Blue Mountains Biodiversity Project Action Alert: Comments Needed by April 6th for the Notice of Proposed Action for the High Buck Vegetation Management Project
You can submit comments electronically to: https://cara.ecosystem-management.org/Public/CommentInput?Project=53033
Mail comments to: District Ranger, Attn: High Buck Project Comments, Walla Walla Ranger District (Umatilla National Forest), 1415 W. Rose St., Walla Walla, WA 99362.
We are concerned by the distorted Forest Service process of only allowing public comments on the Notice of Proposed Action and not on the Environmental Assessment, the only document that would disclose more specific information about the project area values at stake and that would include detailed analysis of potential environmental effects of the proposed action and any other alternatives.
We are asking the Forest Service to withdraw the Notice of Proposed Action, cancel the associated comment period, and issue an Environmental Impact Statement for this project with a 45 day public comment period or else cancel the proposed High Buck Vegetation Management Project entirely.
Information about the proposed action from the Notice of Proposed Action:
The Forest Service is proposing commercial logging on 2,195 acres, including 320 acres of skyline cable logging on steep slopes; non-commercial thinning of trees up to 10” diameter (dbh) on 2,315 acres; landscape prescribed fire across 2,770 acres; and 5.5 miles of “temporary” road building, as well as re-opening of closed roads and intensive burning of biomass, including existing down wood. Commercial logging would include created openings up to 6 acres and targeted removal of Grand fir, spruce, and Subalpine fir, with preferential retention of Western larch, Douglas fir, and Ponderosa pine.
The Forest Service presents no evidence to support their claims that there are departures from the natural fire regime, tree density, tree species composition and structural stages (which they want to change through logging and burning.) The Forest Service also presents no evidence to support their contention that because of these “departures” the project area is susceptible to disturbance agents at higher rates of “uncharacteristic” intensity or severity. The Forest Services “Range of Variation” assessment is being used to justify conversion of the moist mixed conifer forest to Douglas fir/Western larch plantations and areas of Lodgepole pine for timber production and to greatly reduce tree species not preferred by the timber industry, including Grand fir, Englemann spruce, and Subalpine fir.
The so-called “key forest health issues”—Indian paint fungus, mistletoe, root disease, Mountain pine bark beetle, etc.—are all naturally occurring disturbances that can be found in almost any forest area. This situation does not justify logging, especially as logging may also spread and increase pathogens such as root rot and mistletoe.
Effects to Wildlife: The Fish and Wildlife section only addresses elk and fish species and relegates the rest of wildlife species to: “many other wildlife species, including management indicator species and sensitive wildlife species.” (NPA p. 3) We are very concerned by potential negative impacts of the planned timber sale to Threatened-listed Bull trout and Threatened Mid-Columbia Steelhead trout within or adjacent to the timber sale area and to documented Steelhead spawning downstream of the planning area. Threatened-listed Gray wolves are not mentioned for potential negative effects within the project area even though they are a keystone predator and Gray wolf packs exist on the Umatilla National Forest. We are also very concerned by undisclosed potential negative effects to Management Indicator species, including American marten, Pileated woodpecker, Rocky Mountain elk, and Primary cavity excavator woodpecker species. We are concerned by potential negative effects of the timber sale to any Sensitive-listed wildlife species in the area, which may include Redband trout; Pacific lamprey; Columbia Spotted frog and potentially other frog species; any Sensitive salamanders in the area; potential Sensitive-listed mussel species; any Sensitive insects, including butterfly species and bees; Pacific fisher; wolverine; and Lewis’ woodpecker.
Logging, roading, and burning would degrade old growth multi-layer canopy wildlife habitat, elk security cover, and the maintenance of connected landscape patches (wildlife connectivity).
Effects to Recreation: Impacts to recreational areas such as hiking trails and trailheads are not limited to “short term inconvenience for recreation users in the area during operations”, as the Forest Service claims. (NPA p. 12) Commercial logging would leave long-term degradation of the now relatively natural appearing forest that would be apparent for decades. The vast majority of recreationists do not come to National Forest recreational areas to see more logging, or as the NPA puts it disingenuously, “an incremental addition to the existing managed nature of the landscape.”
