternative. Soil compaction or the loss of soil infiltration capacity in a riparian area from such things as skid roads could establish a mechanism for sediment delivery from concentrated overland flow. As a special design element for this project, practices will be applied within 100 feet of perennial or intermittent stream courses to ensure that infiltration capacity will not be reduced by more than 10% for any activity. This element would consider existing skid trails, which could be re-used as necessary and then be sub-soiled after use to re-establish soil infiltration capacity. There would be no new haul roads, skid trails, or landings within Riparian Reserves. To facilitate log suspension with skyline operations, corridors for cable rigging would be allowed to pass through Riparian Reserves. A maximum clearing width of 12 ft. is required and logs may be yarded, with full suspension, through this corridor if necessary. Corridors should be spaced at an average of 200 feet apart if they pass through Riparian Reserves. Corridor rub trees (standing trees damaged by skidded logs) would be left, even if damaged and/or felled. The Primary Shade Zone is an area where no commercial extraction would occur (larger trees felled for skyline corridor clearing would be left), however some small diameter thinning, fuels reduction or other restoration treatments could occur. Distance from the active stream channel varies according to height of existing overstory trees and hill slope in immediate area. The following table establishes the width of the Primary Shade Zone. Table 2.1: Minimum Width of Primary Shade Zone for Perennial Streams, Based on Adjacent Hill Slope and Tree Height Tree Height Hill Slope <30% Hill Slope 30% to 60% Hill Slope >30% Trees < 20 feet (precommercial thinning) 12 ft. 14 ft. 15 ft. Trees 20 to 60 feet 28 ft. 33 ft. 55 ft. Trees > 60 feet 50 ft. 55 ft. 60 ft. Project Design Criteria Applicable To Action Alternatives Project Design Criteria for Silvicultural Treatments II-13

14 The Temperature Implementation Strategies 3 allow the distances in Table 2.1 to be less (but not less than 25 ft.) if any of the following conditions applies: o o o The trees are located on a south facing slope ( degree azimuth) and therefore do not provide stream shade; An appropriate level of analysis is completed and documented, such as shade modeling, using site-specific characteristics to determine the primary shade tree width; and or Field monitoring or measurements are completed to determine the width where optimum Angular Canopy Density (65% or greater) is achieved. Project Design Criteria for Application of Logging Systems As discussed above, logging system options for stands that provide opportunities for commercial extraction include ground-based systems and skyline cable systems. Aerial (helicopter) systems are not planned, but may be applied if market conditions allow and helicopters become available. The primary concern involved with use of the various logging systems is the potential detrimental effects to soils (and indirectly hydrologic systems and aquatic habitat) beyond Forest Plan Standards and Guidelines. This concern elevates when equipment is considered for use on steeper slopes, sensitive soil types, or unstable areas. Conversely, there is an operational concern for economics between the various systems being considered, i.e., ground based systems are most economic from an operational cost viewpoint, skyline systems increase in operational costs, and aerial systems are the most costly. Road access and landing accessibility are also factors to consider. Considerations for logging systems would follow a logical progression of planning during implementation. If a stand could benefit from treatment, the first consideration is for groundbased operations. If that were infeasible or restricted based on Soil Risk, then consideration for skyline systems would be next, but the prescribed silvicultural treatment would not be changed solely for the purpose of making the operation more economically feasible (i.e., designation of larger, more valuable trees) to help pay for the increased logging costs with skyline systems if that change would compromise the silvicultural intent. Project Design Criteria for Coarse Woody Material (Snags and Large Wood) Snags and down large coarse wood would be retained to support ecosystem function. The overall objective is to manage snags and large wood to provide a renewable supply of coarse woody material well distributed across the landscape in a manner that meets the needs of species and provides for ecological functions. Coarse woody material (CWM) fulfills a number of important ecological functions such as stabilizing surface soils, increasing organic content in soils over the long-term, providing habitat for the many organisms that depend on snags and down logs in various stages of decay, and 3 From the Northwest Forest Plan Temperature TMDL Implementation strategies - Evaluation of the Northwest Forest Plan Aquatic Conservation Strategy and Associated Tools to achieve and maintain stream temperature water quality standards (USFS and BLM; latest version September 9, 2005) Project Design Criteria Applicable To Action Alternatives Project Design Criteria for Application of Logging Systems II-14

