BMBP’s statement on our participation with Blue Mountains Forest Partners Collaborative Group

Blue Mountains Biodiversity Project’s statement on our participation with Blue Mountains Forest Partners Collaborative Group

Blue Mountains Biodiversity Project (BMBP) is a grassroots ecological protection organization based in Fossil, Oregon. BMBP has been field surveying timber sales on National Forests in eastern Oregon since its inception in 1991. Every summer, we and dozens of our volunteers survey thousands of acres of timber sales. We submit our survey sheets to the Forest Service, and share our knowledge of on-the-ground conditions and our concerns with the public. We engage extensively with the public comment process, and our comments and negotiations have resulted in ecologically beneficial modifications to many large timber sales.

Karen Coulter, the Project’s Director and Co-founder, has lived in Fossil for over 26 years. Living rurally, she has first-hand experience with many of the challenges of living in the area. For example, she and her family lost their home, some of their livestock, and most of their possessions to a wildfire several years ago.

Blue Mountains Biodiversity Project’s work area includes the Blue Mountains District of the Malheur National Forest, the district associated with the Blue Mountains Forest Partners collaborative group (BMFP). Blue Mountains Biodiversity Project was a member of the BMFP collaborative group for several years. We withdrew our membership over our concerns about the collaborative process, and the increasingly environmentally destructive projects and policies that the group was endorsing.

The Blue Mountains Forest Partners collaborative group is not working towards common ground, and is not respecting existing legal framework or environmental sideboards. For example, when the BMFP collaborative supports the logging of large trees, they are going against established legal direction based on well-vetted science. Logging of large trees ≥ 21” in diameter at breast height is prohibited by legal direction in the Forest Plan. We took the position of opposing the logging of large trees in the BMFP collaborative and blocked consensus on this vote, and submitted, in writing, a list of reasons for the block. Yet the collaborative group relegated our opposition to a small footnote in their letter to the Forest Service claiming full consensus to log large trees. The collaborative group abandoned their own consensus-based statements in order to increase logging revenue. We parted ways with the collaborative over this issue. The collaborative also supported the Forest Service violating their own Forest Plans in order to resume logging of large trees, despite the well-documented regional deficit of large tree structure compared to historic conditions.

Though we are no longer members of the BMFP collaborative, we have continued to attend some meetings and field trips, and raise concerns in relation to logging large trees. For example, the collaborative has stated that they are comfortable with the Forest Service’s use of the Van Pelt guidelines to identify and preserve “old” trees (≥ 150 years old). We have repeatedly pointed out that the Van Pelt guidelines do not apply to Grand fir, which is the primary species targeted for large tree logging; that other Forest Service specialists on the Deschutes National Forest have noted that the guidelines are not appropriate for use with Grand fir and that a diameter limit should be used; that the Malheur National Forest’s own tree coring data show that the use of the Van Pelt guidelines and current timber sale protocols will not protect many “old” trees from being logged; and that large trees need to be protected regardless of age in order to provide wildlife habitat. The collaborative chooses to ignore these crucial realities, and continues to contend, despite all evidence to the contrary, that their endorsements will be sufficiently protective of “old” trees and forest ecosystems. We feel that the disregard of these issues is emblematic of systematic dismissal of facts, ecological concerns, and public and scientific controversy.

