Comments on the HFQLGFRA DEIS and Biological Assessment
Regarding Analyses Related to Potential Effects on Spotted Owls

prepared by Steve Self
Wildlife Biologist, Sierra Pacific Indusries, and QLG member

A. General Comments:

1)   All of the analyses related to potential effects on spotted owls or their habitat do not include an evaluation of the positive and/or negative effects resulting from the various alternatives' ability (or inability) to increase or decrease in potential affects from wildfire. The CASPO Technical Report stated that the greatest concern regarding continued spotted owl viability in the Sierra Nevada range was the threat of catastrophic wildfire. Each alternative has a different approach and pace in regards to addressing this major threat to the spotted owl. Alternative 1 continues the current scenario which the CASPO Technical Team felt was not a viable approach. Alternatives 3-5 have no coherent strategy nor do they present an objective driven pace to achieve a desired condition within the 5 year pilot term. Only Alternative 2 has a specific strategy and pace that can be expected to have an in place strategy by the end of the pilot term.

B. Specific Comments

1)   On page 51, the Biological Assessment (B.A.) states that Alternative 2 would reduce connectivity between the northern spotted owl (NSO) and the California spotted owl (CSO) because DFPZ treatments would increase the risk of decreasing connectivity. However, this is not true. DFPZs are designed to have a clumped stand structure with an overall canopy closure near or above 40%. This condition is to be achieved by thinning from below while leaving all large trees (>30” dbh) and meeting the CASPO IGs in Select and Other strata for basal area retention. These objectives and IGs essentially force the DFPZs to meet the infamous 50-11-40 rule (50% of the area to be in stands with dominant and co-dominant trees at least 11 inches in dbh and total tree canopy closure to be at least 40%). Under full implementation, the DFPZs proposed for Alternative 2 will comprise approximately 15% of the landscape and will meet the 11-40 portion of the rule. The stand conditions resulting from this rule are designed to meet the needs of spotted owls for foraging and dispersal.

   In addition, the major concern regarding continued connectivity between the NSO and the CSO is the threat of catastrophic wildfire. In fact, the Fountain fire of 1992 created a major area of unsuitable habitat between these two sub-species. This fire of over 64,000 acres (burned in three days at an average rate of 14.8 acres per second) completely destroyed stands throughout it's perimeter. Within the perimeter, a number of “areas” had been recently treated to mimic the stand conditions of a DFPZ. The fire in these “areas” moved out of the canopy and burned across the floor until it reached the edge of the treated area, at which time the fire moved back into the canopy and continued its destructive march. If a system of DFPZs had been in place prior to this fire, firefighters would have had a number of much safer and more effective zones from which to attempt suppression activities.

2)   The B.A. on page 61 refers to some of the demographic areas that exist within the range of the CSO. However, the B.A. neglected to include the demographic study area that exists in the Transverse ranges south of the Sierra Nevada range. It is critical to include the data from this study are in any discussion regarding the predicted trend in the populations of the CSO. All demographic study areas predict that the studied populations are declining, including the study area in Sequoia/Kings Canyon National Park and the one in the Transverse ranges, neither of which has ever experienced a significant vegetation management program, other than fire suppression. While the predicted rates of decline appear to be significantly different from a stable population, none of the study areas (except for the on in the Transverse ranges) is any different from the others. In other words, there is no statistical difference in predicted population trend between study areas which have received significant vegetation management activities and study areas which have not experienced historic vegetation management activities.

   These similar population trend predictions between areas with very diverse management histories suggests one of two explanations:

1. The predicted rates of population change are not related to management history;

2. The demographic study design is flawed or biased in such a manner as to mask actual difference between the study areas.

3)   The predictions of the demographic study area in terms of owl population trends do not make sense given the empirical data. The CSO population was described by the CASPO Technical Team as being well distributed essentially throughout its range in spite of the history of vegetation management for between 50-150 years in most of its current range. The B.A. on page 64 states that surveys for spotted owls on private land as of 1992 had covered approximately 18% of the 1.45 million acres of private forest land in the Sierra Nevada range. These surveys have documented the presence of 135 territories within the surveyed area which totals approximately 260,000 acres. This equates to a crude density of on owl territory every 2000 acres of survey area on private lands. This density, which is high compared to the demographic study area figures, occurs on those lands with the longest management history.