15 ensuring adequate coarse woody material recruitment to meet the ecological needs of aquatic systems over time. Large snags over 20 inches diameter are particularly essential for forest function. In addition, at least 96 wildlife species in Oregon and Washington are associated with snags in forests, using snags for shelter, roosting, and foraging/hunting. Most species use snags greater than 14 inches diameter (Rose et al. 2001). Ridges, upper thirds of slopes, and riparian areas or lower third of slopes are very important for late-successional dependent species. Snags in various size classes also are important to the recruitment pathways of the down coarse materials important to soils. As with snags, down logs are important for wildlife and aquatic ecosystem function. In addition, large coarse woody material is particularly important to maintaining and holding soils in place. Under the Action Alternatives, down logs are to be retained and are considered excess only when all site considerations have been met and in accordance with direction provided from the Forest Plan Standards and Guidelines. Assessments across the National Forest have established desired levels of dead wood by size class per acre for major plant associations (table below). These figures were derived from Ecology Plot data, adjusted by past conditions established by Plant Associations, with consideration of the DecAID5 advisory system. These represent the standard to be met in each action alternative. Recommendations will follow snag and down wood guidelines by Plant Series identified by Hochholter (2010) for the Cascade Province of the Rogue River-Siskiyou National Forest.. In matrix, strive to maintain the mean ± 1 SD for snags and down wood in the 11 and 20 classes. In riparian reserve, maintain the mean + 1 SD for snags and down wood in the 11 and 20 classes. Table 2.2: Target Sizes and Amounts for Snags and Coarse Woody Material Levels Plant Series Diameter Class CWD mean pieces per acre (SD) CWD mean length per acre in cm (SD) Snag mean number per acre (SD) White fir = or >11 and <20 44 (44) (6) White fir = or >20 10 (18) (5) Douglas-fir = or >11 and <20 58 (79) (13) Douglas-fir = or >20 10 (20) 93 2 (4) Mountain Hemlock = or >11 and <20 18 (21) (19) Mountain Hemlock = or >20 15 (13) (4) Note: A piece is defined as a log a minimum of 20 feet long. Three alternatives are analyzed in detail in this EA. Alternative 1, the Proposed Action, would use vegetation treatments within Matrix and Riparian Reserve areas to promote the development Project Design Criteria for Coarse Woody Material (Snags and Large Wood) II-15

16 of fire and disease resilient mature and older forest for a diversity of public values including wildlife habitat, wood production, and recreation. Alternative 1 represents the maximum extent of proposed treatments. Alternative 2 modifies the Proposed Action by eliminating all treatment within the Riparian Reserve as defined by the Northwest Forest Plan, FMZs, and all temporary road construction. For the planning area, the Riparian Reserve buffer is 156 from the stream course for non fish-bearing streams (intermittent or perennial) and 312 from the stream course for perennial fish-bearing streams. Alternative 3, among other changes, eliminates all treatments within high quality spotted owl habitat consistent with Recovery Action 32 as discussed in Chapter 1 and reduces the size of any opening created to no greater than 3/4 of an acre. Each of the Alternatives described below contain the applicable design criteria as described in the sections above. Alternative 1 - Proposed Action This is the alternative originally conceived to meet the Purposes and Needs and provided to the public in early 2008 for review and comment. Function The Proposed Action proposes a variety of management treatments and is designed to attain the Purposes and Needs described in Chapter 1. The Planning Area is located primarily within Matrix and Riparian Reserve land allocations (a small piece of the Planning Area is located within a Late-Successional Reserve though no actions are proposed therein). Alternative 1 represents the maximum extent of proposed treatments. Description This proposal would treat approximately 10,402 acres with a variety of silvicultural treatments. The anticipated treatments are summarized in Table 2.3. A complete listing of treatments is included in Appendix 1. Final detailed prescriptions would be developed prior to implementation. The proposed treatments include a combination of silvicultural methods within individual units to account for variations in stand conditions and to meet multiple objectives. The total of these treatments would yield an estimated 64 million board feet of commercial volume that would be offered in multiple timber sales over a period of 3-5 years. Other treatments would occur over an estimated 10-year period. Table 2.3: Alternative 1 Summary Treatment Acres Density Management 5753 Riparian density management 2223 Pre-commercial thinning 924 Overstory Treatments 661 Sanitation 154 Meadow Enhancement 7 Fuel Management Zone (outside of other treated units) 680 Total Acres Treated 10,402 Alternative 1 - Proposed Action II-16