Popular recreation uses of the High Buck area are very diverse and not limited to the adjacent Wilderness Area or to trails and trailheads: “Popular uses include hiking, berry picking, mountain biking, motorcycling, snowmobiling, and cross-country skiing….” (Notice of Proposed Action (NPA) p. 2) People are also coming to the area to hike, horseback ride or hunt in the adjacent North Fork Umatilla Wilderness and are likely camping in dispersed campsites or the developed campground near the Wilderness boundary within the High Buck project area. Since recreational uses are varied and dispersed, the proposed timber sale would likely negatively affect all of these uses. With at least three trails, trailheads, one developed campground and three other recreational sites, this is an area that has been developed and designated for high recreational use for a long time. The recreational economic and social investment in this area would be sacrificed through extensive and obvious degradation of recreational and scenic values from commercial logging effects. These effects would be evident in commercial logging sale units situated adjacent to the North Fork Umatilla Wilderness Area and next to trails leading into or adjacent to the Wilderness Area ( the Lake Creek, Nine Mile, and Rim trails,) around the Lake Creek trailhead, next to major access roads ( Highway 204 and the Summit Road), and within the interior of the project area. We are very concerned by the potential negative impacts to all of these recreational uses and to scenic quality.
Indigenous people use the Buck Mountain area for traditional foods, medicine gathering, and religious and spiritual sites. Yet the two sentence section on “Heritage Resources” does not even disclose the names of the Native Nations using the area or how these traditional foods, medicines and cultural sites would be protected from planned timber sale management actions.
Climate Change Effects: Commercial logging of mature trees and associated hazard tree felling and burning removes considerable amounts of existing carbon sequestration (from live trees) and carbon storage from live trees, snags and logs that would otherwise help reduce climate change effects. Commercial logging, road work, and various types of biomass reduction with burning would emit Carbon dioxide, a Greenhouse gas that local and state governments are trying to reduce across the country. There is no mention in the Notice of Proposed Action of climate change, even though it should be a key issue for detailed analysis as the biggest global crisis of our time.
The effects of 2,000 sheep grazing in the High Buck project area warrants cumulative effects analysis of the impacts of the proposed timber sale combined with the sheep grazing where the effects overlap. Yet the Forest Service plans to exclude the issue of overlapping sheep grazing impacts from detailed analysis.
It is outrageous for the Forest Service not to disclose the findings of the High Ridge study, a national study of the effects of timber harvest on water quality within the planning area that is already completed. Analysis of the effects of planned logging in the High Buck project area should include consideration of the findings of the High Ridge study regarding effects of timber logging on water quality in the area.
Wildfire issues: The NPA account of the wild fire situation fails to disclose that there is significant scientific controversy over the Forest Service’s use of fire regime and condition class to determine theoretical “departure” from fire return intervals: “Wildland fire has had little impact within the project area in the past 120 years. Active forest management and fire suppression have altered the natural fire regimes of the project area. Historical fire regimes 1, 11, and 111 are in conditions that put the area at risk of loss to uncharacteristic disturbance. These regimes are characterized by a mean fire return interval of less than 35 years (17% of the project area) and 35-200 years (34% of the project area.)” (NPA p. 4, emphasis ours.) The Forest Service fails to quantify terms, including “little” impact and “uncharacteristic” disturbance, with no evidence supporting these conclusions. The Forest Service admits that active forest management and fire suppression have altered the natural fire regimes of the project area. More active forest management and fire suppression, as planned for the High Buck area, would further alter the natural fire regimes of the project area, contrary to the stated purpose and need of reducing the “risk” of wild fire. The Forest Service repeats their chronic mistake of conflating mean fire return intervals with the maximum fire return interval for fire conditions that would be considered within the normal range. A lack of wild fires over 120 years would not be “uncharacteristic” at all for forest that is characterized by the Forest Service as having a 35-200 years mean fire return interval or longer.
The Forest Service basing their high fire “risk” assumptions on “fuel” conditions ignores the scientific consensus that ambient air temperatures, humidity, and wind speeds are the main determinants of fire severity and extent, not biomass levels. Proposed logging and extensive biomass manipulation could actually increase wild fire severity by eliminating moisture-retaining shady forest canopy, leaving highly flammable slash piles in the forest for one or more fire seasons, increasing wind speeds by opening up the stands and reducing the number of future more fire resistant large trees.
We are concerned by potentially significant negative impacts to soil integrity, fertility and productivity and water quality from planned logging, increased road use and removal of down wood through burning.
