Blue Mountains Biodiversity Project Action Alert on the “Walton Lake Restoration Project” (timber sale) Environmental Assessment and Forest Plan Amendments—Comments Due by April 17th at the latest
Blue Mountains Biodiversity Project already challenged this insidious Forest Service scheme to log old growth forest and large trees from within the Ochoco National Forest’s most popular recreation site at Walton Lake when it was first proposed under a Categorical Exclusion to speed up and short circuit the public involvement process. However the Forest Service is back again with basically the same disastrous timber sale proposed under the guise of logging to control root rot and thus protect public health and safety—even though logging is known to spread root rot. Root rot is a natural disturbance agent that moves slowly, creating small openings in the forest and snags beneficial to woodpeckers. Logging to “control” root rot would not significantly reduce root rot unless entire root systems of affected trees were removed, and even then, it would likely remain in the soil in wood fragments. It is inconsistent with the stated purpose and need for the Walton Lake project to log to control root rot, since logging spreads root rot.
The commercial logging proposed would completely transform the Walton Lake recreational setting by clear- cutting existing large and old firs within beautiful old growth forest visible from the lake and campground area. The devastation of planned logging removal of about571 trees equal to or greater than 21” diameter at breast height (dbh) plus clear-cuts removing all fir trees (as root rot host species, even if they do not have root rot) would permanently change the character of the Walton Lake area to a heavily logged site. The lake area would be unrecognizable to generations of Oregonians and other visitors who experienced a sense of place there, with memories of big old fir trees and intact old growth forest. To add insult to injury, the Forest Service would replant heavily logged areas with only Ponderosa pine and Western larch, even though the forest is naturally moist mixed conifer, thus attempting to artificially convert the existing moist mixed old growth forest to a dry forest with young trees. They would also log out existing large Douglas and Grand fir that they estimate to be younger than 150 years old in the commercial thinning sale units, even though these are a minority in those drier Ponderosa pine dominant stands and pose no real threat to the old pines.
The Forest Service is planning to violate the existing Forest Plan by using Forest Plan amendments to allow the logging of Late and Old structure forest (old growth) which is under its historic abundance level (“historic range of variability”) and to allow the logging of trees equal to or greater than 21” dbh. We are strongly opposed to the use of Forest Plan amendments to violate already weak Forest Plan standards. These Forest Plan amendments are part of an increasing cumulative trend of similar Forest Plan amendments across the Ochoco National Forest and other National Forests in eastern Oregon, contributing to the significant cumulative loss of large trees and old growth forest over time. These Forest Plan amendments are not really site specific, as claimed, because they incorporate similar “purpose and need” rationales for the planned logging of old growth forest and large trees, such as asserting thatsuch logging will reduce wild fire risk and reduce competition stress between old Ponderosa pines and younger large fir, and improve the “health and resiliency” of the remaining Ponderosa pine and Western larch, despite known impacts of logging to forest health and resiliency. Most of the area around Walton Lake has either already had logging for fire risk reduction through the Canyon timber sale or is well buffered by abroad paved road. The new twist of improving the safety of recreationists at Walton Lake is being exploited to rationalize out-dated and unpopular clearcutting and logging of large trees and old growth forest in the Ochoco’s most popular recreation site. This timber sale is not really about protecting the safety of recreationists, as theForest Service is already allowed to remove legitimate hazard trees around Walton Lake in the most heavily used areas. The Walton Lake project is really a very lucrative timber grab for some of the last relatively intact old growth forest and large trees where they have been protected for future generations.
The Forest Service is using the unnecessary closure of the campground if No Action (no logging) is chosen or implementation of the action alternative is delayed to force the public to accept the utter destruction of the old growth forest context for Walton Lake. Yet the campground has been open for decades with the presence of root rot, and the Forest Service can still fell properly identified hazard trees for public safety, regardless of the decision on this project.
