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Plan Maintenance Documentation


To Change the Implementation Schedule for Survey and Manage and Protection Buffer Species

Bureau of Land Management Districts and Field Offices in Oregon and California within the range of the northern spotted owl

The USDI Bureau of Land Management (BLM) and the USDA Forest Service (hereinafter referred to as the Agencies) have jointly analyzed a proposal to delay for one year the Survey and Manage requirement for 32 species. The Agencies propose to change the survey schedule for 32 Survey and Manage Component 2 species and Protection Buffer species for a period of one year based on the technical infeasibility of surveys and the lack of substantially increased risk to the species from changing the schedule. This proposal and alternatives have been analyzed in an environmental assessment (EA), "Environmental Assessment to Change the Implementation Schedule for Survey and Manage and Protection Buffer Species."

The EA was made available for public review and comment in October 1998. Public comments did not indicate that any changes to the EA were warranted, but the EA has been appended with a summary of public comments and the Agencies' responses. These appendices are attached to this document. Twelve substantive issues were raised during the development of the EA. Some of these comments provided additional information concerning the species. Many comments questioned the sufficiency of the EA process to change the survey schedule originally described in the Northwest Forest Plan. Several commentors questioned the Agencies' assessment of risk to species and a few suggested an additional alternative that would postpone surveys for a longer period of time, or only survey for the 12 species considered to be at "high risk" from a further delay. These comments and responses are found in Appendix G.

Other related environmental documents which were taken into account include: the Resource Management Plans (RMPs) for the BLM Districts and Field Offices listed below, and their supporting National Environmental Policy Act (NEPA) documents; the Record of Decision (ROD) for Amendments to Forest Service and Bureau of Land Management Planning Documents Within the Range of the Northern Spotted Owl, also known as the Northwest Forest Plan, and the supporting Final Supplemental Environmental Impact Statement on Management of Habitat for Late-Successional and Old-Growth Forest Related Species Within the Range of the Northern Spotted Owl (FSEIS). The existing RMPs incorporated the Northwest Forest Plan ROD into their decisions, and the environmental impact statements supporting the RMPs incorporated by reference the analysis in the FSEIS.

In addition to the schedule change proposed in this EA, the Agencies will consider in the future other changes to the Survey and Manage and Protection Buffer provisions (EA, pp. 4, 8), which will be analyzed under a separate environmental document. On November 25, 1998, a Notice of Intent to prepare an EIS for these changes was filed in the Federal Register. The proposed action in the planned EIS would alter Survey and Manage provisions based on new information; would merge the Protection Buffer species into the Survey and Manage provisions; and would make some changes to species' Survey and Manage categorization (63 Fed. Reg. 65167-65158).

BLM will maintain the RMPs listed below by implementing Alternative 2 described in the Environmental Assessment (EA) to Change the Implementation Schedule for Survey and Manage and Protection Buffer Species. Based on the analysis in the EA, the Finding of No Significant Impact, and comments received from the public, other agencies and cooperators, the Agencies will postpone the survey schedule for 32 of the FY 1999 Component 2 Survey and Manage Species for a period of one year. These species are listed in Appendix B of the EA. Surveys are considered to be infeasible at this time for these species. The survey schedule for these species will be changed from FY 1999 to FY 2000. Surveys for the remaining 48 Component 2 species will be unaffected by this plan maintenance. Selection of this alternative will not cause a significant risk to species.

BLM will implement this plan maintenance for existing RMPs for the Salem, Eugene, Coos Bay, Roseburg, and Medford Districts, and the Klamath Falls Field Office of the Lakeview District in Oregon, as well as the Redding Field Office, Arcata Field Office, King Range National Conservation Area, and Ukiah Field Office within the grouping of independent Northern California Field Offices known as NORCAL. This change in survey schedule will refine the previously approved decisions in these plans based on a minor change in data (43 CFR 1610.5-4). Such a change in survey schedule is provided for in the Northwest Forest Plan ROD and the existing RMPs. The change in survey schedule will not result in a change in the scope of resource uses or a change in the terms, conditions, and decisions of the existing RMPs, and therefore a plan amendment is not required (43 CFR 1610.5-5). As explained below, the purpose of this action is to maintain the scope of resource uses identified in the existing RMPs.

