To:       Jim Roden                                                                                January 16, 2007

            Clackamas River Ranger District

595 NW Industrial Way

            Estacada, OR 97023                                                               



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 Mt. Hood National Forest in over 10 years. 


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 


The southern third of the 2007 Plantation Thinning is located in what is considered “the most unstable area of Mt. Hood National Forest” according to the Collawash/Hot Springs Watershed Analysis. This fact, combined with the recent Blister Fire, plans to move forward with the adjacent Collawash Timber Sale, high level of roads (temporary or otherwise) that already exist and those planned to be constructed and plans to degrade nearly 1000 acres of dispersal habitat for the NSO compounded by the lack of preferred habitat and dispersal habitat over the past 60 years, among many other things require a greater analysis of cumulative effects then is provided.


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.


Additionally, 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 Pacific Northwest according to a recently published text called Restoring the Pacific Northwest: The Art and Science of Ecological Restoration in Cascadia.  (Full citation of this text is included in the reference section and therefore becomes part of this legally binding document)


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


  • A 30 day comment period is too short of a timeframe for the public to fully review the impacts of a project this size.


  • P. 115 examines landslide risk and asserts that since thinning has less of an impact that regeneration the stands have been “tested.”  This argument appears to miss the crucial issue of cumulative impact by making the argument that since there weren’t earthflows after regeneration in the past that it shouldn’t be a problem now (other than in places where problems developed in the past). That is not correct since the cumulative impact of the creation of impervious surfaces occurred over decades.  The current level of impervious surface creates quicker and higher flow events in these moderate to severe earthflow areas than there has been in the past.


  • p. 126 lichen: No impact is expected to the one Pseudocyphellaria rainierensis site found in the project area since it is outside the thinning unit boundary.  How far outside the thinning boundary? What is the buffer that should be associated?


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…


  • The PA noted (p. 13) that trees larger than 20” would not be cut in the LSR.  This is great.  Why is this not true for Riparian Reserves?


  • The PA noted that if a tree larger than 20” had to be cut in the LSR it would be left in place.  This is great.  Why is this not true for Riparian Reserves?


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 PA notes that no-harvest buffers will be treated as “skips.”  Will the streambeds that the buffers line be treated as gaps?  If not, why not?


  • The PA notes that no-harvest buffers will be treated as “skips.”  This is going to have a serious impact on skip levels in the rest of the unit.  This appears to have a pretty serious impact on the ability of skips to protect important structural components in the remainder of the unit.  For example, a million square foot unit with a linear Riparian Reserve (which minimizes the skip size by minimizing the buffer size) would have the following impact:
    • An intermittent stream buffer 1,000’ long and 30’ wide would be 30,000 sq. feet and 3% of the unit.  If the Riparian Reserve was in Matrix than only 2% would be left to other skips to protect important structural components (since Matrix will have up to 5% of its land as “skip”).  If the remaining 2% was concentrated in the rest of the Reserve, then almost no skips would be found in the Matrix.
    • A buffer of 50’ would consume the entirety of the land set aside for skips and would allow no skips in the remainder of the Riparian Reserve or the Matrix unit to protect important structural component.
    • A buffer of 50’ on a stream in an LSR would consume half of the maximum amount of skips (3%-10%) allocated to the LSR unit.
    • A buffer of 100’ on a stream in an LSR would consume the entirety of the land set aside for skips in an LSR and would allow no skips in the remainder of the Riparian Reserve or LSR unit.


  • Could a cable transport system for moving logs (versus forwarder) be used within 100’ of streams where Riparian Reserve logging is being done via tractor (such as was suggested along 4610 in the No Whisky sale)?


  • If landings are going to be re-used within Riparain Reserves, the resultant slash should not be burned (potentially causing serious damage to soil in Reserve).  The remaining slash in Reserves should be pulled off of the road to avoid this type of damage.


  • Compacted or damaged landings in Riparian Reserves should be restored and revegetated.


