April 30, 2003


Brad Keller and Randy Herrin

Salem BLM

Cascade Resource Area

1717 Fabry Rd. SE
, OR 97306


RE: Clear Dodger Timber Harvest EA


Dear Brad and Randy,


Thanks for the opportunity to comment on this project.  As you know, I am always concerned about logging stands of mature and old forest.  I feel that part of this project targets commercial logging in stand types underrepresented in the lower Clackamas.   While the proposed thinning of younger stands is less objectionable, we strongly object to the plans to cut in units C-1, D-1 and B-2.  Dropping these three units would make this project much less controversial and increase public trust.  These units are richest in the legacy features, particularly large trees and snags, as well as a diverse understory.  The amount of stands with these features are far below the range of viability in the Cascade range, and are particularly in short supply in the project area.


Both of you know better than I that GFMA lands are the principal sources of wood fiber on O&C lands.  But as you note on page 2, matrix lands must be managed to (amongst other objectives) maintain a variety of stand age and size classes in the vicinity and provide elements of complex stand structure such as snags and coarse woody debris.  The stands identified to be cut in this project, particularly units C-1, D-1 and B-2, make up a significant portion of the complex stands in the vicinity.  Without these stands, the vicinity will become more uniform in terms of stand ages and size classes and have fewer elements of complex stand structure.   Retaining five acres of old trees in section 13 while cutting the rest is not adequate.


Even though you do not plan to cut the largest and oldest trees in these controversial units, the value of these older trees goes beyond just keeping them standing.  The developing second cohort of trees and understory plants near these trees as well as the dispersal of epiphytes, lichens and bryophytes; and other processes beneficial to late-Successional forest habitat and dependent species extend into the adjacent younger forest around these remnant trees.  BLM should retain snags, large trees and associated communities in clumps.  Aggregate retention of these trees can eliminate any safety concerns by keeping operations away from falling or shifting legacy features.


New road construction.

As we discussed in March, I cautiously support some limited, short spur road construction to efficiently yard trees from young stands slated for multiple objective thinning.  For me, new roading must be justified with a balance of harms, with the benefits thinning outweighing the risks of doing nothing.  But in units C-1 and D-1 the benefits of no treatment outweigh the benefits of logging these units.  Nearly a half mile of new road construction, including some in a riparian reserve (which is not consistent with ACS Objectives) to access 16 acres of healthy, productive forest is not a sound investment of agency resources.  I do appreciate that you mention that a no new road construction alternative is within the scope of the alternatives analyzed.   This project suddenly becomes much more palatable without new road construction and without logging in these two older stands with remnant old growth trees. 


Northern Spotted Owls

USFW determined that this project is likely to adversely affect Northern Spotted owls, as 128 acres would be downgraded to dispersal habitat and 33 acres of dispersal habitat would be lost.   While USFW determined that all the FY 2003-2004 Habitat Modification projects in the Willamette Province would not cause jeopardy, federal agencies have a responsibility not just to avoid extirpating listed species, but to recover their populations.  It is true that the owls are doing better in the Oregon Cascades than anywhere else in the region, but the most recent research indicates that they are still declining more rapidly than predicted. 


Cumulative effects

This area is highly impacted by past management on all lands, regardless of ownership.  BLM and USFS should be working to promote habitat diversity and enhance water quality, not plan activities that continue to degrade underrepresented habitat types and increase risk of events that degrade water quality and aquatic environments.  Notwithstanding the extensive and continuous short rotation logging on the private land in the area, significant federal land logging has occurred or is expected to occur shortly.  These projects include Clear and Artful Dodger on your district and Guard and Unguard on the Clackamas District of the Mt. Hood National Forest.


While I agree that it is out of the scope of the analysis of this project to remove the stands from a matrix allocation as noted on page 4, projects on GFMA lands must be consistent with a legitimate cumulative effects analysis that:


Examines a variety of temporal and spatial scales

Incorporates current modeling that is site appropriate

Addresses more than one variable 


The WAR cumulative impacts analysis does not adequately access the cumulative impacts because it only looks at peak flows and is based on a technique developed nearly 25 years ago and recently adapted for application in a different state.  The WAR analysis for Clear Dodger does look at a variety of temporal scales but uses only one spatial scale and does not even define for what area the analysis was done.  But even with this flawed analysis, the WAR analysis found that the “threshold value for considering the effects of increased bed mobility and bed scour” has already been exceeded given the current conditions.  While it is true that regardless of what action the BLM takes, actions on private lands will degrade aquatic environments, BLM has an obligation to maintain and enhance these environments.  BLM should not get in on risking degradation because private landowners are doing it.