PO Box 12065

Portland, OR  97212



December 10, 2003


July 26, 2005


Andrei Rykoff

595 NW Industrial Way

Estacada OR 97023

Tel. 503-630-6861.


Dear Andrei,





We are writing to express our concerns with the Collawash project as outlined in the Preliminary Assessment (PA). The Collawash / Hot Springs Watershed Analysis (CHSWA) describes this watershed as “the most unstable within the Mt. Hood National Forest.” Most of the Collawash thinning units are in areas designated as B-8 Earthflow areas, with some B-6 Special Emphasis Watersheds, B-2 Scenic Viewsheds, and others (a small amount of C timber emphasis designation) as well.  A GIS layers available from the Mt. Hood Data distribution center also lists most of the harvest acreage as ranging from High Risk to Moderate to High Risk of landslides (Collawash Mass Wasting Risk Map).  Soil analyses list soils within the harvest area as being highly erosive and unstable.


In addition to being the most unstable watershed on Mt. Hood National Forest, Collawash overlaps is also a Tier 1 watershed, which means that it is prime anadromous fish habitat.  The mitigation measures for many of the anadromous fish species discussed in appendix J2 of the Northwest Forest Plan suggest the removal of Tier 1 watersheds from the timber base. Given this, we feel that any actions taken need to be designed with restoration in mind, first and foremost, involving both clear short and long term benefits. The Northwest Forest Plan is an ecosystem management plan that requires biodiversity to be maintained and enhanced in these special emphasis watersheds.  The Collawash project should specifically address the specific manner in which the proposed thinning will both maintain and enhance biodiversity, with examples from scientific literature relevant to unstable landscapes.


There have been many lessons learned in the aftermath of the Fish Creek watershed fiasco; the lack of actual fish in Fish Creek being the prime indicator of a history of erosion, slides and mass wasting. Mean monthly flows for Collawash River indicate that it is much flashier, and therefore more prone to deliver sediment and degrade fish habitat, than both Fish Creek and the Upper Clackamas River (CHSWA, 3-12).  Fan Creek shows clear signs of recent landslide activity and slides, slumps and debris are clearly present in half of the proposed units. Logging in Riparian Reserves under these highly unstable conditions will yield indeterminate outcomes.  This is unacceptable under the Northwest Forest Plan provisions for special emphasis watersheds. The Collawash project area is currently home to an array of threatened fish species and has historically harbored a variety of other fish species, including steelhead. 


Instead of conducting commercial logging and road building within the Collawash watershed, which will generate highly controversial consequences, a restoration effort should be undertaken to create conditions that would increase threatened fish populations and bring back steelhead and other fish historically present in this area.  Additionally, due to the complex and possibly severe adverse effects of the Collawash project, we request that a full Environmental Impact Statement (EIS) be issued.  We also ask that questions raised in this letter be thoroughly investigated in the EIS.



Purpose & Need


The scoping letter states that, “There are many second-growth stands that are experiencing a slowing of growth due to overcrowding.”  How do you define over-crowding? The Pacific Northwest Science Update “Restoring Complexity: 2nd Growth Forests & Habitat Diversity” states that “crowded trees are tall but skinny; little vegetation grows on the forest floor” (4).   Most of the Collawash units we explored had a rich diversity of life on the forest floor. There was much Oregon grape, vine maple, and rhodendrum. In many respects, this forest does not fit into the description of an impaired plantation stand that might benefit from human intervention.  The PA for Collawash maintains that “stand exams indicate that the trees are becoming too crowded and that growth and health would begin to decline if there were no thinning” (PA, page 21).  This affirmation is in opposition to our observations, the CHSWA and subsequent sections of the PA.  The CHSWA’s executive summary insists that the Forest Service should “focus restoration silvicultural projects in Riparian Reserve early seral stages” (CHSWA, 1-4).   Forests at mid seral stages are not fit for thinning for two reasons.  First, they do not respond as positively to thinning as early seral forests because “as stands mature they reach an age at which thinning may not result in the same growth response that would be expected in younger stands” (PA, page 36).  Second, their ability to function as dispersal corridors for late seral species is highly ambiguous (CHSWA, 3-31).  If mid seral stands can fulfill functions similar to late seral stands, thinning would generate much more ecological trauma than enhancement.  The plantations designated for this project are mid seral stands and have already reaped the benefits from thinning at an early age.  Thinning projects in these stands should be immediately aborted and instead directed toward early seral growth.


It is clear from the PA that the ultimate goal of this is to speed up tree growth for future harvest, irreguardless of forest health.  The entirity of section 4.4.1, which “describes the likely future scenario for thinning” (PA, page 31), is devoted to highlighting the steady amplification of thinning projects in the Clackamas River Ranger District since the 1970’s, and projects a more than doubling of current thinning acreage in the near future.  It states that thinning at multiple stages throughout a forest’s life, especially during the most economically beneficial and ecologically detrimental period of maturity, is standard.  One must assume that future harvest for economic benefit will occur.  As stated, the position and geology of these units make them extraordinarily inappropriate for commercial harvest, both now and in the future. This intent is not compatible with the goals of a Tier I Watershed, where protection of water quality for the sake of anadromous fish is the overriding objective.  In fact, as subsequently discussed, the health of anadromous fish species is not even a secondary goal.  According to the PA, the effects determination for threatened anadromous fish species is “May Affect, Not Likely to Aversely Affect.”  Instead of enrichment, a possible degradation of fish habitat will occur as a result of this project.  This is unacceptable in a Tier 1 Watershed.