Another example in which we feel that the collaborative group is moving away from common ground with local environmental stakeholders is their recent approval of commercial logging within Riparian Habitat Conservation Areas (RHCAs). Both Blue Mountains Biodiversity Project and Oregon Wild submitted letters suggesting that the collaborative focus their efforts on less controversial and ecologically risky issues; the collaborative instead voted to approve commercial logging along streams. Blue Mountains Biodiversity Project has been extensively engaged with the Riparian Restoration Subcommittee of the BMFP collaborative group since the subcommittee’s inception approximately two years ago. The subcommittee has focused on approving logging in RHCAs, despite our objections and our well-researched summaries of scientific studies documenting the negative impacts to water quality and fish from logging in RHCAs and the scientific controversy around rationales for logging. The research and citations we submitted were not addressed nor responded to by the subcommittee or the collaborative. The collaborative also did not address the numerous outstanding ecological and legal issues we raised about current Forest Service proposals to log in RHCAs. Many streams within current timber sales are suffering from very elevated stream temperatures that negatively affect ESA-listed fish, yet many miles of RHCA logging is proposed in the sales. For example, the Camp Lick sale on the Blue Mountains District of the Malheur NF proposes commercial logging in RHCAs along numerous streams that are not meeting Forest Plan or ODEQ standards for temperature and/or sediment. We’ve also voiced alarm over the many miles of streams with proposed RHCA logging and thinning across back-to-back timber sales in the Blue Mountains District—current collaborative endorsements include RHCA commercial and non-commercial logging that would affect over 40% of Redband trout habitat and over 23% of Threatened steelhead habitat on the Malheur National Forest. Despite the research we submitted and expert opinions we brought in that document the ecological harm likely to result from logging in RHCAs, the collaborative has again chosen to ignore scientific and public controversy in favor of increased logging.

The BMFP collaborative has continued to support Forest Service timber sales despite issues we have raised regarding the Forest Service’s failure to follow standard scientific protocols. For example, the rationale for logging in the Big Mosquito timber sale was based in part on fire scar data collected by the Forest Service that at sites that were not randomly or systematically selected, were not statistically robust, did not include a description of methods or protocols, and did not have an associated summary or report. The Forest Service also repeatedly claimed that the Big Mosquito project would lower stream temperatures, misrepresenting modeling related to mine tailing restoration and failing to mention that no modeling was done regarding possible stream temperature increases in relation to logging. The BMFP collaborative did not respond to or address these problems in relation to their endorsement of this project, even though we raised these issues.

Blue Mountains Biodiversity Project was heavily involved in the collaborative monitoring effort on the Malheur National Forest through the Collaborative Forest Landscape Restoration Program, which has expanded to include the Blue Mountains District. BMBP extensively researched stream temperature monitoring, including seeking the advise of a statistician from the Oregon Department of Forestry, in order to develop our proposal to the group for stream temperature monitoring design and protocols. After numerous productive meetings and field trips which left off on the cusp of key decisions to be made about resource allocations and finalization of monitoring plans and protocols, all communication from or about this monitoring group ceased. We have been unable to find out what has happened to this group which we were heavily involved with, nor have we been able to find out specific information about what if any stream monitoring will be taking place in relation to currently proposed logging in RHCAs. The BMFP member that had been hired by the BMFP collaborative to be the liaison between the monitoring group and the collaborative also cannot address our questions about water quality monitoring plans, and does not know whom else to contact about these issues.

Collaborative groups are inherently subject to disproportionate influence from the most powerful members of the community within the group; these often tend to be those with a financial stake in resource extraction. In addition, some attendees at meetings are paid either by the Forest Service and/or the collaborative itself; such information is not clearly communicated and presents potential conflicts of interest or introduces biases in opinions that are often portrayed as scientific expertise. Independent environmental representatives are an extremely small minority in collaborative groups, including the BMFP collaborative. Increasingly, independent environmental voices are absent from the table at many collaborative groups, as a result of years of marginalization. We are very concerned that the collaborative process does not reflect ecological concerns nor does it prioritize scientifically sound decision-making. Yet, collaborative groups are nevertheless gaining increasing legal deference with regard to decisions with enormous ecological implications for forests and streams. Attempts to give additional deference to the collaborative endorsements of Forest Service projects would further undercut the NEPA process, undermine scientific and public controversy, and enable the gutting of legal ecological protections.

This summary contains only a few examples of some of the many issues we have faced when dealing with the Blue Mountains Forest Partners collaborative group. Similar issues exist with other collaborative groups in the region. We appreciate the individual members of the BMFP collaborative that come to the table with a respectful attitude and are polite and friendly. We also appreciate recent efforts from the BMFP collaborative to at least provide the opportunity to allow differing opinions to be presented. However, we remain extremely concerned that the collaborative process as it is currently structured is inherently flawed and is a dangerous model that will not sufficiently protect ecological values in National Forests.

Sincerely,

Paula Hood, Co-Director

Blue Mountains Biodiversity Project