Crystal Clear: This proposal is not a fire mitigation project to protect the forest.

To our friends at USFS and beyond.


In the eleven years I have called Portland my home I have been fortunate to spend many hours exploring the diverse ecosystems of Mt Hood National Forest.  As an ecologist trained in climate science and fire ecology, I read with concern the scoping letter for the enormous Crystal Clear planned timber sale, mistakenly called a “Restoration”



Of greatest concern is the unusually short timeline for decision-making on this project, especially given its unusually large size.  The proposed project was first announced in November of 2016, and this comment period closes on April 1.  The letter states that final decisions will be made in the summer of 2017.  An important part of the public engagement process is the opportunity for concerned persons to visit the site.  Winter snow cover at elevation inhibits such visits and limits the ability of visitors to see understory vegetation.  Comments received, like this one, will come from a general understanding of forest ecology and practices, rather than from direct observation.


Also of great concern is that this project is entirely within critical habitat for northern spotted owls, as well as supporting other sensitive wildlife species.  The scoping letter does not mention this fact.


The letter describes accumulations of dead and downed wood as a problem in terms of fire risk and forest health.  This raises two questions.  First, does the timber sale propose to remove only dead wood, rather than live trees?  Second, why is this being described as a problem?  A visitor to old growth forest sites will observe abundant dead and downed wood. Standing snags are important habitat for many wildlife species, and downed logs provide sites for growth of both understory and canopy vegetation.  Decomposing dead wood creates the rich, moisture-retaining forest floor so characteristic of mature forest.  Many plant, lichen and fungal species can thrive only where decomposing downed wood is abundant.


In areas without human habitation, a central fallacy is the premise that fire is a problem to be prevented.  The natural systems of this bioregion evolved with fire, and there are many native species that thrive after a fire. Some native plant seeds are unable to germinate without fire.  The east side of Mount Hood is rich with fire-dependent vegetation. I read with some hope that the plan for this area of forest does include reintroducing natural fire.


The second fallacy is the assumption that the best way to reduce the probability, spread, and intensity of forest fires is by reducing fuel loading.  In fact, many other factors are at play - ambient temperature, humidity, slope, and more.  In many cases the most important factor is wind speed.  My own research has shown that cleared areas typically allow much faster and more extensive spread of fire at any intensity. The proposed thinning reduces the canopy enough that the wind-breaking effect of wooded areas is greatly reduced, potentially allowing higher winds and accelerating the land-clearing effect of fire.


Canopy reduction also encourages the growth of sun-loving and highly flammable species such as grasses and Himalayan blackberry, which provide fine fuels that both increase the probability that a fire will begin, and support its spread.


The assessment discusses fire risk to human settlements.  It is often advisable to clear brush and fine fuel away from human habitation.  A management strategy to protect communities from fire would emphasize clearing brush and mowing grasses, while maintaining tree canopy for shade and cooling.


Finally, as more evidence shows that climate change is accelerating, we cannot in good conscience allow any significant reduction of our forest canopy.  It is well known that trees are an important sink for atmospheric carbon. Furthermore, the 50% or more canopy reduction in these "thinning" proposals reduces both transpiration and shading, warming the local microclimate.  This accelerates the decomposition of forest floor organic matter, releasing not only carbon dioxide but other global change gases such as nitrogen oxides, which create local pollution and catalyze the destruction of stratospheric ozone, and methane, a much more powerful greenhouse gas than carbon dioxide.


This proposal is not a fire mitigation project to protect the forest.

It is a huge and rushed timber sale for commercial logging.  I propose it be named as such, and that USFS undertake a full EIS to assure that no old growth forest or other critical spotted owl habitat areas will be damaged.


Thank you for hearing my concerns,


Rachel Freifelder

MS Ecology, Stanford University, 1993.


cc: Senator Jeff Merkley

Tina Kotek, Representative, State of Oregon Earl Blumenauer, Representative, 3rd Congressional District Brenna Bell, Staff Attorney, Bark



Rachel Freifelder

Handmade Gardens - Edible and Native Organic Land Care/Food Education