Blue Mountains National Forest Plan Revisions

Blue Mountains National Forest Plan Revisions Action Alert
Hell’s Canyon’s comment writing party in Portland
Comments due August 15th

As the comment deadline nears we want to remind everyone that it is very important to comment on the Forest Plan Revisions.

If you can make it: Hell’s Canyon Preservation Council is hosting a comment letter-writing party in NE Portland on August 7th. They will have tips and provide guidance for writing comments on the proposed Forest Plan Revision. See their website for details:

The Forest Plan is a broad, overarching, and legally binding document that gives guidelines and direction for how the Forest Service manages National Forests in E Oregon. The Forest Plan Revision is a big deal for the forests in Eastern Oregon and its important that BMBP and as many biocentric individuals and groups as possible comment on it. Even if you don’t have time for in-depth comments, it’s still important to send in short comments based on this action alert.

It’s important to show that people care about protecting old growth forest, wildlife, fish, and recreation and want much more Wilderness added to the current Wilderness Areas.

Key Points:
– A plan is needed that emphasizes more wilderness (the FS is falling short of wilderness across the board, and in many national forest Plan Revisions, too).
– No grazing or at least much more strict constraints on grazing.
– The use of STANDARDS in the Forest Plan Revision. Standards are legally binding and enforceable, whereas other mechanisms for achieving goals such as “desired future condition” are not enforceable.

The proposed Revised Forest Plan and Draft Environmental Impact Statement (DEIS) are available at the Forest Plan web site at: or you can request a CD or printed copy by emailing them at or calling (541) 523-1246 or (541) 523-1302. These phone numbers can also give you information regarding upcoming public meetings.

The Forest Plans for three National Forests in eastern Oregon are being revised because they are very outdated (24 years old so far). The Forests affected are the Malheur, Umatilla, and Wallowa Whitman. Forest Plan revision is taking place to meet the legal requirements of the National Forest Management Act “to address changed conditions and provide consistent management direction (as appropriate) across the three national forests; to incorporate changes in law, regulation, and policy, and to use new scientific information,” (DEIS p.i).

It is important to recognize that some terms and objectives used in the DEIS don’t mean what the average person might assume. For instance the Forest Service goal of “restoring” plant and animal species habitat often translates to plans to log it. “Addressing management of fuels and fire risk,” also translates as logging, sometimes very heavy logging. “Addressing climate change,” generally means they want to log areas to a lower density of trees. This is based on the expectation that otherwise these forest areas won’t survive climate change. It also means that they also plan to change the tree species composition to better suit the timber industry—and theoretically drier climate conditions. “Recognizing the interdependency of social and economic components,” means they intend to prioritize logging and other management (livestock grazing, etc.) in eastern Oregon to produce revenue for local communities. Consideration of recreational values and revenue and people’s spiritual connection to the land are quickly dismissed.

Forest Service defined key issues to address in comments

You need to speak up if you want additional areas allocated to Wilderness or to undeveloped backcountry. This could satisfy needs for solitude, non-motorized recreation, and larger intact areas with little disturbance to wildlife, among other benefits. Some of the rarest of species, like Gray wolves, wolverines, and lynx are harmed by human disturbance, which includes access for trapping and shooting. The motor vehicle recreation lobby is advocating for more roads and off road vehicle use all over.

Economic and Social Well-being
We do not need current or higher levels of unsustainable logging and livestock grazing. These are eliminating wildlife and fish habitat and are destroying soils and water quality. Rather, it’s time to prioritize ecological values, suggest a more ecologically conservative approach, and emphasize non-extractive sources of revenue. Such non-extractive revenue as recreation and ecologically sound restoration to protect forest values contribute to sources of economic and social well-being such as water quality; a stable climate; a diversity of native wildlife species, birds, and fish; soil integrity; intact and functioning stream systems, etc.

There are strong timber industry, livestock grazing, off-road vehicle, and local community forest extraction revenue lobbies in eastern Oregon that are demanding more ecologically destructive extraction. They are doing this despite the obvious collapse of stream systems; loss of soil productivity, wildlife species viability (even deer are declining), and fish runs. There actions result in widespread loss of large and old trees, old growth forest, and large blocks of intact, undisturbed wildlife habitat. They want to do this on top of a century of over-logging and over-grazing by livestock.

