• Recognition that hardwood resources provide the most biologically diverse wildlife habitat in the Angeles, Cleveland, Los Padres and San Bernardino National Forests. The California Wildlife Habitat Relationships system lists hundreds of amphibians, birds, mammals and reptiles, including many special status species, that "prefer or make great use of" the hardwood habitat attributes that characterize the planning area. This multitude of wildlife species demonstrate the exceptional biological value of the hardwood ecosystem found within the southern California national forests.
  
  
• The coarse-filter Southern California Mountains and Foothills Assessment (SCMFA) correctly identified valley oak and Engelmann oak woodlands as rare ecological communities. Unfortunately this evaluation failed to acknowledge that most hardwood resources within the management area represent biologically critical or essential habitat. The DEIS must identify high-quality hardwood habitat areas for special status species, provide standards to minimize habitat degradation in those areas and establish specific standards to maintain or enhance the hardwood ecosystem within each National Forest. COF is confident the fine-filter review of the DEIS will confirm that woodland and montane hardwood resources warrant the highest habitat conservation designations.
  
  
• Inclusion of key wildlife species for hardwood ecosystem assessment, management and monitoring. This list should include coast horned lizard, California spotted owl, ensantina, golden eagle, purple martin, ringtail and Townsend's big-eared bat. These species are consistent with the new planning rule definition for focal species: "species that provide insights to the larger ecological systems with which they are associated."
  
  
• Use of the Sierra Nevada National Forest Plans Amendment EIS as a guide to address hardwood management issues related to grazing, fuels management and monitoring standards. The SCMFA stated that, "On national forest system lands, 60 percent of Engelmann oak woodlands and 87 percent of blue oak woodlands are within grazing allotments." The California GAP Analysis Project observed, "Several oak species, notably valley oak, blue oak and Engelmann oak have exhibited low rates of recruitment in recent decades, adding to the concern about the long-term viability of these ecosystems." The DEIS must integrate grazing and oak reforestation management.
  
  
• · Development of an adaptive management strategy stating that management activities occurring on private hardwood lands adjacent to the southern California national forests will directly affect recreational use of hardwood resources on National Forest lands. The SCMFA succinctly expressed this Forest Service responsibility: "The trend towards increased development of foothill woodlands has several clear implications for public land management. As the urban interface expands and increasingly surrounds public wildlands, demand for recreation and other facilities increase and the ability to manage fire on the landscape becomes more constrained. Second, the decline of high-quality oak woodlands on private lands increases the significance of such habitats on public lands." Notably, the current Land Management Plan for the Angeles National Forest allocates 42,104 acres of Oak/Conifer forest for recreation but only 19,494 acres of Oak/Conifer forest for biological emphasis. The DEIS must include specific hardwood management direction to control recreation-related hardwood habitat degradation.
  

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