Update as of 3/23/2020: The official comment period to submit comments on the Walton Lake Environmental Assessment closed on March 19th. However, we requested that the Forest Service extend the deadline or open a new public comment period. The public comment period largely overlapped with the coronavirus epidemic, which severely hampered the public’s ability to comment. Also, members of the public experienced problems with the Forest Service’s link to the comment portal during the official comment period. Please continue to call and write the Forest Service to request additional opportunities to comment, and to tell the Forest Service your concerns about the Walton Lake project. You can call the Forest Service at 541-416-6463 or email email@example.com. Please speak up for the old growth forests around Walton Lake, and voice your opposition to the USFS’s plans to log of this magnificent old growth forest.
Walton Lake Old Growth, Large tree, and Clearcut Logging Plan Comments Needed Again! The comment deadline is March 19th!
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 Forest Service refuses to let go of their plans to irrevocably destroy the natural character of Walton Lake, one of the most popular recreation areas on the Ochoco National Forest. The Forest Service is, yet again, proposing clearcutting of old growth and mature moist mixed conifer forest visible from the lake, the campground, and the loop road around the lake, as well as the planned commercial logging of dry mixed conifer forest, including the logging of large trees over 21” diameter in violation of the Forest Plan Eastside Screens.
Please help us show opposition to this unnecessary and destructive timber sale by sending in comments by March 19th at the latest!
Comments can be submitted to the Forest Service through their website at: https://cara.ecosystem-management.org/Public//CommentInput?project=47019. Written comments can be mailed to: Slater Turner, District Ranger, 3160 NE Third Street, Prineville, Oregon, 97754. You can also call Beth Peer at the Ochoco National Forest at (541) 416-6463.
Some useful talking points include the following:
* The Forest Service is using the guise of public safety and hazard trees to log in the Walton Lake recreation area, despite the fact that the Forest Service continues to be free to deal with hazard trees. The Forest Service has maintained public safety in the area for decades by annually inspecting for and removing true hazard trees. We support that practice. USFS still offers no explanation for why they need to dramatically depart from that practice and log hundreds of large and old-growth trees.
* The Forest Service proposed action includes logging 571 large trees, many of them old growth, from an area of only 178 acres. This is a shocking conversion of mature and old growth forest to a virtual clearcut. Also, we are concerned that the agency’s estimate of the number of large trees planned for logging does not align with past estimates, and that the Forest Service has not provided consistent, transparent, or reliable information about the project during their repeated attempts to log this forest.
*If you oppose the following, please tell the Forest Service: logging of large and old growth trees; clearcutting (called “Sanitation Harvest” for this sale); logging of popular recreation sites; and use of Forest Plan amendments to enable violations of Forest Plan standards and guidelines that serve to protect wildlife habitat and recreational values.
*Point out that the proposed action regarding heavy logging to reduce root rot is inconsistent with the purpose and need to increase public safety and maintain a natural outdoor setting for recreation. Logging will not address perceived root rot issues, and the resulting logging would be an unnatural ugly clearcut.
*If you are concerned about effects to wildlife, some of the wildlife that could be affected negatively include the following that we know are using the area: Pileated woodpeckers and Northern Flickers (both harmed by removal of large trees for nesting and snags and logs for foraging); Black bears (who forage in large logs and snags); elk, deer, and wild horses who use the forest for thermal and hiding cover when coming to drink at the lake; a variety of songbirds that would be harmed by removal of shrubs and denser forest; and potential predators such as marten, who need abundant down logs for winter foraging under snow and Gray wolves, who need hiding cover to protect themselves from people shooting them.
*Ask for the entire sale to be dropped or for an Environmental Impact Statement to be prepared for public comment with far greater public outreach solicitation that includes the hometowns and cities of recreational visitors, including Portland and Eugene.
*If you have been to Walton Lake and feel this proposed timber sale would harm your recreational enjoyment of the area, please tell the Forest Service what you value about Walton Lake and how your recreational experience there would be harmed.
