PO Box 12065

Portland, OR  97212



June 28, 2005


Brad Keller

Acting Cascades Field Manager

Salem District

Bureau of Land Management

1717 Fabry Road SE

Salem, OR 97306


October 15, 2003


Re: Hillock Timber Sale


Dear Brad:


We are writing in response to your request for information and concerns with the Hillock planning units.  We did get an opportunity to explore some units before this letter, although it was hard to discern the boundaries, as it seems there is only flagging for surveys and the random flagging tape of hunters. We are concerned there may be some old growth involved in some units in section 24, and as this area contains some of the last remaining old growth in the watershed, we feel strongly that it should be preserved. 


There is also a rich diversity of trees in the area that should be conserved in any thinning project. While removing trees from some of these crowded stands may expedite the growth of stands, we worry that the export of future downed woody debris would deplete a vital source of humus to sustain a forest community into the future. In thinning projects within these stands, the removal of trees would also create a loss of habitat by destroying the potential for future snags.




As you likely know, the South Fork Clackamas is in terrible shape. Bark followed the stream from Unit 26 to Unit 24 B and could not believe the condition. There were times we could not even see the stream because it was buried under so much slash. There are hardly any trees growing adjacent to the stream. The soil in many areas is not even exposed enough to start seedlings. Further, there are clearcuts all along the east side of the South Fork. There are signs all over these clearcuts of soil loss.  This is ultimately ending up in the river. With there being no vegetated buffer strip along the South Fork and the clearcuts extending right up to the stream, we would strongly encourage restoration in these areas to prevent further sedimentation. Given the steep slopes in this area, we hope that any activity in Units 26 A and B will entail some sorely needed restoration. We would also encourage that streamside restoration throughout section 24 be included in the planning process. 


There should also be comprehensive cumulative effects analysis done to be sure there is no further compromise to this water source. In the Clear Dodger EA it stated there were already moderate water quality issues in the Clackamas Watershed. Any analysis should consider the potential impact to communities’ water supplies. An environmental analysis should also recognize that there are 5 other timber sales slated to occur on the South Fork Clackamas River and take these into consideration when assessing the impact to the watershed.  There should also be site-specific analysis to see how an increase in peak flows will affect the health of each stream channel. 


Also on these steep slopes, the use of skid trails may disrupt the drainage system, as these areas will denude their path and potentially create mass wasting and reroute water flows.

We encourage you to eliminate areas with steep slopes from the planning area.


Late Successional Forests


The view from Road 45 offered the opportunity to witness the abuse this valley has already received. The Northwest Forest Plan (NWFP) states that watersheds that have less than 15% of its area in late successional forests should be managed to retain all Late Successional Old Growth (LSOG).  The Lower Clackamas Watershed Analysis sited only 15% late successional forest left in the area. So legally, it seems that all the late successional forests in this area should remain. According to NWFP scientists citing “the bare minimum,” this area cannot support the loss of vital old growth , given that there is so little left in the South Fork. Also the NWFP requires the protection of isolated patches of old growth in Matrix lands where little remains (C-44).  These last stands provide critical habitat, are a genetic reserve, prevent erosion (especially on these steep slopes), and serve as a firebreak.    


These few pockets of old growth in the area also possess the only substantial amount of snags available for habitat, as many of the planning units are already clear cuts and young forest.  As there are few such habitats available for wildlife, these areas should be preserved. Further, any thinning activity should maintain snags already present in the units for the future. Human made snags do not replace nature made snags. Girdling a tree creates a snag only by definition.  The problem with this is that without the natural decay process this “snag” is uninhabitable. (“Created Snag Monitoring in the Willamette National Forest” by Boleyn, Wold, and Byford).   


Lastly, according to scientists at the Regional Interagency Executive Committee we should now protect all that remains of late successional/old growth forests.  Further, recent polls have shown that 75% of the American public supports an end to logging LSOG forests. These are just a couple of details we think planners should keep in mind when planning this sale. 







