PO Box 12065
Portland, OR 97212
December 10, 2003
January 17, 2007
595 NW Industrial Way
Estacada OR 97023
EMAILED TO: email@example.com
For over ten years Bark has been monitoring logging in the Clackamas River Watershed. During that time we have witnessed the Forest Service evolve from proposing new old-growth timber sales to targeting younger forests, many in plantations, in order to achieve the annual volume targets. While this evolution has occurred due to public pressure and legal challenges, not agency-initiated management direction, it is still an key step in improving the health of the Clackamas River watershed. Bark and our nearly 4,000 members applaud the changes.
As you know, Bark believes that the commercial timber sale program is an inappropriate tool for achieving the needs of managing Mt. Hood National Forest for recreation, water quality, and wildlife habitat. In the Pacific Northwest this program has resulted in the extirpation of wildlife species, the degredation of drinking water, and the decline of recreation experiences not marred by clearcuts. Despite this, Bark has participated as a partner in the Clackamas Stewardship Partners (CSP) group, with the stated goal of “Enhance ecosystem/natural resource health and economic viability of local communities within the Clackamas River Ranger District through collaboration with diverse stakeholders that employs stewardship contracting and other tools to meet restoration goals. Collaboration is the deliberate coming together to find solutions.” The latter sentence of the mission is key to the CSP and to the Clackamas River watershed. It implies that there is a problem that needs to be addressed and hopefully solved.
Bark believes that five major problems require attention in the Clackamas River Ranger District in Mt. Hood National Forest:
1) Water quality for drinking: Every action that takes place in the watershed has a small impact on the quality of drinking water that ultimately is consumed by residents of Oregon City, Lake Oswego, West Linn, and many more. A recent shut down of the Bull Run Municipal Watershed clearly demonstrates that these impacts can harm the watershed for decades to come.
2) Water quality for fish: Dams, over fishing, roads, and logged-over streams have contributed to the crash of a number of fish populations including steelhead, chinook and coho salmon.
3) Recreation: At the national level, recreation continues to be defunded. As one of only 14 Urban National Forests in the country (with more than one million Oregonians within a short drive) this situation is unacceptable. In the FY2007 Forest Service budget for Timber Products in the Pacific Northwest alone is realizing a $40 million increase and Wilderness and Recreation across the nation is losing $10 million. Recreation is one of the newest endangered species in our forests.
4) Wildlife: Wolves, wolverine, grizzly bear, Canada lynx…these are all species that no longer exist in Mt. Hood National Forest. In addition to their intrinsic value, we are still learning the importance of these predators. For example, Ripple and Larsen found that the extirpation of wolves in Yellowstone National Park led to increased consumption of riparian aspen, thus leading to degraded fish habitat.
5) Roads: According to the Mt. Hood National Forest 1999 Access and Travel Management Plan 49% of the existing road system is a candidate for closure and/or decommissioning. Items 1-4 above are all impacted by the crumbling road infrastructure.
Bark sees the 2007 Thin as an opportunity for the Forest Service to address some, if not all of the concerns above. Although it is not a “deliberate coming together,” it can still be an opportunity for good work to be done. Before going on, it is worth noting that these comments look different than Bark’s usual comments. This is for two reasons: 1) Jim Roden has expressed his frustration with long comments from Bark; and 2) Bark has not been able to visit approximately 95% of the sale area. The comment period fell over mid-winter and covers seven square miles of forest, much inaccessible due to snow. The ability of the public to observe the proposal and provide feedback to the Forest Service was made impossible due to the size of the project and winter comment-perioed. Bark has visited some of the units, but most of our comments are based on the Preliminary Assessment (PA) alone. This is a concern since our last experience with a PA in the Clackamas Ranger District (No Whisky) found multiple instances where the information in the PA did not match what was found in the forest. That said, these comments are necessarily general. Bark would like to incorporate by reference the comments of Joseph Auth, Michele McKinzie, Paula Hood, and Charlie Ferranti. These members of Bark have all visited the 2007 Thin project area and are expected to provide more site-specific comments for consideration.
