Walton Lake

The Forest Service is targeting the forests around Walton Lake for logging (again!). The Forest Service proposal includes old growth logging and clearcutting in one of the Ochoco’s most popular recreation areas.

The Forest Service is again threatening the old growth forest around Walton Lake with logging. They are proposing to log in magnificent old and mature forests, including logging of large trees (some up to 3-4 feet in diameter) in the very popular Walton Lake recreation. The Forest Service is particularly targeting fir trees, and would log almost all of the fir in some areas, creating a virtual clearcut.

Walton Lake is located in the Ochoco Mountains in central Oregon, northeast of Prineville. The Lake is a very popular recreation area because of the lake itself, its old growth trees, a developed campground, and its scenic beauty and abundant wildlife. A trail and paved road around the lake are abutted by numerous old growth Ponderosa pine, Douglas fir, Grand fir, and Western larch. South and east of the Lake an unusual (for central Oregon) stand of old growth fir provides both the scenic backdrop that is featured in many pictures of Walton Lake and excellent habitat for wildlife species that favor old growth forests.

Since 2016, Blue Mountains Biodiversity Project, represented by Tom Buchele of the Earthrise Law Center and attorney Jesse Buss of Willamette Law Group, have twice stopped the Forest Service from logging this area. Unfortunately the Forest Service is at it again–they are proposing (for the third time!) to log this majestic forest using flimsy rationales.

The ostensible purpose, as stated by the Forest Service, for this timber grab is to: “Address laminated root rot infestation and provide for public safety in a developed recreation area; Improve the resiliency of large legacy ponderosa pine trees and lower the risk of bark beetle attacks; [and] Reduce inter-tree competition and enhance hardwoods.”

There are several reasons that the proposed logging is inconsistent with the Forest Service’s stated purpose and need for the timber sale:

1) Logging does not reduce root rot. Reducing root rot (a native disease that provides important ecosystem functions) would require digging out entire tree root systems and volumes of soil to eliminate root rot in an area. Eliminating root rot in the area would likely not be possible.

2) The area with root rot that is proposed for clearcutting and re-planting with Ponderosa pine and Western larch seedlings is historically and naturally moist mixed conifer with large old Grand fir and Douglas fir that would be logged out. Root rot is ubiquitous in moist mixed conifer forest, as the Forest Service admits, and has likely been in the area for decades, if not millennia. So the forest there would keep trying to revert back to moist mixed conifer, with fir and root rot.

3) Root rot is a native disease that forests have evolved with, and it is crucial for creating wildlife habitat and maintaining natural disturbance and biodiversity. Laminated root rot allows the forest to thin itself, which is what the Forest Service often claims it is trying to achieve through logging as their “desired condition.” Root rot also reduces inter-tree competition and creates openings for hardwoods.

4) Based on our field surveying of the sale units, the Ponderosa pine/Douglas fir stands are not “over-stocked” as claimed by the Forest Service. Smaller trees that are growing in patches could easily be non-commercially thinned up to 9” dbh (diameter at breast height.) There are no “excess” mature or large trees in those stands, which are already fairly open and healthy.

5) Logging decreases the resiliency of forest stands and subsequent prescribed burning often increases diseases and pests, and decreases biodiversity and ecological integrity.

6) While we have no objection to hardwood planting, there are already hardwoods around Walton Lake; this is not the real purpose of this aggressive timber sale.

Root rot has been in the Walton Lake area for at least decades, if not millennia. This is not an emergency. Reasonable public safety can be established through legitimate hazard tree removal and posting warning signs around the root rot areas (with no closure or fines.) The Forest Service already has the option to conduct legitimate hazard tree removal; nothing is stopping them from felling trees that pose actual threats to public safety.

Currently, the campground has been re-opened without logging in the laminated root rot areas, and signs advising the public to keep out of the root rot area are deemed sufficient by the Forest Service for public safety now. The public use is generally concentrated around the lake outside of the root rot area.

The virtual clearcutting planned for the root rot area would completely change the character of the Walton Lake recreational setting, as the Forest Service admits in their project records but not in the public information given out so far on the public sign at Walton Lake or on their scoping information.

The entire area is designated under the Forest Plan for protection of developed recreation values, not for logging. The proposed clearcutting and logging of large fir trees also in other parts of the area would destroy scenic values, degrade forest health, and not ensure public safety. The Forest Service is already allowed to fell legitimate hazard trees and pose warning signs around the root rot areas, which they have done. Their so-called “Sanitation harvest” would basically result in clearcutting with few leave trees as most trees in sale units 2, 3, and 4 are fir, not Ponderosa pine or Western larch. Logging and “restocking” the area as planned would drastically change the appearance of the recreational setting as it would be visible from the ring road, the camping areas, and from across the lake. Further, this would be an artificial conversion from mixed conifer old growth and mature forest to different tree species planted as seedlings in complete defiance of the original protection of this area for its natural forest character.

The Forest Service is proposing Forest Plan amendments to eliminate the following ecologically protective standards which would normally apply to the sale area:

• The strict visual quality standard that applies to the Walton Lake recreation area;
• A Forest Plan limit on clearcutting (“regeneration cuts”) to 2 to 5 acres for mixed conifer stands in the Developed Recreation management area;
• An exemption from the Developed Recreation management area standard requiring “Retention”, defined as “Human activities are not evident to the casual Forest visitor”;
• The Eastside Screens provision that prohibits timber sales to take place within old growth (LOS) stages that are below the historical range of variability;
• The Eastside Screens requirement “to maintain all remnant late and old seral [old growth] and/or structural live trees >= 21 inches DBH [diameter at breast height] that currently exist within stands proposed for harvest activities.”