We will be curious to see what the road density of the area is.  Just by looking at the map, the area appears to have an exceedingly high road density.  It seems there are many roads in the area that are not needed in the road network; for example, Road 4510. Where this road connects with Road 150, Road 150 has deep pits from erosion and is now only passable by ORV or Jeep, which is exacerbating the problem.  Just west of Road 4510 at this juncture, the forest floor has been covered with soil from the runoff of these roads, caused by the recent rains.  There are also “ghost roads” created by ORVs and/or Jeeps that are not part of the system, just off Road 45. These roads are going straight up embankments and causing serious damage. These paths should be blocked to prevent any further destruction.


There are also roads such as the road just south of 4530 on Road 45 that we feel should be decommissioned.  This road just goes up half a mile before reaching a berm. This berm should be relocated to where this road begins.  Also Road 180, ½ a mile from the Road 45 juncture, goes right over the top of a stream.  A berm was constructed, but it is currently acting as just another exciting obstacle for ORVs. We encourage you to properly decommission this road in order to protect this watershed. We are also curious about the state of road 4530, which has been gated all season.  As we have already informed you, the only road heading west from 4530 in section 24 now has a pond in the middle of it. Thank you for keeping this road closed. Are you planning on permanently decommissioning this road? Are there any projects planned for the area in the near future?


Survey and Manage


The last time we were in this area, we found elk scats in units 24 B and C.  As the weather has been getting colder, it would be good to see how many elk are relying on these late successional forests for thermal cover this winter. We have also seen pilleated woodpeckers throughout section 24, which indicates that other old growth dependent species may be present in these units. Surveys for sensitive, listed, and management indicator species likely to inhabit the area should be conducted if there is not reliable recent population estimates for the species.


Population studies should also be performed on old growth dependent species such as the spotted owl. As stated by the Endangered Species Act (ESA), the BLM must “insure that any action authorized, funded, or carried out by such agency is not likely to jeopardize the continued existence of any endangered species….” There should be surveys conducted to show potential effects from the project to spotted owl habitat. There should be a clear environmental baseline developed for species potentially at risk from activities. There also should be cumulative impacts analysis done for wildlife and their habitat.




When walking through or near unit 24 C at the top of the hill between Road 45 and 4510, there was a large quantity of downed logs of substantial girth. As we ventured further east, there was an old logging road and then small dense trees.  It appears previous activities have already induced some blowdown. Please consider potential loss from Blowdown on steep slopes when determining canopy closure estimates for the units.




As mentioned earlier where road 4510 connects with Road 150, there is dirt from the road that has completely covered all of the ground cover adjacent to the road. With this much erosion apparent at this juncture, it’s not hard to imagine the amount of sedimentation entering the South Fork Clackamas.  At many areas there are clearcuts starting right at the water’s edge and extending a ¼ mile up these very steep slopes. It also seems there are poor revegetation rates in these activity areas, which should be kept in mind while proceeding. The state of the South Fork combined with the steep slopes present require great caution and detailed analysis. This is especially true in units 26 A and B. Environmental analysis should include quantification of sediment to completely gauge the full impact of proposed activities. It would also be encouraging to see road closures as a part of the project to decrease this problem.


Cumulative Effects


As stated in Thomas v. Peterson, your analysis documents need to include the effects of past, present, and reasonably foreseeable future projects. There are five other timber sales slated to occur in the South Fork Watershed, and these actions should be assessed as a whole. There should also be assessments performed on habitat availability for sensitive, management indicator, and threatened and endangered species.  We would also encourage the inclusion of post monitoring and mitigation when assessing the costs and long-term effects of any project in your environmental analysis.


Fire Risk

We are concerned that your proposed activities will increase the risk of fire in the area with due to planned thinning and road building / reconstruction. Scientific evidence has shown that fire risk increases in forests that are thinned, due to the increase in slash and ground fuels as result of the projects in addition to creating a warmer microclimate. Given the high recreational use of this area by hunters and the fact that forest fires often start on or near road, this area is at high risk. Additionally, this area is surrounded by tree farms, known to ignite more readily than native and old growth forests. There are a number of nearby communities that would be at risk in the case of a catastrophic fire.



Based on the potential environmental impacts listed above, we encourage you to complete an environmental impact statement for the Hillock project. Thank you for considering our concerns. If you have any questions, please feel free to contact us.




Gradey Proctor



Sandi Scheinberg

Executive Director, Bark