Action Alert! Comment on large tree logging in the Crow timber sale

Please send comments to the Forest Service about their proposal to log large trees over 8,000 acres in the Crow Project on the Malheur National Forest!

Comments are due by August 7th
You can email comments to comments-pacificnorthwest-malheur-emigrantcreek@fs.fed.us. You can also mail comments to: Joshua Giles, 265 Highway 20 South, Hines, Oregon 97738 (postmarked by August 7th required for meeting the deadline)

The Crow “Hazardous Fuels Reduction Project” on the Emigrant District of the Malheur National Forest proposes to log large trees (≥21” diameter at breast height (dbh)) on approximately 8,000 acres.

The Forest Service is proposing to log large Ponderosa pines, Grand fir, and Douglas fir on approximately 3,378 acres, as well as large Grand fir and Douglas fir across an additional 4,635 acres.

The Malheur National Forest is planning to log large trees under the guise of reducing “hazardous fuels” (aka live trees, snags, and down wood–aka wildlife habitat) and for “salvage harvesting” (logging of recently killed trees). The Forest Service is proposing to use an illegitimate, project-specific Forest Plan amendment to log large trees, in violation of Forest Plan standards and guidelines.

Talking points:

The Forest Service‘s plans to log large trees ignores the following:

  • Large trees, including large fir, develop thicker, more fire resistant bark, and survive fires more often than smaller trees. Logging large trees undercuts Forest Service arguments that this sale will reduce fire severity or risk.
  • Under climate change, retention of large trees is vital for their greater carbon storage and to reduce climate change effects
  • Large trees provide crucial wildlife habitat for many native species.
  • Reducing the number of live large trees also reduces the number of future larger trees, large snags, and large logs needed by these and other species, and reduces the quality of mature and old growth habitat.
  • Old growth trees are likely to be logged in this sale, in violation of the Forest Plan’s stated goals and standards. Trees commonly reach approximately 150 years old when they are between 21” and 30” dbh.

In addition:

  • There is still a deficit compared to historical conditions in large trees and large tree structure across eastern Oregon due to past over-logging of large and old trees. Large trees are crucial for wildlife, carbon storage, and recreation values.
  • Many species of wildlife depend on large tree (regardless of age) including Pileated woodpecker, Northern flicker, Lewis’ woodpecker, White-headed woodpecker, Williamson’s sapsucker, Great grey owl, American marten, and Pacific fisher.
  • Large trees are especially important for combating climate change and the effects of climate change. Large trees sequester and store large amounts of carbon, contribute to soil carbon storage, and are important for watershed hydrology. They are also important for connectivity corridors, which species can use to move across landscapes. For species to be able to survive and adapt to climate change, connectivity corridors are important so that species can find food and mates, maintain genetic diversity, and find suitable habitat as conditions change and ranges shift.
  • The planned Forest Plan amendment to allow for the logging of large trees ≥21” dbh is not legitimate, as it is not site-specific or unique to this sale (the Malheur NF has been doing many similar amendments, increasing over time in scale and now in tree species targeted to include Ponderosa pine). This project-specific Forest Plan amendment is being used to violate Forest Plan standards and guidelines.
  • The Forest Service claims “Late and Old Structure” (LOS) stands will not lose their status (which offers some increased protection). The Malheur definition of LOS requires 10 large trees per acre. Though the Forest Service plans to leave 10-12 live large trees per acre, that means that just 1-3 large trees dying and becoming snags or down logs is enough for each acre to lose its LOS status and any agency obligation to protect LOS.

Additional background:

As part of the Crow sale, the Forest Service is proposing to log Grand fir and Douglas fir trees ≥21” dbh on approximately 4,635 acres. The Forest Service scoping package also details agency proposals to log Grand fir, Douglas fir, and Ponderosa pine ≥21” dbh and up to 30” dbh limit on about 3,378 acres, including in mature and old forests (i.e., “Late and Old Structure” or (LOS), in Forest Service lingo); thinning of 3,199 acres that includes logging large Grand fir and Douglas fir up to 30” dbh; and 1,791 acres of logging large Grand fir, Douglas fir, and Ponderosa pine up to 30” dbh.

The Forest Service does not say they will retain trees that have old growth characteristics, even though the ≥ 21” dbh limit for logging was set in eastern Oregon Forest Plans because most Ponderosa pine are likely to be at least 150 years old (thereby meeting the definition of old growth) at 21” dbh. The Forest Service has acknowledged that there are many Grand fir and Douglas fir that have old growth characteristics and qualify as old growth between 21 to 30” dbh. Without specifying that trees with old growth characteristics would be saved from logging, this Crow timber sale would likely log old growth trees as well as large trees.

An additional 12,000 acres of commercial logging of trees up to 20” dbh is also proposed, and includes: 5,067 acres of commercial thinning in second growth mixed Ponderosa pine/Douglas fir/Grand fir stands, with only residual basal areas of 25-75 feet (very open, much like a clearcut with reserve trees); thinning within 999 acres of Late and Old Structure stands (i.e., mature and old growth stands); commercial thinning within wildlife connectivity corridors over 6,045 acres in Late and Old Structure & old growth stands; and commercial thinning of Lodgepole pine stands over 289 acres.

Smaller diameter thinning is also proposed as part of the Crow sale. This includes small diameter thinning in LOS/old growth stands over 1,173 acres and small diameter thinning over 4,570 other acres; juniper logging in Ponderosa pines over 1,357 acres; and more.

The Crow sale is now up for scoping comments until August 7th, with an Environmental Assessment being up for comments at a later date.

Please help us show opposition to this sale now before these Forest Service plans to log large trees over 8,000 acres become entrenched.

Thank you, and please consider donating to help our work continue.

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