  • Within 50 feet of the stream protection buffers, only low impact harvesting equipment such as, but not limited to, mechanical harvesters or skyline systems, which have minimal ground disturbance would be allowed. Mechanical harvesting equipment would be required to operate on slash-covered paths. Trees in this zone would be directionally felled away from the protection buffers to minimize the disturbance to the forest floor. These requirements would maintain the indicators for sediment, stream temperature, stream bank condition, and large woody material indicators. How about that within 50’ of intermittent streams that only cables get used?


  • On page 115 the EA states that the local climate of the area is very conducive to high levels of vegetative production, and it is possible that the high measured level of detrimental soil impact does not affect site productivity as much as it would in drier areas.  An increase in detrimental soils, road density and basically all impervious surfaces increases the peak flow volume and intensity. This creates a stress on the streams that did not occur during the original clearcutting since the increase in detrimental soils and impermeable surfaces has been a cumulative increase.  Consequently, the assertion on page 116 that the “conservative” approach would be to only look at old areas that showed movement would do for RR is quite wrong, since the impact of the accumulated damage to the watershed had not happened in the past.


  • On page 39 the thinning prescriptions within riparian reserves state they would maintain an average 50% canopy closure up to one site potential tree height from all streams in order to retain shade producing vegetation within the secondary shade zone. This design criterion is expected to maintain a canopy closure that provides adequate shade over streams and therefore is unlikely to alter water temperatures.  Even if this statement is accurate, won’t this prescription cause more wind to travel through the area causing the landscape to become more arid and thus changing the microclimate?  Ways to prevent this would consist of planting a diverse native understory within these areas in a short amount of time following the logging. While the EA discusses revegetating portions of the planning area, it does not list specific areas where planting will occur or what types of plants will be planted, nor does it discuss a step-by step process of how these planting will be implemented.  Without this information the reviewer can not, therefore, be certain that your claim that the design criteria is unlikely to alter water temperatures is accurate.  Nor is the planner able to assert this without considering what, where and how revegatation efforts will take place.    


  • Please include a no mechanized equipment buffer similar to No Whisky in all Riparian Reserves.




The area east of FR 46 between Big Creek and the Clackamas River hosts the majority of the roads recommended by the Forest Service to be decommissioned in their 2003 Roads Analysis.  Only 2 of the roads recommended for decommissioning in this area are currently NEPA ready, however.   Ironically this portion of the sale has the largest concentration of newly proposed “temporary roads”.  It appears that approx ½ of these new “temporary roads” are actually being added to the end of prior existing temporary roads.  Why did the district choose to ignore the recommendations of the 2003 Roads Analysis and propose a plan that is in complete opposition to the Roads Analysis’s recommendations? (consider adding charlies comment about helilogging)


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?).

  • If reconstruction of temporary roads is going to occur within Riparian Reserves, will any of these roads cross streams?
  • If reconstruction of temporary roads is going to occur within Riparian Reserves, will any of these roads cross into the no-harvest buffers?
  • If reconstruction of temporary roads is going to occur within Riparian Reserves, was there any WEP modeling done for such units other than unit 348 (which showed a 75% probability of sediment)?




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. 


  • Is the cost of the road reconstruction included in the Financial Analysis?


  • Is the cost of continued road maintenance included in the Financial Analysis?  Since this project has chosen to ignore the suggestion of the Roads Analysis, this plan should be including the continued maintenance cost of the roads that are reconstructed rather than obliterated.


  • Is the cost of grinding the pavement included in the Financial Analysis?


  • Is the cost of the road reconstruction included in the cost/benefits ratios comparing the Alternatives?


  • Is the cost of the continued road maintenance included in the cost/benefit ratios comparing the Alternatives?


  • Is the cost of the pavement grinding included in the cost/benefit ratios comparing the Alternatives?


  • Is the cost of the road reconstruction reflected in the timber value on the chart that compares helicopter costs with tractor or skyline?


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.





Michele McKinzie




Hollings, C.S. 1978 Adaptive Environmental Assessment and Management. Wiley,



Montgomery, D.R. and J.M. Buffington. 1995. Pool Spacing in Forest Channels. Water

Resources Research 31(4):1097-1105.


Society For Ecological Restoration International. 2006. Restoring the Pacific Northwest:

The Art and Science of Ecological Restoration in Cascadia. Island Press,

Washington DC.