Old Forest
The Forest Service is proposing to “restore” old forest by logging it to reduce density (disregarding whether density should be reduced for a particular forest type or not). They intent to scrap the “old growth forest management areas” set aside to be protected from logging. They wish to eliminate the prohibition on logging large trees over 21” diameter at breast height (dbh). They want do this even though there’s a well-documented huge regional scarcity in large trees of this size due to over-logging of large trees. Only one alternative (C) proposes to retain the 21” limit; the rest would either scrap all limits or switch to only “old tree characteristic” prohibition on logging or else a 150 year limit.

The problem with only protecting “old” trees is that it fails to protect needed large tree structure for: large cavity nesting birds and mammals (e.g. Pileated woodpecker and American marten), contribution to needed pools in streams for fish habitat, large logs to contribute to soil nutrient recycling, large wood to store carbon to slow climate change (as live trees, snags, and logs) and large live trees, snags, and logs to provide recreational values and natural reference sites by which to judge the effects of logging “management”.

Livestock Grazing and Grazing Land Vegetation
Cattle and sheep grazing on these forests has severely degraded entire riparian systems, including streams, rivers, springs, fens, and ponds. Livestock use has eroded and trampled stream banks and contributed too much sediment to streams for fish to survive, trampled wet meadows. Grazing has completely eliminated or seriously reduced riparian shrubs that would otherwise stabilize stream banks and shade the water (cooling it enough for fish to survive). It has changed the morphology of streams, destroyed flood plains, compacted soils, and changed hydrologic flows. Livestock use has also greatly reduced the plant forage that would otherwise be available for native ungulates such as Mule deer, Rocky Mountain elk, and pronghorn.

Riparian areas are the most biodiverse areas of these forests when in a natural condition. Livestock are thus directly harming amphibians such as Columbia Spotted frog, sensitive mollusks and macro-invertebrates, and a variety of riparian-associated Neotropical migratory songbirds. Yet there is an influential minority of ranchers dependent on public lands livestock allotments on National Forests who are opposing further restrictions on livestock grazing on allotments due to financial and social impacts to them.

Recommended Additions to the National Wilderness Preservation System:
Many people asked the Forest Service to propose additional areas for Wilderness designations to protect all the wild and natural values that are only found in Wilderness. These include wildlife habitat for far-ranging species, the wilderness recreation experience, and protection of wild Nature in its natural condition, including protection of a full range of biodiversity and ecological processes on a larger landscape scale.

Others requested that no additional areas be proposed for wilderness designation because this would limit economic benefits from management activities such as logging and limit motorized recreation.

Ecological Resilience:
The Forest Service has been promoting the idea that logging and other management activities such as prescribed burning promote ecological resilience. In some cases small tree thinning and prescribed burning may be warranted. These cases are valid due to the effects of past logging and fire suppression in dry forest types, but the timber sales billed as “restoration” generally log far too many mature trees. In some cases they even log large trees or engage in clearcutting or virtual clearcutting. From our point of view, there needs to be much less logging, more use of wild fire, and prohibition against logging of large or old trees, as well as much less logging of mature trees to support ecological resilience. In most cases the forest is already heavily over-logged and needs time to recover, not more logging.

All the alternatives other than alternative C propose more logging than we think is sustainable, given that there is always pressure to log too many mature trees to make the project pay for itself. Logging is not a natural disturbance and causes many unnatural impacts such as removal of wood from the ecosystem and intensive soil compaction. Even still, many local people, including those dependent on the timber industry, are supporting more and heavier logging to bring revenue to economically stressed communities. They readily jump onto the band wagon that logging is good for the forest.

Action Alternatives Offered
The Forest Service is offering alternatives A through F, with A being “No Action”, or the status quo, Alternative E being their preferred alternative, and Alternative C being the most environmentally benign alternative that they offer. Blue Mountains Biodiversity Project will probably advocate for a modified version of alternative C, but there are other options being dismissed by the Forest Service that take a more radical stance and are still worth advocating and incorporating, such as “No commercial logging, restoration only”, “No livestock grazing”, “No herbicide use” and “Allocation of all unroaded areas larger than 1,000 acres as new Wilderness Areas.” The Forest Service could have incorporated these public suggestions into offered alternatives but declined to do so for various reasons (see DEIS pp. 41-44).