Water quality for drinking
Oregon has a history of protecting its drinking water. In 1892 President Harrison established boundaries and prohibited entry or development of the Bull Run watershed, which supplies drinking water for Portland. This proclamation was followed by multiple bills to further protect the forest providing this crucial resource to Oregonians. Unfortunately, between 1960 and 1990, nearly one-third of the once-pristine Bull Run watershed was clear-cut, leaving behind thousands of stumps and 300 miles of logging roads. The results of this have been high sedimentation and turbidity during heavy rain events and multiple shutdowns of the water supply, the last being 14 days long in November of 2006. Even with the vision leaders had over 100 years ago to elevate the status of Bull Run, logging and road building led to the degredation of the water quality. The Clackamas River is also a drinking watershed. It provides drinking water to hundreds of thousands of residents of Oregon City, Clackamas, West Linn, and other downstream communities. Unlike Bull Run, it has never received congressional attention for its status as a water provider. The resulting timber harvest has reflected this: in the Collawash Fork of the Clackamas alone, over 26,000 acres of forest was cut (mostly clearcut) during the same time as the Bull Run. Bark believes that this unique feature of the Mt. Hood National Forest, and particularly the Clackamas Watershed, deserves to be prioritized above other management objectives.
1) Adopt a Hippocratic Oath of “first, do no harm” for the drinking water quality of the Clackamas Watershed. This philosophy has served the medical community well for centuries, and is an excellent method for ensuring a conservative approach to land management. “First, do no harm” does not preclude management of the forest (see #2 below). However, this approach is currently not being practiced in the Clackamas watershed. Instead, harm caused by logging and road building is mitigated or quantified and allowed to occur to the greatest extent possible. Bark assumes that this is due to the Forest Service mandate to provide for “multiple uses” in the forest. In researching the legislative and administrative history of the mulitple use mandate, Bark has found no basis for all multiple uses occuring on all acres of the land. Simply put, if in some instances one use is more important than the other (e.g. drinking water) then the Forest Service does not have to include non-compatible uses (e.g. logging).
For example, on pages 45-47, the PA describes a variety of measures for hydrological recovery and the “threshold of concern” for these measures. Every drainage is currently modified (measured by “watershed impact areas” this is a percent of the drainage that has been logged or cleared) to some extent, anywhere from 4% in Sandstone Creek to 27% in Dutch Creek. However, the “threshold of concern” is 35% and because the 2007 Thin will not break the threshold it is considered hydrologically sound. On page 41 of the PA the discussion of hydrological impacts begins, “All of the drainages are steadily moving towards hydrologic recovery as young plantations grow.” If this is true, then why do harm when it clearly does not benefit the objective of protecting water quality?
2) Provide for a net decrease in sediment delivery. Any increase in sediment from activities should be compensated with an equal or better decrease in future sedimentation in the project area. The Forest Service is undergoing road deconstruction activities in the Bull Run watershed. These activities are estimated to increase sediment to streams by .45 tons per year, but will reduce the sediment in the long term. Bull Run Road Decommissioning Preliminary Assessment 2006 In contrast, leaving the road network intact will lead to a “considerable increase” in sedimentation. The 2007 Thin provided a Water Erosion Prediction Project (WEPP) analysis for some of the 2007 Thin units. In some of these units no sedimentation was predicted for a 25 year storm event. For others a sediment load of up to 1.5 tons/year was predicted. Bark believes that the deconstruction of roads in the 16 effected drainages can offset the impacts proposed by the 2007 Thin. See “Roads” section below for details.
3) Manage for long-term risk – reduce impact on earthflows. Nearly fifty percent (2,014 acres) of the 2007 Thin occurs on B2 Earthflow land designation. The portion of the forest in which the 2007 Thin is occuring is consdered the most geologically unstable in the Mt. Hood National Forest. The risk of natural events causing significant ecological damage is high. Thus the identification of land features such as “high risk earthflows.” The result of such natural impacts on drinking water could be enormous. Thus the impact on these landforms should not only be zero, but other portions of the watershed should be hydrologically capable of moderating such an event. Neither of these situations exist, or if they do, they were not presented in the PA. The Hot Springs/Collawash Watershed Analysis suggests that the objective for these land forms should be, “Manage landscape patterns to reduce risk (human induced) to low levels.” Page 1-6. Bark believes that all 2007 Thin activities on “high” and “moderate risk earthflows” should result in no human impact (logging or roads) in the future.
4) Protect riparian areas. This can be accomplished three ways:
1) Provide a minimum 50-ft buffer for all riparian areas, including seasonal wetlands.
2) Do not cut trees larger than 20” in diameter.
3) Provide contractual accountability for this requirement. In 2006 Bark walked 90% of the riparian boundaries in the No Whisky Timber Sale. In doing so it found multiple places where the 25 or 50ft buffers were not properly marked. The Forest Service promptly addressed these discrepencies. However, this approach requires citizens to groundtruth miles of riparian boundaries in the 2007 Thin to ensure adequate protections. Instead, Bark would like to propose including in the timber sale contract a provision for fining the contractor for activities within these buffers, regardless of Forest Service markings. This would ensure sensitivity by the contractor and allow Bark, the CSP, and members of the public to monitor activities randomly without requiring walking all riparian boundaries. Ultimately this would save the Forest Service and taxpayers money.