* The Forest Service proposed action includes logging 571 large trees, many of them old growth, from an area of only 178 acres. This is a shocking conversion of mature and old growth forest to a virtual clearcut. We are also concerned that the actual number of large trees at risk of being logged may be higher. In their proposals to log the Walton Lake area, the Forest Service has repeatedly provided misleading and unclear information to the public, and has not been transparent or inclusive during the public comment process.
Previously, we stopped the timber sale once through stopping the Forest Service from using a Categorical Exclusion to rush through the sale with no public opportunity to see detailed analysis of potential environmental impacts and no opportunity to file informed comments or objections or to negotiate with the Forest Service for a reasonable outcome. Then we stopped the sale again when we challenged their use of a grossly deficient Environmental Assessment that did not disclose many of the significant impacts of the sale. Now the Forest Service is back again with a revised Environmental Assessment open for public comments that proposes almost the exact same proposed action, along with the addition of two modified alternatives, and a No Action alternative. Following are descriptions of these alternatives and some of the environmental impacts they would cause.
Our recommendation is the No Action alternative, modified to end the public closure on the root rot areas, and to re-mark the cancelled timber sale that is already marked to cut within the closure and in other sale units by blacking out all markings for cut or leave trees and removing all flagging and unit boundary signs. Retention of the warning signs around the root rot areas are a reasonable part of the No Action alternative that could be used. There is no need to log mature and large trees in the Walton Lake area. The Forest Service already identifies and fells legitimate hazard trees that could threaten public safety in the recreational use area every year. This would not change regardless of the outcome of this sale.
Here’s the current alternatives offered by the Forest Service:
The proposed action, alternative 2, is what the Forest Service still wants to do:
178 acres would be commercially logged, including logging of large trees over 21” diameter at breast height (dbh), in violation of the Forest Plan’s Eastside Screens, over 68 acres in sale units 1, 2, 3, 4, and 5 (within most of the sale area except for already open Ponderosa pine areas between the loop road and the lake.) The Forest Service is proposing to use two Forest Plan amendments to allow for net loss of “Late and Old Structure” forest (forest with a minimum number of large trees, usually old growth) and to allow for logging and removal of large trees equal to and over 21” dbh, both in violation of the Eastside Screens protections for large trees and old growth (LOS) forest structure under the Forest Plan.
The Forest Service is also still planning to use “Sanitation harvest” (code for a virtual clearcut) over 35 acres “to eliminate trees infested and [/or] susceptible to root disease,” which encompasses most of the trees in the root rot-affected areas, since they are almost all firs, including old growth Douglas firs and Grand firs up to 30-67” dbh. This means that the Forest Service would not just fell and remove root rot-affected trees but that they would also remove healthy firs of all sizes that are not affected by root rot as “host” trees susceptible to root rot. The Forest Service also intends to “treat fuels” (i.e. burn existing and created logs and logging slash, “reforest” by planting only Ponderosa pine and Western larch seedlings in place of the diverse mature and old growth moist mixed conifer forest with large and old firs that now exists there, and “enhance hardwoods” by thinning up to 12” dbh around existing riparian hardwood trees and shrubs.
In addition to the two planned Forest Plan amendments described above, the Forest Service would also use Forest Plan amendments to change the Forest Plan standard for the Developed Recreation Management Area (the entire Walton Lake project area) from “retention” (in a natural state) to “modification or better” for 10 to 15 years following implementation of the timber sale. In reality, the impacts of virtual clearcutting would be visibly evident for much longer than 10 to 15 years and the Walton Lake area would be unrecognizable to those who have spent time there and may visit the area often, losing any sense of place. The Forest Service would also use a Forest Plan amendment to violate the existing Recreation Management Area restriction of only five acres for clearcut patch sizes, extending the clearcut “patch size” to 35 acres. The resulting clearcut would completely alter the mature and old growth fir forest backdrop for the lake, and be visible from the lake, the loop road, and the campground.