Critical Habitat for Northern Spotted Owl


The Collawash thinning project, as proposed, will degrade Northern spotted owl critical habitat, contributing to the regression, not recovery, of the threatened Northern spotted owl.  Unit 10 and a portion of Units 9A and 9 B, totaling 55 acres, are in land federally designated as Critical Habitat for the Northern spotted owl (Critical Habitat Unit OR-12). One of the FWS’ consultation duties is to ensure that other federal agency actions do not result in the destruction or adverse modification of designated critical habitat.  16 U.S.C. § 1536(a)(2). In addition, Forest Service regulations require measures for preventing the destruction or adverse modification of critical habitat. 36 CFR § 219.27 (a)(8).  “Critical habitat” is defined in the ESA as “[t]he specific area within the geographic area occupied by a species . . . on which are found those physical and biological features (I) essential to the conservation of the species, and (II) that may require special management considerations or protections.”  Id. § 1532(5)(A)(i).  “Destruction or adverse modification” of critical habitat is defined as “direct or indirect alteration that appreciably diminishes the value of critical habitat[,] . . . includ[ing], but . . . not limited to, alterations adversely modifying any of those physical or biological features that were the basis for determining the habitat to be critical.”  50 C.F.R. § 402.02.  “Conservation” is further defined as “to use and the use of all methods and procedures necessary to bring an endangered species to the point at which measures provided pursuant to this Act are no longer necessary.”  16 U.S.C. § 1533(3).


These statutes and regulations provide strict requirements for habitat protection that will be violated under the proposed action.  According to the initial Biological Opinion of the FWS: “The Biological Opinion anticipated that 68 acres of dispersal habitat would be removed by heavy thinning and 62 acres of Nesting/Roosting/Foraging (NRF) habitat would be downgraded (USDA 2005, page 121). After refinement of the proposed action and field verification, the current assessment of impact is zero acres of dispersal removed and 55 acres of NRF downgraded” (PA, page 39).  What were the precise decisions that caused this change in acreage?  Additionally, “All of the harvest units are dispersal habitat” (PA, page 38). 


Habitat degradation of this type is causing the Northern spotted owl to become increasingly threatened.  The PA argues that this short term decrease in habitat quality is acceptable because “the area would eventually become NRF habitat again” and “in the long term” the habitat may be more suitable for spotted owls (PA, page 39).  For a species listed as threatened, this is a risky and unacceptable conservation strategy. Exactly what does this timeline look like—how long will “eventually” take?  As recognized by the spotted owl status review, all existing suitable habitat could be critical to the survival of the spotted owl. Will there still be a local spotted owl population to repopulate the area in the future?  Degrading NRF habitat from suitable to unsuitable habitat today will only exacerbate the trend in reduction of NRF habitat quality and suitable NRF quantity which is “resulting in reduced populations of spotted owls” (PA, page 41).  Currently, only 49% of the Collawash watershed is suitable NRF habitat, compared to the historic level of 75 % of the watershed.  The PA claims, however, that “there would be no discernable cumulative effect” on spotted owls because although the quality of critical spotted owl habitat will be diminished, no overall change in habitat quantity would occur (PA, page 39).  This is untrue: a quantity of 55 acres of suitable NRF habitat, which is also defined as Critical Habitat, will be made unsuitable (PA, page 41).


The CHSWA acknowledges the likely decline of spotted owl populations, targeting timber harvest such as the proposed action as one of the main contributors to spotted owl regression.  The Analysis insists that spotted owl population declines are directly dependent on location of harvest units and that “a slow decline would pose less risk to the population and would be best achieved by concentrating harvest outside known owl activity centers” (CHSWA, 3-36).  Because the timber harvest units proposed in Alternative B encompass spotted owl Critical Habitat, NRF habitat and dispersal habitat, the recommended alternative may accelerate spotted owl decline.  No thinning project claiming to use ecological restoration as a motivation can jeopardize local populations of a threatened species. The Proposed Action fails to adhere to conservation stipulations enacted for the protection of the northern spotted owl and therefore should be withdrawn.


Barred owl territorial expansion as a result of harvesting may further displace spotted owl populations.  Reduction in habitat quality post-harvesting could cause an increase in both inter- and intra-species competition.  In the case of the threatened Northern spotted owl and its common competitor, the barred owl, this competitive escalation could very easily result in spotted owl displacement and loss of habitat.  If this scenario unfolded, the PA would support Alternative B under the erroneous affirmation that “No loss of dispersal habitat would occur” (PA, page 39).  Spotted owl critical habitat will, with certainty, experience an even greater reduction in quality as a result of the project, and possibly experience reduction in quantity. 


Furthermore, this project very poorly adheres to BMPs concerning spotted owl protection.  During the critical nesting period for spotted owls, noise generating activities are allegedly prohibited.  However, road use by inescapably loud trucks, log hauling and hazard tree removal are condoned.  These activities not only sufficiently pollute the area through their noise production, but also disturb nesting, roosting and foraging activities in other ways.  On top of this, the already minimal noise restriction may be waived if no nesting activity is detected.  How can we be assured that the survey protocol employed to determine nesting activity will be thorough, especially given the decreasing levels of staffing in the district?  Even minor negligence can result in an inaccurate determination, which may prove critical to the species.