Water quality for fish
As long as fisheries in the Clackamas River watershed remain endangered, it should be the role of the Forest Service to improve habitat for these fish. As explained on page 53 of the PA, not moving forward with the 2007 Thin will have no effect on the five fish (Lower Columbia River Steelhead, Upper Willamette River Chinook, Lower Columbia River Coho, Lower Columbia River Chinook, Coastal Cutthroat Trout) that occur in the area and are on the Endangered Species Act list. Alternatives B and C warrant what is known as “May affect, Not Likely to Adversely Affect.”
Bark and the Clackamas Stewardship Partners believe that the improvement of fish habitat is a top priority. To accomplish this, it simply does not make sense to move forward with actions that could do damage to the resource that needs improvement.
An analysis done in a GIS investigated the presence of and possible detriment to anadromous fish present in streams near the proposed 2007 Thin area. Map layers downloaded from the Mt. Hood Data Distribution Center were used (available at: http://www.fs.fed.us/r6/data-library/gis/mthood/data-library.html). Figure 1 below shows streams supporting anadromous fish in the vicinity of the proposed logging activities. Species in this area, according to Forest Service data, include Coho Salmon, Chinook Salmon, Coastal Steelhead Trout and Sea Run Cutthroat Trout. Streams highlighted in red are those directly adjacent to proposed units, representing 42.2 miles of streams, or 9% of the total anadromous fish-bearing stream mileage within the Mt. Hood National Forest. While the stream in red may be the most directly affected, any detriment to fish downstream, especially those returning from the ocean, will be felt further upstream as well, perhaps even more so. The Clackamas River represents one of three or perhaps four major pathways for returning anadromous fish into the Mt. Hood National Forest, and have been heavily impacted already from past logging activities and hydro-electrical projects. The 2007 Thin logging activities will compound an already sensitive area, and potentially affect 30%, or 140 miles, of the stream runs for anadromous fish on Mt. Hood, if areas upstream of the proposed thin are considered (depicted in blue in Figure 1).
Figure 1. Map depicting anadromous fish-bearing streams potentially affected by logging activities of the 2007 Thin.The 2007 Thin overlaps 16 drainages (subwatersheds) in the Clackamas River Ranger District.
1) Follow “water quality for drinking” suggestions above
2) Undertake whatever precautions necessary to warrant a “no effect” impact on fish that are threatened or endangered.
3) Follow the guidance provided on page 4-17 in the Hot Springs/Collawash Watershed Analysis, namely:
a. The goal is to “improve aquatic habitat,” and the suggested project types are:
i. Plant hardoowds and cedars in riparian areas
ii. Reintroduce beaver to overgrown meadows and streams with suitable habitat
iii. Obliterate roads
iv. Place instream structures
v. Restore CWD
vi. Remove culverts that block access to historical fish spawning and rearing areas
vii. Implement projects to restore and mitigate disperesed recreation areas that lie within Riparian Reserves and conflict with Aquatic Conservation Strategy
viii. Concentrate on removing and restoring unneeded roads that lie within Riparian Reserves and cross unstable, high risk, sediment producing areas.
The most conspicuous issue for recreation in the project area is the lack of recreational opportunity. “In the vicinity of the project units there are no campgrounds, trails or other destination recreation features.” PA at 43 Recreation is essential to the management of Mt. Hood National Forest. As one of only 14 “Urban” National Forests in the nation, it receives nearly five million recreational visits per year. In Clackamas County alone, “travel” accounted for 4,460 jobs in 2004, or 2.2% of the workforce. Obviously this number cannot be attributed only to the qualities provided by Mt. Hood National Forest in Clackamas County, but do an internet search for “Clackamas” and you will be directed to www.mthoodterritory.com, the website of the Clackamas County Tourism Development Council. Mt. Hood is promoted as the number one attraction for visitors to Clackamas County. However, according to the PA the 2007 Thin will provide for 357 direct and indirect temporary jobs related to timber. Is the short-term gain in jobs worth it? The economic analysis contained in the PA does very little to justify the project one way or the other. Bark is concerned that this is not a sustainable model for Clackamas Counties economy.
In addition, other forms of recreation are being preempted by off-road vehicles. The Clackamas District has been challenged by consistent abuse of road closures by off-highway vehicle (OHV) users. On several recent trips to the 2007 Thin area, Bark staff and volunteers witnessed trucks towing multiple OHVs on road 4620 and signs of OHV use beyond berms on Road 4620-174, as well as an abandoned 4WD truck beyond the closure. By condoning a culture of indifference for road closures by taking away berms and other somewhat ineffective obstructions, the already increasing problem of
illegal use will only get worse.