This early stage of NEPA projects is designed for public comments to identify key issues for detailed analysis in an Environmental Assessment as well as the range of alternatives for the EA, yet this NPA has already excluded a No Action alternative and narrowly defined the issues for analysis by completely excluding standard issues for EA analysis from detailed analysis, including: Range; Invasive plants; Air Quality; Environmental Justice; and Inventoried Roadless Areas, Wilderness/Wilderness Study Areas, Wild and Scenic Rivers, and Areas of Critical Environmental Concern. (NPA p. 14)
Following are some of our recommendations for reducing the impacts of the proposed action:
* Drop all planned commercial logging in moist mixed conifer forest, Lodgepole pine or Subalpine fir high elevation forest and the 34% of the project area assumed to have a mean fire return interval of 35-200 years, as well as any other forest areas with infrequent fire regimes.
* Drop logging within Late and Old Structure forest or old growth wherever it occurs. We oppose logging in never before logged forest, roadless areas, and most mature forest.
* Drop planned tree species conversion to timber industry/Forest Service “desired” tree species and creation and maintenance of plantations.
* Reducing existing contiguous habitat and movement connectivity corridors for wildlife species should not be allowed. With climate change, wildlife species need the higher elevation and moister habitat.
* We ask the Forest Service to drop all commercial logging in Management Area C4 Wildlife Habitat (350 acres), A3 Viewshed 1 (305 acres) and A4 Viewshed 2 (170 acres.) Commercial logging, roading and biomass removal is not consistent with providing high levels of potential habitat effectiveness for wildlife species or for maintaining scenic quality “as a natural appearing landscape.” (NPA p. 6)
* We are opposed to steep slope logging due to greater detrimental soil impacts and loss of less accessible refugia for wildlife. We ask the Forest Service to drop the 320 acres of skyline cable yarding.
* Drop planned masticating and grapple piling of naturally occurring woody debris, which is fundamental to soil nutrient cycling, soil carbon storage, moisture retention for soils and micro fauna habitat, fungi and other plants. Prescribed broadcast burning and landscape burning should not be done in moist mixed conifer, Subalpine fir/Lodgepole pine habitat, and Dedicated Old Growth habitat. Burning eliminates soft decaying snags and logs used by Pileated woodpeckers for foraging and abundant down wood used by marten for winter foraging and could reduce large snags used by Pileated woodpeckers for nesting and by marten for denning.
* Drop the building of “temporary” roads and re-opening of closed roads because this increases access for ATVs, livestock, illegal firewood cutting, fur trapping and the introduction and dispersal of invasive exotic plants. “Temporary” roads are often not fully decommissioned and may be re-used later.
* Completely buffer and protect all cultural sites and First Foods from any timber sale impacts.
* Ground disturbance should automatically be prohibited for any Sensitive plants found in surveys through flagging of buffers. The extensive and intensive ground disturbance planned should be avoided in order to greatly reduce the potential for invasive plants to become established in new areas.
If this project is still planned to go forward, the Forest Service should prepare an Environmental Impact Statement with detailed environmental effects analysis that is made available for a 45 day public comment period with normal NEPA process.
If this project is still planned to go forward we ask that the following High Buck sale units be dropped completely due to steep slopes or slopes over creeks, a spring, or the North Fork Umatilla River: commercial logging sale units: 178, 171, 116, and 93 over the North Fork Umatilla River; 78 over Johnson Creek; 46 & 62 over Buck Creek; 23 over Lake Creek; 11 over Swamp Creek; 55 over Phillips Creek; 2 next to Whim Spring; 143 & 144 over East Phillips Creek; and 179, 180, 181, 182, & 183 over Pedro Creek.
The following High Buck commercial logging sale units also need to be completely dropped due to negative effects to recreational uses and scenic quality: sale units: 3, 2, 11, 26, 32, 9, 45, 46, 73, 71, 97, 89, & 90, all adjacent to or visible from the North Fork Umatilla Wilderness Area; 93 & 94 next to the North Fork Umatilla River; and along trails or around trailheads, sale units: 28, 42, 45, 46, 73 & 71, and 74, 77, 78, 97, 89, 90, 93, & 116, and 23 & 32.
* We recommend that the High Buck project simply be cancelled permanently.
Blue Mountains Biodiversity Project still needs volunteers for this summer’s field season. Call (541) 385-9167 and leave a message with your name and phone number if you would like to volunteer. We also need donations to help us meet expenses for our ecological protection work. Please send contributions made out to Blue Mountains Biodiversity Project to:
Blue Mountains Biodiversity Project, Eugene Office, 1560 Chambers St., Eugene, OR 97402.