If “in the context of the local and watershed scale, the project would adversely affect the spotted owl and its habitat” (PA, page 40), how does the project contribute to spotted owl recovery?   As required by law, the FWS must physically protect and restore designated critical habitat to achieve “recovery” not just maintain the species in bare survival mode. This is the legal mandate of the  ESA as reflected in three circuit court opinions Gifford Pinchot Task Force v. FWS (9th Circ August 6, 2004), Sierra Club v. U.S. Fish and Wildlife Service, No. 00-30117 (5th Cir. Mar. 15, 2001). N.M. Cattle Growers Ass’n v. United States Fish and Wildlife Serv., 248 F.3d 1277, 1283 & n.2 (10th Cir. 2001).  In order to ensure that any action taken will lead to the recovery of the Northern spotted owl, we request a thorough research and report addressing the Northern spotted owl habitat in the Environmental Impact Statement.


Steep Slopes & High Risk of Landslides


According to the Background Sediment Regime Map of the CHSWA (2-16), units 1-4 of the project are in or adjacent to areas of the Collawash Riverbank categorized as “Ancient landslide (active and dormant), Streambanks, Unstable Drainageways, Rapid Stream Downcutting, Debris Slides and Flows in Major Drainageways, Soil Creep, Slope Undercutting” (2-16).  On the map, the thickness of the line indicating this condition denotes its relative sediment production rate.  This area of the Collawash Riverbank occupied by units 1-4 consists of one of the thickest lines on the map.  Consequently, units 1-4 produce among the highest rates of sediment in the entire Collawash / Hot Springs Watershed area, already one of the most unstable watersheds of the National Forest.  Also, there are active landslides near units 9, 9A & B, and 10 that, according to the PA, are associated with previous logging activity.  If these sites are harvested, there is a high probability for increased landslides in the future. Any sediment produced as a result of timber harvesting flows directly into the Collawash River from perennial and intermittent streams.  Dutch Creek, for example, which is at the base of the units 9 and 10 drains directly into the Collawash River. Additionally, most of the units fall under an “Ancient Landslide (Dormant)” categorization in the Landform Type Map (CHSWA, 2-20), which has a medium to high relative hazard rating.  The relative hazard rating is based on (1) susceptibility of landform type to mass-wasting events and (2) likelihood of sediment from that event reaching a defined channel.  This indicates that not only is the sediment production rate abnormally high in the units, but also, there is a high probability that nearby streams will be impacted by this sediment production.  The information provided in the CHWA, therefore, directly contradicts the PA’s speculation that threatened fish species and overall water quality will not be adversely influenced by the project.


The Flows Map (CHSWA, 3-41) indicates that units 1-4 are in a “Mass Wasting / Sediment Area” flowing directly into the Collawash River, while units 9 and 10 occupy the same type of area, instead flowing into Fan Creek, which then flows into the Collawash River.  While mass wasting and sediment production is a problem under normal conditions, the CHSWA admits to the escalation of this hazard as a result of forest management activities such as Alternative B.  “Management activities on these landforms [those with an inherent risk of mass wasting, including the majority of Collawash thinning units],” the CHSWA states, “increase the relative hazard for inducing landslides and mass wasting occurrence” (CHSWA, 2-21).  The CHSWA further recommends that roads built on unstable topography be removed in order to “maintain or restore natural flows” (CHWA, 1-7).  Yet this project proposes to reopen 0.7 miles and construct 0.8 miles of roads.  What will be done to prevent landslides as a consequence of this project, more specifically in relation to the proposed road building?


Steep Units of Concern:

Unit 423 (3)

Unit 5 (420)

Unit 6

Unit 7 (487)  Sign of landslide along northern border


Unit 9B (428) B East side is very steep.

Unit 10 (429)


In order to justify logging on highly erosive and unstable terrain, the PA claims to follow Best Management Practices (BMPs).  However, the soil types of the logging area preclude the project’s ability to follow certain BMPs.  One such BMP incorporates the stipulation that, “during unit and road placement, certain areas were avoided such as sensitive soil types and landforms” (PA, page 33).    The PA aims to abide by this BMP through road construction “only where conditions would prevent sediment delivery to streams” (PA, page 16).  However, the soils of the proposed units are the most sensitive in the entire watershed area.  All of the units’ soils falls under one of the following two categories: ‘Moderate Deep’ to ‘Deep’ soil, categorized as “very erosive soil types…are usually unstable, associated with large ancients landslides both dormant and active;” or ‘Stream Adjacent Soils,’ categorized as “very erosive, unstable, lack topsoil and organic horizons…they are always associated with perennial streams and major drainage ways, they are constantly subject to erosional forces despite heavy to modest forest cover” (CHSWA, 2-12). This limitation on road construction does not fulfill BMPs because it completely ignores the fact that the majority of units are wholly located in extremely sensitive soil areas.  Unit placement did not avoid sensitive soil types as advised by BMPs, and because of this, selective road placement prevents sediment delivery only relative to other highly unstable areas.  Is this acceptable in a special emphasis watershed?  The PA claims: “Adverse impacts eliminated or substantially reduced by use of BMPs” (PA, page 18).  However, as indicated through this example, BMPs are only partially followed, and therefore the adverse impacts are not avoided.


Because of the highly unstable nature of the proposed units, clearly and consistently indicated by the CHWA, the project’s objective to “manage for conditions contributing to watersheds ability to produce long term high quality water” will not be met.  Increased sediment delivery to streams will worsen water quality, irregardless of the alleged forest stand condition improvements.






