DECISION MEMO Authorization of Botanical Special Forest Products - PDF by bsr14041

VIEWS: 17 PAGES: 27

									                                      DECISION MEMO

                Authorization of Botanical Special Forest Products Program

                                     USDA Forest Service
                                Gifford Pinchot National Forest
        Clark, Cowlitz, Klickitat, Lewis, Skamania, and Yakima Counties, Washington



PURPOSE AND NEED
Public demand for special forest products has increased in the last decade. Recognizing this,
new regulatory direction has been drafted which facilitates sustainable harvest of special forest
products, including forest botanical products. The special forest products program on the
Gifford Pinchot National Forest includes the commercial and non-commercial harvest of a wide
variety of plants and plant materials.

The purpose of this decision is to authorize and regulate the commercial harvest and sale of
forest botanical products, as well as regulate the limited free use of these products. Forest
botanical products are a subset of the Forest’s special forest products program and include such
products as salal, beargrass, huckleberries, and mushrooms. This action strives to meet the
intent and direction for determining product sustainability as defined and directed in Draft 36
CFR 223 – Sale and Disposal of National Forest System Timber; Special Forest Products and
Forest Botanical Products. This decision does not authorize the harvest of Christmas trees,
firewood, fence material, mine props, posts and poles, shingle and shake bolts, or rails, as those
products are covered under separate decision.

There is a need to ensure that the regulatory direction set forth in Draft 36 CFR 223 is followed
by providing the public the opportunity to harvest botanical products while placing limits on
amounts, location, or method of collection to ensure sustainable harvest and protect resources.
By regulating commercial and personal-use harvest activity, and monitoring the effects of
harvest on a product’s long-term sustainability, the Forest can prevent resource loss and
environmental damage due to illegal or over-harvest activity; ensure consistent administration
across the Forest, and protect other resources from adverse effects incurred from special forest
products collection.

There is also a need to address the efficiencies of the program management and address issues
related to the implementation of the program such as tribal treaty rights and traditional tribal
uses, illegal harvesting, non-compliance of permit direction and provisions, conflict amongst
users, competition for limited resources, and social impacts such as user conflicts between a
variety of ethnic cultures involved in harvesting and the forest harvester work environment.

Traditional Tribal Gathering
Public harvest of forest botanical products must be coordinated with traditional tribal gathering.
The Gifford Pinchot National Forest Land and Resource Management Plan directs that
traditional food and plant material gathering sites used by Native Americans may be managed
for continued production of native roots, berries, nuts, herbs, beargrass, and other plant


                                                                                                   1
materials typically gathered from the land (Forest Plan, IV-50). In recognition of the religious
and cultural importance of the Sawtooth Berry Fields to the Yakama Nation, the Forest Service
honors the terms of the “1932 Handshake Agreement” between Chief Yallup and Gifford
Pinchot Forest Supervisor Bruckert granting Native Americans exclusive berrypicking rights to
a 700-acre portion of the Sawtooth Berryfields east of Forest Road 2400 (Forest Plan, IV-21,
IV-50 #15; MOU, 2)). A Memorandum or Understanding for Coordinated Yakama Nation and
USDA Forest Service Management of Treaty Resources and Anadromous Fish Habitat on the
Gifford Pinchot National Forest was signed on February 6, 1997 (and amended and reaffirmed
on February 15, 2007) to provide a framework for cooperation to manage Treaty resources.

In addition, the Medicine Creek Treaty of 1854 (for the Nisqually, Puyallup, Squaxin Island,
and Steilacoom Indian Tribes) and the Yakima Treaty of 1855 for the Yakama Indian Nation
include the privilege of hunting and gathering roots and berries on lands under US
administration (Forest Plan, IV-50).

Permit Non-Compliance and Illegal Harvesting
The Forest has looked at various ways to enforce permit compliance with commercial
harvesters; yet, there is still evidence that illegal harvest of major products (such as beargrass
and huckleberry) is occurring.

The personal use harvest of huckleberries does not require a free use/personal use permit, and it
is unknown if recreational pickers are receiving the rules and regulations of harvest or the map
showing areas off-limit to harvest.

Another concern is the use of illegal harvesting techniques which can permanently damage
products especially huckleberry plants and mushrooms. Rakes or other implements have been
used by mushroom harvesters to remove forest duff to find partly buried mushrooms, which
have been demonstrated to reduce mushroom production. Huckleberries have also been
removed through mechanical means (rakes or other brush disturbing devices) which can remove
leaves and damage plants.

Conflict Amongst Users and Social Impacts to Users
The Forest has received complaints from personal use harvesters or other Forest users that there
has been a steady increase in trash and sanitation issues, as a result of the commercial harvest of
Forest products. There have been reports of garbage and sanitation concerns in areas where
large groups tend to congregate for harvesting or camping. A large number of harvesters are
migrant workers and language and cultural barriers exist when communicating leave-no-trace
principles. In addition, other Forest users have complained to the Forest that with the increase
in the commercial harvest of products, their historic experience has changed and they feel
intimidated or even unsafe in areas of the Forest where commercial harvest occurs.

Additionally, with the increase in commercial demand for huckleberries, commercial pickers
are harvesting huckleberries before they are completely ripe. This has led to conflicts between
commercial pickers, and Native Americans and recreational pickers, who complain that the
most accessible berries have already been picked before they arrive to harvest the ripe berries.
In recognition of this growing problem, the Gifford Pinchot National Forest instituted a new



                                                                                                     2
policy in 2005, to delay the commercial huckleberry season until after the Yakama Nation has
held their first foods ceremonies (there was previously no date restriction).

Unfortunately, buyers located outside the Forest boundaries have not restricted their buying to
meet with these timelines, and illegal commercial harvest was apparently common during the
2006-2007 season. Lack of enforcement has allowed illegal pickers to carry their harvest to
buyers located outside of Forest Service lands without impediment.

The Forest has received a few comments from the public and Indian tribes that as commercial
harvest increases for mushrooms and huckleberries, recreational harvesters are feeling
displaced and are voicing concern that their experience harvesting these products has changed.
The Forest acknowledges the concern that historic use may have changed, but at this point there
is only anecdotal evidence that displacement is occurring. With the proposed changes to the
program, the Forest intends to monitor user conflicts with the goal that proposed changes will
enhance the recreational experience.


DECISION
To meet the purpose and need, the Gifford Pinchot National Forest proposes to continue to
authorize and regulate the sustainable harvest of the following botanical special forest products
found on the Forest: salal, edible mushrooms, huckleberries, beargrass, burls, cones, ferns and
transplants. Several less-frequently requested products such as bark, bryophytes (including
mosses and lichens), bulbs, forbs, grasses, nuts, pine straw, roots, sedges seeds, shrubs, tree sap
and wildflowers will only be authorized in minor amounts if approved by a Forest Service
botanist and line officer. Any harvest above minor amounts will require future analysis prior to
approval. Harvest would be permitted for both personal and commercial uses, depending on the
species.

Indian tribes with reserved treaty rights or other adjudicated rights may harvest special forest
products in accordance with the terms of the treaty rights and are not subject to the application
and permitting requirements included in this decision. The Medicine Creek Treaty of 1854 (for
the Nisqually, Puyallup, Squaxin Island, and Steilacoom Indian Tribes) and the Yakima Treaty
of 1855 for the Yakama Indian Nation include the privilege1 of hunting and gathering roots and
berries on lands under U.S. administration. In addition, the “1932 Handshake Agreement”
between Chief Yallup and Gifford Pinchot Forest Supervisor Bruckert granting Native
Americans exclusive berrypicking rights to a 700-acre portion of the Sawtooth Berryfields east
of Forest Road 2400 would not change under this proposal.

The action areas for the special forest product harvesting program are within National Forest
System lands located throughout the Gifford Pinchot National Forest. Special forest products
would be made available only within those land allocations where harvesting is not otherwise
limited or prohibited, where consistent with the restrictions and conditions set forth in this
decision and subsequently contained in each individual product’s permit terms and conditions,

1
  The courts have interpreted this use of “privilege” as an existing right that the tribe retained after ceding land to
the U.S. It was not a special privilege granted by the U.S. to the Tribe.