   The history of management of the public timber lands of the Sierra Nevada range includes a peak of harvesting in the 1950's at about 1.6-1.9 billion board feet (bbf). Between about 1957 and 1979 the harvest rate was approximately 1.3-1.6 bbf, a reduction of approximately 20% form the peak. Harvest rates from 1980-1990 average about 1.1 bbf, a near 40% reduction from the peak period of the 1950's. Since 1990, the harvest rates have been steadily declining with an overall average of about 0.5 bbf harvested, a reduction of approximately 75% from the peak period. The predicted decline in the spotted owl population of between 4-8% per year has occurred essentially since 1990, when harvest rates were at their lowest since the 1950s. If the predicted decline in owl populations was related timber harvest activities, the rate of decline would likely have been higher in the 1960-1998 period, when harvest rates were much higher. However, assuming an average rate of owl population decline over the period of 1960-1989 (30 years) of 5%, there would have been a total decline of 78 percent of the owl population. If this were true, how could the remaining population of CSO be well distributed throughout their range? The reality of the current owl population suggests that there is little correlation between the predictions of the demographic study areas and the actual rate of change within the measured owl population.

4)   Both the B.A. and the DEIS use 50% total canopy closure as the lower limit for foraging habitat for spotted owls. However, this is too conservative as has been shown by a number of studies and past management decisions. The CASPO Technical Team report states that the intent of the IGs for “select” strata was to leave them in a condition after harvest “in or near a structural condition corresponding to suitable foraging habitat for spotted owls” (pg. 23). On page 24, the Technical Team states “Our next concern was with the final canopy closure in the stands, which should be >40% to be within the range of suitable owl foraging habitat.”. Clearly, the Technical Team felt that canopy closure greater than or equal to 40% were within the range of suitable foraging habitat for the CSO. Other studies and management plans have come to the same conclusion. The ISC Strategy for the northern spotted owl determined that stands with at least 40% canopy closure with dominant and co-dominant trees at least 11 inches in dbh were suitable for foraging and dispersal for the NSO. The US Fish and Wildlife Service and the California Department of Fish and Game use 40% canopy closure and a cutoff for suitable foraging habitat for spotted owls in there determinations of potential project level impacts to individual spotted owl territories.

   The DEIS uses data from the telemetry study on the Lassen N.F. and N.P. to state that suitable foraging habitat in the true fir forest type should be considered to include stands with >30 total canopy closure (DEIS at 3-82). This is significant because only Alternative 2 proposed management activities in the true fir as part of the strategy to reduce the risk of catastrophic wildfire. The other Alternatives focus their proposed activities outside the true fir. However, in the B.A. and the DEIS, this fact it ignored. It is assumed in both of the documents that foraging habitat requires canopy closures > 50%. This assumptions in false in two regards: 1) as stated above, foraging habitat in forest types other that true fir is considered “suitable” when canopy closure reaches or exceeds 40% and; 2) foraging habitat is considered suitable in the true fir when canopy closure reaches or exceeds 30%. The effects of Alternative 2 are disproportionately biased in a negative way when discussing potential changes to owl habitat. This must be corrected.

5)   The B.A. on pages 66-67 states that it assumes that nesting habitat (Select habitat) will be reduced below 40% canopy closure. This is not true. All nesting habitat is included in the Select habitat category. All Alternatives must follow the CASPO IGs which require a minimum of 40% canopy closure to be left in all Select strata after any vegetation management activities occur. This assumption results in an incorrect analysis of potential impacts to nesting and foraging habitat. At a worst case, nesting habitat that receives any vegetation management activities will remain as foraging habitat and will also be suitable for dispersal activities.

6)   The analysis of potential impacts from “fragmentation” of existing is incorrect. This analysis should state that all acres treated as part of a DFPZ in Alternative 2 will remain functional as foraging and dispersal habitat and, in some cases, as nesting habitat. In addition, the predicted effects for all alternatives essentially ignore the risk of fragmentation from catastrophic wildfire. The CASPO Technical Team considered the risk of catastrophic wildfire to be the greatest threat to the CSO. The reduction in this risk varies by alternative based on each alternatives ability to reduce the size of fires that “get away”, generally considered to be those fires greater than 100 acres in size. The approach of each alternative to addressing this major risk of fragmentation must be evaluated using their individual strategies (some alternatives do not appear to have a strategy) and implementation rates. Only by being in place can a fire containment strategy be effective.

7)   In both the B.A. and the DEIS, reference is made to a 1995 paper by J. Bart which discusses the relationships he found between the amount of “suitable habitat” within predicted home ranges of northern spotted owls and their measured turnover and reproductive rates. Bart stated that both turnover rates and reproductive rates increased with an increasing amounts of “suitable habitat” within individual NSO territories. He also stated that there appears to be a threshold such that if less that 30-50% of a home range was “suitable habitat”, the territory was at risk of being non-viable. Bart recommended that it should not be assumed that all home could be reduced to the minimum without adversely affecting the overall population. Bart's analysis was conducted in an area where “suitable habitat” was easily defined because of past management history. Within the area of his analysis, the major harvest prescription has been clear-cutting. However, this has not been the harvest history in the Sierra Nevada. This range has experienced a wide variety of management prescriptions, most of which leave stands with varying levels of “suitability” for spotted owl activities, including nesting, roosting, foraging and dispersal. This vide variety of stand conditions is used to varying degrees by the CSO, as is shown by the results of habitat use studies included in the CASPO Technical Report. This finding led the CASPO Technical Team to state “The R5 definition of suitable habitat does not appear to be appropriate across the range of the California spotted owl.” This same finding was made by the ISC Team in their final report. They stated “The full range of suitable habitats for spotted owls in California has net yet been determined, although much is known.” “Because many owls in California occupy areas where relatively little suitable habitat occurs as defined by current FS guidelines, the adequacy of these guidelines is open to question.”

