Mt. Hood National Forest Management Relative to the Forest Stewardship Counsel Pacific Coast Regional Standard
Principle /
Subject Area
P1: FSC
Commitment
and
legal Compliance
Strengths Relative to the Standard
Weaknesses Relative to the Standard
CAR/REC #s
 Forest managers express a strong commitment to
 The Forest Service has not yet provided a written  Major CAR 2006.1
complying with laws/regulations - lawsuits help
statement of commitment to the FSC
define/interpret the decision space for these statutes and the
 CAR 2006.5
Principles and Criteria and such a
MTHNF managers are committed to managing within that
statement of commitment is not yet incorporated
defined decision space.
into the MTHNF Forest Plan or another official  REC 2006.1
document. In addition, if actual certification
 MTHNF managers go above and beyond NEPA
were sought, the Forest Service would need to
requirements and basic sharing of information through its
document the reasons for seeking partial
work with partners. They have engaged diverse
certification (if only some National Forests
stakeholders and have in a number of instances worked in
sought certification).
the field to share plans and modify them in response to
stakeholder concerns. In many instances, their procedures
for public participation exceed required legal obligations.
 The Forest Service has been proactive with its treaty
obligations, especially through its advancement of a Mt.
Hood-Confederated Tribes of Warm Springs partnership.
 The Forest Service has not adopted and
memorialized a policy assuring that when
conflicts arise between U.S. law and FSC
Principles and Criteria (P&C) that such conflicts
will be referred to the FSC for resolution.
 Though it is not yet an acute problem, OHV use
levels are on the rise, as are other unauthorized
activities.
Compliance Would Require Either a Change in the Standard, or
Change in Forest Policy
Change in Regional or National Policy
Change in Law, Regulation, or Appropriations
Mt. Hood National Forest Management Relative to the Forest Stewardship Counsel Pacific Coast Regional Standard
Principle /
Subject Area
Strengths Relative to the Standard
P2: Tenure &
 Timber sale perimeters are clearly marked. . .
Use Rights &
 The FS affirmatively allows for customary uses
Responsibilities
 Legal tenure claims to the land are not in doubt.
 Recreation, Non-timber Forest Products (NTFP) gathering, Tribal
customary uses are all respected
 There is a demonstrated sense of responsibility with regard to historic and
cultural resources
Weaknesses Relative to the Standard
CAR/REC #s
 Huckleberry gathering is an important tribal use 
on the Forest and MTHNF managers have
pursued informal strategies for providing for this
customary use but there is acknowledged
uncertainty as to whether or not tribal gathering
can be assured through a formal
designation/reservation.
REC 2006.2
 There is extensive consultation with stakeholders through NEPA
(excluding CE process) and through other partnership and consultative
processes
 The FS has formed many working partnerships with local groups; there is
a good understanding of what collaboration is and how it might be
improved
P3: Indigenous
Peoples’ Rights
 The MTHNF is exceptional in its advancement of government-togovernment tribal relations through direct work with the Tribes and
through its partnering process, which includes sending employees to tribal
cultural educational workshops
 At present, MTHNF managers seek nation-tonation interaction only with neighboring tribes
now based in Oregon

REC 2006.3
 There is a program of strong, affirmative contact, outreach, and joint
project work with CTWS at all levels
 FS and CTWS representatives meet quarterly
 There is a Memorandum of Understanding (MOU) at the government-togovernment level (MTHNF to CTWS). • Generally, MTHNF ensures that
tribal resources are protected from adverse management effects
 The agency is working to establish a ten-year stewardship project with the
CTWS.
 FS employees are respectful of tribal knowledge and confidentiality
(example: huckleberry map)
 The Mt. Hood NF also coordinates on strategic efforts with the Columbia
River Inter-tribal Fish Commission (CRITFC). This is a coalition of ALL
Northwest Oregon & Washington tribes.
Compliance Would Require Either a Change in the Standard, or
Change in Forest Policy
Change in Regional or National Policy
Change in Law, Regulation, or Appropriations
Mt. Hood National Forest Management Relative to the Forest Stewardship Counsel Pacific Coast Regional Standard
Principle /
Subject Area
P4: Community
Relations &
Workers’ Rights
Strengths Relative to the Standard
 The general view . . . is that the Mt. Hood National Forest is an excellent
employer: management is responsive to employee issues and understands
the challenges for employees in light of budget limitations
 Stewardship contracts/partnership approaches create opportunities for
increasing contact with constituents ,and blend production of resource
commodities and land stewardship in positive ways.
Weaknesses Relative to the Standard

