Please send comments by January 30th to: https://cara.ecosystem-management.org/Public//CommentInput?Project=58081
Or to: Elysia Retzlaff, Environmental Coordinator, Ochoco National Forest 3160 NE 3rd St., Prineville, OR 97754
The Ochoco National Forest is proposing a commercial timber sale under the guise of “dry forest restoration” on about 23,015 acres adjacent to the Mill Creek Wilderness Area within a project area of about 36,485 acres that is mostly within the Mill Creek Wilderness Area, which is off-limits to logging. Commercial logging and new road construction, such as the “temporary” road construction planned, is not restoration. The Ochoco Forest’s current accelerated scale and pace of logging is unsustainable ecologically, socially, and economically. It’s well past time for the Forest Service to change course to implement ecologically sound restoration without more destructive timber sales and road construction.
We propose adopting a different action alternative as follows: a proposed alternative that does not include any commercial-size logging or new road construction but does include active riparian restoration, small tree non-commercial thinning by hand up to 9” dbh–only in plantations and riparian hardwood habitat where needed, with prescribed burning only in the dry Ponderosa pine or juniper-dominant forest types, skipping moister mixed conifer habitat suitable for Pileated woodpecker, American marten, or other species dependent on denser habitat such as elk and Northern goshawk, to preserve habitat niches for a variety of wildlife species. Otherwise we can only support the No Action alternative.
Context and Recommendations:
The Forest Service is responsible for riparian damage from timber sales, road construction, and livestock grazing, as well as for dense, homogenous continuous pine plantations that the Forest Service cleared and planted. Why should we trust the Forest Service to accomplish different results with the same misguided management plans repeated over decades? For example, the following public relations rhetoric from the scoping letter: “The proposed project is needed to restore characteristic (i.e. historic) dry forest vegetative conditions in the Mill Creek project area, thereby increasing resilience to insects, disease, fire, and drought; reducing the risk of uncharacteristic high severity fires; and enhancing and restoring RHCAs.” (Mill Creek scoping letter, p. 2) This could have been cut and pasted from virtually any of the Forest Service timber sales proposed over the last two decades in eastern or central Oregon. There’s nothing site-specific to the project area about these unfounded claims.
Contrary to the purpose and need stated for the Mill Creek timber sale “project”, planned management (commercial logging, road building, and prescribed burning) has all weakened forest resilience due to past timber sales, not improved forest resilience. Contrary to the stated purpose and need stated for the Mill Creek timber sale there is no evidence that all the past timber sales across the West have increased “resilience to insects, disease, fire, and drought” or reduced the risk of so-called ‘uncharacteristic” high severity fires. Instead there’s evidence of greater loss of resilience with most timber sales, with more insect epidemics and more intense fires. There is also recent science finding never logged forest areas to be more resilient to disturbance.
More commercial-size logging would remove mature trees next in line to replace large trees lost to past logging, so lack of fire resilience would be maintained, since large trees are more resistant to fire. Fire intensity could be increased with created openings producing drier conditions with higher wind speeds through the stands and more flammable slash. Incremental removal of mature trees through repeated commercial logging leads to the majority of remaining trees being homogenous in-growth of more flammable small young trees. Then the Forest Service uses the resulting condition of mostly small flammable trees as an excuse to commercially log mature trees yet again.
We are strongly opposed to any logging of live trees or snags >/= 21” dbh and large down wood removal because of the scarcity of large live trees, large snags, and large logs due to past logging of large trees. Large wood structure is needed for wildlife habitat; erosion control; carbon storage; nutrient cycling in soils; and recreational natural aesthetic values.
The Ochoco National Forest has a high degree of variation regarding topography, elevation, slope aspects, and moisture regimes. These create heterogenous conditions supporting different forest types, which cannot all be lumped together as simply “dry” forest. Diverse forest conditions create important habitat niches that support biodiversity, which should not be rendered virtually sterile by “one size fits all” blanket logging and burning “prescriptions”.
Mixed and high severity wild fires historically occurred, not just low severity fire. Based on current best available science, mixed and high severity fire was much more common historically than previously assumed. Looking at recent fire maps of fire intensity in eastern and central Oregon, most fires were a mosaic of low, middle, and high intensity fire, as well as skipped green areas. Fire of all levels of intensity serve beneficial functions for the ecosystem. Native wildlife and plant species evolved with wild fire and are associated with or dependent on habitat niches created by fire. If the Forest Service wants to reduce fire “risk”, they should do so adjacent to people’s homes, not in the back country.
