To: Jim Roden
Clackamas River Ranger District
Dear Mr. Jim Roden
Thank you for providing
the opportunity for the public, including me, to comment on your proposal, the
2007 Plantation Thinning. While I
respect the authority who gives us this right, I am concerned that the timing
for public release of these documents does not lend itself to the full extent
of public involvement provided under law and therefore is not an appropriate
time to release such a document for public review. Releasing a legally binding document for
public review over a span of time that includes three nationally celebrated
holidays is not only bad neighboring, but suspicious behavior. The potential of denial over the full, still
hardly sufficient, 30 day comment period looms, especially considering this is
the largest commercial timber sale planned in
While I do not disagree with your proposal in its entirety, I have many questions, concerns and comments. Please address my questions and consider my comments and concerns before modifying and/or moving forward with your proposal.
General Concerns Regarding Purpose and Need of “Enhancement” and Call for Stewardship Contract
southern third of the 2007 Plantation Thinning is located in what is considered
“the most unstable area of
While I applaud the districts efforts to take a leading role in promoting logging projects that promote ecological restoration of monoculture plantations, I am concerned that this project is too shortsighted to effectively lay the foundation for true restoration to take place in the planning area. True restoration on a landscape level takes place over a much longer timeline then 1, 5 or 10 years and should consist of comprehensive step by step plan designed to meet the multiple objectives of restoration over a 10+ year timeframe. Even if silviculture prescriptions are the first step in this plan, the plan is likely to fail in its enhancement objectives if there is no subsequent plan to carry out other necessary components of a true restoration/enhancement project, such as decommissioning of roads, removal of noxious weeds and planting a diversity of conifers, hardwoods and under story plants and shrubs. While Watershed Analysis’s are helpful in guiding management by providing recommendations, they do not constituent an action plan intended for direct implementation.
Page 41 on the issue of hydrology states that “The assumptions in the ARP model indicate that if post treatment canopy cover is between 50 and 69%, the stand would be considered 91% recovered and it would take five years for the stand to reach full recovery, and if post treatment canopy cover is between 30 and 49%, the stand would be considered 73% recovered and it would take ten years for the stand to reach full recovery”. Under either scenario this logic is flawed because there is currently no step by step plan to achieve full recovery over a multi-year timeframe (i.e. a restored landscape) and it is impossible for a landscape consisting of 30-60 year monoculture plantations to be considered fully recovered in as little as 10 years, therefore your claim is inaccurate.
due to lack of funding it is unlikely that the additional necessary components
of true restoration (such as decommissioning of roads, removal of noxious weeds
and planting a diversity of conifers, hardwoods and
under story plants and shrubs) will not get completed as a part of this
project. Therefore, if the purpose and
need of this project is to enhance RR, LSR and diversity then a portion of or
the entire project must be completed under a Stewardship Contract in order to
provide funding for road decommissioning etc.
The plan will fail to achieve its purpose and need of enhancement
without these necessary components in place.
This rationale lends itself to leading research in the field of
Ecological Restoration in the
Moving forward with an improved version of Alternative C under a Stewardship Contract would therefore allow the district to get closer in achieving its purpose and need of true enhancement of the area in question, by providing the funding for road decommissioning and perhaps removal of noxious weeds and planting of a diversity of native trees and shrubs.
If stewardship contacts become the norm, it may be possible to create a full-time restoration based workforce while maintaining the dwindling silviculture and logging based jobs, so long as planning and prescriptions are landscape based and restorative in nature and logging is monitored for illegal timber theft and general quality control. If the agency’s future desire is truly to move into the realm of the enhancement and restoration of the landscape then I applaud their efforts and believe that most reasonable environmentalists would too. However, for me to drop my concern that there are other unwanted motives within your intent, I need to see the agency and the district using stewardship contacts that include longer timeframes for implementation sooner then later and the 2007 Plantation Thinning, due to it’s size and purpose and need of enhancement, is a great place to start.
Other General Concerns
Riparian Reserve Silviculture
In general riparian silviculture projects should address ecosystem functions that have been lost or degraded and the goal should be to design prescriptions that will result in a forest structure and composition that support ecological functions (Montgomery and Buffington 1995). With this in mind please answer the questions below…
In addition, riparian forest communities have varying influences along the river continuum. Therefore site-scale projects should be designed to enhance the functional needs of the ecosystem at a landscape level (Hollings 1978). Further emphasizing this fact is a very important concept in ecological restoration has been a shift from structure-based to process-based restoration. With these concepts in mind please answer the following questions and concerns…
The area east of FR 46
between Big Creek and the
At the very least, no new temporary roads should be constructed within the entire vicinity of roads recommended for decommissioning in the 2003 Roads Analysis. As it currently stands Alternative C does not include decommissioning or closures of any of the roads recommended in the 2003 Roads Analysis, and instead lists closures of existing system roads for wildlife enhancement (Pg. 117). This is a good start, but by adding the Roads Analysis’s road decommissioning recommendations to the list of roads to be closed, decommissioned or obliterated under Alternative C, would allow these roads to become NEPA ready and therefore, they would be one step closer to actual decommission or closure once funding becomes available (hopefully through a stewardship contract associated with this proposal).
By definition a temporary road “is not intended to be part of the forest transportation system and not necessary for long-term resource management. Temporary roads are required to be revegetated within 10 years of completion of their use. Temporary roads can remain active for up to 5 years as part of timber sales” (36 CFR 212.1). If existing “temporary roads (roads that were originally proposed as “temporary” in past timber sales are now being used to add further access for “resource management”, at what point then, is a temporary road no longer a temporary road and therefore requires analysis as a system road and added to the road density calculations for the district?