The Forest Service is finally admitting that “the changes to those units will be obvious to most people because the treatment for root disease [“Sanitation Harvest’] is to remove all infested and susceptible Douglas fir and grand fir trees.” (Revised EA p. 10) This would be in addition to the commercial logging with large fir removal in the other sale units, which would also be evident from the lake, the loop road, the campground, as well as the day use area.
The other action alternatives included in the Revised EA for the timber sale include alternatives 3 and 4: Alternative 3 would reduce the size of the area logged in the root rot area (virtual clearcutting in sale units 2, 3, and 4) by reducing the logging to a 150 foot “buffer” next to FS rd. 22 just outside the Walton Lake boundary, thus reducing the number of large (and old growth) fir trees cut from 521 to 240 trees, saving 281 large trees from logging compared to the proposed action. However we see no reason to log any large trees or do any clearcutting at all.
Alternative 4 would reduce the number of large firs (over 21” dbh) from being logged by dropping the clearcut sale units (2, 3, and 4) entirely and by retaining large firs over 21” dbh in units 1 and 5 (the dry mixed conifer where commercial thinning with large fir logging is proposed) that are “crowding” larger Ponderosa pine and Western larch. Commercial thinning would still be allowed in sale units 1 and 5 up to 20.9” dbh, still affecting recreational values around the day use area and near the campground, lake, and loop road. Alternative 4 forgoes management that would require amendment to the visual quality standards (according to the Forest Service) by dropping the root rot logging in sale units 2, 3, and 4.
All action alternatives offered by the Forest Service would also include under a half mile of “temporary” road construction, closure and relocation of the existing Walton Lake trail (which happens to be adjacent to some of the largest old growth firs), non-commercial small tree thinning in the other sale units adjacent to the lake, and continued use of the root rot hazard warning signs around the root rot area, as well as continuation of the closure to the public of the root rot area. See more about that in the paragraph below regarding the No Action alternative.
Under the “No Action” alternative, hazard trees would continue to be assessed, identified, and felled on an annual basis prior to opening the campground each year and regular campground maintenance would take place. (Revised EA p. 20) This effectively takes care of the safety concerns and has been the method for keeping the Walton Lake area relatively safe as a natural environment for as long as Walton Lake has existed as a recreation site. The rest of the moist mixed conifer forest across the Ochoco National Forest is also subject to naturally occurring laminated root rot, with attendant risks, and only legitimate immediate hazard tree felling is used for providing safer conditions across the rest of the Forest. The rest of the Ochoco also receives a lot of recreational use; it is just more dispersed. This includes most of the hunters and their families and friends, as well as hikers, mountain bikers, dispersed campers, horseback riders, wildlife photographers, cross-country skiers, ATV riders, snowmobilers, past solar eclipse viewers, etc.
However the No Action alternative would not truly represent the original status quo before the Walton Lake timber sale was planned as it would retain a closure against public entry and use of the root rot area, which currently includes fines of $1,000 for each individual violating the closure and a $10,000 fine against any organization violating the closure. We have no problem with retaining the warning signs posted around the root rot area to warn the public about possible falling trees; this was actually our suggestion as an alternative to logging the root rot area. However, what is the Forest Service trying to hide with the closure? What is being kept from public view in the closure area is a fully marked to cut timber sale, with sale unit boundary signs, flagging, and paint marks on the trees showing which would be logged. The Revised EA fails to disclose that this marked timber sale was actually put out as a contract for a logging company before any final decision was signed for the timber sale, which is illegal. This sale marking should not be retained. Instead the Forest Service should return the area as much as possible to its original state by blacking out the marking to cut and removing the boundary marking and flagging. Otherwise this is not a true No Action alternative but instead is being used to continue to retain and hide a timber sale ready to be logged.
You can read a summary overview of some of the long-standing issues with the timber sale here. The link to Karen Coulter, our Director, discussing that hazard trees are not the issue is here. You can also see our 2018 press release about our previous work to stop logging around Walton Lake here.
Please also consider supporting our ecological protection work with Blue Mountains Biodiversity Project through our website: bluemountainsbiodiversityproject.org or by sending donations to 27803 Williams Lane, Fossil, OR 97830. 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!