PO Box 12065

Portland, OR 97202



June 20, 2007


Scott MacDonald

Barlow Ranger District

780 NE Court St

Dufur, OR  97021


Dear Scott,


Please accept these comments regarding the Billy Bob Fuels Reduction Project.  Bark was originally a part of the collaborative process, but was unable to continue attending meetings.


We were encouraged to find out and appreciate that this project will not be categorically excluded. By including an environmental assessment in the public comment process, we have more site-specific understanding of the Forest Service project intentions and are able to communicate our concerns in a more thoughtful, constructive way.


As well, we appreciate the absence of new roadbuilding in this project. Bark has been taking considerable more time lately to look at the roads in Mt. Hood National Forest in anticipation of the upcoming Travel Plan revisions. We have witnessed the backlog of maintenance on this crumbling road system and are supportive of the Forest Service eliminating new roadbuilding in logging projects.


Upon reviewing the preliminary map, the recommendations of the collaborative group and visiting the area, we have some concerns about this project. Unfortunately, we were not made aware of the existence of a unit map until just two days ago, by a participant in the collaborative group. Due to technical issues with the file size of the unit map, the Forest Service was only able to provide a unit map to Bark hours before the comments deadline. In order to comment on site-specific concerns, a map is a necessary tool for the public to respond to agency project proposal. As computer generated maps become more complex and large in file size, we understand that it is not cost-efficient to always send one to an entire mailing list. However, notifying interested parties via email that a map is available would cut down the chance of such late notice in requesting materials for comment.


Therefore, please understand any inconsistency with our site-specific information and the most updated project proposal. We have referenced the “Proposed Billy Bob Planning Area” map, which has been posted on our website at



So far the Forest Service has not addressed diameter limits or any other criteria to ensure large trees are left standing. There are large, legacy ponderosa pines in the area and a range of tree ages, in general. These older stands are integral for maintaining the existing forest diversity. We have been told Unit 7 contains old growth characteristics, as it was previously in a designated 100-acre late-successional reserve. We expect the Forest Service to maintain all current old growth characteristics and trees with older qualities (thick bark, yellowing bark, a flat top, asymmetric crown, broken tops, forked tops, etc.)


These large trees provide important qualities for the forest that thinning will not; visual beauty for recreation such as bird-watching, hiking, mountain biking and camping, deep soil structure for this dry, slow-recovery landscape, canopy coverage that will keep new growth from exposure, as well as habitat, nesting opportunities and natural snag creation.



We have been informed by the collaborative group participants that the Forest Service has proposed to change language in the Land Resource Management Plan to accommodate for this timber sale. Our understanding is that the changes would occur in the Standards & Guidelines, adding the term “treatment of hazardous fuels” to the list of reasons for deviating from Visual Quality Objectives in B2-016 & 017 Scenic Viewshed and FW-556 & 557.


With regards to the Visual Resource Management changes (FW-556 & 557), the proposed change adds a human disturbance to a list of natural “catastrophes.” By including the term “treatment of hazardous fuels,” the essence of the management changes from a natural disturbance response tool to a human disturbance action tool. The deviation from visual quality objectives is not intended to act as justification for continued fire suppression and human management, but as a realistic way for the agency to recover an area AFTER disturbance without the constraints of visual quality objectives.


Our trust in the Forest Service ability to meet Visual Quality Objectives was tested with the Tap Timber Sale and Eight Mile Timber Sale. Both of these logging projects had units along Road 44, in the designated viewshed. From the viewer position (the road), VQO retention was designated. However, a clearcut has decimated any visual quality that was intended to be maintained in the Tap sale. As Eight Mile continues to be logged, we are skeptical the agency will raise their standards.


The ambiguity of the term “hazardous fuels” leaves an unacceptable number of exceptions to these standards. Would this include snag removal? Would this include downed woody debris? What are the determinations, by the Forest Service of hazardous fuels? From our perspective the use of this term has led to large-scale logging and fire suppression.