In your comments, it would be helpful if you refer to any recreational experience you have had at Walton Lake, and how your recreational interest there would be impaired by the proposed heavy logging removal of large trees and old growth forest—even if you haven’t been there yet. Following are other points it would be good to raise in your comments and information on how to find the Walton Lake Environmental Assessment (EA) on the internet or obtain a hard copy from the Forest Service if you would like to read it for yourself, as well as information on how to send in comments. Here are some of our further concerns regarding the Walton Lake project:
*We are very concerned that there are 10 Sensitive plants with suitable habitat in the project area that may be considered to be threatened with extirpation from the state ofOregon since they are listed on the ORBIC list 2, as well as four Sensitive Botrychium plant species that are considered to be threatened with extinction throughout their range (ORNHIC List 1), and the Sensitive Peck’s Mariposa lily that is endemic to the Ochoco National Forest, all of which could be harmed by proposed heavy logging (including logging within Riparian Habitat Conservation Areas (RHCAs), “temporary” road construction, and other planned management in the Walton Lake project. It is not reassuring that these plants were not located in surveys in the Walton Lake project area, given that the surveys consisted of only two days in late August, when the plants would be withered, dried up, or already consumed by herbivores. Further, many of these plants are difficult to find even in the best conditions, as they do not grow above ground every year, are tiny, or are hard to identify.
*The Walton Lake proposed action is admitted to cause high risk of introducing and dispersing exotic invasive plants that could threaten the viability of any rare Sensitive plants in the area, both by competition and by later likely use of indiscriminate herbicides that could kill native plants. The management actions planned adjacent to known invasive plant populations should be canceled or changed to avoid introducing and spreading invasive plants, including skid roads, bare soil creation, and log haul on roads with known invasive plant populations. Instead of avoiding unnecessary management plans that pose high risk of introducing and dispersing invasive plants, the EA only proposes to “treat” the invasive plants (likely with herbicides) once they appear. This is in direct contradiction to recommendations on EA pp.125 to include mitigation measures for high risk projects, ensure funding for these mitigations, and incorporate appropriate prevention measures for every alternative proposed.
*We are concerned by the increased risk of landslides and mass wasting that could be triggered by planned logging and increased road construction and use in the project area, which is generally moist and unstable, with numerous signs of past soil instability, including scarps, debris lobes, slump-prone areas, existing slumps, leaning trees, and multiple seeps, springs, sag ponds, and fresh tension cracks. Increased rain on snow events, faster spring runoff, and higher precipitation levels from climate change could increase the risk of more severe landslides and mass wasting in combination with planned logging and road use.
*There is no guarantee from the EA analysis that detrimental soil impacts would not violate Forest Plan standards, based on all the heavy equipment use, including clearcutting.
*We are strongly opposed to commercial logging and commercial-size tree felling within RHCAs, including the unspecified quantity of felling and removal of mature and large trees along Forest Service rd. 2220, and the cutting of conifers to favor hardwoods in units 6,7, and 8. There is no analysis demonstrating that existing Redband trout andColumbia Spotted frog and their habitat would not be harmed. We are opposed to planned “RHCA thinning treatments around large Ponderosa pine in Unit 5” (EA p.48), which don’t appear to be fully disclosed or analyzed for their effects to riparian areas even though the EA claims to fully buffer RHCAs from logging impacts to meet INFISH standards to protect streams and fish. We are opposed to mature and large tree felling within 25 feet of Camp/Cady Creek and within the RHCA. There is no sufficient analysis in the EA as to how increased sedimentation of the creek and loss of shading and bank stability for the creek would be avoided, or of effects to meeting INFISH Riparian Management Objectives and effects to Redband trout and Columbia Spotted frog.
*We are concerned by the loss of current and future large snags for Pileated andLewis’ woodpeckers, Northern flicker, and Whiteheaded woodpecker for nesting and foraging through proposed heavy logging of large trees. Pileated woodpeckers and American marten also need abundant down wood for foraging and prey habitat, and Pileated in particular need readily decayed large Grand fir snags and logs.