                                                                                                                          3
and as designated on the Gifford Pinchot National Forest’s special forest products map as open
to harvest. The sale of all products would be consistent with the rules and regulations of Draft
36 CFR 223 – Sale and Disposal of National Forest System Timber; Special Forest Products
and Forest Botanical Products; these activities would generally be controlled by permit or
contract.

Collection and harvest techniques vary among the special forest products. Collection and
harvest of most botanical forest products occurs mainly throughout the snow free portion of the
year and adjacent to roads. Products such as beargrass and edible mushrooms are harvested
further from road systems if the product is abundant. Each product has a season when it is
generally available or most often sought after. Gathering operations would typically be
accomplished by one person alone or several permitted people working together. In many cases,
collection of an item involves gathering only a portion of a plant, such as leaves, stems or fruits.

The Forest has made a focused effort in recent years to improve harvester education, permit
compliance and conflicts between harvesters. Further improvements will be put into place
starting in 2009 and an adaptive management plan will guide management to ensure that
changes are effective at administering the program.

Recent Improvements
   • In the summer of 2005, a later date of August 15th was set as the first day each season
      that commercial huckleberry permits would be made available on the Gifford Pinchot
      National Forest. Postponing the commercial season until later in the year was an
      agreement with the Yakama Nation to avoid conflicts between commercial harvest and
      traditional use.
   •   On June 12, 2008, changes were made to the Washington State law that regulates the
       sale and purchase of wild huckleberries. The law now requires that anyone selling
       huckleberries must have a properly filled out permit and that buyers of huckleberries
       must record the information from each seller. Permit information must include the
       buyers’ and sellers’ contact information, amount harvested, and location of harvesting.
       The total number of commercial huckleberry permits sold on the Forest increased by
       66% in 2008 and the Forest believes that this is due to an increase in permit compliance
       rather than an overall increase in individuals harvesting.
   •   To increase law enforcement presence in the Sawtooth Huckleberry Fields, a Forest
       Service law enforcement officer was dedicated one day each week during the 2008
       huckleberry season to patrol the Sawtooth Huckleberry Fields and monitor permit
       compliance. Forest Service Protection Officers’ presence in the woods during the
       commercial huckleberry season was also increased during the 2008 season to check for
       permits, and to monitor camping and picking areas.
   •   For future, long-term monitoring efforts, a formal process for documenting contact
       information and collection data among harvesters was created and used and large
       camping and picking areas were mapped during the summer of 2008.
   •   During the summer of 2008 to improve harvester education, a universal sign was
       developed and posted at areas closed to commercial picking. In addition the Forest
       installed over 20 posts and sign boards around areas closed to commercial picking and

                                                                                                   4
       signed areas closed to commercial picking. Specifically, the Handshake Agreement area
       in the Sawtooth Berry Fields on the Mt. Adams Ranger District was posted with more
       visible signs.
   •   The Mt. Adams Ranger District hired bilingual personnel at the front desk to help
       translate permit terms and conditions and answer questions from Spanish-speaking
       botanical special forest products harvesters.
   •   Litter bags have been handed out with each commercial permit on the Cowlitz Valley
       Ranger District. Because of its presumed success at reducing garbage left in the Forest,
       this same practice was started across the Forest during the 2008 season. More than
       1,000 litter bags were given out during the 2008 season. In addition, more of an effort
       was made by Forest Service personnel to pick up garbage at larger campsites mid-
       season in order to discourage the practice of littering. Other Forest users noticed the
       improvement and efforts will continue in the coming years.
   •   Huckleberry restoration/enhancement projects have been planned across the Forest
       which should improve huckleberry habitat. Approximately 50 acres were treated as part
       of the Mowich Huckleberry Restoration project in the summer of 2008. A larger,
       landscape-level effort is in the planning stages to reduce the canopy and improve
       huckleberry habitat on 1,200 acres within the Sawtooth Berry Fields. Implementation is
       expected in 2010.


Due in a large part to the recent changes that were made to the program, every commercial
harvester contacted by law enforcement or other Forest Service personnel during the summer of
2008 had a commercial permit on hand and was found to be in compliance with that permit.
Additional actions are proposed and will be incorporated into the program starting as early as
2009. Although not NEPA decisions, these actions and proposals were considered in the NEPA
analysis to measure the effects of the program on sustainability of products and other resources.

Additional Improvements Expected During the 2009/2010 Season
Tribal Treaty Rights:
    • The start of the commercial huckleberry season will continue to be timed to avoid
        conflicts with traditional tribal gathering.
    • The Forest Service will work with the Yakama Nation to develop a joint public service
        patrol of the Sawtooth Berry fields on the Mt. Adams Ranger District during traditional
        use times.
    • The Forest will have regular communication (at least once annually) with the Yakama
        Nation regarding the special forest products program, especially the commercial
        huckleberry program, using the framework from the Memorandum or Understanding
        for Coordinated Yakama Nation and USDA Forest Service Management of Treaty
        Resources and Anadromous Fish Habitat on the Gifford Pinchot National Forest.

Harvester Education:
   • The special forest products map (both forestwide and district-specific maps) will be
       updated to better reflect no harvest areas and will be attached to each permit.



                                                                                                  5
   •   The Forest will continue to emphasize the importance of hiring bilingual front desk staff
       to communicate rules and regulations to harvesters.
   •   Permit terms and conditions and pack-in and pack-out principles will be translated into
       common permittee languages and handed out to harvesters at offices across the Forest.
   •   A community outreach strategy is in the process of being developed to implement better
       communication with the harvesting communities. The Forest has established key
       contacts in ethnic harvester communities and is currently looking into the best ways to
       establish regular communication with current and potential harvesters. (This will
       include a strategy to communicate proper harvest methods.)

Permit Compliance:
   • Additional law enforcement would be funded through the retained receipts of the
       program.
          o Full-time forest protection officers dedicated solely to permit compliance will be
              hired on the Forest in fiscal year 2009. The focus will be on communication with
              harvesters and presence at the bigger camps with an emphasis on education and
              gaining voluntary compliance.
          o The Forest has allocated funding in fiscal year 2009 for overtime salary for
              Forest Service law enforcement personnel to patrol the Forest for special forest
              product permit compliance.
          o The Forest is looking into shared law enforcement opportunities with Skamania
              County and the Washington Department of Fish and Wildlife law enforcement
              departments that would include cooperative cost-sharing.

Resource Protection:
   • Commercial harvesters will be required to contain and remove their waste from the
      National Forest. This language will be included in each commercial special use permit.
   • The commercial huckleberry permit length will be limited to match other commercial
      products.

Mitigations (some already included in permit conditions):
1. Permit must be in permittee’s possession while harvesting and transporting products. Copies
   are not allowed.
2. Harvesting is prohibited in Wilderness Areas, Legislative National Volcanic Monument,
   Botanical Areas, Research Natural Areas, Campgrounds, and Administrative Sites, or as
   otherwise identified on the special forest products map.
3. The “Handshake Agreement” area within the Sawtooth Berry Fields is closed both to
   commercial and personal use huckleberry harvest with the exception of tribal members.
4. Commercial huckleberry permits will not be issued until a date agreed upon each year by
   the Gifford Pinchot National Forest and the Yakama Nation.
5. Motorized vehicles are not allowed off existing roads that are open to the public. Harvested
   special forest products must be hand-carried to the road from the harvest site.
6. Motorized vehicles are prohibited on roads that are closed by a gate, earth berm, or other
   closure device, unless allowed by contract.
7. Commercial permittees are not allowed to camp in areas closed to harvest.
8. The permittee is required to remove all trash and litter resulting from permittee’s activities.