The Collawash River is especially prone to sediment production and delivery due to its “flashy” nature; this characteristic is a direct result of the dense road network in the Collawash watershed, and further road building will only exacerbate the problem.  As indicated by the Mean Monthly Flow Chart (CHSWA, 3-12), the Collawash River is much flashier than the Upper Clackamas River and Fish Creek, which are highly comparable in other regards.  The Mean Daily Stream Discharge Chart (CHSWA, 3-13) indicates a significantly higher winter discharge for Collawash River than for the Clackamas River.  Because of this increased winter discharge, summer flow is kept at a minimum.  This is critical to “sustaining habitat for riparian flora and fauna, maintaining cover, forage and travel corridors for other terrestrial wildlife, and providing water for human uses…affecting not only the amount of water available for these beneficial uses, but also the quality of water” (CHSWA, 3-15). Collawash’s tendency for flash flooding, elevated sediment production and summer low flows are a direct result of the already extensive road system veining the watershed.  The CHSWA claims, “Currently, there is a greater amount of sediment production and delivery sites than what existed under the reference sediment regime.  Many upland forested sites that were not sediment sources in the past are now sites of chronic production; most can be directly attributed to roads” (PA, page 3-8).  Collawash watershed is a particularly poor area for road construction, especially considering it has the highest road density of the entire National Forest (CHSWA, 3-14). 


The Collawash watershed hosts 3.5 miles of roads per square mile; the Fan Creek subwatershed hosts an astounding 6.2 miles of roads per square mile.  The impact of the existing roads should be the primary objective addressed in a revised environmental assessment. Considering that there are 6.2 miles of roads per square mile within the Fan Creek subwatershed alone, there should be no additional roads in the Fan Creek subwatershed – temporary or otherwise.  Evidence shows that there is no such thing as a “temporary” road in terms of hydrological impacts.  Nor is the Fan Creek subwatershed the only watershed/subwatershed that would be affected by these sales that currently endure excessive roading. To paraphrase the Northwest Forest Plan, if funds do not exist to decommission roads in key watersheds, no new roads may be built.  Alternative B builds 0.8 miles of new road and recommissions 0.7 miles of old road, while decommissioning none.  It is clear from this and other projects that decommissioned roads always have the oppurtunity of being reopened, reversing the already temporally extensive revegetation process.  Not even touched upon in the PA, the impact of the existing roads should be the primary objective addressed in a revised assessment.


Not only does the watershed have an unusually high road density, but the road placement is less than ideal.  Throughout the watershed, eighty-five miles of road exist within riparian reserves. There are 665 stream crossings, and thirty-two miles of road exist on very unstable slopes and landforms (CHSWA, 3-8).  In just the proposed units, two roads (4620, 6322) are labeled “Roadways on unstable or very unstable landforms, high failure potential” according to the CHSWA.  In addition, portions of 6322 are labeled as “High sediment production sites, existing source” (CHSWA 3-9).  Building new roads in this area will contribute to mass wasting and sediment production, causing severe damage to riparian reserves.  The CHSWA strongly advises against additional road construction, recommending instead, to “reduce the road contribution to flashy streamflows” and “defer activities which may delay hydrologic recovery in certain high risk subwatersheds” (CHSWA, 1-6).  While the PA for Collawash maintains that new road construction will have a negligible effect on riparian areas, the CHSWA affirms the opposite result:  “Existing management related sediment production and delivery in the watershed comes primarily from the road system; some sites are chronic producers.  Pathways for sediment transport and delivery have been expanded by road related drainage” (CHSWA, 1-6).  The CHWA continues, “[this causes] potential loss of aquatic habitat, with effects manifested downstream of this watershed” (page 1-6).  The CHSWA’s objective to “reduce human causes of erosion/sedimentation, related to timber harvest and roads” cannot be met with the addition of skid trails, roads and bare soil inevitable from Alternative B of the Collawash thinning project (CHSWA, 1-6).  Even if decommissioned at the project’s end, the added roads will continue to contribute negatively to riparian areas and will likely be reconstructed for future thinning projects prior to their rehabilitation, which will take decades.  Roads are not easily obliterated due to soil compaction, and invasive species often seed first.  Not only will riparian areas and the threatened fish species inhabiting them suffer from sediment deposition and low summer flow, but the reopening and building of roads will further contribute to the fragmentation of habitat, negatively impacting all varieties of wildlife.


The PA states that stream sedimentation will not occur: “The chance that measurable amounts of fine sediment would enter any stream as a direct result of logging activity is negligible. This is because the proposed roads are located on stable landforms, do not cross streams and would be decommissioned” (PA, page 19).   Yet there already exist roads on unstable landforms. Two roads in the unit (4620, 6322) are labeled “Roadways on unstable or very unstable landforms, high failure potential” according to the CHSWA.  In addition, portions of 6322 are labeled as “High sediment production sites, existing source” (CHSWA, 3-9).  In fact, the road system 4620 is highly unstable. On the same south facing slope as new units are proposed for 10 and 9B west, there is a very large wash out in an old plantation (west of intersection bet 4620 and 6322). We feel it is irresponsible to propose logging on this same unstable terrain. 6322-170 has been washed out in one spot and at its intersection with Fan Creek the culvert has blown-out. The “road” is not a functioning road. Fixing this road will be a significant expense hardly worth the cost of extracting trees, and the road will very likely just wash out again. And at what environmental cost?  Additionally, during a previous visit in April of 2002, Road 6321 was cracked and beginning to come apart soon before unit 424. Old roads entering unit 4 crumbled shortly after leaving that road into landslides. Although the 6321 appears to be repaired, the area clearly has a high potential for landslides.  Not only are roads historically unlikely to be built on landforms with sufficient stability (because even the relatively stable land in this highly unstable area is unfit for road-building), but also numerous seeps, intermittent streams and perennial streams have not been marked on the map. Road 4620-330 has three streams crossing it, one perennial and two intermittent. Thus how can we be assured that the proposed roads will not cross any streams?   How can we further be promised that road decommissioning will mitigate sedimentation when road decommissioning will occur only if there exist “earthflows or … detrimental forest conditions [that] exceed Forest Plan standards” (PA, page16).  In sum, the affirmation that logging activities will not contribute to stream sedimentation is supported only by three partially erroneous or highly uncertain assumptions: proposed roads (1) are located on stable landforms, (2) do not cross streams and (3) would be decommissioned.




