Please help us stop extensive logging of large trees and old growth forest, and destruction of watershed integrity and habitat for marten, Threatened Steelhead and Bull trout, Sensitive Columbia Spotted frogs, and more….
Located in the Malheur National Forest, about 9 miles North of Prairie City, OR lie the Ragged Ruby timber sale. Despite past heavy logging in parts of the this “project area,” the area still contains magnificent creeks with critical habitat species such as Threatened Steelhead and Bull trout. This beautiful area also provides high quality habitat for Sensitive Columbia Spotted frog and Long-toed salamander, and critical riparian corridor and high elevation habitat for American marten. The latter is a weasel species ranked as vulnerable in Oregon and especially vulnerable in the Malheur Forest.
The vast majority of the so-called “upland restoration activities” planned in Ragged Ruby consist of extensive heavy commercial logging that impairs ecological resiliency and threatens the viability of numerous wildlife species in the area, including Pileated woodpecker, Sensitive Western-ridged and California floater mussels, and possible rare Pacific lamprey. As the Draft Environmental Impact Statement (DEIS) admits in its summary, Ragged Ruby Project watershed, fisheries, and wildlife habitat restoration is limited to 10 acres of aspen restoration (18 stands) and installation of two bat gates in mine entrances for their protection, in the face of 8,210 acres to 9,200 acres of commercial logging (under alternative 3 and the proposed alternative 2 respectively) plus 11.6 to 12.4 miles of “temporary” road construction, 2.9 miles of road opening, and miles of new trail construction from roads into two Inventoried Roadless Areas, plus lots of prescribed burning across the whole area—31,500 acres to 34,000 acres.
Unfortunately there is little significant difference between the two action alternatives, as both incorporate similar extensive logging and burning and way too many threats to watershed integrity through “temporary” road building on hill slopes (usually over creeks) and within Riparian Habitat Conservation Areas, and many stream-crossings. Both alternatives propose Forest Plan amendments to effectively violate Forest Plan standards by commercially logging large Grand and Douglas firs over 21 inches in diameter at breast height (dbh); logging in and reducing late and old (old growth) forest stands; and not maintaining existing wildlife connectivity corridors between late and old structure and old growth forest stands.
To make a long story short, alternative 3 is better than alternative 2 as it avoids logging more marten habitat and undeveloped (never logged or roaded) lands, commercially logs 1,000 acres less overall than alt. 2, drops commercial logging in lithosol (a type of soil consisting mainly of rock fragments) high desert areas and dry meadows, designates 1,060 acres more as wildlife connectivity corridors, reduces logging of large trees by 400 acres, commercially logs 190 acres less late and old structure forest than alt. 2, and excludes bicycle use from several trails in Inventoried Roadless Areas to prevent illegal bicycle use in the North Fork John Day Wilderness Area.
However, neither alternative is acceptable to us, as both pose serious threats to watershed integrity, critical habitat for Steelhead and Bull trout, and marten habitat, and extensive logging of large trees and logging within late and old structure forest, and both would fail to meet Forest Plan standards for wildlife connectivity corridors.
We are greatly concerned by Ragged Ruby project proposed impacts to watershed integrity, including logging on steep slopes, log hauling on already damaged roads that concentrate overland flow, “temporary” road construction within Riperian Habitat Conservation Areas (RHCAs), and many stream crossings with heavy equipment or log trucks, combined with highly detrimentally altered existing watershed conditions. Legacy management impacts and ongoing management impacts have already altered the quantity and timing of surface water runoff, so extensive road use within riparian areas with the Ragged Ruby timber sale would create significant cumulative impacts to watershed conditions that weren’t adequately considered in the DEIS.
With extreme climate change already in progress, severe storms are likely to further exacerbate the effects of Ragged Ruby logging, road construction, log haul, and stream crossings have on alterations of surface water runoff, water quality, water quantity, and timing of peak flows. Yet the DEIS fails to analyze these critical cumulative effects from proposed actions plus climate change.
We are also concerned that planning area creeks and streams are already not meeting stream temperature standards and that the intensive management planned for RHCAs in the Ragged Ruby sale would further increase stream temperatures to the detriment of listed fish species, including Bull trout and Steelhead trout. The foreseeable erosion and sedimentation effects of so many (123) stream crossings where log hauling is proposed also threatens water quality essential for critical fish habitat.
Our concerns regarding Ragged Ruby project impacts to American (Pine) marten habitat and population viability:
The Ragged Ruby area is evidently a stronghold for marten on the Malheur National Forest compared to other parts of the forest. The DEIS establishes that: Marten presence in late and old structure forest was documented multiple times in the Ragged Ruby planning area, including females with kits.
Based on the Bull and Heater (2000) study and the Raphael and Jones (1997) study cited in the DEIS (p.189), marten select for large snags over 20” dbh and averaging 26 to 38” dbh for resting and denning in Eastern Oregon, and would therefore be threatened by removal of large firs over 21” dbh, as proposed by both action alternatives. Downed wood used as rest and den sites by marten in the Blue Mountains average 26” dbh (Bull and Hunter, 2000), indicating an additional impact to marten viability from logging large trees.
