The Camp Lick timber sale is within one of the top three priority watersheds identified by the Forest Service for aquatic restoration on the Malheur National Forest to improve habitat for Threatened Mid-Columbia River Steelhead trout and improve water quantity and quality into summer.
The Forest Service is planning to remove 25-35 million board feet of timber over 12,430 acres through their Camp Lick Project timber sale, including riparian and upland watershed “restoration treatments” that include commercial logging within Riparian Habitat Conservation Areas (RHCAs) and stream headwaters.
Such logging and heavy equipment use within RHCAs and near creeks could reduce needed shading to keep water cool enough for Threatened-listed Mid-Columbia Steelhead trout, to retain water flow for Sensitive Western Ridged mussel, and to retain moisture around the stream for Sensitive Columbia Spotted frog. Logging and heavy equipment use in RHCAs could also destabilize stream banks, causing erosion and sedimentation of the creeks harmful to fish.
There would also be 70.2 miles of log hauling on dirt roads within 300 feet of streams and construction of a “temporary” road that includes 200 feet located within the West Fork Lick Creek RHCA and 520 feet of road within a Category 4 (intermittent) stream RHCA, which are likely to also contribute fine sediment to the creek and stream that could choke out Steelhead trout or Redband trout. Nine of the proposed “temporary” roads are within 100 feet from the stream RHCA. The Forest Service is also planning to reopen 3.8 miles of closed road segments that are already hydrologically connected to streams, potentially introducing fine sediment that could choke out fish, instead of decommissioning them so that they are no longer hydrologically connected. BMBP has asked the Forest Service to cancel their plans for commercial logging in RHCAs and headwaters of streams, to drop planned re-opening of closed roads and construction of “temporary” roads, especially where they are near streams or creeks or are within RHCAs, and in general to scale back proposed logging, road construction and use, and heavy equipment use, including in riparian restoration, to better protect critical fish habitat and other aquatic species such as the Columbia spotted frog, the Pacific lamprey, and Western ridged mussel.
BMBP is very concerned that the Forest Service is using a ‘site-specific Forest Plan amendment to log large trees, in violation of existing Forest Plan protections. Large tree structure is critical to the habitat needs of many imperlied or at-risk species, including American marten, Northern goshawk, and potential Pacific fisher.
BMBP also objected to the Forest Plan amendment to allow the logging of late and old structure stands (old growth), in violation of existing Forest Plan standards to protect late and old structure stands. Many species are dependent on old growth stands with large live trees, large snags, large logs, and complex structure, including the species named above. Pileated woodpeckers, American marten, and Northern goshawk are Management Indicator species that represent the habitat needs of a whole host of other species that require large trees and old growth structure. BMBP has requested that the Forest Service drop both of these Forest Plan amendments and to cancel plans to log newly designated Replacement Old Growth areas (ROGs) and Dedicated Old Growth areas (DOGs) that would be partly or wholly re-designated. While we appreciate and support proposed increases in Dedicated and Replacement Old Growth Areas and designation of Pileated woodpecker Feeding Areas (PFAs), none of the above old growth-associated species benefit from the commercial logging of these areas, which degrades their habitat suitability. Therefore BMBP requested that changes be made to the Forest Plan amendment for re-designating or designating new DOGs, ROGs, and PFAs that cancel planned logging in these areas. BMBP is also very concerned that repeated Forest Plan amendments that effectively violate existing Forest Plan standards, such as the amendments to log large trees and within Late and Old Structure forest, are being repeated across the Malheur National Forest and are causing significant cumulative loss of large tree structure and complex old growth habitat. These are not really site-specific amendments as they are being repeated in various sales and across different conditions across the landscape.
The Forest Service should have conducted a full Environmental Impact Statement for the Camp Lick sale, due to likely significant and cumulative impacts to large trees, wildlife, fish, and water quality. The Forest Service failed to adequately consider the cumulative impacts to fish These include the Austin, Big Mosquito, Magone, and Ragged Ruby timber sales, which are all being implemented within the same general area of the Blue Mountain Ranger District, often with adjacent or nearly adjacent boundaries, and within the same general timeline for implementation, creating extensive cumulative effects that are not being analyzed.
The Camp Lick Project EA should have included a full range of action alternatives, not just the No Action Alternative and the Forest Service proposed Alternative. BMBP has repeatedly requested serious consideration of other alternatives that do not include logging of large trees, logging in Late and Old Structure stands, logging of Replacement and un-designated Dedicated Old Growth Areas, and logging within RHCAs, and focuses instead on ecologically sound aquatic restoration and small tree thinning up to 8-10” dbh and/or prescribed burning for restoring riparian hardwood trees and shrubs and thinning denser young tree growth from past logging and possible wild fire suppression. Otherwise I can only support the No Action alternative, which does not include any needed restoration actions such as road closures.
We are also concerned by the large cumulative loss of forest thermal and hiding cover for Management Indicator Rocky Mountain elk and for Mule deer and Columbia White-tailed deer due to the combined impacts of the Austin, Big Mosquito, Camp Lick, Magone, and Ragged Ruby timber sales. The Camp Lick area includes 1,900 acres of elk priority area, which includes an elk nursery area. It further concerns us that these five timber sales will also cumulatively reduce existing and future snag habitat for primary cavity excavator woodpeckers over a large partially contiguous area over a long consecutive time period, yet these cumulative effects to elk, deer and woodpeckers were not adequately analyzed in the Camp Lick Environmental Assessment.
BMBP repeatedly asked that the Forest Service drop any logging on steep slopes and to drop commercial logging sale units with higher existing soil impacts or sensitive soils. BMBP has ongoing concerns about heavy equipment and prescribed fire impacts to undiscovered populations of sensitive and rare plants, as the EA acknowledged repeatedly that it is likely there will be impacts to undiscovered sensitive and rare populations. We are very concerned that so much ground disturbance create bare ground and compaction, which is conducive to invasive plant introduction and increase vectors for invasive plant dispersal. Invasive plant species threaten native rare plants. During the public comment process, BMBP requested that the identified 1,790 acres of undeveloped land and the 60 acres of undeveloped land that would be lost to “temporary” road construction be completely dropped from logging and roading. The Forest Service was not willing to