BMBP’s statement on the BMFP collaborative group’s “Riparian Restoration Zones of Agreement” 10/19/17

Statement on Blue Mountains Forest Partners Collaborative Group’s “Riparian Restoration Zones of Agreement”

Blue Mountains Biodiversity Project is generally supportive of placing wood in streams and of hardwood restoration. We are also supportive of restoration actions such as road decommissioning, excluding cattle from RHCAs (particularly where ESA-listed fish are present), culvert repair or replacement, eliminating fish passage barriers, mine tailing restoration, and other such actions.

We are strongly opposed to commercial logging within RHCAs. We are extremely concerned that commercial logging and extensive non-commercial thinning will negatively affect water quality and streamside habitats, and retard the attainment of RMOs such as those for temperature, sediment, and bank stability. Many streams within current sales (such as Camp Lick) are suffering from very elevated stream temperatures that negatively affect ESA-listed fish. The Camp Lick sale proposes commercial logging in RHCAs along streams that are not meeting RMOs for temperature and/or sediment. The agency and the collaborative have not focused on addressing the primary threats to streams, such as roads and cattle grazing. In areas where such issues are already causing extensive damage, logging will make matters worse.

We are very concerned that commercial logging and extensive non-commercial thinning will degrade or destroy wildlife corridors—especially given that the RHCAs contain some of the only remaining mature forest and high-quality habitat in many areas. For example, logging in the outer RHCA will reduce recruitment of snags, downed wood, and instream wood into the future. Meeting minimal requirements for Forest Plan standards before logging will not meet the biological needs of many species.

We are concerned that logging proposals to shift species compositions and create extensive openings within mixed-conifer RHCA forests are not well supported by science. Similarly, the science is not well developed regarding the effects of thinning in RHCAs on water quality, nor is the science well developed regarding the rationales or outcomes of such proposals. For example, only a handful of studies have investigated effects to water quality and riparian habitats due to thinning. Several studies have shown significant negative effects to streams from thinning including increased temperatures and sediment, long-term shifts in nutrient cycling and biota, and other such impacts. We feel the science shows that the risks to water quality and fish are large, and outweigh the more experimental and scientifically controversial perceived benefits. Please see BMBP’s Concerns RE: RHCA commercial logging for a summary of scientific concerns that we submitted to the Riparian Subcommittee.

I’d like to note that BMBP has been extensively involved with the Riparian Restoration subcommittee, and attended every single meeting since the group’s inception. We’ve also field surveyed hundreds of acres of RHCAs with proposed restoration activities and logging, and were extensively involved with the riparian restoration monitoring group.

RHCAs contain uniquely delicate and extremely ecologically important habitats. There is significant public and scientific controversy surrounding logging—especially commercial logging– within RHCAs. We suggest that there are other areas with less ecological risk and that have much less scientific and public controversy that the collaborative could focus their efforts on.

Lack of site-specific detail in agency NEPA and within collaborative ZOAs create unnecessary risks of over-simplification during project implementation. We are very worried about the precedent set by generalized recommendations. Silvicultural management and ZOAs are likely to be used as templates in other forests and districts, and will have influence and repercussions beyond the current individuals involved. Including the Forest Service decision tree in the ZOA is a good step in addressing this concern, but there is no requirement that the agency or the collaborative adhere to the decision tree.

We are also very worried that approval of the current Riparian ZOA will be an incentive to commercial logging within RHCAs.

We urge the collaborative to steer away from commercial logging in RHCAs, and to approach extensive non-commercial logging with additional caution. If the collaborative adopts commercial logging within RHCAs as part of their ZOA, the collaborative is moving further away from common ground with environmental stakeholders.

Thank you for considering our concerns.

Paula Hood, Co-Director

Blue Mountains Biodiversity Project