Comment on Timber Sales & Other Projects!

Blue Mountains Biodiversity Project Action Alert: Ringo timber sale comments due May 1st

The proposed Ringo timber sale on the Crescent District of the Deschutes National Forest overlaps suitable and sometimes occupied Northern Spotted owl habitat, including 6,424 acres of Spotted owl dispersal habitat around and on Odell Butte, Ringo and Cryder Butte, and on the north side of Davis Mountain. Nearly 4,000 acres of Northern Spotted owl nesting, roosting, and foraging habitat in this area was already eliminated by this District’s prior Five Buttes timber sale, which Blue Mountains Biodiversity Project fought in court, won in District Court, and then lost at Ninth Circuit Court when the timber industry appealed our District Court victory. The Environmental Impact Statement for the Five Buttes timber sale admitted that Northern Spotted owls were in precipitous decline on the Crescent District even before the loss of almost 4,000 acres of their nesting, roosting, and foraging habitat with the Five Buttes sale. Now the Northern Spotted owl is in grave danger of being extirpated completely from the District and the Ringo sale area, since the Forest Service is proposing to once again log in suitable Spotted owl habitat, eliminating its suitability for Spotted owls.

Other values in the Ringo timber sale area at risk to proposed logging and up to 104 miles of closed road re-opening and 13.6 miles of “temporary” road construction (Alt. C) include:

*High quality wildlife habitat for Sensitive and Threatened-listed species, including Threatened Northern Spotted owl, Threatened Oregon Spotted frog, and Sensitive Redband trout, and for Management Indicator and focal species such as Pileated woodpecker, American marten, Northern goshawk, Cooper’s hawk, Great Gray owl, and woodpeckers dependent on future large snags, such as Northern flicker and Lewis’ woodpecker. Various water birds including Northern waterthrush, and mollusks, as well as Oregon Spotted frog and Redband trout could be at risk due to proposed logging of Lodgepole pine within the Riparian Habitat Conservation Area and seasonal wetlands of Crescent Creek, the only perennial creek (beautiful, like a river) in the Ringo planning area. Mule deer are already in sharp decline on the Deschutes National Forest and elk are already low in numbers, yet the Ringo sale would also remove critical hiding and thermal cover that they need in such an area of high recreational and hunting disturbance. The Ringo Draft Environmental Impact Statement admits that: “Proposed treatment would conversely reduce habitat for marten, pileated woodpeckers, and hiding cover around the existing wet meadow edges for big game…” (DEIS p. 1-7) Yet marten and Pileated woodpecker are already ranked as “vulnerable” by the Oregon Department of Fish and Wildlife for the state of Oregon, and deer are already declining on the Deschutes.

*Also at stake: recreational values for hiking, wildlife viewing, scenic driving, camping, fishing, hunting, cross-country skiing, and Snowmobiling, all of which are currently enjoyed in the Ringo area. The scenic integrity and views of the Odell Butte lookout tower experience would also be degraded.

Yet the Forest Service claims there is a “need” to commercially log (including large and old trees, old growth habitat, and within known Northern Spotted owl home ranges and dispersal habitat and along Crescent Creek) in order to reduce tree density and surface “fuels” under the guise of wild fire risk reduction, even though there is much scientific controversy over whether such commercial size logging really reduces wild fire incidence or severity. See for example Schoennagel et al. (2016): “Adapt to more wildfire in western North American forests as climate changes.” This study suggests a shift in planning regarding wild fire risk: “Key aspects of an adaptive resilience approach are (i) recognizing that fuels reduction cannot alter regional wildfire trends; (ii) targeting fuels reduction to increase adaptation by some ecosystems and residential communities to more frequent fire; (iii) actively managing more wild and prescribed fires with a range of severities; and (iv) incentivizing and planning residential development to withstand inevitable wildfire. These strategies represent a shift in policy and management from restoring ecosystems based on historical baselines to adapting to changing fire regimes and from unsustainable defense of the wildland-urban interface to developing fire-adapted communities.” (from the Schoennagel et al. abstract)