                                                                                                6
9. Permittee shall complete the “product quantity removal record” on the permit in ink prior to
    transporting products.
10. Rakes or other ground disturbing devices are prohibited for mushroom harvest.
11. Rakes, mechanical devices, or other bush damaging methods are prohibited for huckleberry
    harvest.
12. During hunting season permittees are encouraged to wear “HIGH VISIBILITY” clothing.
13. All holes are to be filled in for transplants. Transplants will be removed at the specified
    spacing.
14. Collection of pendulous Usnea spp (a lichen) is not permitted on the Gifford Pinchot
    National Forest, except for scientific study conservation purposes, or by tribal members as a
    cultural resource.
15. Collection of whitebark pine cones is not permitted on the Gifford Pinchot National Forest,
    except for scientific study or conservation purposes.
16. Collection of endangered, threatened, sensitive or other rare and uncommon species is
    prohibited except for approved scientific or conservation purposes. Permitting for such
    purposes will be done in consultation with a botanist or botanical specialist
17. Requests for collection of the following products in minor amounts will be authorized on a
    case-by-case basis in consultation with appropriate forest service resource specialists: bark,
    bryophytes, lichens, bulbs and roots, burls, conks, forbs, grasses, nuts, sedges, seeds,
    shrubs, tree sap, wildflowers.
18. In order to minimize the effects of ground disturbance associated with transplants, no
    individual can be taken within 12 feet of another.
19. It is recommended that transplant harvest be avoided in areas with invasive species located
    nearby.
20. Avoid use of ground disturbing methods when harvesting pine straw. This will help prevent
    disturbance of fungal mycelial networks present in the soil.


SUSTAINABILITY
Sustainability analyses were conducted to evaluate the ecological and harvest sustainability of
the botanical products harvested on the Forest and can be found in the project file. The harvest
of most of the products is at such low levels or infrequent enough that it was determined that
harvest at current levels is sustainable (See Appendix A). For the four major products,
including: salal, fungi (including mushrooms), huckleberries, and beargrass, with much larger
harvest levels, a more extensive analysis was conducted which determined that current harvest
levels are sustainable. A summary of the assessments are included below. The complete
assessments are included in the project file for this decision.

Vaccinium membranaceum (big huckleberry) is the most commonly harvested huckleberry of
the Pacific Northwest and Northern Rockies (Minore 1975; Minore et al. 1979 as cited in
FEIS). Big huckleberry is a rhizomatous, deciduous shrub which grows in the understory of
montane and subalpine forests of the Gifford Pinchot National Forest. Big huckleberry is
harvested for commercial, personal and tribal use. Productive habitat for this species is
shrinking across the Forest, even as commercial demand increases. Management of big
huckleberry as a resource presents significant challenges both ecologically (i.e. maintenance
and/or creation of habitat), socially (i.e. balancing the needs of different user groups), and
administratively (i.e. enforcement of harvest policy). Since the early 1990s, forest thinning has


                                                                                                 7
become the most common silvicultural treatment on the Gifford Pinchot National Forest.
Currently, disturbances that create early seral conditions favorable for huckleberry release,
growth and berry production are rare.

Although the persistence of the species on the landscape does not appear to be at risk as a result
of harvest, it is clear that management of big huckleberry for sustained berry yield will require a
proactive, long-term approach (Ruchty, 2007).

Salal (Gaultheria shallon) is a forest understory shrub that is used extensively as greenery in
floral arrangements. No data was found on the historic distribution and abundance of salal on
the Forest. It is likely that its abundance has varied widely over time, depending on the amount
and intensity of natural disturbances such as fire, windthrow and volcanic activity. At the
present time, management activities such as pre-commercial and commercial thinning are
helping to maintain and stimulate salal growth in many young and mid-seral stands by opening
the forest canopy and allowing additional light to reach understory shrubs and forbs. In older
forest stands where management is no longer warranted or an option, salal is gradually
decreasing, as forest canopies close and multi-layered conditions result in less light reaching the
forest floor. The largest data gap related to salal harvest sustainability is the localized effect of
intensive, annual harvest on the production of the salal product, which is the undamaged,
annual stem growth that is required by the floral industry.

Overall, there appears to be little concern that salal as a species will be decreasing in abundance
over the short-term (10 years), nor is this likely in the long-term (50-100 years). Considering
the autecology, distribution, abundance and current harvest levels and trends of salal, ecological
concerns about the sustainability of this species are relatively low, except perhaps in some
heavily utilized locations on the Forest. The high percentage of overall Forest salal harvest is
concentrated on the Cowlitz Valley Ranger District and occurs in a relatively small area within
a few miles of the town of Packwood, and along a handful other forest roads in the Johnson
Creek and Smith Creek drainages due to easily accessible areas. Monitoring is necessary in
these areas to determine if access and abundance may be having a long-term, adverse effect on
the availability and sustainability of the salal product (i.e. annual stem growth)(Kogut, 2007).

Several species of mushrooms are harvested on the Gifford Pinchot National Forest both for
personal use and commercial sale. Mushroom harvests vary widely from year to year
depending on weather and other conditions, complicating the task of detecting trends in their
abundance. In general, careful harvest of mushrooms has been shown not to be detrimental to
future production. The principal species commercially harvested on the forest, matsutake and
chanterelles, are mycorrhizal associates of forest trees. Therefore timber harvest affects
mushroom harvest, in proportion to its intensity. Data on mushroom harvests is being
collected, but because the mushroom fruiting is so variable, more years of data collection will
have to be accomplished before long-term trends can be identified in the Pacific Northwest.
Monitoring is needed to assess quantities and locations of mushroom harvest to detect other
trends, and to adapt management practices to sustain the resource (Swartz, 2007).

Beargrass is a rhizomatous, understory forest shrub that is widespread on the Gifford Pinchot
National Forest. It is used extensively for greenery in floral displays. Based on the abundance,
distribution, and autecology of beargrass, and current harvest levels and permit distribution,


                                                                                                   8
there is an overall low concern about the harvest sustainability of the beargrass product (annual
stem and leaf growth). Monitoring is recommended to determine if there are sustainability
concerns at particular harvest sites. Monitoring is also needed to assess and quantify the
ancillary resource impacts of beargrass harvest, such as garbage dumping, wildlife poaching,
creation of illegal wood tracks, and road closure violations (Chandler, 2007).


SUSTAINABLE HARVEST LEVELS
Draft regulations for the Sale and Disposal of National Forest System Timber; Special Forest
Products and Forest Botanical Products (Draft 36 CFR, part 223) require the Forest Service to
determine the sustainable harvest level for each naturally occurring special forest product prior
to offering that product for sale or free use. As defined in the draft regulations, the sustainable
harvest level is the “aggregate quantity of the product that may be disposed of from a National
Forest annually in perpetuity on a sustained yield basis” (Draft 36 CFR, part 223.219).

Formal assessments (summarized above) and informal observations by special forest product
coordinators and other Forest Service personnel indicate that the current level of botanical
special forest product harvest is sustainable. These observations are substantiated by Appendix
A – Sustainability of Botanical Special Forest Products and include the Forest’s current
capability to administer/enforce the program. The Forest established a maximum allowable
harvest for each of the botanical special forest products available as a starting point based on
current levels. The harvest levels are detailed in Table 1, included below. Future monitoring
will determine if harvest levels should be adjusted.