The scope of the proposed action and the range of the alternatives were focused on achieving the defined purpose of maintaining the balance sought in the Northwest Forest Plan between its two primary goals: providing sustainable timber harvests, and maintaining and restoring healthy old-growth ecosystems to support stable populations of fish, wildlife, and plants (ROD, pp. 2, 26, 51, 61). The scope was limited because the proposed action only addressed the survey schedule and did not alter the management of known sites for Survey and Manage and Protection Buffer species. The scope was further limited to a period of one year for which the survey schedule would be changed.

Besides the selected alternative, a "no action" alternative, Alternative 1 (EA, p. 11), was analyzed in detail. Under this alternative, the Agencies would continue to implement the Survey and Manage and Protection Buffer species Standards and Guidelines according to the schedule defined by the Northwest Forest Plan ROD. Under the Standards and Guidelines for Alternative 1, surveys for 80 Component 2 species "must be completed prior to ground disturbing activities that will be implemented in F.Y. 1999 or later." (ROD, p. C-5).

Alternatives which would change the schedule from FY 1999 to FY 2000 for all 80 Component 2 species were not analyzed in detail because these alternatives did not meet the need for species protection under the Northwest Forest Plan, and the purpose of and need for this action, established in the EA, which specifically regards the unanticipated infeasibility of surveys (EA, p. 2).

The purpose of the proposed action is to achieve the two primary goals of the Northwest Forest Plan: providing sustainable timber harvests, and maintaining and restoring healthy old-growth ecosystems and habitat for populations of native fish, wildlife, and plants (ROD, pp. 2, 26, 61). The need for the proposed action is demonstrated by new information that surveys for some species are technically infeasible, and that the inability to complete surveys would postpone or preclude a major portion of planned management action, which was not anticipated in the Northwest Forest Plan. The need for the proposed action is to allow continuation of planned management actions, such as timber harvest and prescribed burning, in the next year without substantially increasing risks to any Survey and Manage and Protection Buffer species.

Agency officials considered the ability of the alternatives to meet the stated purpose and need of the action; to comply with applicable laws, regulations, and policies; and to respond to issues and public comments about the proposed action. Three principal issues were identified in this assessment: risk to species, feasibility of surveys, and risk to other resources.

The alternatives were analyzed in the EA based on the most current scientific data available at the time the EA was prepared. New information related to species and survey requirements was obtained from field observations following four years of implementation of the Northwest Forest Plan, consultation with agency experts for the taxonomic groups, and materials obtained from herbaria and museums. The effects to other resource programs were analyzed on the basis of field unit estimates of program outputs.

Alternative 1 ("no action") was not selected because the best available information indicates that it is not feasible to survey for these species, and this alternative would not achieve the two primary goals of the Northwest Forest Plan in that it would not meet the need to provide sustainable forest products. Alternative 1 would not permit most planned ground-disturbing activities to proceed for FY 1999, including beneficial activities such as prescribed burning or watershed restoration, and would provide little corresponding benefit to the species that the standards and guidelines were designed to protect (EA, pp. 12 -14). The Agencies considered the "continuation of the programs authorized and anticipated in their respective land management plans" (EA, p. 2) which defines the need for this action.

Alternative 2 was selected because it better meets the purpose of and need for the action: it provides for the continuation of planned resource management activities for the remainder of FY 1999 without making significant changes to the Survey and Manage Component 2 program. Selection of this alternative affects only the 32 species in question and would have no effect on the 48 other Component 2 and Protection Buffer species. Changing the schedule for 32 species could allow loss of some individuals and localized populations that would otherwise be protected (EA, p. 14). The proposed schedule change is of limited duration and would affect, at most, 0.16% of the federal land in the Northwest Forest Plan area (EA, p. 15). Therefore the risk to species was found to be insignificant (FONSI, pp. 2-3). This alternative would involve little, if any, risk to other resources (EA, pp. 16-17). This alternative would allow the continuation of most timber harvest, prescribed burning, and other actions necessary to meet multiple-use objectives for public lands and achieve the dual goals of the Northwest Forest Plan. These objectives could not be met under Alternative 1, which would not permit a major portion of the planned management actions to continue.