Further impacts to marten populations from planned management actions in the Ragged Ruby sale are well documented in the science: “Reduction in the amount of late-seral forest [such as large and old growth Grand fir and Douglas fir] and associated large snags and logs, and associated fragmentation of habitat are the main reasons marten are considered vulnerable (Hargis et al. 1999, Wisdom et al. 2000).” (DEIS p. 190) “Pine marten populations appear to be sensitive to changes in their environment, particularly a reduction in fuels and forest complexity (Moriarty et al. 2016).” (DEIS p. 190)
We are very concerned by the admissions in the DEIS that: “Depending on the size and intensity of fall burns, alternatives 2 or 3 could remove a substantial amount of suitable marten habitat in the planning area.” (DEIS p. 198) “Because this planning area contains occupied and extensive suitable habitat for pine martens, the overall direct, indirect, and cumulative effects could result in a negative population trend. Combined with other similar projects, particularly in the Middle Fork John Day River corridor, the loss or alteration of habitat could be significant at the scale of the Forest….Ultimately, not enough information is known about pine marten populations or distribution across the Forest to accurately determine continued viability….localized populations (Middle Fork John Day River corridor martens) could see considerable declines in suitable habitat or populations.
Cumulatively significant loss of snags and downed wood for wildlife, carbon sequestration and nutrient cycling in soils: We are very concerned by the high potential cumulative loss of snags and downed wood from the Ragged Ruby sale combined with many similar timber sales across the Middle Fork John Day area (e.g. Camp Lick, Magone, Big Mosquito, and Galena) which have recent and over-lapping timelines of logging and road use.
Rare plants at risk in the Ragged Ruby project area: Four rare vascular plant species and one moss species live within the Ragged Ruby planning area: Buxbaumia piperi (Bug on a stick), Eleocharis bolanderi (Bolander’s spikerush), Lomatium tarantularioides (Spider biscuitroot), Pinus albicaulis (Whitebark pine), and Pyrola dentatadentate (Undulating wintergreen.) We are concerned that the Ragged Ruby timber sale may contribute to a trend toward up-listing, or increasing the threat to the four rare vascular plant species and one rare moss species known to exist in the area. This concern is due to an admitted lack of thorough plant surveys for this project.
We request the following changes to the Ragged Ruby project:
*All logging of large trees =/> 21” dbh needs to be dropped.
*All commercial size logging in late and old structure forest must be dropped.
*The Ragged Ruby Project needs to fully comply with Forest Plan standards for wildlife connectivity corridors. (Drop all Forest Plan amendments. )
* We want all suitable marten and active Pileated woodpecker habitat dropped from commercial-size logging and prescribed burning.
*Logging should also be dropped in all mature and Late and Old structure cool moist forest (which can be Pileated woodpecker and marten habitat.)
*All logging or roading in undeveloped lands must be dropped.
*Drop all logging and road construction and most log hauling within RHCA buffers, including stream-crossings.
* There should be no prescribed burning or commercial logging in wildlife connectivity corridors, which provide crucial dispersal and climate change migration habitat for many species, including marten, lynx, and Gray wolves.
*We are strongly opposed to creating openings (mini-clearcuts) in the Inventoried Roadless Areas, even where there is no removal of felled trees. Inventoried roadless areas are some of the last areas left in an unmanaged state outside of Wilderness Areas and need to be left that way to allow for critical wildlife refugia, headwaters protection of streams, intact blocks of undisturbed habitat for wide-ranging predators (wolves, lynx, fisher, marten), significant carbon sequestration, undisturbed natural ecological processes, and semi-primitive recreation.
*This sale either needs to be abandoned completely (our preference) or scaled down significantly, in part by removing all logging and roading out of RHCAs and off steep slopes above creeks.
You can view a longer, more detailed version of this information to help you write comments here: Ragged Ruby DEIS Action Alert
Alternately, you could send email comments to: firstname.lastname@example.org
Electronic comments must be submitted as part of the actual email message or as an attachment in .doc, .docx, .rtf, or .pdf. Emails sent to other email addresses, in other formats, or containing viruses will be rejected by the Forest Service.
Include your name, address, telephone number, organization represented (if any) and the title of the document (Ragged Ruby Project Draft Environmental Impact Statement) with written comments.
Thank you for helping us show opposition to the Ragged Ruby Project timber sale. Please support our ecological protection work with Blue Mountains Biodiversity Project:
Donations can be sent to: Blue Mountains Biodiversity Project, 27803 Williams Lane, Fossil, OR 97830
In-kind donations needed: Lawyer and law student assistance with our potential legal cases & volunteers to field survey proposed timber sales in Eastern Oregon next summer: Call (541) 385-9167 (message)