*We are concerned that planned virtual clearcutting in units 2, 3, and 4 would eliminate suitable Cooper’s hawk nesting and foraging habitat and potential Northern goshawk nesting and foraging habitat, and would greatly reduce large trees and snags that could otherwise provide perching, nesting, and roosting habitat for potential Osprey and Bald eagle using the lake. The proposed logging would eliminate habitat suitability over 59 acres of primary nesting habitat for Northern goshawk.
* The Walton Lake EA engages in disingenuous and grossly inadequate cumulative effects analysis by discounting all similar past management effects as a largely unexamined partof the existing condition and all future projects posing foreseeable cumulative effects as not foreseeable, despite the Forest Service’s adherence to long term timber sale planning on a regular rotation around each District, and other predictable management such as herbicide use and livestock grazing.
*The climate change analysis in the Walton Lake EA is particularly egregious in that the Forest Service pretends that “forest stands would be retained and thinned to maintain a vigorous condition that supports trees and sequesters carbon long-term” (EA p.128), when in fact the proposed clearcut “sanitation harvest” would not retain the existing forest stands and would eliminate a great deal of existing carbon sequestration—an outright lie that is contrary to NEPA requirements for accurate use of the science, detailed analysis, and professional integrity. The EA also fails to disclose significant scientific controversy that suggests that logging actually releases more carbon emissions into the atmosphere than wild fire.
*Due to significant scientific controversy regarding logging as “restoration”, logging of old growth forest and large trees, clearcutting, and logging to control root rot, as well as due to the unique characteristics of the Walton Lake recreational site and its high value to the public, the Forest Service should have used an Environmental Impact Statement rather than an Environmental Assessment in order to more thoroughly analyze the environmental impacts of the proposed action and to give the public more time to be aware of what is being proposed and to comment.
*Only two alternatives, No Action and the proposed action, are not the full range of alternatives that are required by the National Environmental Policy Act (NEPA), especially as there was no scoping period for the public to suggest other alternatives prior to the release of this Environmental Assessment. The prior Categorical Exclusion gave very little information as to the extent and severity of logging proposed and no specifics on potential environmental impacts to consider. As a consequence, we can only support the “No Action” alternative.
*The Forest Service makes many false claims to demonstrate that their proposed Forest Plan amendments would satisfy regulatory requirements, such as by providing opportunities for people to connect with nature (required by 219.10 (a) (10)) (apparently through clearcuttingand removal of large trees), and by preserving aesthetic values and scenic requirements (by leaving isolated old Ponderosa pines in wasteland of ripped up clearcuts.) The proposed action also threatens the recreational setting, viewsheds, ecosystem services, fish and wildlife species’ habitat, recreation opportunities (e.g. hiking through intact old growth forest), and riparian areas, all in apparent violation of 36 CFR 219.10 (a) (1).
The Environmental Assessment can be found on the internet at: http://data.ecosystem-management.org/nepa_project_exp.php?project=47019 or you can request a print copy by calling (541) 416-6500.
Comments can be submitted online by April 17th at: https://cara.ecosystem-management.org/Public/CommentInput?project=47019
You can also mail comments by April 17th to: Marcy Anderson, Walton Lake Restoration Project, 3160 NE 3rd Street, Prineville, Oregon 97754.
Thank you for helping us show public opposition to the logging of the Walton Lake recreation area!
You can support the ecological protection work of Blue Mountains Biodiversity Project by donating online or by sending contributions to: Blue Mountains Biodiversity Project, 27803 Williams Lane, Fossil, OR 97830. You can also donate monthly to become a sustaining contributor.
You can also volunteer with us, field surveying proposed timber sales in the summer, doing internet research for us, or providing legal services if you are a law student or lawyer. Call Karen at (541) 385-9167 about volunteering for our summer internship program or if you are a law student or lawyer– please leave a detailed message with call-back information. Please call or email Paula at 510-175-6238 or email@example.com about volunteer opportunities regarding internet research or comment writing (including comment writing trainings).