Surveys for the 32 species will begin during the year if technical feasibility problems can be solved. (EA, p. 1).If it is determined by species experts that survey feasibility issues have been resolved throughout the suspected range of any of the 32 species, a letter of direction to field units will be issued from the Regional Foresters and BLM State Directors to require surveys. The letter of direction will apply to ground-disturbing activities to be implemented during FY 1999 and later. Surveys for the species listed in the letter of direction would be required for one or more of the 32 species covered by this decision for which surveys were previously considered to be infeasible, provided that taxonomic descriptions and approved protocols have been developed. The requirement to survey for these species would not be retroactive to decisions signed prior to the date of the letter of direction. Effective dates to initiate surveys will be determined with consideration for adequate training of all field units within the suspected range of the species. Current versions of the approved survey protocols and field guides must be in place or attached to the letter of direction. Pursuant to this decision, and while not required, surveys will be carried out in localities where the necessary expertise to perform the surveys exists.

The monitoring strategy for this plan maintenance is to tier to the existing monitoring plans and strategy in the Northwest Forest Plan and individual BLM Districts, as detailed in the EA (p. 17). No specific additional monitoring is identified in this plan maintenance.

This plan maintenance is guided by the provisions of the Northwest Forest Plan, in which agencies "may propose changes . . . [which] could include changing the schedule, moving a species from one survey strategy to another, or dropping this mitigation requirement for any species whose status is determined to be more secure than originally projected" (ROD, p. 37) as experience is acquired with the Survey and Manage requirements. The Northwest Forest Plan ROD was incorporated into the decisions on RMPs within the range of the northern spotted owl.

The implementation of this plan maintenance is provided for by BLM planning regulations (43 CFR 1610.5-4). The Forest Service will implement this change in survey schedule as a non-significant plan amendment, in accordance with the National Forest Management Act. The two different implementation mechanisms result from the differences in the Agencies' planning regulations regarding minor changes to existing plans.

On September 25, 1998, a scoping letter was sent out through each National Forest and Bureau of Land Management District within the area that would be affected by this change in survey schedule. These Forests and Districts mailed the scoping letter to their lists encompassing over 1,200 interested individuals, organizations, Federal agencies, and state, local, and Tribal governments. This letter notified the public that an EA was being prepared, the purpose of and need for the action, the proposed action, and an invitation to participate and make comment during the formal comment period.

The EA was issued for a 30-day formal comment period beginning October 7, 1998. A total of 72 individuals and representatives of organizations, agencies and governments commented during this period. Their comments and Agencies' responses were categorized in 12 substantive issues. The summary of comments and responses is attached as Appendix G of the EA. A list of the individuals and organizations submitting comments on the EA is found in Appendix H.

A Finding of No Significant Impact (FONSI) has been made and is attached to this document. The FONSI is based on the analysis in the public comments, and information found in related environmental documents as noted in the FONSI. In the FONSI, we find that the change in implementation schedule for 32 Survey and Manage and Protection Buffer species for a period of one year will not cause a significant risk to the species. Therefore, in accordance with 40 CFR 1501.4(e), an Environmental Impact Statement (EIS) will not be prepared. Findings required by other laws, regulations, or policies are also detailed in the FONSI.

There are no opportunities for administrative review of this plan maintenance. The purpose and expected result of the change in survey schedule is to maintain the basic decisions made in the existing RMPs as to the scope of resource uses. The terms of the Survey and Manage provisions of the existing RMPs included making changes in the schedule as experience was acquired. A change in the schedule was thus part of the existing decisions. A determination of exactly what the change of schedule should be is therefore simply a refinement to comport with actual experience and data, and is not a change in the RMP decision itself. Neither the protest provisions of 43 CFR 1610 nor the appeal provisions of 43 CFR Part 4 apply to plan maintenance.

Notice of this plan maintenance will be published in the following newspapers: The Sacramento Bee and The Oregonian.

Records documenting the preparation and review of this schedule change are available at:

Survey and Manage Project
c/o Regional Ecosystem Office
PO Box 3623
Portland, OR 97208-3623

For further information, please contact: Cynthia Henchell, EA Team Leader, c/o Regional Ecosystem Office, PO Box 3623, Portland, OR 97208-3623, Ph: (503) 808-2493.

By signing this Plan Maintenance Documentation, we exercise our respective authorities over only those portions relevant to our authority.


/s/ Elaine Y. Zielinski
State Director, Oregon & Washington
USDI Bureau of Land Management

Date:  February 26, 1999

/s/ Ed Hastey
State Director, California
USDI, Bureau of Land Management

Date:  February 26, 1999

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Last Updated:  January 04, 2005 11:56 PM