                                                                                                      9
Table 1. Permit Information and Total Harvest Level for Forest Botanical Products
                                              Highest # of                    Calculation
             Highest # of
                             Quantity         Personal/       Quantity        for
             Commercial                                                                                 Total
Forest                       Allowed/         Free Use        Allowed/        Determining
             Permits Sold                                                                               Harvest         Comments
Product                      Commercial       Permits Sold Personal/Free Total
             in Last 3                                                                                  Level/Yr
                             Permit           in Last 3       Use Permit      Harvest
             Years
                                              Years                           Level/Yr
                                                                                    Highest quantity
                                                                                       sold in last 3                   Commercial harvest
                                                                    Free Use = 1
                             10-day = 1000 lbs                                              years        1,559,280      levels were taken from
                                                                    permit/year
Salal             979        20-day = 1600 lbs         5                            (1,298,900) plus         lbs        the Forest Service
                                                                   Personal Use =
                             30-day = 2400 lbs                                          personal use                    Timber Information
                                                                       100 lbs
                                                                                     (500), plus a 20                   Manager Database.
                                                                                      percent buffer
                            2-day (weekend) =                                       Highest quantity
                                                                                                                        Commercial harvest
                                12.5 gals                                              sold in last 3
                                                                    Free Use = 1                                        levels were taken from
Edible                      10-day = 20.0 gals        1,755                          years (102,331)      185,997
                  826                                               permit/year                                         the Forest Service
Mushrooms                   20-day = 30.0 gals   (free use only)                       plus free use
                                                                                                                        Timber Information
                             Biannual = 62.5                                         (52,650), plus a
                                                                                                                        Manager Database.
                                   gals                                             20 percent buffer
                                                                                    Highest quantity
                                                                                       sold in last 3
                                                                                      years (36,392)                    Estimated 20,000 gals
                                                                    Free Use = 3    plus an estimate                    tribal harvest. Includes
Huckleberries     834             40 gals        No permit req’d      gals/year          of free use    121,6718 gal    estimated collection by
                                                                                       (45,000) and                     tribal members
                                                                                       tribal harvest                   exercising treaty rights.
                                                                                     (20,000), plus a
                                                                                    20 percent buffer
                                                                                    Highest quantity                    Commercial harvest
                                                                                       sold in last 3                   levels were taken from
                             5-day = 1000 lbs                                               years                       the Forest Service
                             10-day = 2000 lbs                     Personal Use =   (4,278,470) plus    5,734,164 lbs   Timber Information
Beargrass        3390                                  0
                             20-day = 3500 lbs                         100 lbs        an estimate of                    Manager Database.
                             30-day = 5000 lbs                                         tribal harvest                   Estimated 500,000 lbs
                                                                                    (500,000), plus a                   tribal harvest. Includes
                                                                                    20 percent buffer                   estimated collection by



                                                                                                                                              10
                                                                                           tribal members
                                                                                           exercising treaty rights.
                                                       Highest quantity
                                                         sold in recent                    No burl permits were
                                                         years plus an                     issued in the last 3
Burls         NA        1 burl       2      1 burl      estimate of free      15 burls     years. A high from a
                                                         use and tribal                    previous year was
                                                       harvest, plus a 20                  used.
                                                         percent buffer
                                                                                           Commercial harvest
                                                                                           levels were taken from
                                                       Highest quantity                    the Forest Service
                                                         sold in last 3                    Timber Information
                   Minimum/permit-
                                                       years (2680) plus                   Manager Database.
                      40 bushels
                                          20 bushels       estimated        3408 bushels   Prior to any permits
Cones         67   Maximum/year-     5
                                                          quantity of                      being issued, a Forest
                    1000 bushels
                                                        personal (160)                     Service silviculturalist
                                                       plus a 20 percent                   must be consulted to
                                                             buffer                        determine the cone
                                                                                           year production for the
                                                                                           species.
                                                       Highest quantity                    Commercial harvest
                                                          sold in last 3                   levels were taken from
Cuttings
              42       200 lbs       NA      NA         years (18,000)       21,600 lbs    the Forest Service
(Ferns)
                                                       plus a 20 percent                   Timber Information
                                                             buffer                        Manager Database.
                                                       Highest quantity
Edible                                                 authorized in last
Cuttings      NA         NA          26      200        3 years (1,334)        6,240
(Ferns)                                                plus a 20 percent
                                                             buffer
                                                       Highest quantity
                                                          sold in last 3
                                                         years (1,448),        1,738
Transplants   45        Each         3      Each
                                                       plus personal use
                                                         (20) plus a 20
                                                        percent buffer
                                                                             Only minor
Forbs*        NA                     NA                                                    See footnote below
                                                                            amounts on a



                                                                                                                 11
                         case-by-case
                             basis
                          Only minor    See footnote below
                         amounts on a
Grasses*       NA   NA
                         case-by-case
                             basis
                          Only minor    See footnote below
                         amounts on a
Nuts*          NA   NA
                         case-by-case
                             basis
                          Only minor    See footnote below
                         amounts on a
Pine straw*    NA   NA
                         case-by-case
                             basis
                          Only minor    See footnote below
                         amounts on a
Sedges*        NA   NA
                         case-by-case
                             basis
                          Only minor    See footnote below
                         amounts on a
Seeds*         NA   NA
                         case-by-case
                             basis
                          Only minor    See footnote below
                         amounts on a
Shrubs*        NA   NA
                         case-by-case
                             basis
                          Only minor    See footnote below
                         amounts on a
Tree sap*      NA   NA
                         case-by-case
                             basis
                          Only minor    See footnote below
                         amounts on a
Wildflowers*   NA   NA
                         case-by-case
                             basis
                          Only minor    See footnote below
                         amounts on a
Bark*          NA   NA
                         case-by-case
                             basis
Bryophytes     NA   NA    Only minor    See footnote below



                                                             12
(including                                                                                                         amounts on a
mosses) *                                                                                                          case-by-case
                                                                                                                       basis
                                                                                                                    Only minor     See footnote below
                                                                                                                   amounts on a
Lichens*              NA                                       NA
                                                                                                                   case-by-case
                                                                                                                       basis
                                                                                                                    Only minor     See footnote below
Bulbs and                                                                                                          amounts on a
                      NA                                       NA
Roots*                                                                                                             case-by-case
                                                                                                                       basis
  * These products may be authorized on a case-by-case basis after consultation with a Forest Service line officer and botanist (and any other
  applicable Forest Service resource personnel).Incidental collection by tribal members is allowed, as is incidental amounts for scientific collection,
  bio-prospecting, or conservation purposes.


  Note: No limit would be placed on tribal harvest of any product listed above without consultation with the appropriate Indian tribe.




                                                                                                                                                        13
PUBLIC INVOLVEMENT
This project was described in the April 2008 Schedule of Proposed Actions for the Gifford
Pinchot National Forest. The proposal was sent to members of the public and other agencies for
comment during the scoping period that was initiated on April 15, 2008. A separate letter was
also sent to the Puyullap Tribal Council, Nisqually Indian Community Council, Yakama
Nation, Squaxion Island Tribal Council, Steilacoom Tribe of Indians, as well as the Cowlitz
Indian Tribe. This letter was sent out on March 26, 2008 and asked for feedback on issues and
concerns regarding special forest product harvesting.

Nine letters and one phone call were received in regards to the scoping letter. Concern was
expressed over the reissuance of free use permits, the lack of huckleberries after commercial
picking, and some commenters wanted to see more enforcement with commercial harvesters.
Original letters can be found in the project record. Changes made during the 2008 season and
those expected in 2009 and 2010 (together with the adaptive management plan) will address
these concerns.

A letter was also received from the Yakama Nation on April 7, 2008. The tribe suggested that
the Forest and tribal staff meet to discuss sustainable harvest levels for treaty resources. The
Forest has made an effort in the past and will continue to work closely with Yakama Nation on
the botanical special forest products program. A meeting was held with representatives from the
natural and cultural resource staff of the Yakama Nation on February 18, 2009. Tribal
representatives reviewed the draft decision and draft adaptive management plan and provided
comments in a March 9, 2009 letter. Those comments have been incorporated into this decision.


REASONS FOR CATEGORICAL EXCLUSION
The Council on Environmental Quality (CEQ) regulations at 40 CFR 1507.3 provide that
agencies may, after notice and comment, adopt categories of actions that do not normally have
significant impacts on the human environment and that do not require preparation of an
environmental assessment (EA) or an environmental impact statement (EIS). It is our
determination that this action may be categorically excluded from documentation in an EA or
EIS as stated in Forest Service Handbook (FSH) 1909.15.

The botanical special forest products program fits within the parameters of FSH 1909.15,
Section 31.1 (8) "Approval, modification, or continuation of minor, short-term (one year or
less) special uses of National Forest System lands," and Sections 31.2 (3) "Approval,
modification, or continuation of minor special uses of National Forest System lands that require
less than 5 contiguous acres of land." All permits for botanical special forest products are issued
for less than a year and are minor in nature. Where commercial permits are authorized, they are
limited in number and are regulated through permit administration and must follow permit-
specific terms and conditions.