There is a compelling, scientifically supported need for mature and large tree structure retention for carbon sequestration to slow or reduce climate change effects and to provide for unlogged wildlife refugia habitat and migration corridors so species losing suitable habitat can survive extreme climate change. Climatologist Dr. James Hansen has warned that stopping fossil fuel emissions and switching to renewable energy sources will not save us from extreme climate change effects unless we fully protect existing natural carbon sinks, including the oceans, forests, and soils.
There’s also current science finding that with the effects of extreme climate change, fires are not likely to be reduced in size or intensity by thinning of the forest. Drought conditions with low humidity and high temperatures and increased wind speeds from climate change are driving the intensity and fast expansion of major recent fires —weather conditions, not “fuel” loading.
The Forest Service is also proposing commercial logging in Riparian Habitat Conservation Area “no logging” buffers. Most conifer “encroachment” in riparian areas is only small trees less than 10 to 12” dbh, so no commercial thinning is needed. Wood in the floodplain is needed for roughness to slow overland flows and increase water retention and mature trees are needed for pool formation, bank stability, and erosion control. We are strongly opposed to any commercial logging and tree removal within any part of the Riparian Habitat Conservation Areas.
Drop prescribed burning in moister mixed conifer areas so as to protect suitable habitat for moister mixed conifer and denser forest-associated wildlife species, including the Management Indicator species Pileated woodpecker, American marten, and Rocky Mountain elk, as well as the focal species, Northern goshawk. Prescribed burning does not have the same effects as wild fire and can be especially damaging in areas that historically burned at mixed or high intensity or were skipped by past fires.
The Mill Creek timber sale proposal involves a lot more road re-opening and construction than needed road closures and decommissioning. More road construction and re-opening of closed roads would perpetuate the same predictable negative impacts to RHCAs; elk security and calving habitat; native plants, including invasive exotic plant introduction and dispersal; and increased access for ATVs, fur trapping, livestock, and illegal firewood cutting. Road closures have chronically not been enforced and “temporary” roads have not been decommissioned and are being planned for re-opening as “existing disturbance”—defacto system roads. This is contrary to past Forest Service promises that these roads would be only temporary and would be fully decommissioned.
Drop all planned “temporary” road construction, including both new and existing disturbance “temporary” road construction. Use effective barriers for closing roads, not just easily circumvented berms or post and pole barriers. Close and schedule for decommissioning all roads that are ecologically damaging; causing disturbance to wildlife, such as for migration corridors or calving and fawning areas; are overgrown; or are unnecessary or redundant. All roads within RHCAs should be decommissioned except main system roads with adequate paving or gravel and sufficiently large culverts.
Regarding active riparian restoration: Clearly define what kinds of “floodplain manipulation” are being proposed, the methods, used, and the potential negative ecological effects. Don’t construct roads or landings within RHCAs and don’t ignite fires within RHCAs. Any large wood felling into streams should not include trees >/= 21” dbh or be from trees that currently exist in the natural stream recruitment zone for wood recruitment over time.
Our Recommendations Regarding Forest Plan management areas in the Mill Creek project area:
Drop commercial logging adjacent to the Mill Creek Wilderness Area. The Mill Creek Wilderness Area needs intact unlogged forest buffers to maintain a natural setting and preserve solitude. Drop all commercial logging in: old growth (MA-F6); Summit Historic Trail Retention Corridor (MA-F7); Steins Pillar Recreation Area (MA-F17); Winter Range (MA-F20); scenic “visual” corridors (MA-F26); and RHCAs. Our recommendations are due to conflicts between commercial logging and reasons for these Management Area designations, such as “No Scheduled Harvest” for old growth (Mill Creek is a scheduled timber sale); “retention” for the Summit Historic Trail; forest thermal cover needed for elk in winter range; and meeting Riparian Management Objectives for RHCAs, with riparian functioning being the priority. Management in visual (scenic) corridors needs to respect the intent of not having management activities evident or “visually subordinate” to the surrounding landscape.
If you would like to support our work please mail donations to:
Blue Mountains Biodiversity Project 27803 Williams Lane, Fossil, OR 97830
Or donate on our website: bluemountainsbiodiversityproject.org
Call (541) 385-9167 voicemail to volunteer for our summer 2021 timber sale field surveying season, which does require following a strict protocol of social distancing, mask wearing when we are less than six feet apart from each other, and bringing your own transportation, cooking set-up, and food.