Update as of 5/18/2019: Even though the public comment period closed on May 17th, we are encouraging people to continue to contact the Forest Service to let them know that the public is opposed to this sale.
Please speak up to protect an ecologically sensitive and beautiful recreational area — tell the Forest Service “No Way!” to proposed logging around Suttle Lake.
The Forest Service has extended the public comment period for the “Greater Suttle Lake Vegetation Management Project” until May 17th. We have a second chance to send in more scoping comments—please take this opportunity to show public opposition to planned heavy logging all around Suttle Lake on the Sisters Ranger District of the Deschutes National Forest, just off highway 20.
The Forest Service needs to hear that the public is strongly opposed to this proposed devastation of existing natural and recreational values within and around four campgrounds, two large organizational camps, hiking trails, and the Suttle Lake forest area itself. The Forest Service is fast-tracking this proposal for heavy logging in this popular recreation area under a “Categorical Exclusion”, which would exclude further opportunities for public comments and objections.
Below are more details about some of our concerns:
Under the Forest Plan, the Forest Service should not be commercially logging these areas at all, except for legitimate existing hazard tree felling (which the agency is free to do without a timber sale). We know of no “applicable exemptions” allowing the Forest Service to commercially log these areas just as they would for any standard “scheduled” timber sale. With this second Forest Service scoping letter, they admit that the project area is primarily located in the Administratively Withdrawn land management allocation. The Forest Service admits that: “This land allocation includes recreation and visual areas where the management emphasis precludes scheduled timber harvest. The Blue Bay, Link Creek, South Lake and South Shore campgrounds and Camp Tamarack and the Suttle Lake United Methodist Camp organizational camps are located in this land allocation. Unless there are applicable exemptions, the NWFP (Northwest Forest Plan) defers to the standards and guidelines outlined in the applicable Forest Plan” (emphasis ours).
Riparian areas, including those around waterbodies such as Suttle Lake, are especially vulnerable to long-term damage from heavy logging. Riparian areas are a subset of the Administratively Withdrawn (from logging) allocation that includes Riparian Reserves. The Forest Service claims that the planned actions would not prevent attainment of the objectives of the Aquatic Conservation Strategy yet offers no detail on riparian buffers or other mitigations to back this claim. The Forest Service also acknowledges that the special use boundary of the Suttle Lake United Methodist Camp includes a 9 acre section of a Late Successional Reserve, which is also supposed to be off limits to logging that would degrade Spotted Owl habitat, which heavy logging and planned tree species conversion would do. The Forest Service claims that all applicable LSR standards and guidelines would be applied but fails to specify what these standards and guidelines are or how they would be met. Apparently we’re just supposed to trust the agency even though they somehow neglected to tell us any of these critical details in the first scoping letter. Then the Forest Service takes an abrupt sharp turn of suddenly ignoring all these overlapping Management Area restrictions they just disclosed by saying that the proposed action would be guided by standards for intensive recreation, including for the four campgrounds and the two organizational camps. They also disclose that the roadside hazard tree felling overlaps both a Bald Eagle Management Area and Late Successional Reserve, both of which should preclude logging of large trees.
The Forest Service admits in the second scoping letter that there would be no size limit for the logging, so large and old trees could be removed. It is unacceptable for the Forest Service to log large and old trees in this ecologically sensitive recreation area. Large trees are needed by many wildlife species, and are important to the scenic values of the area.
The logging the Forest Service is proposing is too intensive and extensive to meet the need to maintain the recreation setting for recreational values over the short to long-term. This forest area does not need to be “managed” (i.e. logged) to change the tree species composition. Felling of identified existing hazard trees should be sufficient to deal with public safety hazards, especially if there is periodic checking of hazard tree conditions. It sounds like either the Forest Service caused the current conditions by selectively logging out Ponderosa pine as hazard trees or else this is just a bogus rationale for logging heavily and essentially replacing diverse moist mixed conifer species with mostly young Ponderosa pine/Western larch stands through re-planting. Ecologically there is nothing wrong with a forest stand reaching a climax stage Late Successional tree species composition, which in this case includes large old Douglas firs, Grand firs, Englemann spruce, and Mountain hemlock. The Forest Service has a long history of replacing naturally diverse moist mixed conifer forest (such as would be expected around a large lake like Suttle Lake that receives heavy snowpack in the winter) by virtual clearcutting or other heavy logging and replanting only timber industry preferred tree species—i.e. Ponderosa pine and Western larch.
When the District Ranger promotes a “more proactive approach”, in this case what he means is very heavy logging to reset the forest stands with mostly timber industry preferred species. We read the original scoping letter carefully in coming to the determination that this timber sale would entail heavy and extensive logging to the point that the recreational areas may be unrecognizable afterwards, losing their intrinsic recreational value and sense of place for those accustomed to enjoying the area as it is now.
This timber sale warrants preparation of an Environmental Impact Statement. When the Forest Service writes that: “Mixed conifer stands would be managed to perpetuate or enhance the characteristic landscape”, this is Forest Service code for making it match the surrounding drier site Ponderosa pine stands regardless of this moister site’s natural tendency to revert to and maintain moist mixed conifer tree species composition. The “desired visual character” the Forest Service claims to be maintaining means the visual character desired by the Forest Service/timber industry, not necessarily what recreationists would want to see. The combination of heavy logging with pruning and tree topping of healthy trees could leave highly altered sites. The Forest Service is trying to justify excessive logging through the use of public relations propaganda about native tree diseases and public safety threats. However, the Forest Service is not supposed to be logging here at all except for legitimate hazard tree reduction.
There are extraordinary circumstances associated with the Suttle Lake timber sale that should prevent the Forest Service from using a CE for this planned logging—these include planned heavy logging in Management Areas admitted to preclude scheduled timber harvest. Since this sale would be a standard timber sale in all but name, these areas should not be logged at all except for already allowed legitimate currently existing hazard tree reduction. Further, these are highly popular recreation areas managed for recreational purposes under the Forest Plan, yet planned logging to the point of needing to replant trees, shrubs, and grasses would likely destroy the existing recreational character of the area. “Sanitation harvest”, which is what the Forest Service is proposing to do, often looks like a virtual clearcut.
Please join us in strongly opposing the “Greater Suttle Lake Vegetation Management Project.”
Email your comments by May 17th to: email@example.com Please put “Greater Suttle Lake Vegetation Management Project” in the email subject line.
Or mail comments to: Greater Suttle Lake Vegetation Management Project, Attn. District Ranger Ian Reid, c/o Michael Keown, Environmental Coordinator, P.O. Box 249, Sisters, Oregon 97759. You can also fax your comments to: (541) 549-7746 or call in comments to: (541) 549-7746.
For more information on the project, you can read BMBP’s previous Action Alert for the Suttle Lake project by clicking here. The Forest Service project proposal has not changed since we published our initial Action Alert. The Forest Service’s project webpage is here.