Jim Roden

Mt. Hood National Forest

Clackamas Ranger District

595 NW Industrial Way, Estacada, OR 97023




RE: 2007 Plantation Thinning Preliminary Assessment


January 11, 2007


Dear Mr. Roden,


            We are writing to provide comments on the 2007 Plantation Thinning Preliminary Assessment (PA).  CSP strives to enhance ecosystem health and economic viability of local communities within the Clackamas River Watershed.  We are committed to a collaborative process that employs stewardship contracting and other innovative tools to meet restoration goals.  CSP restoration goals focus on improving water quality, fish habitat, wildlife habitat, and local economies.  The collaborative group is comprised of a variety of interest groups including Clackamas County, local industry, state agencies, and environmental groups. 


            We are supportive of the Clackamas River Ranger District’s Alternative C proposal to thin young plantation stands.  Members of the CSP met with the Clackamas River Ranger District during two public meetings to discuss the 2007 Plantation Thinning Project and over the course of these meetings key issues were identified.  Members of CSP voiced their concerns over the proposed new temporary roads, intermittent stream buffers, and impact of roads on water quality and wildlife.  Alternative C incorporates and addresses CSP concerns on these issues and therefore we believe Alternative C is the most appropriate action.  We also encourage the FS to seriously consider the suggestions described below and provide clarification on some of the questions raised in this letter. 


Roads-Water Quality and Fisheries, Road Closures and Decommissioning


            The ecological effects of forest roads have been extensively researched in the Pacific Northwest. They alter hydrology by reducing soil infiltration, converting subsurface flow to surface flow, concentrating water through road drainage structures, and increasing peak flows (Jones et al. 2000, Luce 2002).  They can result in geomorphic changes, including chronic erosion and elevated sediment delivery into streams (Gucinski et al. 2000, Megahan and Kidd 1972), extended channel networks (Wemple et al. 1996), and increased risk and rates of mass wasting (Montgomery 1994, Swanson and Dyrness 1975).  Roads also influence the ecology of terrestrial and aquatic ecosystems through direct habitat degradation and fragmentation, loss of soil productivity, spread of exotic, non-native species, and associated human impacts as a result of increased access (Gucinski et al. 2000, Newcombe and MacDonald 1991). 


            Alternative C of the 2007 Plantation Thin includes no new temporary road construction and instead proposes approximately 4.5 miles of roads to be decommissioned, 43.2 miles of roads would be bermed, 8.9 miles would be closed year-round with new gates and one existing gate that is only closed seasonally would be changed to a year-round closure affecting 6.5 miles.  Although we are disappointed there will still be 7.3 miles of old existing temporary roads and old skid trails reopened and reconstructed, the CSP group is pleased to see the inclusion of 63.1 miles of road closures (decommissioning, berms, year-round gate closure) and no new temporary road construction, therefore we support Alternative C.


            Several concerns and questions arose as we examined the system roads proposed to be temporarily re-opened and compared the list with the Mt. Hood National Forest 2003 Roads Analysis list of roads with low access needs and high environmental risk and the list from Alternative C of proposed road closures.  First, five road segments (4620-011, 4620-013, 4621-022, 4621-125, 4621-140) are listed to be re-opened (PA 15) and are additionally listed on the 2003 Roads Analysis list of roads with low access needs and high environmental risk (p. 44 Figure 19).  The Roads Analysis does not explicitly state the specific environmental risk for each road segment, but our understanding is that for a road segment to be scored high (8-10) there is a significant environmental risk.  We suggest that the FS include a description on what the environmental risk is associated with each road segment and include an analysis of the overall impacts and tradeoffs of re-opening these road segments in the decision.  Second, nine road segments listed to be temporarily reopened (PA 15) are additionally listed in Alternative C to be closed (PA 22).  Why would a road that is already closed “with berms or other devices” need to be closed again with berms or gates (PA 15)?  None of the nine segments are proposed to be decommissioned under Alternative C, which is the only reason we could think of that they could be on the same list.  Can you please double-check the road segments and clarify this in the decision document?    


Intermittent Stream Buffers


            Intermittent streams play an invaluable role in protecting and regulating the aquatic environment.  In addition, they play pivotal roles in various forest ecosystem functions (i.e., connectivity/dispersal, riparian microclimate, specialized habitat, etc.).  Both FEMAT and the NWFP fully recognize these varied and important roles.  Protection of intermittent streams was an intentional piece of the NWFP and specifically chosen to provide protection of the riparian habitat and provide continuity between upland and riparian areas.  Not only is this an essential piece of the Forest Plan but its inclusion was, in part, to adequately respond to Congressional concerns about species protection and viability.