FR 6330-160 is scheduled to have a Berm placed at it’s entrance under Alternative C. This road currently has multiple illegal OHV trails heading into the forest and I found several instances where existing berms, put at the entrances of old temporary road did not succeed with the original intent of closing the road. Due to these examples, please change the prescription of this road in Alternative C from Berm to Decommission. The reasoning for this is enhanced by the fact that this stretch of road already has 5 landslides originating on the cut slope of the road.
In addition, please drop the unit (unit 322 or 324, its hard to tell which one it is) at the end of FR 6330-160 from the proposal or at the very least helicopter log it due to the fact that the last ½ mile of the road leading to this unit would need to be entirely reconstructed since it has naturally closed on it’s own. Additionally, in many places along the last ½ mile the landscape has actually reclaimed its natural steep slope to the point where the original road has literally become a trail no wider then 2-3 ft. Rebuilding this section of the road, in combination with logging the unit at the end of it would put the area (already affected by 5 landslides) at even a greater risk for future landslides.
The portion of the sale that falls south of Hwy 224 between Fish Creek and Pup Creek and within the LSR shall contain no new temporary roads. The Fish Creek divide has a history of severe landslides. The eastern half of this area is steep and anti-social behavior (OHV use, shooting and dumping) is prevlent. FR 5410 and FR 5411 are the main roads through this area. According to the EA numerous temporary roads are planned in this area and although each new temporary planned is less than ¼ of a mile long, there are a ton of them. This will give OHV uses, already present and causing destruction in the area, lots of temptations to expand their illegal OHV paths.
The Forest Service admits that they do not have the resources to monitor and enforce all areas where illegal OHV use is prevalent; hence it is inconvincible that the agency would plan to create new roads, even if temporary, that would be considered tempting for OHV uses to drive through. Please provide an enforcement strategy of how the district plans to keep illegal OHV use from spreading throughout this area if you decide to move forward with road construction in the area described above.
No new temporary roads allowed in Riparian Reserves.
Grinding pavement as a way of reducing road maintenance costs is understandable. However, the transition from pavement to gravel will increase erosion and potentially in-stream sedimentation. By not grinding the pavement in the vicinity of stream crossing the potential for increased in-stream sedimentation due to the overall increase in road-related erosion would be reduced.
Where new gravel is going to be laid, be sure to use rounded gravel in proximity to fish bearing streams. Typical sharp-sided (jagged) gravel can puncture fish eggs causing them to die.
ODOT delays projects until after nesting season so as to comply with the Migratory Bird Act. Does the Forest Service have a similar restriction that is based on this Act?
Will former temporary roads that are located within Riparian Reserves be reconstructed and used? This appears to be the case in units 206, 220, 264, 268, 316, 328, 346, and 348 (others as well?).
Does NSO analysis include a cumulative impact assessment on the species due to loss of preferred habitat and dispersal habitat over the past 60 years due to past logging that took place in the area?
The NSO table is misleading. And even if this project really does only degrade another 2% of dispersal habitat, when is there just not enough left for a species that is declining at a rate of 4% every year across its entire range?
On page 66 the EA states that there would be a short-term loss of approximately 985 acres of dispersal habitat as a result of project implementation. This temporary loss of dispersal habitat would occur in both the Matrix and LSRs. So there would be no degradation or loss of dispersal habitat in Riparian Reserves?
On page 71 of the EA it states that as fragmentation of a landscape pattern increases, the amount of interior forest habitat decreases and the amount of edge habitat increases. As fragmentation increases, the amount of interior forest habitat decreases, impacting organisms that prefer large patches of interior habitat, such as the spotted owl. This sounds like a good reason to be doing road removal in LSRs and RRs to me.
Snags and Course Woody Debris
On page 24 the EA states that the LSR Assessment contains a discussion of goals for coarse woody debris and snags. The goal is to eventually have 15 to 30 snags per acre and 10 to 15 percent of the ground covered by down logs. The existing condition for plantations is well below these levels. Achieving these goals with this proposed action is not considered a viable option according to the EA.
On page 56 the EA states that one of the aspects of the purpose and need is to enhance or accelerate the development of mature and late-successional stand conditions on 1237 acres in the project area. The “stand condition” for late-successional stands includes quantities of decadence that will be missing or greatly reduced due to the thinning unless there is active management for its inclusion and maintenance.
The cost of girdling and felling trees is estimated at up to $3,900 per acre. According to the EA there would also be a reduced economic viability of the thinning timber sale because up to 75 additional trees per acre would have to be left after thinning. While this may be true economic return should be a secondary product of the restoration effort not the main goal. In addition, funding for this and/or inoculation could be achieved, at least partially, through a stewardship contract.
Economics - Financial Analysis
The economic analysis in the EA does not include a environmental degradation quotient nor a quotient used to estimate the additional amount of money that will need to be spent by public municipalities to filter drinking water or clean the air of pollutants for example, and therefore is not entirely accurate. There are ways to include this type of information into a economic analysis and the district and agency should begin using them immediately to avoid further confrontation in the future.
Also, if the intent is to enhance (i.e. restore) the landscape then money gained can not be first priority.
If no monies exist to implement road decommissioning, removal of noxious weeds, the creation of snags and CWD, or native planting of conifers, hardwoods and understory species to restore diversity among the stands then use a Stewardship Contract instead of a timber sale contact.
Thank you sincerely for considering my questions, comments and concerns. I apologize for getting this to you at the last minute, but with the holidays and the short comment period for size of the project lends itself to nothing eles.
Hollings, C.S. 1978 Adaptive Environmental Assessment and Management. Wiley,
Resources Research 31(4):1097-1105.
Society For Ecological Restoration International. 2006. Restoring
The Art and Science of Ecological Restoration in Cascadia. Island Press,