EVALUATION OF EXTRAORDINARY CIRCUMSTANCES
According to Forest Service Handbook 1909.15, Section 30, a proposed action may be
categorically excluded from further analysis and documentation in an environmental impact
statement (EIS) or environmental assessment (EA) only if there are no extraordinary


                                                                                                14
circumstances related to the proposed action. Resource conditions that should be considered in
determining whether extraordinary circumstance related to the proposed action warrant further
analysis and documentation are listed below (A-F). As stated in Section 30.3 of the handbook,
“the mere presence of one or more of these resource conditions does not preclude use of a
categorical exclusion. It is the degree of the potential effect of a proposed action on these
resource conditions that determines whether extraordinary circumstances exist” (FSH 1909.15).

After review of the resource specialist reports and documents in the project file I have
determined that there are no impacts to resource conditions that would warrant extraordinary
circumstances or indicate that this proposal would have significant effects to any resource
conditions. This analysis is summarized below.

a. Federally listed threatened or endangered species or designated critical habitat, species
proposed for Federal listing or proposed critical habitat, or Forest Service sensitive
species. Collection of special forest products are so widely dispersed that, although there may
be some localized adverse effects to species and habitat, they are expected to be very low
overall.

Wildlife Species: Wildlife species that may be affected by the special forest products program
include: northern spotted owl and northern spotted owl critical habitat, American peregrine
falcon, and several sensitive terrestrial mollusk species.

Human disturbance has the potential to adversely affect the spotted owl during nesting season
and would be most critical during early nesting season (March 1 to June 30). Beargrass, salal,
and spring mushrooms are most likely to be harvested in habitat that is used by spotted owls.
Spotted owl nests sites are usually late-successional conifer forest stands with high canopy
closure. Due to the nature of the nesting sites, salal and beargrass are not likely to grow in high
quantities in the nest stands, and mushroom harvesting tends to be more dispersed and less time
is spent harvesting in a given location. Therefore the potential to disturb spotted owls at nest
sites is low during product harvest, and foraging spotted owls are unlikely to encounter harvest
activity since foraging occurs primarily at night. There would be minimal effects to the spotted
owl prey base, and minimal potential for noise disturbance near nesting sites; therefore, the
special forest products program may affect, but is not likely to affect spotted owls.

Commercial mushroom harvest has the potential to affect spotted owl habitat by reducing
forage for small mammals which the owls prey upon. Since mushroom harvest tends to be
widely dispersed across the Forest, and spotted owls are unlikely to be measurable affected, the
Special Forest Product program may affect, but is not likely to affect critical habitat for spotted
owls.

Human disturbance may impact individuals or habitat of the sensitive peregrine falcon, but the
wildlife biologist has determined that it would not lead to a trend towards federal listing or loss
of viability of the population or species. Salal harvest does occur near one known nest site, but
has been infrequent and sufficiently non-threatening enough in the past to keep the pair from
abandoning the nest site. Salal and beargrass can grow in forested stands where sensitive
terrestrial mollusks may occur. Illegal rake harvest of mushrooms may also impact sensitive
mollusks. Since mollusks have tiny home ranges, removal of all the mushrooms within a small


                                                                                                 15
area could impact individuals. Since this mushroom harvest is widely dispersed across the
Forest, and occurs relatively close to roads, the majority of suitable mollusk habitat on the
Forest would not be subject to harvest; and, therefore, the botanical special forest products
program may impact individuals or habitat, but would not lead to a trend towards federal listing.

Botanical Species: At this time there are no federally listed plant species known to occur on the
Forest, however one federally threatened species (Howellia aquatilis) is suspected. Howellia
aquatilis has an extremely narrow habitat tolerance, generally confined to palustrine emergent
wetlands with seasonal drawdown. Special forest product harvest as proposed does not
generally occur within wetlands. Thus, this program will have no effect on federally listed
botanical species.

The botanist determined that there was a low likelihood that most sensitive species will be
impacted by special forest products harvest because of plant characteristics (not showy, not
generally targeted, cryptic, etc.) and/or habitat outside of areas generally targeted by harvesters.
A list of these species can be found in the Botanical Resource Report in the project file. It is
assumed that there is some incidental impact to sensitive botanical species either through
collection or indirectly through impacts to habitat during collection of other special forest
products. For these species, the determination was made that there is a low likelihood of impact
resulting from the special forest products program. The determination was thus made that
continuation of the program (as proposed) may impact these species or habitat for these species,
but will not likely contribute to a trend towards federal listing or cause a loss of viability to the
population or species as a whole. Note that for fungal species, this determination is dependant
on implementation of the permit provisions that prohibit use of rakes. Use of rakes can impact
mycelial networks of fungal species, and may impact more than just the target species,
damaging or killing the actual ‘body’ of the fungus, in contrast to above ground collection
methods (picking or cutting off the fruiting body or ‘mushroom’) which targets only the ‘fruit’.
This prohibition against raking is part of the standard permit provisions included in both
commercial and personal use fungi collection permits.

Certain botanical species have a moderate likelihood that they will be impacted by special
forest products harvest. A list of these species can be found in the Botanical Resource Report in
the project file. Species listed as having a moderate likelihood of impact have a reasonable risk
of direct impacts from collection of the species and/or a reasonable risk of impacts to habitat.
However, to protect the species from harm, a mitigation has been included that requests for
wildflowers, sedges, rushes, grasses, mosses, lichens, forbs or transplants of any of these
entities, bulbs, rhizomes, roots, or seeds are approved on a case by case basis, and in
consultation with a botanist or botanical specialist. The determination was thus made that
continuation of the program (as proposed) may impact these species or habitat for these species,
but will not likely contribute to a trend towards federal listing or cause a loss of viability to the
population or species as a whole.

Only one sensitive botanical species, Usnea longissima, was thought to have a high likelihood
of impact as a result of special forest products harvest. This species is a pendulous, epiphytic
lichen highly sought after by wildcrafters. Because this species is often specifically targeted by
lichen seeking wildcrafters, there is a clear risk of direct impact to this species from harvest. For
this reason, mitigation has been included that collection of pendulous Usnea is not allowed on


                                                                                                  16
the Forest. With this mitigation in place, there would be no impact to Usnea longissima
anticipated as a result of special forest products harvest. Usnea longissima is identified as an
ethnobotanical cultural resource used by tribal members and because of this, incidental tribal
collection is authorized.

Fish/Aquatic Species: There is no effect or impact to any federally-listed or Forest Service
sensitive fish species or habitat because harvest does not generally occur in riparian areas.
Harvest is dispersed across the Forest and very little to no impact is expected in wet areas. The
species with the highest demand occur in drier open-canopy stands (such as huckleberries) or
heavily canopied stands (such as beargrass or salal).

b. Floodplains, wetlands, or municipal watersheds. Based on typical harvest and permit
conditions, there would be no impacts to floodplains, wetlands, or municipal watersheds. The
species of high demand are found in dry or mesic zones. Although harvest is allowed in
municipal watersheds on the Forest, the nature of harvest would not threaten the watershed
resources.

c. Congressionally designated areas, such as wilderness, wilderness study areas, or
national recreation areas. Under the restrictions and conditions of the special forest products
program, harvest will not be allowed in wilderness areas, so the program will not affect
wilderness resources. There are no wilderness study areas or national recreation areas on the
Forest.

d. Inventoried roadless areas. None of the products available for harvest would allow road
building, or any changes to the road system. Therefore inventoried roadless area characteristics
should not be altered or significantly affected.

e. Research natural areas. According to permit conditions, harvest will not be allowed in
research natural areas (RNA), so there will be no impact to RNA resources.

f. American Indians and Alaska Native religious or cultural sites; Archaeological sites, or
historic properties or areas. A cultural resource analysis documented that harvesting of the
majority of special forest products does not involve ground disturbance, and based on the
mitigation measures list, the continued commercial sale of Botanical Special Forest Products
will have No Effect on heritage resources.