Deer and Elk Winter Range


Disturbing deer and elk during winter months when food supplies and nutrient reserves are low may have critical results.  Human and mechanical encounters elevate stress levels causing increased metabolic rates and lessen the already limited foraging areas.  The Forest Service plans to deal with this by prohibiting harvest operations from December 1 – March 31 (PA, page 13). However, this prohibition is waived when snow accumulation is less than 12 inches or if elk are determined not to be present in the area.  There are a number of problems with this conditional protection of deer and elk during critical winter months. First, weather conditions on Mt. Hood are such in this era of global climate change that there is great variation of snow levels. Snow will accumulate only to suddenly melt during a warm spell, which will then be followed by severe winter conditions lasting well into spring. Warm interludes during long winter months allow for a brief period of lipid buildup necessary for deer and elk survival. Under the proposed waiver, a restriction would be raised during a warm spell, allowing for the harassment of deer and elk in the vicinity and the lipid depletion that results.  Fat reserves that should receive a boost during that time, will instead suffer the opposite, decreasing deer and elk viability during long winters.  Second, the waiver falsely assumes that disturbance will only occur if snow levels are high. If the snow melts, the animals present will still likely use the area, and not go to another area.  Lipid depletion will result both when snowfall is over and under the decided 12”.    This waiver is clearly designed to favor logging at the expense of deer and elk.  The Forest Service seems to be selectively advocating the protection of deer and elk only when such protection strategies do not conflict with timber harvest opportunities.



Value of Native Stands in Heavily Managed Area


The 55 acres of thinning units (9a, 9b and 10) that are natural second growth are of primary concern.  These stands are some of the last intact forests in the area, particularly along road 4620, which is very fragmented from past management. These few intact stands need to stay undisturbed. Most of the surrounding area is in form of young plantations or recent clearcuts. Not only do they contain nesting/roosting/foraging and dispersal habitat for the threatened northern spotted owl, but also provide valuable habitat for other wildlife as well.  According to the PA, these acres currently “function as optimal cover for deer and elk”, but after thinning would function only as thermal cover (PA, page 50). At least seven migratory bird species (Vaux’s swift, brown creeper, red crossbill, pileated woodpecker, varied thrush, hermit warbler, Hammond’s flycatcher, Wilson’s warbler, and winter wren) using the 55 acres of late-seral stands would be forced to relocate in an already fragmented habitat (PA, page 54).  Currently healthy soil in these 55 acres would be brought to unhealthy conditions (PA, page 58-59).  The natural second-growth stands provide good potential habitat for the pine marten and pileated woodpecker, but thinning would cause significant habitat deterioration, primarily due to the removal of snags.  (PA, page 52)


Snags provide essential habitat for wildlife, and the natural second-growth stands are abundant with them. The PA states that “unmanaged stands similar to the Collawash natural second-growth units have approximately 5 medium snags per acre and approximately 2.9 large snags per acre.” However, “Managed stands similar to the Collawash plantations have approximately 0.1 medium and 0.1 large snags per acres” (PA, page 43).  These numbers demonstrate the significant detrimental impact thinning has on snag habitat. According to the CHWA, a key objective is to “Restore and retain habitat for late seral associated species in Late Successional Reserves, Riparian Reserves and key connectivity areas important to flows across the landscape” (CHSWA, 1-3).  These areas include Riparian Reserves that need to be managed for this objective. Steps to restore and retain this habitat include the creation and maintenance of snags and down logs. These habitat features are relatively abundant in the Collawash native second growth stands, and snag density will be significantly reduced as a result of logging.


While we have concerns about any logging proposed in naturally regrown stands, Unit 9 A (428 A), is a particularly poor choice. This stand is a healthy, intact native forest with very large Doug firs scattered throughout the unit. These trees are well beyond the age that could benefit from any “release.” There was a large downded woody debris on ground and several large snags present throughout unit. The planned new road appears (orange flagging?) to be punched through some large downed woody debris and right next to (or possibly including) several very large remnant trees. Such a road would adversely affect adjacent trees by compacting roots and demolishing downed woody debris which is in very short supply in the project area. Downed wood is a critical feature of a healthy habitat and any remnant logs must be protected in both native and plantation stands (such as unit 8) where they are present. Logging in native stands would jeopardize this important characteristic.





The CHSWA characterizes the watershed as vital to a large number of species that are "declining or at moderate risk for viability" (CHSWA, 1-4).  "The high density of special habitats," the analysis claims, "makes this watershed a significant resource for rare and sensitive species" (CHSWA, 1-4).  On our field visit, we saw a lot of signs of wildlife. The stands were full of birds. Tracks in the snow revealed the presence of snowshoe hare, deer, elk, weasel, rodents, and bobcat. Deer scat and coyote scat were prevalent throughout the area. Pacific salamander and a newt were also sited. Clearly this is an area that is serving as habitat for a range of species.