Greater attention could be paid to capacities
and training needs associated with contractors
that perform services on the Forest
CAR/REC #s
 REC 2006.4
 REC 2006.5 .
 REC 2006.6
 Contractors were pleased that stewardship contracts have been
handled/managed well
 Forest work is also established in part through collaborative processes
which reduces conflict and increases cooperation
 Non-supervisory FS employees have the right to organize
 Safety is emphasized as well as adherence to OSHA requirements
 Daily safety briefings are held prior to field visits
 The Mt. Hood National Forest has developed a number of partnership and
collaborative ventures that offer opportunities . . . to provide input and
even participate in management above and beyond NEPA requirements
P5: Benefits
from the Forest
 The Forest Service is not engaged in activities driven by an immediate
need for revenue generation that compromise long-term forest resource
considerations.
 There is an de facto preference for local processing of logs, as these
mostly low-value logs can’t be economically hauled far
 There are Small Business Association (SBA) timber sales, but all active
qualified bidders meet requirements
 Special forest products permits are small enough to facilitate the entrance
of new, small businesses
 Due to ongoing and substantial budget
 Major CAR 2006.2
reductions, the managers of the MTHNF are not  CAR 2006.6 .
able to demonstrate that they are financially able  CAR 2006.7
to support long-term forest management and
restoration, including planning, inventory,
resource protection and post-harvest
management activities at a level that assures full
and continuing conformance with the FSC
certification standards. This is a situation that
pertains to all units of the National Forest
System, not just Mt. Hood. .
 Harvest levels on the MTHNF are presently
insufficient for assuring that managed stands
(i.e., those stands allocated to active
management) are being kept from over-stocked
conditions; there are large extents of overstocked
stands on the MTHNF.
 The probable sale quantity (allowed) is 64 MMBF; actual harvests are in
the range of 25-30 MMBF
Compliance Would Require Either a Change in the Standard, or
Change in Forest Policy
Change in Regional or National Policy
Change in Law, Regulation, or Appropriations
Mt. Hood National Forest Management Relative to the Forest Stewardship Counsel Pacific Coast Regional Standard
Principle /
Subject Area
P6:
Environmental
Impact
Strengths Relative to the Standard
Weaknesses Relative to the Standard






 A sample-based review of partial harvest operations on the
MTHNF leads the audit team to conclude that residual stand 
damage is not minimized and that there are opportunities to

further reduce the damage level.



 Presently, roughly 50% of the road network on MTHNF is

not needed to support management activities and public
access needs on the Forest. Because of budget reductions that 
have, among other things, resulted in the elimination of the