FEMAT V-31: Intermittent streams are an important, and often over-looked, component of aquatic ecosystems (Naiman et al. 1992).

NFP B-14:Including intermittent streams and wetlands within Riparian Reserves is important for successful implementation of the Aquatic Conservation Strategy.


            CSP encouraged the FS to increase the no-cut buffer from 30’ to a minimum of 50’, which is reflected in Alternative C.  No-harvest buffers are implemented to balance the short- to medium-term ecosystem degradation (or potential degradation) of the VDT within the Reserve.  As demonstrated above, the ecosystem processes that support this intermittent stream riparian zone habitat needs more than 30’ (9 meters) of protection because microclimatic change directly impacts species use and habitat availability.  We are pleased to see the inclusion of an increase to the no-harvest buffer for intermittent streams in Alternative C and strongly encourage the FS to incorporate this characteristic in the final decision.

Restoration Silviculture

            We are encouraged the Forest Service has proposed to thin in a way that would introduce structural diversity through variable spaced thinning.  We support the objectives described in the PA to achieve “a more appropriate mix of tree species”, a “greater variability of vertical and horizontal stand structure”, a “greater diversity of live and dead trees with elements of wood decay”, “increased habitat diversity”, and “an accelerated trajectory that would result in suitable habitat sooner” (PA 61, 65).  The summary of practices and design criteria to vary leave tree spacing within and between units; create skips, gaps and heavy thinning areas in a variety of sizes; and retain underrepresented species, snags, and trees with elements of wood decay are consistent with the best available science to achieve these objectives.


            While we support the objectives and design criteria in general terms, we need more clarification on how variability in spacing will be achieved in each land allocation and in each unit.  Clear and detailed descriptions of how restoration objectives will be met by thinning, is of paramount importance to many CSP members.  The CSP will be much more amendable to implementing the thinning analyzed in this document with stewardship contracting if the Forest Service is dedicated to designing prescriptions that clearly introduce between and among stand variability of leave tree spacing.


            In terms of Riparian and Late-Successional Reserves, the PA does not specify whether or not the thinning and associated activities are designed to accelerate the development of mature and late successional stand conditions with a single entry or a multiple entry approach.  This is a critical long-term distinction that influences design and we would like to have this clarified in the decision document.  In addition, if it is a single entry, roads leading to these units should be closed on the way out to ensure future management reflects this intention. 


            In the riparian reserves, it appears that plantations will either not be thinned (in protection buffers) or will be thinned to a relative density of 30.  While we understand that the Forest Service is following guidance from NOAA to recruit large wood to improve in-stream habitat, riparian reserves also are intended to serve as corridors and refugia for terrestrial species associated with late-seral habitat.  In the decision documents, we would like to see the NOAA guidelines disclosed and the Forest Service use any discretion it has to introduce more variability in spacing (i.e. to thin deliberately the upland sections of riparian reserves to the greatest possible variety of relative densities that average to 30).  We also encourage the FS to incorporate additional measures to the management of Riparian Reserves such as retention of patches infected with native tree disease since these pathogens act to create canopy openings over time. 


            In the late-successional reserve units, we are pleased to see a broader range of target leave tree relative density (20-40), emphasis on retention of large trees, and a range of created skips (minimum of 10% of each unit) and gaps (3-10% of each unit).   In the decision document, we recommend that the Forest Service describe the scientific justification for this range of target relative densities and disclose which portions of each unit will be thinned to each target relative density, as well as how much of each unit will be left in skips and gaps and the location of skips and gaps in relation to roads, landings, protection buffers, and the sections of the unit that will be thinned.  We believe the lowest target relative density (around 20) should be limited to gaps and the small heavy thinning patches.  We encourage the Forest Service to place these skips and gaps in areas to maximize heterogeneity by placing gaps away from landings and roads and surrounding skips with thinned areas.


            We believe that large trees are important ecological resources regardless of the land allocation in which they are found.  In the decision document, we encourage the Forest Service to disclose those units in the matrix and riparian reserves with more than just scattered 20’+ diameter trees are located and how the project would change if the 20’ diameter limit used in the late-successional reserves was applied to riparian reserves and matrix.  We believe that leaving patches of large trees will add necessary variability and we encourage the FS to place skips around patches of large trees in all land allocations.




            Overall we are pleased that the Forest Service incorporated key issues identified from public meetings into Alternative C and encourage the District Ranger to select this alternative.  Throughout the letter we made several suggestions and asked for clarification on several points and we would like these addressed in the final decision document. 




Lisa Doolittle /s/

Gifford Pinchot Task Force

Clackamas Stewardship Partners