The CHSWA suggested goal is to "limit disturbance near special habitats"(CHSWA, 1-4).  How is logging on highly erosive soil types and in Riparian Reserves achieving this goal?  Many wildlife species within the watershed depend directly on Riparian Reserve health for their continued viability.  Logging within Riparian Reserves will disrupt wildlife populations and possibly alter forest conditions to the detriment of the population.  Bat populations within the Collawash watershed depend heavily on riparian areas for their future success.  According to the CHSWA, “Most bats also rely heavily on lakes, ponds, wetlands and meadows…Several of the bat species that are predicted to have a low probability of achieving a well distributed viable population are highly associated with wetlands and riparian areas for foraging” (CHSWA, 3-30).  It further states that “experts consulted for the FSEIS felt that the lack of buffer protection provided to small wetlands under the interim riparian reserve boundaries could compromise viability for several bat species” (CHSWA, 3-22).  The PA analyzes management effects on only one bat species, claiming for that species, “no impact.”  What developments have occurred since the CHSWA was written that enable logging in Riparian Reserves without impacting dependent bat species?  How will other bat species be affected by management activities? 


Amphibians also largely depend on the condition of Riparian Reserves.  The CHSWA states that “amphibian occurrence is expected in most of these habitats” and that “dispersal between suitable habitats is likely the most significant issue facing amphibian populations” (CHSWA, 3-30).  How will logging in Riparian Reserves affect amphibian dispersal habitat?  According to the CHSWA, “Few surveys have been conducted and there is little local knowledge of the distribution of aquatic amphibians relative to stream gradient, temperature, shade and sediment” (CHSWA, 3-22).  What studies have been completed since the Watershed Analysis’s publication that have led the Forest Service to assure “no impact” on many amphibian species?


Evidence of beaver in the form of downed trees and several nesting sites was detected adjacent to unit 1.  The CHSWA claims that despite the ability of the watershed to support a relatively high density of beaver, few to no beaver are now occupying these sites.  How will logging activities affect beaver habitat meters away?  In addition to providing beaver with prime habitat, the pond adjacent to unit one may support waterfowl, wading bird and bat populations.  How will logging activities in such close proximity to this crucial riparian habitat affect its inhabitants?


Known sensitive plant species occurring in wet areas within the watershed include: Sisyrichium sarmentosum, found in wet meadows; and Ophioglossum vulgatum, which is found on the edges of ponds and wet meadows.  There are several other plant species of concern that have potential to be found in wetland and riparian areas within the watershed.  The CHSWA admits that information on survey and manage species within this watershed is “lacking,” but “the watershed does contain potential habitat for many of them” (CHSWA, 3-30).  How have you improved on survey and manage knowledge in order to accurately evaluate management effects on sensitive plant and animal species? 



Riparian Logging


We are concerned about the large amount of Riparian Reserve logging included in this project under Alternative B.  Not only is the Collawash watershed very susceptible to landslides, but the Riparian Reserves in these units are recovering quite well.  All the streams we have seen were covered in healthy riparian plant species, and most units had a vibrant understory – including western red cedar – growing up.  The Collawash units appear to be a perfect example of an area that is capable of recovering on its own. This observation is supported by the CHSWA, which affirms that "along many of these affected streams [those affected by past management], deciduous vegetation has reestablished and now provides sufficient shading" (CHSWA, 3-20).  The proposed logging will have a detrimental impact on the riparian areas. One obvious example is unit 6, which straddles Fan Creek. The steepness of the Western edge of the thin, the steepness of several areas directly bordering the creek make it particularly sensitive to riparian degradation and to sedimentation.


The small seeps, streams, and intermittent streams that are supposedly too small or numerous to mark on the maps (PA, 21-22) should be marked for clarity, and to ensure that riparian serving critical wildlife needs are not inappropriately logged and are afforded adequate protection. There are some areas that even if not logged would be impacted by the edge effect of nearby logging. Unit 8, for instance, had two creeks running through it that were significant enough to have culverts built for them on road 6320, but these are not marked on the map. The east side of unit 1 is also wet with cedars present and should not be logged. Unit 5 is in or adjacent to “Shrub Wetland” and “Moist or Wet Meadow,” as seen in the Wet Areas Map of CHSWA (3-29).  This is not acknowledged in the Preliminary Assessment.  What measures are being taken to protect this area from possible adverse effects?


The PA claims that 88 acres of riparian reserves will be enhanced under alternative B and that no acreage will be enhanced under the other alternatives.  It is unacceptable to make this statement without any acknowledgement of the vast amount of controversy over this issue.  While canopy coverage may thicken over the long run as a result of management activities, sediment production and instability in an already hazardous are highly likely to increase and this should be acknowledged in the discussion of effects.




There are hardwoods present in some of the units that would be threatened by the proposed logging. Any and all hardwood needs to be protected. Unit 6 in particular has mature alders lining the streams.  We also noticed a transect line across one of the streams. Was this for surveys or is there an intention of placing a skyline logging corridor across the stream? We hope not. The northwestern part of the unit was very wet and soggy. The soil throughout was loose, wet, and sliding. Logging in this area would not have a restorative effect.




What is the scientific basis for the blowdown concern outlined in the scoping letter and PA?  The PA identitifies one of the project’s purposes is to “enhance growth resulting in larger wind firm trees” (PA, page 4). What kind of science do you have that shows that thinning will reduce wind-damage? The impacts to the Eagle Creek Sales that were logged illustrated the link between logging and blow-down of adjacent trees, and we’ve seen inumerable instances of thinning projects affecting the blow-down potential of valuable habitat adjacent to the units. If trees blowdown due to short-term increased wind-damage susceptibility, they will be unable to garner the assumed long-term benefits. Moreover, natural blow down taking place is already creating variable density with natural openings that allow more light to reach some trees.