17 A combination of logging systems would be used to harvest the trees. Tractor, or ground-based systems, would be used on approximately 90 percent of the harvested area. Skyline systems would be used on approximately 10 percent of the harvested area. A combination of fuel treatment methods would be used to treat activity-created slash. These methods include: biomass utilization, underburning, handpiling and burning piles, pruning ladder fuels, lop and scatter, thinning, chipping, brushing, whole tree yarding, and yarding with tops attached. To meet the need to reduce natural fuels condition class, most of these same fuel treatments will also be applied in areas not treated silviculturally. To effectively lower the condition class, however, it may take more than one of these treatments. In addition, Fuel Modification Zones (FMZ s) would be constructed in strategic locations utilizing roads and ridge tops. Riparian Reserves would be treated as needed, to meet Aquatic Conservation Strategy Objectives as described above. Overstocked Riparian Reserves would be thinned (commercially or noncommercially depending on distance from stream, as discussed above) and/or underburned. Riparian Reserves that lack an overstory component could be planted if that were a feasible action to produce future shade. Riparian Reserves would be delineated and treated as described in the Northwest Forest Plan. Restricted Riparian will be managed as prescribed in the LRMP. Approximately 10 miles of new temporary road construction is proposed to access some units under this alternative, as well as 6-7 miles of reconstruction of existing system roads. In addition, resource specialists proposed an estimated 9.9 miles of roads for decommissioning. These roads are listed below in Table 2.4. Table 2.4: Roads proposed for decommissioning Road Number Miles Road Number Miles Road Number Miles Total miles proposed for decommissioning: 9.90 Alternative 1 - Proposed Action II-17

18 Figure 2.1: Treatments - Alternative 1 (Proposed Action) Alternative 1 - Proposed Action II-18

19 Alternative 2 Reduced Impacts to Aquatic Resources, Soils, and Large Trees. Function Alternative 2 is based on the Proposed Action, but includes modifications designed to address the issues concerning Water Quality and Aquatic Resources; Soils and Site Productivity; and effects to large trees. Description This alternative includes the candidate stands and opportunities from the Proposed Action, with modifications that: o o o o Deletes all treatments within the Riparian Reserves and meadows; Eliminates overstory removal treatments (though precommercial thinning of these stands remain); Excludes temporary road construction and whatever treatment units were dependent on them. Drops the creation of Fuel Management Zones. These modifications result in an approximately 39% reduction of the treated acres from those in the Proposed Action. This proposal would treat a maximum of approximately 6,328 acres with a variety of silvicultural treatments (a 39% reduction of the treated acres from those in the Proposed Action). The anticipated treatments are summarized in Table 2.5. A complete listing of treatments is included in Appendix 8. As field exams are completed, site-specific information may suggest some changes to the preliminary prescriptions. Prescriptions will be finalized during implementation. The proposed treatments include a combination of silvicultural methods within individual units to account for variations in stand conditions and to meet multiple objectives. The total of these treatments would yield an estimated 53.6 million board feet of commercial volume that would be offered in multiple timber sales over a period of 3-5 years. Other treatments would occur over an estimated 10-year period. No Riparian Reserves would be treated under this alternative. Table 2.5: Alternative 2 Summary Treatment Acres Density Management 4592 Riparian density management 0 Pre-commercial thinning 1586 Overstory Treatments 0 Sanitation 150 Meadow Enhancement 0 Fuel Management Zone (outside of other treated units) 0 Total Acres Treated 6,328 Alternative 2 Reduced Impacts to Aquatic Resources, Soils, and Large Trees. II-19

20 A combination of fuels treatments methods would be used to treat slash created from vegetation treatment activities. These methods include biomass utilization, underburning; handpiling and burning piles; pruning ladder fuels; lop and scatter; thinning; chipping; brushing; whole tree yarding; and yarding with tops attached. To meet the need to reduce natural fuels condition class, most of these same fuel treatments will also be applied in areas not treated silviculturally. To effectively lower the condition class, however, it may take more than one of these treatments. A combination of logging systems would be used to harvest the trees. Tractor, or ground-based systems, would be used on approximately 95 percent of the harvested area. Skyline systems would be used on approximately 5 percent of the harvested area. No new temporary road construction is proposed under this alternative. However, it is estimated that there would be 4-5 miles of reconstruction of existing system roads. In addition, an estimated 9.9 miles of roads have been proposed for decommissioning. These roads are the same as in the Proposed Action and are listed in Table 2.4. Alternative 2 Reduced Impacts to Aquatic Resources, Soils, and Large Trees. II-20

21 Figure 2.2: Treatments Areas - Alternative 2 Alternative 2 Reduced Impacts to Aquatic Resources, Soils, and Large Trees. II-21

22 Alternative 3 Protection of High Quality Spotted Owl Habitat Function Alternative Three was developed to be consistent with the 2008 Spotted Owl Recovery Plan 4. That plan includes a recovery action, known as Recovery Action 32, which calls for the maintenance of substantially all of the older and more structurally complex multi-layered conifer forests on Federal lands outside of Managed Owl Conservation Areas (MOCAs) (Recovery Plan, page 34). Description In response to the recovery plan, this alternative starts with the candidate stands and prescriptions from the Proposed Action, and then drops those acres within habitats identified as meeting the intent of Recovery Action 32. The following table identifies units from the Proposed Action that were dropped or reduced in size for Alternative Three: Table 2.6 Unit changes to further protect owl habitat for Alternative Three Units dropped Units reduced in size a c b 102d e The final Recovery Plan for the Northern Spotted Owl was approved in May 2008 in compliance with Section 4(f) of the Endangered Species Act. The act calls for the plan to include site-specific management actions necessary for conservation and survival of the species. This particular plan relies on federal lands to provide the major contribution for spotted owl recovery (Recovery Plan page VIII). A copy of the plan may be located at Alternative 3 Protection of High Quality Spotted Owl Habitat II-22

