Action Alert: Ragged Ruby

Draft Environmental Impact Statement (DEIS) is out and open for public comment until December 17th!

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….

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Karen with old growth fir tree in the Ragged Ruby timber sale, Malheur

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.IMG_1060

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.

IMG_1550We 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.

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Tall mixed conifer forest and alders over upper Granite Boulder Creek (Bull trout habitat planned for aquatic restoration and below some of the commercial logging sale units.) Ragged Ruby sale, Malheur NF

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

Please send in your comments right away, or at least by December 17th!

Email: we have created a campaign on Action Network to help you easily create and send an email to the contact for the Blue Mountain Ranger District regarding this sale.

Click here to use this tool

Alternately, you could send email comments to: comments-pacificnorthwest-malheur-bluemountain@fs.fed.us

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.

There is also this electronic form available to submit online 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)

Action Alert!: Ellis Timber Sale

Help us fight the extreme Ellis timber sale: More than 56,960 acres of heavy logging in one sale!

We need help to defeat the largest timber sale proposed so far in Eastern Oregon under the guise of “restoration” for resiliency and reducing future wild fire severity. The picture below was taken elsewhere in the Umatilla, and we plan on surveying the Ellis sale this summer.

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Volunteers surveying Upper Touchet Timber Sale in Umatilla National Forest, July 2018

The proposed action would take place in the Umatilla National Forest 7 miles west of Ukiah, OR. Commercial logging would additionally occur on up to 33, 730 acres (283 miles) of road and trail corridors 300 to 500 feet from either side of the roads or trails, along with small diameter thinning, burning, and pruning. So the timber sale would cover about 60% to 90% of the 114,834 acre project area.

The term basal area in forestry is used to describe the average amount of an area (usually an acre) occupied by tree stems. It is defined as the total cross-sectional area of all stems in a stand measured at breast height, and expressed as per unit of land area (typically square feet per acre). Read more about basal area here, but the main idea is it measures forest density. 40 to 60 square feet of basal area after logging looks like a clearcut with only widely spaced mature seed trees or a “shelterwood” clearcut with small clumps of mostly small trees. The Ellis timber sale would take forest removal even further by proposing “dry” forest retention rates of only 30 to 60 square feet of basal area; with the lower range down to only 20 square feet of basal area retained for naturally denser cold forest in a range of 20-80 square feet of basal area per acre; and with the astonishingly low retention down to only 10 square feet of basal area for naturally more productive, denser cool moist forest in a range of 10 to 90 square feet of basal area per acre. The Forest Service does not guarantee that any mid-range number of square feet of basal area would be retained overall for any of these forest types, so overall forest retention could be extremely low.

The Ellis sale area overlaps multiple timber sales that were logged within the last 27 years, a very short rotation for commercial logging that is not supported by ecological science.

The Ellis sale also proposes an undefined acreage of clearcutting.

The Ellis project includes a variety of more acceptable kinds of management but based on the high acreage of heavy commercial logging proposed, it is clear that the real over-riding purpose is not restoration or wild fire reduction, but forest structure removal for private corporate profit. The Blue Mountains National Forests, including the Umatilla, are being directed by the Trump, Inc. administration in Washington, D.C. to at least double the logging volume.

The commercial logging is claimed to “improve culturally significant resources” such as by theoretically improving forest health and vigor and improving wildlife habitat. Commercial logging is also being justified as reducing the “risk” of “undesirable” wildfire, despite growing scientific evidence to the contrary.

Please help us show public opposition to this disastrous timber sale. The USFS materials about this sale, including maps, can be reviewed here.

We are making the following comments and invite you to consider these points for your comments, due by January 4th:

We are opposed to:

-such an enormous timber sale

-such heavy logging down to very low basal areas

-any clearcutting

-any logging or roading in roadless and undeveloped lands

-such intensive management of nearly the entire project area

-any logging in late and old forest structure, including designated Dedicated Old Growth Areas and Replacement Old Growth Areas

-any logging of trees equal to or greater than 15” dbh

-any use of Forest Plan amendments to effectively violate Forest Plan standards

-any logging within Riparian Habitat Conservation Areas *

-any new road construction

-any opening of closed roads not being maintained for motorized use

-toxic herbicide use on Ventenata grass (which is proposed), as it could likely poison other native grasses where it grows

-such big fuel breaks along roads and trails

We are concerned by potential impacts of the Ellis project to:

-ecological integrity and biodiversity

-forest structural complexity

-the already great deficit in mature and large trees in the area compared to historical conditions