Here is the Forest Service’s description of Alternative C, the offered alternative we find the least objectionable:

“Alternative C varies from Alternative B by emphasizing the role of natural processes in forest restoration (also referred to as passive restoration.) When compared to the other alternatives, less timber would be harvested, more area would be allocated for non-motorized recreation, and more area would be allocated to recommended wilderness areas. Similar to alternative A, old forest would be mapped and allocated to a management area. The harvest of large trees (21 inches d.b.h. or larger) would be prohibited with no exceptions. Managed wildland fire for resource benefit would be highest in this alternative to achieve the desired condition. Wildlife corridor management areas would be mapped and allocated to management area. This alternative would make substantial reductions to the permitted number of domestic livestock. The default width of riparian management areas would be greater than what is proposed for the other alternatives,” (DEIS p.31).

Some of the advantages of alternative C over the other offered alternatives

*No National Forest System lands would be designated as motorized backcountry. All cross-country over-the-snow vehicle travel is prohibited.

*This alternative designates the most recommended wilderness areas (although there may be more that should be included.) Approximately 505,000 acres would be recommended wilderness, the largest amount of the alternatives.

*For wildlife corridors, the open road density would be 1 mile per square mile or less. Approximately 502,200 acres would be allocated to Wildlife Corridor management area. (MA 3C)

*For winter elk habitat, the open motor vehicle road density would be 1.5 miles per square mile or less.

*Road maintenance costs would be the lowest because fewer roads would be open for vehicle use.

*The predicted annual timber “harvest” for the three forests would be approximately 47 million board feet (mmbf), the smallest projection among all the alternatives. Desired conditions describe the desired forest densities and limits would be placed on canopy cover reduction.

*The area that would be considered suitable for cattle grazing would be reduced to approximately 785,000 acres, the smallest acreage among the alternatives. This decrease would result from the classification of riparian areas and subwatersheds with habitat for listed fish species as generally unsuitable for cattle grazing. The area that would be considered suitable for sheep grazing would be reduced to approximately 90,000 acres, also the lowest projection among alternatives. This decrease would result from the classification of subwatersheds within the maximum foray distance for bighorn sheep rams as generally unsuitable for sheep grazing (due to domestic sheep transmission of disease to bighorn sheep.)

*Old forest (390,900 acres) would be allocated to Old Forest Management Area (MA 4C). Only trees 8 inches d.b.h. or less would be authorized for timber harvest in this management area. This alternative would include a standard that would strictly prohibit the harvesting of trees 21 inches d.b.h. and larger, both within and outside of old forest.

*Alternative C is designed to emphasize the role of natural processes in the restoration of ecological resilience.

*The greatest amount of subwatersheds would be improved with alternative C.

*The riparian management areas would be 300 feet (slope distance) on each side of any stream, regardless of classification. Alternative C would greatly restrict livestock grazing within riparian areas.

*All streams considered eligible for inclusion in the National Wild and Scenic River System by the Forest Service would be so allocated. (MA 2A)

While Alternative C responds to many of our concerns, it is important to realize that the Forest Service probably has no intention of adopting it. We need public pressure to get these Forest Plans to be as ecologically protective as possible.

While Alternative C proposes 47 mmbf in timber “harvest”, alternative D proposes 243 mmbf and the Forest Service preferred alternative E proposes 162 mmbf. While Alternative C designates 390,900 acres as old forest to be protected from mature and large tree logging, all the other alternatives would not set aside any designated old forest areas. While Alternative C recommends 505,000 acres of Wilderness, Alt. D fails to recommend any Wilderness and Alt. E would only recommend 91,000 acres of Wilderness. (See DEIS pp. iv-vi) These are big differences on the ground that could make viability for a species possible or drive it to extinction on these forests.

You have until August 15th to submit your comments on the DEIS:

Proposed Revised Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests” to:

Blue Mountains Forest Plan Revision Team
P.O. Box 907
Baker City, OR 97814

or fax to: (541) 523-6392

Or email to:

Emails need to be receipt confirmed to be accepted as comments and will be rejected if they carry a virus.

If you need assistance in submitting your comments or working through their electronic system call (541) 523-1246 or (541) 523-1302.

Thank you for helping us protect biodiversity & ecological integrity!

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