   In his doctoral thesis, Dr. Alan Franklin conducted a study of habitat availability within varying distances of NSO activity centers in the Willow Creek Study Area. This study area is much similar in biological capability and historic management activities that the areas included in Bart's study. Using the R5 definition of “suitable habitat” Franklin's findings regarding the relationships between owl demographic parameters and the amount of suitable habitat were quite different than that found by Bart. Franklin found that while turnover rates appeared to increase with increasing amounts of “suitable habitat” reproductive rates did not follow the same pattern. In fact, reproductive rates were highest when there were intermediate amounts of suitable habitat within and owl territory and that higher amounts of suitable habitat actually reduced reproductive rates. Given the vast differences in terms of biological capability between the Sierra Nevada range and the areas included in Bart's study, his results should be viewed with a great deal of caution and limited application. Franklin's study would appear to be more useful, if used in the context of the habitat use data presented by the CASPO Technical Report.

8)   The B.A. and DEIS both assume that reducing a predicted CSO home range to less than 50% nesting or foraging habitat will have adverse effects on the viability of an individual territory's performance. This assumption ignores Bart's recommendations that it would be unwise to reduce all territories to a minimum threshold and that the threshold lies somewhere between 305-%, not at 50%. However, even with this questionable use of Bart's results, all alternatives considered are predicted to maintain between 60-72% of all known CSO territories with greater that 50% suitable habitat. In addition, this analysis excludes stand conditions documented in the CASPO Technical Report to be used by spotted owls for foraging and nesting. In fact, approximately 1 in CSO nests occurred in habitat conditions specifically excluded from this analysis (P4P, M2G, M3P, M4P, AND R3P) (Pg. 81 of CASPO Technical Report and pg. 62 of B.A.).

   Another way of looking at the potential affects of reducing home ranges below 50% suitable habitat includes using the home range data and SOHO and PAC strategies that are in place in all alternatives. PAC sizes were developed, in part, using a 50% adaptive kernel analysis of home range telemetry data for the CSO. This means that, on average, approximately 50% of an owls breeding season foraging locations are included in PACs and are protected from vegetation management activities in all alternatives, except as allowed by the CASPO IGs. Thus, on a percentage basis, 50% of the locations in a home range could be potentially affect by activities within the predicted home range outside of the PAC. If the home range were 3000 acres in size, that would leave 50% of the locations within 2700 acres of habitat. Assuming that these locations are randomly distributed throughout the “suitable habitat” within the home range, one can predict the % of foraging locations potentially lost through removal of habitat by the various alternatives. The amount of “suitable habitat” removed by the alternatives ranges from 7-16%. This would equate to an average loss of 3.5-8% of the total amount of foraging locations, assuming that alternate habitats are not available in adjacent areas or through under utilization of other existing habitat. In any case, none of the alternatives, even under the inappropriate “worst case analysis” of the B.A. and the DEIS, will cause a significant loss of habitat within any of the home ranges.

   This potential loss of habitat is to be further mitigated through site-specific analyses conducted prior to implementation of DFPZs and other treatments. These site specific analysis will result in the movement of treatment units to adjacent stands that will have less affect on the existing habitat than predicted by the B.A. and DEIS. These mitigations will further remove short-term loss of owl habitat as an important distinction between alternatives.

9)   Alternative 2 suffers from a bias inherent in the assumptions about affects on habitat suitability that may be cause by implementing DFPZ prescriptions. The B.A. and DEIS assume that development of DFPZs will reduce canopy closures to below 40% and that this resulting condition will not be suitable for foraging by CSO. This is not true. Many stands to be treated within DFPZs will not be reduced below 40% CC. All stands within furbearer networks must be maintained at a minimum of 60% canopy closure. All Select strata stands must be maintained at a minimum of 40% canopy closure.

   In addition, only Alternative 2 proposes DFPZ treatments in the true fir. True fir is considered suitable foraging habitat when canopy closure is at least 30% (DEIS pg. 3-82). DFPZs will not reduce canopy closure below 30%. All DFPZ treated acres within the true fir will remain as suitable foraging habitat. DFPZ treatments in all other alternatives are focus outside of the true fir zone. The error inherent in this assumption error causes Alternative 2 to be evaluated incorrectly.


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