-Pileated woodpecker and American marten suitable habitat

-possible Pacific Fisher habitat

-suitable habitat for Lewis’ woodpecker and White-headed woodpecker (old wild fire burned forest) and Blackbacked woodpecker (recent wild fire burns)

-suitable habitat for Three-toed woodpecker (mature Lodgepole pine forest)

-carbon sequestration to slow or lessen climate change impacts

-aquatic and riparian habitat, including impacts to fish species listed under the Endangered Species Act, Sensitive Redband trout, Sensitive Columbia Spotted frog, and Sensitive salamander, mussel, and macroinvertebrate species

-elk and deer security cover, including forest thermal and hiding cover

-Sensitive and rare plants

-recreational values

-Neotropical migratory songbirds

-Soil productivity and integrity

We suggest scrapping this over-management project entirely or adopting a “restoration only” action alternative with no commercial logging.

Written comments on the Ellis Integrated Vegetation Project can be:

-submitted by fax: (541) 676-2105

-mailed to: Brandon Houck, ATTN: Leslie Taylor, P.O. Box 7, Heppner, OR 97836

-be submitted electronically on the Umatilla National Forest’s project webpage here

For a copy of the scoping letter, call or email Elizabeth Berkley (Forest Service) at 541-278-3814 or elizabethberkley@fs.fed.us or check the Umatilla National Forest website for the “Ellis Integrated Vegetation Project Proposal.”

Comments due by January 4th!

For more thorough talking points and ideas for comments, we have provided Karen’s longer write up on the Ellis Timber Sale as a pdf below:

Ellis sale action alert-long version

 

 

 

 

Update and Action Alert on Walton Lake

After legal challenges stopped logging twice, forest advocates prepare for the next fight over the Ochoco’s most popular recreation site

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The beautiful Walton Lake in the misty morning

Blue Mountains Biodiversity project and Earthrise Law Center have successfully challenged, and halted, the US Forest Service’s attempts to log hundreds of magnificent large and old fir trees around Walton Lake in the Ochoco National Forest two times since 2016. Claiming that the public is endangered by the potential for falling trees with root rot, USFS has attempted to bypass environmental laws protecting large and old trees in order to extensively log old growth fir forests– including in areas that are not near trails or recreational development. Logging in some units included clearcutting of all firs.

Here are some of the reasons BMBP and Earthrise have successfully opposed this logging:

-USFS has always been, and still is, free to remove any hazard trees that are evident. Extensive logging of firs, including clearcutting of firs in some areas, is not necessary.

In addition, it is documented that logging can actually spread root rot. While some hazard trees may need to be felled near trails, roads, and recreational developments due to root rot, it is unnecessary and ecologically damaging to extensively log in areas away from trails and recreation sites. Root rot is a native disease that serves essential ecological functions such as creating natural openings and wildlife habitat.

-USFS has misled the public by stating the difference would not be noticeable to people who visit the lake. However, when BMBP and Earthrise filed a Freedom of Information Act request to gain access to their internal documents, we learned that the Forest Service stated in their own internal documents that the area would be “unrecognizable,” and they described portions of the project as a “clear cut.”

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The markings to cut of the illegal timber sale

-USFS has deliberately utilized a special loop hole called a “categorical exclusion” in environmental regulations to exclude public comments from being gathered. BMBP stopped this rush to logging in court, but found the trees around the lake had already been marked, flagged and numbered to cut. USFS has kept the logging contract in place despite the fact that it is an illegal sale, and they will be prevented from doing an objective environmental assessment with this contract in place. Currently there are areas by the road around the lake closed to the public due to root rot. In the fine print of these closures it says individuals and organizations venturing past the signs can be fined $5000 or $10,000 respectively, and that walking there is misdemeanor that could result in jail time. This unfortunately prevents the public from seeing all the markings to cut on the trees, many of which are old growth, spanning 3-4 feet in diameter.

What We Can Do
BMBP and Earthrise will continue to fight these attempts to commercially log Walton Lake. While we do not have specific information regarding the Forest Service’s current plans, we know that they are moving forward with plans to propose logging again. Here’s what you can do to help in the meantime:

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More firs marked to cut

-Contact Shane Jeffries, Forest Supervisor, and comment that you do not support commercial logging, logging of large or old trees, or heavy logging or clearcutting in any portion of the Walton Lake area.

