William B. Keller
Cascades Resource Area
Sent via fax: (503) 375-5622
RE: Protest of Final
Decision Documentation and Decision Rationale for the Clear Dodger Timber
Dear Mr. Keller,
Pursuant to 43 CFR 5003, please consider the following protest of the Final Decision Documentation and Decision Rationale for the Clear Dodger Timber Sale. We are pleased to see that much of the new road construction has been dropped. As you know, new road construction is one of our major concerns when it comes to the impacts of logging projects. We agree that thinning could benefit the young, relatively uniform stands (1, 2, 4, 5, and 8). But we remain convinced that BLM should withdraw plans for logging in areas that are beginning to develop late-seral structure and have legacy features (snags and CWD). While we recognized that BLM has slightly reduced the acreage in units 3, 6, and 7, these units contain some of the oldest and best functioning older forests in the area. We feel that the emerging science strongly supports early entry into young stands. But the older the stands become, the less thinning promotes late-seral characteristics and the more damage is done to soils, snags, and coarse woody debris.
In the response to comments, BLM recognizes that this project will have a negative impact on snags and coarse woody debris, but says that will be mitigated by creating more. BLM states that “the existing snags are mostly soft, highly decadent and in the later stages of decay.” Snags and CWD that are large and soft take the longest time to replace. While it is appropriate for BLM to create hard snags, the current snag science recognize that having many snags of different sizes and decay classes is key for a healthy continuum of the species responsible for creation of soil and the recycling of nutrients. New small hard snags cannot replace large soft ones.
We continue to disagree with BLM that WAR assessment is sufficient to analyze cumulate effects. As you note in the response to comments, the WAR assessment “was not intended to address multiple resources or multiple effects at multiple scales.” This is the heart of the problem. Aggressive logging of isolated scraps of older forests may have an impact that the BLM has legal obligation to avoid. But the WAR analysis does not seek answers to many important questions regarding cumulative effects, and even for the limited questions it is designed to answer, it fails to provide any conclusive answers. Rather than erring on the side of caution, BLM elects to proceed with the project.
BLM largely ignored much of my comments about cumulative effects and the ability of BMP’s to mitigate damage.
Conducting WAR analysis has nothing to do with compliance with ACS objectives, and ACS objectives are much more comprehensive than calling for reduced or eliminated impacts to stream channels, water quality, and peak flows. In addition, BLM failed to demonstrate how constructing a road in a riparian reserve complies with ACS objectives.