The PA states that as a result of precommercial thinning the plantations proposed for thinning in the project “have strong stems and root systems at this time” (PA, page 35) and the CHWA confirms that windthrow is not a problem in the area (CHSWA, page 2-10). It is not acceptable to manage for blowdown resistance in already substantially resistant stands at the expense of water quality, snag and down log density and Northern spotted owl and other threatened or sensitive wildlife habitat.  On top of all this, how can we be assured that the smallest trees will be removed and the larger wind firm trees will be left? 





Soil is not a renewable resource.  All road building and logging, especially adjacent to riparian areas increases erosion.  Sedimentation of streams is a concern for all watersheds but of particular concern within a Tier 1 Watershed.  Soil compaction caused by road building (in this case there is no difference between temporary and open roads since the soil compaction is the same) and soil compaction due to heavy machinery such as tractors significantly reduce an area’s growth and re-growth (See Barstool EA).  We are particularly concerned about the impacts to soil in the Collawash sale. 


The project area contains two types of soils that are labeled as sensitive. The first is “Moderately Deep to Deep Soils,” which are defined as “Very erosive soil types…are usually unstable, associated with large ancient landslides both dormant and active (earthflows).”  The second is “Stream Adjacent Soils,” which are “often very erosive, unstable...they are constantly subject to erosional forces” (CHSWA, 2-13).  What measures will be taken to prevent soil erosion, landslides, and sedimentation given the sensitive nature of the soils in the project area?


According to the PA’s soil analysis (page 57), in all but one of the units, detrimental soil conditions will worsen after the implementation of Alternative B.  This is unacceptable for soil that is already highly erosive and unstable (see Steep Slopes and High Risk of Landslide section).  The CHSWA indicates that two thirds of the watershed’s soil is sensitive and “particularly susceptible to detrimental impacts from management activities” (CHSWA, 2-14).  The placement of project units for Collawash thinning was ill-conceived and should be reevaluated in light of the CHSWA recommendation for the termination of management activities on highly sensitive soils.


Invasive Weeds


Invasive weeds are an increasing problem throughout the previously logged areas of the Clackamas River Ranger District.  Of particular concern are the large concentrations of Scot’s Broom (Cytisus scoparius) found on many of the existing logging roads.  A casual examination of the area around the Collawash thinning units provides ample examples of this increasing problem (Scot’s broom and exotic blackberry were present on road 6321); fields of Scot’s Broom result from their seeds having been transported deep within the subwatershed on logging trucks.  The problems posed by the introduction of non-native invasive weeds are well documented, which is why a comprehensive plan to address noxious weeds is being prepared for Mt. Hood National Forest. How is it possible that this project will not further spread noxious weeds throughout the planning area?



Threatened Anadromous Fish


The Collawash watershed is a Tier 1 Watershed, indicating it is prime anadromous fish habitat.  Many threatened anadromous species depend on the quality of this watershed for survival.   Increases in sediment production over recent years have likely already lowered fish productivity, and contributed to the decline of fish species at risk (CHSWA, 3-27).  Additionally, “turbidity levels in the Collawash River are consistently higher and persist longer when compared to any other streams in the Clackamas subbasin” (CHSWA, 3-19).  This means that any sediment produced during management activities will adversely impact fish habitat longer in this area than it would in otherwise comparable areas.  “The watershed is designated Tier I, Key Watershed under the Northwest Forest Plan because it contains crucial refugia for at-risk fish species” (PA, page 23), including Lower Columbia River steelhead, Upper Willamette River chinook salmon and Lower Columbia River coho salmon that are as little as 0.14 mile downstream from the project.  Increase in sediment production over recent years has likely already lowered fish productivity, according to the CHSWA (CHSWA, 3-27).  Your impact analysis for threatened fish does not comply with this reality.  Please explain the discrepancy.


Winter Steelhead represent “the strongest stock of wild anadromous fish in the watershed” (CHSWA, 3-24).  Surveys show that 50% of the run present in the subbasin above Two Rivers used the Collawash watershed as a spawning area.  This species is considered a “stock at risk” and any alteration of their habitat (which reaches as close as 0.14 mile downstream of unit tributaries) will greatly impact the viability of the species (CHSWA, 3-24).  Late Run Coho, also a “stock at risk,” are found in the watershed.  In fact, this population is “probably the last wild population of coho found in the entire Columbia River Basin.  Late Run Coho is on the Region 6 Sensitive Species List and “one of the three classes of this stock is very weak and has a high potential for extinction” (CHSWA, 3-24).  The effects determination for this species and the other above listed threatened species are “May Affect, Not Likely to Aversely Affect.”  The PA admits that “thinning within riparian reserves is a ground disturbing activity that has the potential to cause a temporary reduction in water quality by allowing sediment to enter the stream channel from surface erosion or run off” (PA, page 25).  This information combined with the fact that turbidity levels in Collawash are higher and persist longer than those of surrounding streams complicates the effects determination.  If management activities “may affect” threatened fish populations, what will be the possible effects?  Are there no possible adverse effects to anadromous fish populations, as the effect determination leads us to believe, or could there be negative effects as the CHSWA suggests? 


During the process of logging, before revegetation, what preventative measures will be taken to ensure that sediment does not infiltrate the streams?  Also, will the use of grass seed (and mulch in steeper areas) be sufficient to prevent erosion and subsequent stream sedimentation? At what density will the native plants be placed in order to prevent erosion/sedimentation? Furthermore, the Preliminary Assessment states that fertilizer will be placed on "bare soils" in order to accelerate plant growth and thereby reduce erosion (PA, page 14).  This logic is ridiculous.  Placing fertilizer on specifically "severely erosive soils" (PA, page 58) will lead not to erosion prevention, but to the quick and easy transportation of the fertilizer to nearby streams, causing unpredictable damage.  Nowhere does the Preliminary Assessment account for this likelihood.