 Roughly 20 different watershed analyses have been done for the whole
 The Forest Service’s green-up requirements for adjacent
forest; each of which cover all of these topics, and require the participation
clearcuts (tied to 4.5 feet of stand height) does not comply
of botanists, wildlife biologists, fisheries biologists, soil scientists,
with the green-up requirement of 7 feet in the FSC Pacific
hydrologists.
Coast Standard.
 Fire regime condition classes have been mapped for the entire region
 Separate analyses have been done for all Late Successional Reserves
(LSRs), which feed into analyses for NEPA. NEPA also requires
specialists/experts in these areas on a project level basis.
 Additional assessments have been completed for individual Late
Successional Reserves (LSRs).
 Roughly 70% of the forest is excluded from timber harvesting and is
either de-facto or officially designated conservation zones
 Even in matrix lands, regeneration treatments require 15% retention (10%
in clumps, 5% scattered)
 Protection buffers are established around selected species locations under
the “Survey and Manage” program.
 The NEPA process is based upon a formal evaluation of potential
environmental impacts (EA/EIS)
 The Forest Service manages the MTHNF for a wide range of native
species, habitats, stand types, etc.
 The Forest Service was fully forthright in discussing old growth policies
and management with the auditor team during the field evaluation..
 MTHNF has been mapped for landslide hazard as part of the watershed
analyses
 If an area is mapped as High Landslide Hazard, MTHNF does not perform
any harvesting/road construction.
 MTHNF places a strong emphasis on aquatic recovery
 The MTHNF has a network of riparian reserves/buffers required by the
Northwest Forest Plan
 Priority fish habitats, like the Hood River Basin have their own aquatic
habitat restoration plan
CAR/REC #s
Major CAR 2006.2
CAR 2006.8
CAR 2006.9
CAR 2006.10
CAR 2006.11
CAR 2006.12
CAR 2006.13
CAR 2006.14
CAR 2006.15
REC 2006.7
REC 2006.8
REC 2006.9
REC 2006.10
REC 2006.11
Forest road maintenance crew, the overall level of road
maintenance effort is insufficient to keep the road network in
good condition. There is, as yet, no completed road
management plan for the Forest.
 Control of access to temporary and permanent roads on the
MTHNF is presently not adequate in terms of the objective of
minimizing impacts to soil and biota while allowing
legitimate public access. There is a growing problem
associated with unauthorized OHV/ATV use on the Forest.
 With respect to management of old growth, management
practices on MTHNF comply with the Northwest Forest Plan,
but the NWFP standards and guidelines do not comply with
the FSC Pacific Coast Regional Standard, leading
unavoidably to a finding of non-conformity to the
certification standard.
Compliance Would Require Either a Change in the Standard, or
Change in Forest Policy
Change in Regional or National Policy
Change in Law, Regulation, or Appropriations
Mt. Hood National Forest Management Relative to the Forest Stewardship Counsel Pacific Coast Regional Standard
Principle /
Subject Area
P7: Management
Plan
Strengths Relative to the Standard
Weaknesses Relative to the Standard
CAR/REC #s
 Collectively, the MTHNF “management plan” incorporates  The forest plan itself is out of date. Some critical  CAR 2006.16
many planning documents, including:
issues have not been adequately addressed by
planning documents; e.g. roads(need
• MTHNF Forest Plan
Transportation Management Plan) and other
• Northwest Forest Plan (NWFP)
rapidly changing issues such as OHV
management.
• Watershed Assessments
• Project planning
• Reconciliation Document (MTHNF & NWFP)
• Clear goals, objectives, and desired future conditions are
found in the MTHNF Forest Plan, Watershed analyses, and
the Northwest Forest Plan
• There are have been 15 amendments to the MTHNF Forest
Plan
• MTHNF is starting the process now of updating their entire
Forest Plan, with a planned completion in 2011.
P8: Monitoring
 MTHNF produces an annual Monitoring and Evaluation
Report which tracks implementation of the Forest Plan.
& Assessment
 As a pilot forest under the LUCID initiative, MTHNF’s
overall level of systematic monitoring—and reporting
thereof—is quite exemplary
 At present, there is not a clear demonstration of
conformance with the requirement that MTHNF
managers periodically monitor and assess
changes in major habitat elements and the
presence an/or absence of and changes in the
occurrence of key wildlife species.
 CAR 2006.17
 REC 2006.12
 REC 2006.13
 Monitoring of noxious weeds led to the development of the
DRAFT EIS for Site Specific Invasive Plant Treatments:
 The Forest Service has not yet developed a chain
http://www.fs.fed.us/r6/mthood/projects/. This was in the
of custody control system, including written
comment period at the time of the evaluation. If adopted it
documentation thereof.
will become Forest Plan Amendment #16
Compliance Would Require Either a Change in the Standard, or
Change in Forest Policy
Change in Regional or National Policy
Change in Law, Regulation, or Appropriations
Mt. Hood National Forest Management Relative to the Forest Stewardship Counsel Pacific Coast Regional Standard
Principle /
Subject Area
P9: Maintenance
of High
Conservation
Value Forest
Strengths Relative to the Standard
Weaknesses Relative to the Standard
CAR/REC #s
 On the basis of the observations gathered during the
 As the Forest Service’s planning and
 Major CAR 2006.4
evaluation, the audit team considers it unlikely that current
management systems were not developed with
Forest Service standards and guidelines are resulting in
the FSC Principles & Criteria in mind, managers
management actions in the field that are threatening high
of the MTHNF do not have a readily available
conservation values—with the exception of type 1 and type
means by which to demonstrate that they are
2 old growth
meeting the High Conservation Value Forests
(HCVF)-related analytical and consultative
requirements found in FSC Principle 9. As such,
it is not possible for the audit team nor the public
to readily discern if there is adequate
conformance with this Principle. That said,
development of a “crosswalk” document that
demonstrates how various National Forest
planning and analysis procedures map over to
FSC P9 analytical requirements is something that
could be easily done and that in fact has been
done by other Public forest entities that have
undergone the FSC certification process.
Compliance Would Require Either a Change in the Standard, or
Change in Forest Policy
Change in Regional or National Policy
Change in Law, Regulation, or Appropriations