PO Box 12065

Portland, OR  97212



December 7, 2004

Additional Points of Concern Regarding the Annie’s Cabin Project


Eliminate Northern & Southern Units from the Project


1) Constructing Roads in Unstable Areas

This area has experienced a landslide, which has washed out a stretch of road. Despite instability of this slope, the BLM is proposing to construct a new section of road to extract timber in the southern unit north of Aqua vista area. This landslide area is re-stabilizing itself naturally through re-vegetation; new road building would disturb the recovery process and potentially have long term hydrological impacts. Building new road in unstable terrain is not based on good restoration principles. Moreoever, the area that would be opened up to logging from a new road is not dramatically dense, and not in desperate need of restoration. If thinning needs to take place here, trees should be felled and left in place to provide needed nutrients to the forest floor. The southern units should be eliminated from the Annie’s Cabin project completely.



Additionally, the road to the north of the landslide area has re-vegetated and closed in to become a trail, seemingly rarely used. We suggest it be left that way.



3) Road Construction Crossing Streams, Washed Out Road and Non functioning Culvert (T6S-R3E, Section 31).

The below section of road would also require dramatic and costly road reconstruction, again, for short-term use. Reconstructing this road would likely have adverse hydrological impact on the area. To invest significant funds to rebuild this road and replace the culvert for a road that has become a trail and would not need to be used again as road is irresponsible and a waste of resources. All of this for how many board feet of lumber?



Accessing the Northern units near Leap Frog Loop (mismarked on map provided by BLM) would also require road reconstruction over a stream labeled Trout Creek. Again, this is not good restoration practice.



4) Waste of Volunteer Time & Resources  - Trail built Around Land Slide To Be Replaced By Road Going Through Land Slide

When user groups asked to build a trail over the above landslide area, they were told by the BLM that the area was too unstable for a trail, and that any trails should be re-directed around the landslide area. However, the BLM is now proposing to punch a road right through it. Double standard? Volunteers clearly took great pains to install this environmentally sound trail circumventing the slide. Under the Annie’s Cabin proposal, all of this effort and goodwill will go to waste.




5) Need Explicit Diameter Limit for trees to Be Removed

There should be a clear description in the EA about the size of the trees that would be removed, including a diameter limit. Below is a large Tree in northern most unit. Will it stay?



6) No New Road Should be Constructed to Access Amanda’s Trailhead Units (Section 7).

This northern section has fairly healthy sized trees that are not densely stocked. The cost to the environment and recreation are not worth any benefit in terms of reduced density. Significant road reconstruction would be needed in an area that has re-vegetated into a nice trail accessing MacBeth’s Loop Trail. Similarly to southern most units, this area should be dropped entirely from the scope of the EA. An additional problem with this area is invasive weed infestation. There is an existing problem with Scott’s Broom, which will be exacerbated by logging and hauling.