Snags and Down Logs


The CHSWA acknowledges a “low to moderate” level of snags and down logs present in mid and early seral stands (CHSWA, 3-31).  Logging activities in the proposed unit will necessarily decrease snag and down log densities.  Employing BMPs, the Preliminary Assessment aims at the retention of snags “where safety permits” (PA, page13).  In most logging activity, safety does not permit the retention of snags, unless the snags are buffered through intentional marking of save trees surrounding them.  Instead, live trees must be altered to promote their decay and eventual snag status.  Whether this method of snag creation actually works is still under scrutiny.  The stipulation of snag retention only where safety permits is unacceptable, considering the already low levels of snag density. 


Logging activities will also disrupt the vital decomposition processes occurring in down logs.  The PA’s plan to approve skid trail and skyline locations in areas that would avoid disturbing key concentrations of down logs is commendable, but how realistic?  Further, the creation of new wood debris cannot replace large decaying downed logs because the wood debris generated will not have the volume or decomposition process to support the wildlife that depends upon large decaying down wood.


Management activities in these units will reduce already dwindling numbers of snags and down logs.  The PA states that “unmanaged stands similar to the Collawash natural second-growth units have approximately 5 medium snags per acre and approximately 2.9 large snags per acre” (PA, page 43).  However, “Managed stands similar to the Collawash plantations have approximately 0.1 medium and 0.1 large snags per acres” (PA, page 43).  These numbers demonstrate the significant detrimental impact thinning has on snag habitat.  According to the CHSWA, “Many species in the Pacific /Northwest evolved to use the large snags and logs that were historically abundant in the landscape.  As referred to earlier, twenty-seven neotropical migratory bird species occurring within the watershed have significantly declined over the last two decades, based on Breeding Bird Survey data (Sharp, 1992). Of these 27 species, half are snag dependents and insectivorous or birds of prey feeding on forest birds.” (CHSWA, 3-3)   Average snag density in unmanaged stands ranges from 1-7 snags per acre; it ranges from nearly 0-1.75 snags per acre in managed stands (CHSWA, 3-3).  Management processes clearly have a severe impact on snag density, despite attempted preventative measures.  According to the PA, “pine marten and pileated woodpecker habitat has declined over time” (PA, page 53).  Both these species depend on snags for survival and any management-inflicted degradation of an already declining habitat is unacceptable.  Also, amphibians require a great deal of connectivity in the form of large down logs in varying decay classes (CHSWA, 3-31). Management activities would destroy this connectivity. 



Forest Health Alternative & Restoration Opportunities


Many of the forests we visited were on their way toward healing themselves from past management activities. Many have very diverse, healthy understory. Many were not overly dense. Unit 8 had areas where trees were ten feet apart.  Blow down is also happening naturally in many units. (See unit 1 (421), which is enabling them to thin themselves. Unit 5 (420) has places where spacing is 15 feet between trees.


We would like you to reevaluate your plan for the Collawash sale and create instead a restoration alternative. This could involve some thinning any unnaturally dense stands, leaving the trunks for down woody debris, and chipping the limbs for soil fertilization. In a native forest, when a tree falls to the ground it acts as a physical barrier to the movement of soil down a slope.  Over a short period of time the collected soil on the uphill side of a fallen tree sports a variety of young developing plants that further capture soil being transported down a hill.  Some of the steeper units could benefit from thinning with trees left in place on the ground to act to mitigate the soil losses and provide thermal cover.


There are also many nearby areas that could benefit from pre-commercial thinning, for example, the area north of 9B West/10 and the area east of 9B. The part of Unit 2 (422) on the west side of the road is very young (15-30 yr old) Douglas-fir and Western hemlock with lots of rhododendrons, and is somewhat impenetrable.  This area in particular, given the age class of the stand and the fact that it is so steep, is more suited for pre-commercial thinning than a commercial thin.


Road obliteration is desperately needed and would also be part of this alternative, as would invasive plant removal.  Such a project could truly address the forest health issues, without the damage caused by an intensive commercial harvest operation.  It could also serve to provide a sustainable source of employment for timber workers.


The PA immediately rejects a thinning without logging alternative on the sole ground that it does not comply with the NWFP goal of maintaining the stability of local and regional economies now and in the future.  First of all, when has not adhering to only one goal of the NWFP stopped the Forest Service from conducting a project?  For example, the proposed Alternative B of this project will not meet the desired future condition of “well distributed” snags and down logs or hydrologically and physically balanced earthflows, but is still advocated by the Forest Service.  And second, please explain how a non-commercial thinning projects that create jobs and the maintenance of truly healthy forests that provide an array of recreational opportunities do not contribute to stable economies now and in the future?




Thank you for the opportunity to comment on this project.  As stated above, we are concerned about the native stands, steep and unstable slopes, high road density, spotted owl populations and neighboring threatened fish species at risk as a result of this sale. We are highly suspicious of the serious discrepancy between the PA’s conclusions and those of the CHSWA, and would like to see scientific support of the impact determinations reported in the PA.  We are concerned that this project as outlined will cause more damage than good in the sensitive Collawash watershed and we are not convinced that commercial logging is the best way to address the problems that exist in this planning area.  For this reason, we ask that a complete Environmental Impact Statement be performed, and that issues raised in this letter be specifically addressed.  We would like the opportunity to work with you to turn this project into a truly restoration based proposal and are interested in working together with you to find resources to make this kind of project possible.





Sandi Scheinberg

Executive Director