The continued commercial harvest of special forest products, particularly huckleberries and
beargrass, has the potential to affect the traditional use of two Traditional Cultural Properties
located on the Forest, Skis-wa-tum and Kpss-wa-nite. Traditional Cultural Properties are areas
of traditional cultural significance to Indian tribes and listed in the National Register of Historic
Places. Skis-wa-tum includes the ten lake basins which comprise the North Surprise and South
Surprise Lakes Indian Camps. Kpss-wa-nite contains an archaeological component as well as
an historic huckleberry camp and modern longhouse. It was the location of the 1932 Handshake
Agreement, and for the past 25 years has been the site of a first foods feast honoring the
huckleberry. To mitigate these possible affects, commercial harvesting is not allowed within
the boundaries of the Sawtooth Huckleberry Fields and neither commercial nor personal use is
allowed in the Handshake Agreement Area. In addition to prohibiting harvest within the


                                                                                                   17
boundaries of Skis-wa-tum and Kpss-wa-nite, the Forest also proposes to monitor the effects of
harvest across the Forest on product sustainability. The Forest will also implement postponing
the issuance of commercial huckleberry permits until after the first foods feast is held,
increasing law enforcement in the Sawtooth Huckleberry Fields to monitor permit compliance,
and posting of signs in areas where commercial and personal use harvest is prohibited (such as
the Handshake Agreement Area).

Indian Tribes with reserved treaty rights or other adjudicated rights may harvest special forest
products in accordance with the terms of the treaty rights and are not subject to the application
and permitting requirements discussed in this decision. The Medicine Creek Treaty of 1854
(for the Nisqually, Puyallup, Squaxin Island, and Steilacoom Indian Tribes) and the Yakima
Treaty of 1855 for the Yakama Indian Nation include the privilege2 of hunting and gathering
roots and berries on ceded lands under U.S. administration. In addition, the 1932 Handshake
Agreement between Chief Yallup and Gifford Pinchot National Forest Supervisor John
Bruckart granting Yakama Indians exclusive berrypicking rights to a 700-acre portion of the
Sawtooth Huckleberry Fields east of Forest Road 2400 would not change with this decision.

Based on the mitigation measures, the continued commercial sale and personal use permitting
of special forest products will have no effect on heritage resources.

No significant effects or extraordinary circumstances have been identified.


FINDINGS REQUIRED BY LAW

Endangered Species Act
An assessment of all Federally-listed species covered under the Endangered Species Act (ESA)
was conducted and it was determined that this decision is compliant with the ESA. The wildlife
biologist concluded that that the project may affect but is not likely to adversely affect, the
northern spotted owl and critical habitat for the northern spotted owl. There will be no effect to
any other listed or proposed wildlife species or their habitat. Consultation for the northern
spotted owl is covered in the March 2001 Programmatic Agreement from the U.S. Fish &
Wildlife Service. For aquatic and botanical species it was determined that there would be no
effect to any federally-listed species. Consultation with the National Marine Fisheries Service
or U.S. Fish & Wildlife Service for fish species is not required.

National Forest Management Act
The interdisciplinary team reviewed the applicable standards and guidelines of this proposal,
and determined that this decision is compliant with the National Forest Management Act and
consistent with the Gifford Pinchot National Forest Land and Resource Management Plan, as
amended.

National Historic Preservation Act
A heritage resource analysis was completed in compliance with the National Historic
Preservation Act. It was determined that this project would have no effect on heritage

2
    See footnote 1.


                                                                                                18
resources. Consultation with the State Historic Preservation Officer was conducted and can be
found in the project file.

Environmental Justice
The Forest assessed the program to determine whether it would disproportionately impact
minority or low-income populations, in accordance with Executive Order 12898. Many of the
commercial harvesters are migrant workers and are considered under the Executive Order;
however no disproportionate impacts to minority or low-income populations were identified
during scoping or the effects analysis. The changes included in this decision are all minor,
administrative changes that are not expected to cause any undue hardship or displace harvesters.

Other Laws or Requirements
The botanical special forest products program is consistent with all other Federal, State, or local
laws or requirements for the protection of the environment and cultural resources.


IMPLEMENTATION DATE
This decision is effective immediately. While this decision is not subject to appeal pursuant to
Forest Service regulations at 36 CFR 215.8(a)(4), I encourage you to discuss the this project
with me if you have any concerns about implementation.

CONTACT PERSON
A project file has been prepared in conjunction with this decision memo. For additional
information regarding this decision or the Forest Service appeal process, contact Erin Black,
Mt. Adams Ranger District, 2455 Hwy 141, Trout Lake, WA 98650. (509) 395-3411 or by
email: ekblack@fs.fed.us




RESPONSIBLE OFFICIAL:



/s/ Janine    Clayton_                                       5/1/2009________________
JANINE CLAYTON                                               DATE SIGNED
Forest Supervisor
Gifford Pinchot National Forest




                                                                                                19
 The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and
activities on the basis of race, color, national origin, age, disability, and where applicable, sex,
marital status, familial status, parental status, religion, sexual orientation, genetic information,
 political beliefs, reprisal, or because all or part of an individual’s income is derived from any
   public assistance program. (Not all prohibited bases apply to all programs.) Persons with
disabilities who require alternative means for communication of program information (Braille,
    large print, audiotape, etc.) should contact USDA’s TARGET Center at (202) 720-2600
  (voice and TDD). To file a complaint of discrimination, write to USDA, Director, Office of
 Civil Rights, 1400 Independence Avenue, S.W., Washington, D.C. 20250-9410, or call (800)
   795-3272 (voice) or (202) 720-6382 (TDD). USDA is an equal opportunity provider and
                                              employer.




                                                                                                20
         Appendix A – Sustainability of Botanical Special Forest Products



Special Forest Products Harvested on the Gifford Pinchot National Forest, with Notes on
                      their Habitat, and Sustainability Concerns

        SPECIES                     DESCRIPTION OF                              SUSTAINABILITY
                                       HABITAT                                    CONCERNS
Salal                        The range of salal extends from              Considering the autecology,
                             southern California to southeast             distribution, abundance and current
                             Alaska. It occurs throughout the             harvest levels and trends of salal,
                             Gifford Pinchot National Forest and          ecological concerns about the
                             adjacent private lands, mainly in the        sustainability of this species are
                             Western Hemlock plant zone to                relatively low, except perhaps in some
                             approximately 2500 feet in elevation.        heavily utilized locations on the
                             It is particularly abundant on the           Cowlitz Valley Ranger District near
                             Cowlitz Valley Ranger District in the        Packwood, where roaded access and
                             Middle, Upper and Clearfork Cowlitz          abundance may be having a long-
                             (fifth field) watersheds in 90 to 130        term, adverse effect on the availability
                             year old, Douglas-fir and western            and sustainability of the salal product
                             hemlock forest stands that originated        (i.e. annual stem growth) (Kogut
                             from wildfire; this is where the vast        2007).
                             majority of commercial permits are
                             sold (Kogut 2007).
Edible Mushrooms             Chanterelles are ectomycorrhizal fungi        Researchers have found that picking
(including but not limited   fruiting in association with forest trees.   has no negative impact on subsequent
                             They are more abundant in the Pacific        fruiting of chanterelles (Pilz et al.
to chanterelles and          Northwest than matsutake (Swartz             2003 as cited in Swartz 2007).
matsutake).                  2007).

                             Matsutake fungi are known to be              Fungi harvest involves picking the
                             mycorrhizal (associating with tree           ‘fruit’ of the fungus, and does not
                             roots in a symbiotic association), and       (when permit rules and regulations
                             may possibly also have some parasitic        are followed, including prohibition of
                             and saprobic (decompositional)               rakes) impact the ‘body’ of the
                             capabilities (Hosford et al. 1997, as        fungus, which consists of mycelia
                             cited in Swartz 2007). Tree associates       located within the fungal substrate. In
                             found in our area include Douglas fir,       the case of most edible fungi species,
                             western hemlock, grand fir, Pacific          this substrate is soil, as well as
                             silver fir, Engelmann spruce, and            mycorrhizal partners. For this reason,
                             lodgepole pine. American matsutake           it is likely that harvest of fungi is
                             typically fruit in Washington at             sustainable, in most commonly
                             elevations ranging from about 1000 to        encountered situations.
                             4000 feet. In the Cascade Range south
                             to the Columbia River they may be            Because fungi fruit unpredictably, it is
                             found in Douglas fir, western                especially difficult to monitor the
                             hemlock/salal/sword fern stands, or at       status and trends of populations. We
                             higher elevations in stands of mixed         recognize that monitoring is needed to
                             conifer/ericaceous shrubs (Hosford et        document and evaluate management
                             al. 1997 as cited in Swartz 2007).           practices and assumptions, and to
                                                                          detect trends in the resource.