Because of the reasoning listed above and for the sake of public participation in such important and guiding documents as the Land Resource Management Plan, Bark does not think it is appropriate to change language in the LRMP as needed for this or any logging project. There are much larger implications for these changes. Indeed, the LRMP is due for a revision and inclusion of updated science. Bark anticipates the upcoming public process of Forest Plan review, currently slated for 2011. If the Forest Service sees need to implement changes in the LRMP before then, Bark would support an earlier date for this process. The public has paid a high price for the Forest Service operating under this current management plan through excessive logging and roadbuilding. Therefore, until this larger process is underway, Bark will not accept any further expansion of reasons for deviation from any objectives including visual or ecological qualities.



Bark was encouraged to see that the collaborative group made a stewardship recommendation for road decommissioning after logging. Bark volunteers have recently done some surveying on the roads in this area and we encourage the Forest Service to include in the environmental assessment a look at road decommissioning possibilities. The Miles Watershed Analysis sites Eight Mile Creek as a priority area for potential erosion problems and recommends coming up with a management solution for suitable stream crossings, particularly as it pertains to off-highway vehicles and equestrian needs. (The Miles WA 122)


Bark has witnessed some of the intensive off-highway vehicle use throughout Mt. Hood National Forest and are wary of any new actions that might open up new access opportunities. We encourage a thorough analysis of all temporary use of closed spur roads and the risks of unsuccessfully deterring riders from using these roads once they have been used and appear to be accessible, again. Spur road 4460-017 has an ineffective closure with OHV use penetrating the forest. As well, culverts on this road are functioning as ditch relief for road runoff. Should motorized vehicles continue to use this spur road, this runoff will be meeting up to an Eight Mile Creek tributary with no possibility for filtration, putting fish habitat and water quality in direct harm.


Although Road 4460-017 is adjacent to the project area, we recommend a true road obliteration be considered for this road, taking it out of a possible road system. As well, we fully support the recommendation made by the collaborative group for Road 4440-120 and all spur roads from 120 be permanently obliterated. Bark also would encourage the Forest Service to do a full assessment of the status of the culverts throughout this planning area and include potential risks in continuing to use these old roads for large-scale logging operations. The weight of haul trucks is known to have an impact on the road and has led to increased culvert crushing. It is important that the Forest Service begin to incorporate the risks involved with continuing to use unsafe logging roads and the impacts these old roads will have on the forest as they deteriorate with use and lack of maintenance.



Bark is not supportive of removing trees with mistletoe (future snags) and deemed hazardous snags. In Unit 21, the representative from the Boy Scouts for the collaborative group has requested all snags be removed for safety of the campers. They use this area, which is adjacent to Camp Baldwin for camping and are concerned about the snags falling. Are there other ways to ensure the safety of the campers that does not include removal of the snags? Could campsites be determined from the Boy Scouts and then assessing safety hazards directly surrounding those sites?


Over 150 species in the Northwest, including birds, mammals and amphibians use dead and dying trees for habitat. Many of these species are insectivorous and are important for keeping the insect populations in balance. As well, large woody debris plays a role in nitrogen fixation, hydrologic and geomorphic processes, and nutrient cycling. In particular, the largest, most decay-resistant trees are most important to these ecological processes because they can last for over a century. In congressional testimony in November of 2005, prominent scientist Jerry Franklin argued that logging dead trees has a greater negative impact than logging live trees, estimating that up to one-half to two-thirds of forest dwelling animal species (both vertebrates and invertebrates) rely on dead and dying trees.



The Eight Mile subwatershed is an important part of the Tier 1 Miles Creeks watershed. Eight Mile Creek has steelhead trout stock. A May 1994 petition for listing under the Endangered Species Act included genetic and environmental basis for listing. “Loss of the Mile Creeks steelhead would result in extinction of a unique genetic steelhead stock.” (Miles WA, 106) We encourage the Forest Service to include surveys for steelhead, Pacific lampray and other fish stock impacted by this project. The unit map implies merely a standard use of the recommended minimum 300 ft. buffers on the Eight Mile creek. For such an important segment of this watershed, Bark recommends considering additional buffer added to the Riparian Reserve. “National Forest land in the upper 15% of the watershed is a critical source of high quality water and refugia for spawning and rearing steelhead.” (Miles WA, 105)


Thank you for the opportunity to comment on this project proposal. Please notify me with questions or further clarification.




Amy Harwood

Program Director