You can contact Shane Jeffries via email at: sjeffries@fs.fed.us. You can also send comments or call Mr. Jeffries at:

Ochoco National Forest Supervisor’s Office
3160 NE 3rd Street / PO Box 490
Prineville, OR 97754
541-416-6500; FAX: 541-416-6695

Ochoco NF contact form here

-Sign up for our Action Alerts by clicking here. This way we will be ready to weigh in when the Environmental Assessment is released for public comments

-Visit Walton Lake! Go to this magnificent place and soak up the natural splendor. If you take pictures with a time stamp, this helps us establish standing in the area if you are willing to get involved with the case.

 

Roadside Old Growth Ponderosa Pines Being Sprayed, Logged, and Sold

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Dead and dying Pondersosa pines along Highway 20

At several sites in Central Oregon, USFS and ODOT have been logging trees near roadways, citing public safety as the justification. Most of the risk is due to dead trees killed by these agencies when they used an herbicide called Perspective to spray in hopes of managing broad leaf plants along roadsides at several sites. As a result of their failure to heed the warnings on the label of this chemical, hundreds of ponderosa pine trees have died along scenic corridors, and the Forest Service’s response is to log and sell the trees to the highest bidder.

The first site to gain attention for this mishap was Highway 20, where thousands of large and old growth ponderosas that greet drivers entering the Sisters area began showing signs they were failing to thrive in 2014. It was quickly realized this was from three consecutive years of spraying the weed-killer. The Forest Service stated in an interview with the Bend Bulletin on May 3, 2018 that the product’s label did not list ponderosas as vulnerable to damage by the product. This is directly contradicted by their own 2012 literature regarding the use of products containing aminocyclopyrachlor, the active ingredient in Perspective, as well as the EPA label for the product in years before and during it’s usage.

Now the Forest Service is planning on commercially logging these dead trees along Highway 20, trees that had been previously saved from logging by the public in regards to a road widening proposal. We at Blue Mountains Biodiversity Project have proposed that a more appropriate use of the trees would be to utilize them as habitat-enriching logs throughout the public lands of the Deschutes region, where generations of over-logging have reduced this essential bio-mass in our forests.

 

 

After this incident near Sisters, an Oregon Department of Agriculture investigation revealed other sites where this egregious negligence occurred. The public agencies also killed pine trees along two roads in Sunriver, as well as another site north of La Pine. A spokesperson for ODA stated that there is history of this active ingredient killing conifers in other parts of the country as well.

Old growth ponderosas have also been logged by ODOT at Ochoco Summit along Highway 26. These were deemed “hazard trees,” but when BMBP co-director Karen Coulter visited the sale, she observed old growth stumps with sap seeping out, indicating the trees were living when they were cut. She also noted that almost none of the trees had any deformities whatsoever. When contacted about what made these trees a hazard the forest service stated that there are guidelines for choosing hazard trees, and the hundreds of trees along the roadside at this site (about 13 miles of scenic corridor) were all deemed hazardous by ODOT guidelines. They also stated that the trees were sold and the purchaser will remove all the wood, leaving none left for habitat or forest well-being.

 


We at BMBP ask that anyone concerned with the spraying of herbicides on our public lands and the commerical logging of our scenic corridors let the following district offices know. Here are some of our main concerns:

– We oppose irresponsible, widespread use of toxic herbicides and support the use of alternatives where possible.

-We do not support turning these incidents (where logging is necessary to protect public safety) into commercial timber sales. Leaving the downed wood in the forest increases essential bio-mass and habitat. This would also reassure the public that public safety is the true impetus for cutting the trees.

-We support stronger public oversight and review of these types of projects, especially the logging and selling of hundreds to thousands of roadside trees deemed hazardous by ODOT. Why was the sale of the trees on Highway 20 made public for comment, but not on Highway 26?

-We are concerned about the cutting of growth, as it changes the historic character of these public lands

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The dead trees greet motorists returning to the Sisters area on highway 20

Regarding Hwy 20:
Sisters Ranger District Office
Pine Street and Hwy. 20 / PO Box 249
Sisters, OR 97759

Ian Reid ireid@fs.fed.us
541-549-7700; FAX: 541-549-7746

Regarding Sunriver and La Pine:
Bend-Fort Rock Ranger District Office
63095 Deschutes Market Road      Bend, OR 97701

email here
541-383-5300; FAX 541-383-4700

Regarding Ochoco Summit:
Shane Jeffries, Forest Supervisor
Ochoco National Forest
3160 NE Third Street
Prineville, Oregon 97754
(541) 416-6500 sjeffries@fs.fed.us
and Patrick Lair plair@fs.fed.us
541-416-6647