                                                                                                              21
Huckleberries   Big huckleberry* is found from           Big huckleberry has a widespread
                Alaska and British Columbia south        distribution, with wide ecological
                through the Cascade and Olympic          amplitude, a long life span, and the
                mountains to California, and east to     ability to persist indefinitely in forests
                Ontario, Wyoming, South Dakota,          in various seral stages. Berry harvest
                Minnesota, and Michigan (Forest          (if performed accoring to permit
                Effects Information System (USDA,        direction) impacts only the berries,
                FEIS) 2007). On the Gifford Pinchot      and generally does not impact all
                National Forest, big huckleberry         berries on a particular shrub. In
                grows as an understory shrub in          addition, big huckleberries rarely
                montane and subalpine forests,           reproduce via seeds (Barney 2007), so
                reaching highest densities in the        harvest is unlikely to substantially
                Pacific Silver-fir and Mountain          impact sexual reproduction potential
                Hemlock Zones (Franklin and Dyrness      in most cases. For these reasons, it is
                1973; Brockway et al. 1983; Diaz et      unlikely that there is substantial risk
                al. 1997), and highest cover in the      to persistence of the species on the
                Mountain Hemlock/Big Huckleberry         landscape as a result of berry harvest.
                Association (average 34% cover),
                Pacific Silver Fir/Big
                Huckleberry/Queencup Beadlily
                Association (average 10-30% cover),
                and Pacific Silver Fir/Big
                Huckleberry/Beargrass Association
                (average 18% cover). Big
                Huckleberry is most often found at
                elevations between 900 and 1800
                meters (Dahlgreen 1984, as cited in
                Anzinger 2003), though it may be
                found growing anywhere from ~ 600-
                2300 meters (Barney 2007). Although
                big huckleberry grows as an
                understory shrub under dense forest
                canopies, plants are more abundant
                and vigorous under partial canopies or
                in the open (Neiland 1958). Big
                huckleberry can grow in mesic to xeric
                sites (Darrow 1960; Diaz et al. 1997;
                Brockway et al. 1983).

                *Although there are multiple species
                of huckleberries targeted for harvest
                (i.e. Vaccinium deliciosum, Vaccinium
                ovalifolium, Vaccinium parvifolium),
                black huckleberry (Vaccinium
                membranaceum) is the primary
                species targeted for both personal and
                commercial use. For this reason,
                discussions of harvest sustainability
                focus on this species.

Beargrass       The range of beargrass extends from      The habitat and distributional trends
                British Columbia to Central California   for beargrass appear to be stable, or
                east to Idaho and Montana. It occurs     increasing in some areas due to
                throughout the Gifford Pinchot           management practices such as
                National Forest and adjacent private     commercial and pre-commercial
                lands. Beargrass is moderately shade-    thinning. Overall, there appears to be


                                                                                               22
                        tolerant. It survives but seldom         little concern that beargrass as a
                        blooms under a forest canopy             species will decrease in abundance
                        Elevational range for beargrass is sea   over the short-term (10 years), nor is
                        level to 6,000 ‘ in cool dry forest      this likely in the long-term (50-100
                        types.                                   years) (Chandler 2007).

Bark                    Bark generally refers to western         Western redcedar bark is harvested
                        redcedar bark. Western redcedar is a     from living trees. However, the
                        widely distributed conifer species on    methodology prescribed for bark
                        the Gifford Pinchot National Forest,     removal prevents the process from
                        often found as a minor component of      killing trees (improper harvest can kill
                        forested stands, within moist, shady     trees). This is a low demand special
                        microclimates such as riparian zones.    forest product generally collected in
                                                                 small quantities. From 2005-2008, a
                                                                 total of 3 commercial permits for
                                                                 bark, stumps and conks
                                                                 (cumulatively) were processed. At
                                                                 the current low permitted harvest
                                                                 levels, there are no concerns
                                                                 regarding sustainability for this
                                                                 product, or western redcedar as a
                                                                 species. Due to the potentially
                                                                 sensitive nature of the product
                                                                 (improper harvest can kill trees),
                                                                 requests are handled on a case by case
                                                                 basis.
Bryophytes (including   Generally, bryophyte harvest is          There are a number of sustainability
mosses)                 concentrated in riparian areas with      concerns relating to bryophyte
                        well developed hardwood trees and        harvest. First, bryophytes are
                        shrubs (particularly vine maple and      relatively slow growing, and epiphyte
                        bigleaf maple) that support large,       communities may require decades to
                        loosely adherent epiphytic moss mats,    recover after harvesting (Peck 1996
                        that are easy to remove.                 as cited in Peck 1997). Secondly,
                                                                 Sensitive and/or rare bryophytes or
                                                                 lichens may be mixed with more
                                                                 common species that are targeted for
                                                                 harvest, since non target species are
                                                                 often incidentally collected in the
                                                                 moss mats (Peck 1997). Thirdly, the
                                                                 dispersal capabilities and growth rates
                                                                 of the species in moss mat
                                                                 communities may differ, leading to
                                                                 the re-growth of a different
                                                                 community that that which was
                                                                 originally harvested (Vance and
                                                                 Kirkland 1997 as cited in Peck 1997).
                                                                 From 2005-2008, 1 commercial
                                                                 permit, and 0 personal use permits
                                                                 were made. Due to the sensitive
                                                                 nature of the product (whole plant is
                                                                 impacted), permit requests are
                                                                 handled on a case by case basis. As
                                                                 result, there is little concern for
                                                                 sustainability at this time.
Lichens                 Habitat and distribution is highly       Due to the sensitive nature of the
                        dependent on species targeted. Some      product (whole thallus is impacted),


                                                                                                      23
                  commonly targeted species include           permit requests are handled on a case
                  Usnea longissima (distribution is very      by case basis. Lichens are slow
                  patchy, and species is rarely               growing relative to vascular plants,
                  abundant), Letharia spp., commonly          and some species are dispersal
                  known as dog bane ( locally abundant        limited, and/or require specific
                  in dry, westside-eastside transitional or   microclimates. As noted above,
                  eastside forest types), old man’s beard     lichens are sometimes harvested along
                  lichens (Bryoria and Alectoria), which      with bryophytes when large mats are
                  are widespread and abundant in              targeted. Because Usnea longissima
                  montane to subalpine forests in the         a Sensitive species patchily
                  Pacific Northwest. Lung lichens             distributed, and likely disperal
                  (Lobaria spp.) are found primarily in       limited, we recommend that no
                  riparian zones or other moist areas         collection of this species be permitted.
                  with filtered light.                        From 2005-2008 0 permits for lichen
                                                              harvest were made; as a result, there
                                                              is little concern for the sustainability
                                                              of most species at this time.
Bulbs and Roots   Habitat and distribution is highly          Due to the sensitive nature of the
                  dependent on species targeted.              product (whole plant is impacted),
                  Examples of bulbs and roots that may        permit requests are handled on a case
                  be desirable for harvest: western           by case basis. There is very small
                  redcedar, Lomatium spp., camas              demand for bulbs and roots. From
                  (Camassia spp.), wild ginger (Asarum        2005-2008, there is no record of
                  caudatum), devil’s club (Oplopanax          permit requests. As result, there is
                  horridum). According to current             little concern for sustainability at this
                  understanding, there are no species         time.
                  specifically targeted for harvest which
                  are Endangered, Threatened, Sensitive,
                  or otherwise rare or very limited in
                  distribution.
Burls             Various species, including maple and        Due to the sensitive nature of the
                  various conifers. Habitat and               product (standing trees may be
                  distribution is highly dependent on         impacted), permit requests are
                  species targeted.                           handled on a case by case basis.
                                                              There is very small demand for burls
                                                              (From 2005-2008, there were 3
                                                              commercial permits for barks, stumps
                                                              and conks cumulatively). As result,
                                                              there is little concern for
                                                              sustainability at this time.
Conks             Various species of fungi. Habitat and       Permit requests are handled on a case
                  distribution is highly dependent on         by case basis. The conk is a fruiting
                  species targeted.                           body of a fungus growing within a
                                                              tree, snag or stump. Removal of the
                                                              conk does not impact the fungus body
                                                              or the substrate tree. There is very
                                                              small demand for conks (From 2005-
                                                              2008, there were 3 commercial
                                                              permits for barks, stumps and conks
                                                              cumulatively). As result, there is little
                                                              concern for sustainability at this time.
Cones             Various common conifer species,             From 2005-2008, an average of 1
                  including Douglas-fir (Pseudotsuga          commercial permit, and 20 personal
                  menziesii), Ponderosa pine (Pinus           use permits were made. Due to the
                  ponderosa), western white pine (Pinus       abundance of cone production across
                  monticola); other species occasionally      the forest, there are no sustainability