It’s telling that the Forest Service only discusses the planned Forest Plan amendments (that would violate multiple Forest Plan standards) as an attachment after the rest of the scoping letter, as if to keep them out of public awareness.

Reasons that these proposed Forest Plan amendments are illegitimate and likely illegal:

* The Forest Service claims to be following the Forest Plan by clearcutting the root rot area, yet would throw out updated science-based restrictions added to the Forest Plan based on the need to preserve the last remaining old growth habitat and the need to retain remaining large tree structure for wildlife, recreational values, and now also for carbon storage to slow climate change. There is a continuing regional deficit in both large trees and old growth habitat due to extensive past logging of both and continued incremental elimination of both large trees and old growth through such Forest Plan amendments, which are not unique or site-specific to the Walton Lake timber sale.

* There is no “unique” situation established for Walton Lake that would justify these Forest Plan amendments in that it is one of 21 Developed Recreation areas on the Ochoco National Forest (others likely also have root rot); it is only 1% of 1,234 acres of Developed Recreation areas on the Ochoco; it is only one of many areas identified as “critical infrastructure” within the Crook County Community Wildfire Protection Plan and other similar plans; and some of these Forest Plan amendments are just like others being attempted by the Forest Service (as they are probably being directed to use them to increase the logging cut) across Eastern Oregon. These Forest Plan amendments could be later applied to different designated recreational areas and to the moist mixed conifer across the Forest, since root rot is a ubiquitous natural tree disease in moist mixed conifer, as the Forest Service admits.  Multiple such amendments incrementally increase the significance of the cumulative impacts that they cause. Already successive Forest Plan amendments on the Malheur National Forest are steadily increasing the acreage of old growth habitat degraded and the numbers of large trees lost.

As these are common Forest Plan amendments applicable to larger and different areas, it is inappropriate to create piecemeal Forest Plan amendments that are not really site-specific instead of waiting for a comprehensive Forest Plan revision.

The Forest Plan amendments reflect rejection of any parts of the Forest Plan which are inconvenient to Forest Service plans rather than the agency striving to abide by the intent of the Forest Plan in the light of best available current science. This arbitrary selective picking and choosing of parts of the Forest Plan to respect or throw out is in violation of the National Forest Management Act. Failure to use best available science is in violation of the National Environmental Policy Act. The Forest Service is engaging in improper procedure by using non-site-specific Forest Plan amendments, as these amendments could be applied to other Developed Recreation areas and/or across the Forest in general.

Additional considerations for comments:

* Logging is a much greater visual quality impact than natural ecological processes such as patchy forest self-thinning from root rot—especially in a developed recreation area preserved from logging for its natural values which is surrounded by a more heavily logged landscape.

* It’s not just the large legacy Ponderosa pine in the vicinity of Walton Lake that are large old trees worth preserving, but also the Western Larch (not mentioned as legacy trees by the Forest Service) and large old Grand fir and Douglas fir (up to 60+” diameter at Walton Lake), all of which are part of the natural scenic and recreational setting of the lake. The Grand fir and Douglas fir have been selected for elimination just because they are “host” trees for root rot, with many of them actually free from root rot. Ponderosa pine and Western larch are also subject to various diseases (and insects) that cause them to fall down and cause a safety hazard, yet somehow this is not an occasion for the Forest Service to propose multiple Forest Plan amendments to allow clearcutting of old growth/mature forest in a developed recreation area. The Forest Service has been intent on converting moist mixed conifer forest to Ponderosa pine since at least 1910, based on historical records that are more blatant about their preference for Ponderosa pine as a timber industry preferred tree species.

* At stake is the degradation of: wildlife habitat; recreational and scenic values; the integrity of natural disturbance regimes and dominant ecological processes; loss of carbon sequestration and storage to lessen climate change effects; the loss of ability of terrestrial and aquatic ecosystems in the Walton Lake area to adapt to climate change; aesthetic values; cultural values such as sense of place and treaty rights; ecosystem services such as moisture retention; fish and wildlife species; habitat connectivity; the recreational setting and opportunities; riparian areas; soil productivity; surface and subsurface water quality; trails; natural vegetation; viewsheds; and other life sources and uses such as hunting, fishing, and Nature education; opportunities to connect people with Nature; and reasonably foreseeable risks to ecological and social sustainability. These all fall under Substantive Rule requirements for consideration: 219.8 (a) (1) (iv); 219.10 (a) (1); 219.10 (a) (7); and 219.10 (a) (10).

The closure of the root rot area (complete with heavy fines for violation, including for organizations) is effectively preventing the public from seeing the heavy marking to log on the ground for the illegal logging contract the Forest Service signed before public comment and the final decision. Why else would they enact a closure with fines of thousands of dollars if only public safety was their concern? There are already warning signs posted around the root rot area. The Forest Service has used taxpayer funds to paint the trees to cut, mark sale unit boundaries, and even flag skid trails—all before the sale was stopped in reaction to our comments and filing of an objection, before any final decision. So this revised timber sale plan has the purpose of fulfilling a premature logging contract.

Of other alternatives suggested to the proposed action, we support the option of continued hazard tree inspection and felling of legitimate certified hazard trees in proximity to heavily used areas such as camp sites, with the additional amendments of no commercial size logging and only non-commercial size thinning by hand up to 9 inches dbh throughout the entire Walton Lake area, only where needed.

Please also consider supporting our ecological protection work with Blue Mountains Biodiversity Project by sending donations to 27803 Williams Lane, Fossil, OR 97830 or through our website: bluemountainsbiodiversityproject.org. To volunteer for the summer field season surveying of proposed timber sales, leave a detailed message with your phone number at  (541) 385-9167. We also appreciate in-kind donations of cameras, dbh measuring tapes, etc.

Thank you for your support!