Brad Keller, Field Manager, Cascades RA
I am writing to comment on the Turnridge
Timber Sale Environmental Assessment.
1) I am very concerned that the preferred alternative calls for
aggressive logging in mature forests. We
should not be logging in mature or old growth forests. We should not be logging in our last native
forests. In September 2001, a group of
scientists wrote Region 6 stating that based on new scientific evidence, there
should be no more logging of mature and old growth forest ecosystems. I am concerned this information has not been
adequately considered.
2) Cumulative Impacts: There is
very little older forest left in the Rock Creek Watershed. Much of the land there is state and private and
managed on short rotations. The forests
in the Turnridge area contain some of the best late-succesional forest around.
I do not believe the EA adequately discussed the cumulative impact for
cutting these sales.
3) Unit C-2. This is the only unit in the
Connectivity/Diversity Block, in which the Salem BLM Resource Management Plan
says that forest practices should be modified to recover old-growth conditions
to provide for connectivity habitat between Late-Successional
Reserves and maintain legacy structural components like snags, coarse woody
debris, plant diversity, and variable stand densities. (RMP p.
21, 48). This grove
contains some of the largest trees in the
4) Spotted Owls. Portions
of unit D-6, A-1, and B-1 are within the provincial home range radius (1.2
miles) of active northern spotted owl sites. 27 acres of suitable habitat would be
destroyed and 86 acres would be degraded.
This project “may effect, likely to adversely affect" the spotted
owl. Please drop all units that are “likely
to adversely affect” the spotted owl.
5) Red Tree Voles. I do not believe the BLM did an adequate job
surveying for Red Tree Voles in this area.
I understand you are currently re-doing the surveys. I expect that this new information will
significantly change the proposal.
6) New road to unit B-1. There are too many
roads on our public lands. Bark recently
released a report on the state of roads in the Clackamas River Ranger District
of Mt. Hood. It found that 25% of the
roads that were supposed to be closed were not. Both the BLM and the Forest Service continue
to build new roads, even though you do not have the funding to maintain or
adequately close With
what funding do you plan to decommission this road? You did not analyze the current road
density. What will be the cumulative
effect of this road? Even temporary roads have cumulative impacts. They impact the area as they are being built;
they impact the area even after they are decommissioned, and often they are
continued to be used by ORVs. What plan do you have to address ORV
usage? If you have to build a new road
to get to an area to log within the Turnridge sale,
the area was not meant to be logged.
Leave it alone and build no new roads.
Sincerely,
Sarah Wald
301 NE Ivy