23 This alternative also: o o o Rustler Vegetation Management Project Environmental Assessment Includes Riparian Reserves as discussed below, but only in acres not identified as nesting, roosting or foraging habitat, avoiding all high quality owl habitat (RA32), owl nest sites, and mapped owl cores. Includes Fuel Management Zones, but not in acres identified for RA32 or mapped owl cores. FMZs in suitable owl habitat and LSR will be modified to maintain habitat suitability for spotted owls. These FMZs will be constructed to a maximum of 300 wide (150 on each side of a centerline where allowable, commonly along roads or ridges). Limits silviculturally created openings to no greater than ¾ of an acre. Additionally, all commercial overstory removal treatments have been eliminated, though precommercial thinning, fuel management zone creation, and meadow restoration in those same stands are still included. The value of these remaining treatments is not diminished by the retention of the large overstory trees. Temporary road construction was reduced in this alternative with the goal of minimizing impacts to soil productivity, sensitive plant species, and riparian reserves. Reductions in temporary road miles were therefore sought. To identify which roads to drop, opportunities were sought to: o o o o Reduce logging system costs Keep roads that access most volume per mile of construction (if possible), and Consider future management needs of the stands Look for alternative routes to avoid impacts to RA 32 areas. As a result of this assessment, this alternative drops all temporary roads in riparian reserves. This alternative continues to access the stands on Rustler Peak since they are a high priority for treatment, and drops roads in the southeast corner of the planning area (C. mazama concerns, and in LSR), and ultimately reduces temporary road construction to 5.05 miles. As a result, Units 44, 50, and 124 were dropped from treatment consideration to minimize temporary road construction. Reducing this road density leaves units 24, 49, 126, and 128 with limited access. Access to these units will require careful planning of logging with adjacent units. These units will require long skidding distances using ground based systems to roads that access adjacent units. Mitigation measures will be applied where necessary to protect C. mazama and prevent spread of noxious weeds. This proposal would treat approximately 9,052 acres with a variety of silvicultural, riparian, and fuel treatments (a 13% reduction of the treated acres from those in the Proposed Action). The anticipated treatments are summarized in Table 2.7. A complete listing of treatments is included in Appendix 9. Final detailed prescriptions would be finalized prior to implementation. The proposed treatments include a combination of silvicultural methods within individual units to account for variations in stand conditions and to meet multiple objectives. The total of these treatments would yield an estimated 62.3 million board feet of commercial volume that would be offered in multiple timber sales over a period of 3-5 years. Other treatments would occur over an estimated 10-year period. Alternative 3 Protection of High Quality Spotted Owl Habitat II-23

24 Table 2.7: Alternative 3 Summary Rustler Vegetation Management Project Environmental Assessment Treatment Acres Density Management 5,310 Riparian density management 1,280 Pre-commercial thinning 1,584 Overstory Treatments 0 Sanitation 154 Meadow Enhancement 7 Fuel Management Zone (outside of other treated units) 717 Total Acres Treated 9,052 A combination of logging systems would be used to harvest the trees. Tractor, or ground-based systems, would be used on approximately 90 percent of the harvested area. Cable systems would be used on approximately 10 percent of the harvested area. A combination of fuels treatment methods would be used to treat activity-created slash. These methods include biomass utilization, underburning; handpiling and burning piles; pruning ladder fuels; lop and scatter; thinning; chipping; brushing; whole tree yarding; and yarding with tops attached. To meet the need to reduce natural fuels condition class, most of these same fuel treatments will also be applied in areas not treated silviculturally. To effectively lower the condition class, however, it may take more than one of these treatments. Riparian Reserves would be treated, if needed, to meet Aquatic Conservation Strategy Objectives. Overstocked Riparian Reserves would be thinned and/or underburned. Riparian Reserves that lack an overstory component would be planted. Riparian Reserves would be delineated and treated as described in the Northwest Forest Plan. Approximately 5.05 miles of temporary road are required for this alternative (a reduction of nearly 5 miles from the Proposed Action). Four to five miles of system roads are estimated to be in need of reconstruction. In addition, an estimated 9.9 miles of roads have been proposed for decommissioning. These roads are the same as in the Proposed Action and are listed in Table 2.4. Alternative 3 Protection of High Quality Spotted Owl Habitat II-24

25 Figure 2.3: Treatments Areas - Alternative 3 Alternative 3 Protection of High Quality Spotted Owl Habitat II-25