Acting Cascades Resource Area Field Manager
Re: Annie’s Cabin and Missouri Ridge Projects
Dear Rudy Hefter and
Thank you for the opportunity to comment on the Annie’s
Cabin and Missouri Ridge Projects. I was not able to see the Missouri Ridge
Project, due to an impasse with private land access. However, I am heading out
the field with
Annie’s Cabin is a 1,260 acre project planned in the Molalla River Watershed. Stands have been identified by the BLM to range from age 30 to 80 years old. Most of this project would take place in the Molalla River/Table Rock Special Recreation Management Area (SRMA). Bark has numerous concerns about this project, which range from impacts from road building to the affects on recreational opportunities. Much good will has been built up between local community groups, such as Molalla River Watch and the BLM over the years in relation to this area. Thousands of volunteer hours have been devoted to restoring the area to a place of scenic beauty and environmental viability. Proceeding with this project has the potential to destroy not only good will but a much beloved landscape that is just beginning to heal.
One of our main concerns involves potential road building and reconstruction that could be required to log the area. Roads, even if “temporary” by description, have significant affects on the environment. There is abundant science dealing with the adverse affects of roads on wildlife and watersheds. This comes in the form of habitat fragmentation, soil compaction, sedimentation, introduction of invasive weed species, increased likelihood of off road vehicle abuse, and increased risk of fire, to name a few impacts. We strongly oppose any action that would involve building new road or reconstructing old roads which have begun to revegetate. The road density in the planning area is already high. There is also already a high risk of sedimentation due to ongoing winter use of trails from stock and mountain bikes. The day I was in the field in early November, there were muddy pools on many of the trails, and several were closed due to poor conditions. A high priority of the BLM should be to reduce impacts from roads through decommissioning ripping and restoration, turning more road miles to trail miles, not building new roads.
Most of the project would take place in the Molalla
River/Table Rock SRMA. This has been designated, per the Salem District RMP,
for recreation activity and experience opportunities. One of the prized
features of this SRMA is the Shared-Use Non-Motorized Trail System. As your
scoping document states, many partners and volunteers have played a critical
role in developing and managing recreation opportunities in the area. There is
no doubt that the quality of recreation will be negatively impacted by logging.
On a basic level, recreationists will be inconvenienced by the logging
operations, and affected by visual impacts, and noise. The quality of
recreation will diminished for years to come. This area, which is surrounded by
private lands, provides a rare recreational opportunity for local community
members. It also is an attraction for people from surrounding communities.
There is great potential for the City of
During my visit to the area, I noted numerous animal tracks. This area is obviously heavily used by wildlife, particularly deer. There is also a healthy population of fungi and mollusks. BLM’s NEPA analysis needs to include information on the role this planning area plays for wildlife, and in particular its role as a migration corridor for species. What animals rely on this area? How fragmented is the surrounding landscape? Is this the last viable habitat in the vicinity for native species?
CUMULATIVE EFFECTS AND SURROUNDING PRIVATE LANDS
From the project area, facing east, it’s easy to see large
scale clearcuts across the
A number of the areas marked for logging are on very steep slopes. What will the impact be on the soil? What will the cumulative impact be on soil from existing and proposed roads? From additional skid trails?
Invasive weeds have the potential of being a serious p
SNAGS AND PRE-COMMERCIAL THINNING
Due to past management involving clearcutting, this area has
few large downed logs and little downed woody debris on the forest floor.
However, there are signs that the forest structure is beginning to change as
trees in denser stands are falling over and creating openings in the canopy. If
left alone, this process of natural selection will result in downed woody
debris and increased growth rate for nearby trees no longer competing for
resources. I explored the northern section of the planning area, and saw a few
stands which were extremely dense and devoid of undergrowth. These areas could
benefit from some pre-commercial thinning to increase the rate of down woody
debris on the forest floor and decrease competition. However, the majority of
the stands I visited had a lush and diverse array of undergrowth species, with
a healthy amount of space between trees. Bar
In the areas north of the intersection of the Huckleberry
Trail and the Rim Tie Trail, there were numerous larger trees. A few measured
10.6 feet in circumference. Many were 6 feet circumference. These older trees
Several riparian areas are marked for treatment, some of them very steep. I also noted riparian areas that were dense with hardwoods but not dense with conifers—a natural evolution of an area that has been logged and is in recovery. Some of these areas were also already very open due to blow down. What is your proposal for the riparian areas? We are concerned that logging will increase sedimentation and is a risk not worth taking when this area is healing well on its own time.
Based on our above concerns, Bark asks that you cancel the Annie’s Cabin project. We feel that for all of the reasons state above that this area in incompatible with commercial harvesting. The best and highest use of this area is for recreation and native habitat.
Thank you for considering our comments.