The increase in OHV abuse throughout Mt. Hood National Forest is prevalent in many of the heavily logged areas of the forest, the increased open space becoming an enticing mudding opportunity. By opening roads previously closed (even temporarily) there must be increased enforcement to ensure OHV use is mitigated. This type of destructive activity has an exclusionary effect on the possibility of other recreation in the area; destruction of potential gathering areas for mushrooms, unstable slopes from aging non-maintained roads risking landslides into fish-bearing streams (such as can be seen near the Sandstone Creek) and loud engines destroying quiet-use opportunities on trails nearby.
1) Create a destination recreation feature. This could take the form of a hiking or mountain biking trail created from a deconstructed road or a prime fishing hole. Regardless, the problems associated with dispersed recreation (OHV abuse, dumping, illegal shooting, etc.) are less likely if legal recreation opportunities are provided. In particular, the steep terrain of the watersheds in 2007 Thin seem like a prime candidate for mountain biking trails.
2) Improve riparian conditions as outlined above. The fisheries surrounded by the 2007 Thin seem to be the biggest potential recreational draw in the area. If the fish habitat is protected as outlined above then an improvement in recreation is possible.
All 4,374 acres of the 2007 Thin is currently considered thermal cover for elk and nearly all of this acreage would no longer be considered thermal cover after completion. PA at 93 “Although there is the possibility that herd sizes would be reduced to a small degree, these effects are not predicted to last long.” PA at 95 In the next sentence the time scale is clarified, “in about 30 years.” This seems like a long-lasting impact. Especially since the entire wildlife section of the PA references the Watershed Analyses for the areas, which explicitly state the need for more information on resident wildlife, “Is there a herd of elk occupying the benchy area of Buckeye and Happy Creeks? What is the heard size and movement patterns? What is the status of deer in the watershed?” Hot Springs/Collawash Watershed Analysis at 4-21.
Northern spotted owls are in a more critical state now than ever. The recent status review on the owls clearly stated that populations are continuing to decrease. Therefore, it seems strange that 382 acres would be removed from current dispersal habitat for the NSO. In addition 1,142 acres would be degraded by the 2007 Thin. The PA seems to rely on a statement made on page 75, “The action alternative would not significantly alter the landscape’s capability to provide for the continued viability of the northern spotted owl on Federal Lands.” The Northern spotted owl is on the Endangered Species Act and therefore is considered a concern for Bark and its members. Much like the approach to water quality, it seems that the 2007 Thin is created from the perspective that timber harvest is the number one priority, with other resources being mitigated for. Bark would like to see wildlife be a priority for the Clackamas Ranger District.
1) Protect all snags through contractual agreement. As suggested in the “protect riparian reserves” section above, the 100% retention of snags can be attained through contractual language that ensures accountability and is of little cost to the Forest Service.
2) Remove all units that “remove” dispersal habitat for the Northern spotted owl.
3) Deconstruct roads. “High road densities lead to harassment of elk herds.” PA at 91
The 2007 Thin project area has the highest density of environmentally damaging roads in the entire national forest (see 2003 Roads Analysis, Mt. Hood National Forest). Alternative C is a good start to addressing the significant problems associated with roads in the project area. Unfortunately, Alternative C is not the preferred alternative. For a more detailed discussion on roads, please see comments from Bark members incorporated by reference.
1) Deconstruct all roads as recommended by the 1999 Access and Travel Management Plan, 2003 Roads Analysis, and relevant Watershed Analyses. These documents are 4-12 years old and provided clear recommendations for the reduction of road miles in the watershed. Alternative C is a good start toward these recommendations, but is missing some of the suggestions. If you would like Bark’s assistance in identifying these roads we will provide a list.
Thank you for considering our comments. We believe that all five of the major challenges for the Clackamas River watershed: water quality for drinking and for fish, recreation, wildlife, and roads, can all be addressed through a modified version of Alternative C. It is our hope that the Forest Service will address these concerns through a more thorough EA or EIS, and bring these issues to the Clackamas Stewardship Partners for further discussion.
/s/ Alex P. Brown
 Historic aspen recruitment, elk, and wolves in northern Yellowstone National Park, USA
William J. Ripple, Eric J. Larsen. Environmental Remote Sensing Applications Laboratory (ERSAL), Department of Forest Resources, Oregon State University. Received 24 July 1999; received in revised form 26 December 1999; accepted 13 January 2000