                                                                                                   24
             targeted.                                  concerns when cones of common
                                                        conifer species are harvested.
                                                        Because of concerns over the viability
                                                        of whitebark pine (Pinus albicaulis)
                                                        on the Gifford Pinchot National
                                                        Forest (Doede et al. 2006), we
                                                        recommend that no permits be issued
                                                        for cone collection of this species
                                                        unless the collection is required for
                                                        scientific study or conservation
                                                        efforts.
Ferns        The fern species usually targeted for      Concerns for sustainability of ferns is
             cuttings and/or transplants is sword       mainly related to transplantation since
             fern (Polystichum munitum). This           entire ferns are removed from the
             species is widely distributed across the   Forest. Cumulatively, transplants
             Forest as an understory dominant or        (includes small trees, shrubs, ferns,
             co-dominant, and is particularly           forbs) received an average of 25
             abundant in the western hemlock zone.      commercial permits, and 1 personal
             Other fern species occasionally            use permit per year (2005-2008).
             targeted include lady-fern, (Athyrium      Because there is low demand, and
             filix femina), maidenhair fern             targeted species are abundant, there is
             (Adiantum pedatum), or deer fern           little concern for sustainability at this
             (Blechnum spicant); these species are      time.
             also abundant and widespread across
             the forest, though restricted to more
             specialized habitats.
Forbs        The forb category incorporates many        Due to the sensitive nature of the
             different species - examples include       product (entire plant is impacted;
             wild ginger, vanilla leaf (Achlys          many Sensitive or other rare plants
             triphylla), various lilies, twinflower     are forbs), permit requests are handled
             (Linnaea borealis), and lupine             on a case by case basis. Harvest of
             (Lupinus spp.). Habitat and                Sensitive or other rare forb species is
             distribution is highly dependent on        not permitted, except for approved
             species targeted. Many Sensitive and       scientific or conservation purposes.
             other rare plants fall within the forb     Between 2005-2008, no permits for
             category.                                  forbs were processed. As result, there
                                                        is little concern for sustainability at
                                                        this time.


Grasses      The grass category incorporates many       Due to the sensitive nature of the
             different species – examples include       product (entire plant is impacted),
             Elymus glaucus (blue wild rye),            permit requests are handled on a case
             Deschampsia elongata (slender              by case basis. Between 2005-2008,
             hairgrass), and Idaho fescue (Festuca      no permits for grasses were
             idahoensis).                               processed. As result, there is little
                                                        concern for sustainability at this time.
Nuts         The nut category incorporates various      Between 2005-2008, no permits for
             species, but primarily includes Garry      nuts were processed. As result, there
             oak (Quercus garryana) acorns and          is little concern for sustainability at
             hazelnuts from Corylus cornuta (not        this time. Because nut harvest
             generally harvested for food, but rather   impacts the ability of a plant to
             for decoration).                           reproduce, permit requests are
                                                        handled on a case by case basis.
Pine straw   Pine straw consists of pine needles,       Pine needles are ubiquitous (and build
             primarily from Ponderosa pine. This        quickly) in forests with Ponderosa


                                                                                              25
              product is only available on the east     pine. Though harvest of pine straw
              side of the Forest, primarily Mt.         does not impact the pine trees, the
              Adams District.                           method of collection may cause
                                                        impacts to understory species and
                                                        fungi. Between 2005-2008, no
                                                        permits for pine straw were
                                                        processed. As result, there is little
                                                        concern for sustainability at this time.
                                                        Permit requests are handled on a case
                                                        by case basis.
Sedges        The sedge category incorporates many      Between 2005-2008, no permits for
              different species; each species has a     sedges were processed. Due to the
              distinct distributional pattern. Sedges   sensitive nature of the product (risk
              are very difficult to distinguish from    that Sensitive species may be
              each other (by species). On the Gifford   collected during harvest), permit
              Pinchot National Forest, there is one     requests are handled on a case by case
              Sensitive sedge species.                  basis. As result, there is little concern
                                                        for sustainability at this time.
Seeds         The seed category incorporates many       Due to the sensitive nature of the
              different species.                        product (reproductive potential of the
                                                        plant impacted), permit requests are
                                                        handled on a case by case basis.
                                                        Between 2005-2008, no permits for
                                                        forbs were processed. As result, there
                                                        is little concern for sustainability at
                                                        this time.
Shrubs        The shrub category incorporates           Due to the sensitive nature of the
              various species, including but not        product (entire shrub is impacted),
              limited to: vine maple (Acer              permit requests are handled on a case
              circinatum), hazel (Corylus cornuta),     by case basis. Cumulatively,
              Oregon grape (Berberis nervosa),          transplants (includes small trees,
              salal, ceonothus (Ceonothus spp.),        shrubs, ferns, forbs) received an
              manzanita (Artostaphylos spp.),           average of 25 commercial permits,
              juniper (Juniperus spp.), kinnick-        and 1 personal use permit, per year
              kinnick (Arctostaphylos uva ursi), and    (2005-2008). As result, there is little
              rhododendron (Rhododendron                concern for sustainability at this time.
              macrophyllum).
Tree sap      The seed category incorporates many       Between 2005-2008, no permits for
              different species.                        tree sap were processed. As result,
                                                        there is little concern for
                                                        sustainability at this time. Due to the
                                                        potential for harm to the tapped tree,
                                                        permit requests are handled on a case
                                                        by case basis.
Transplants   The transplant category predominantly     Concerns for sustainability of ferns is
              includes ferns. The fern species          mainly related to transplantation since
              usually targeted for cuttings and/or      entire ferns are removed from the
              transplants is sword fern (Polystichum    Forest. Cumulatively, transplants
              munitum). This species is widely          (includes small trees, shrubs, ferns,
              distributed across the Forest as an       forbs) received an average of 25
              understory dominant or co-dominant,       commercial permits, and 1 personal
              and is particularly abundant in the       use permit per year (2005-2008).
              western hemlock zone. Other fern          Because there is low demand, and
              species occasionally targeted include     targeted species are abundant, there is
              lady-fern, (Athyrium filix femina),       little concern for sustainability at this
              maidenhair fern (Adiantum pedatum),       time.


                                                                                              26
              or deer fern (Blechnum spicant); these
              species are also abundant and
              widespread across the forest, though
              restricted to more specialized habitats.
Wildflowers   The wildflower category incorporates       Due to the sensitive nature of the
              many different species, including but      product (reproductive potential of the
              not limited to: lupine, violets (Viola     plant impacted), permit requests are
              spp.), lilies, and composites              handled on a case by case basis.
              (examples: Aster, Erigeron).               Harvest of Sensitive or other rare
                                                         wildflowers is not permitted, except
                                                         for approved scientific or
                                                         conservation purposes. Between
                                                         2005-2008, no permits for
                                                         wildflowers were processed. As
                                                         result, there is little concern for
                                                         sustainability at this time.




                                                                                            27

								
To top