The Forest Service offers three alternatives, No Action (Alternative A, which we support), the original Proposed Action, Alternative B, and Alternative C, the Forest Service preferred alternative, which still logs in suitable Northern Spotted owl habitat but logs a little less and would use multi-age management (i.e. still log large and old trees) “with an arrangement of leave trees and large tree clumps” as a theoretical “better stepping stone for the northern spotted owl” which would still probably render existing suitable dispersal and home range habitat unsuitable for the Northern spotted owl. (Quotations are from Ringo DEIS p. 1-6) There is no intermediate action alternative offered that would avoid logging in suitable Northern Spotted owl habitat or would avoid commercial logging impacts to recreation, elk and deer, marten, Pileated woodpecker, accipiter hawks, and potentially to Oregon Spotted frog and other aquatic wildlife. Thus there is an inadequate range of alternatives as there is no action alternative that responds to the need to protect these key values from logging.

Specifically, Alternative B and C would include the following management actions:

Alternative B: 4,482 acres of commercial thinning; 2,365 acres of smaller diameter thinning; 782 acres Lodgepole pine logging, 64 acres of meadow enhancement thinning, and 5,322 acres of under-burning.

Alternative C: 3,754 acres of commercial thinning; 2,523 acres of smaller diameter thinning (we prefer this to mature and large tree logging); 547 acres of Lodgepole pine logging; 64 acres of meadow enhancement thinning; and 5,752 acres of under-burning.

Both alternatives would include one Forest Plan amendment to allow for prescribed burning to exceed the five acre minimum per burned patch.

Here are some of Blue Mountains Biodiversity Project’s key concerns and comments regarding proposed logging of Northern Spotted owl habitat in particular:

*Drop all sale units within identified Northern Spotted owl dispersal habitat, home ranges, and other known suitable habitat or habitat that has had Northern Spotted owl sightings or call responses. The Five Butte timber sale already logged and eliminated suitability of nearly 4,000 acres of Northern Spotted owl nesting, roosting, and foraging habitat in the Ringo planning area, yet the Ringo DEIS fails to analyze the cumulative effects of past Five Buttes logging and proposed additional Ringo logging of suitable Northern Spotted owl habitat to this Threatened-listed species, or to analyze the effects of Ringo logging of Northern Spotted owl habitat in the context of a sharp decline in Northern Spotted owls on the Crescent Ranger District. Logging of suitable Northern Spotted owl habitat is likely the primary cause of Spotted owl decline, and the largest impact to the species that managers can avoid, as opposed to naturally occurring and inevitable wild fire, with which the species evolved. The Ringo DEIS fails to mention in the analysis that proposed commercial logging in Northern Spotted owl habitat opens up suitable habitat for competing Barred owl, and is likely to increase the threat to any remaining Northern Spotted owls from Barred owl competition.

*We are very concerned by the cumulative impacts to the Northern Spotted owl’s habitat and viability in the Ringo sale area and on the Crescent District by the Five Buttes, Seven Buttes, Seven Buttes Return, and BLT timber sales and possibly the Baja timber sale, and now the Ringo timber sale, within the same general area of Northern Spotted owl habitat. All of these sales, with the possible exception of BLT, eliminated suitability of Northern Spotted owl suitable habitat and necessary large and old tree structure, including nesting, roosting, and foraging habitat, and the proposed Ringo timber sale would eliminate still more suitable Northern Spotted owl habitat. The Northern Spotted owl is nearing extirpation on the Crescent District and within the Ringo planning area and can’t survive further logging loss of its suitable habitat, as it is already in sharp decline on the District. Thus the Ringo timber sale would contribute to an upward federal listing trend for the Northern Spotted owl to Endangered species status and likely extinction, in violation of the Endangered Species Act.

Other key concerns and Blue Mountains Biodiversity Project comments:

*We are concerned by proposed logging within the Riparian Habitat Conservation Area of Crescent Creek since Crescent Creek is already 303 (d) listed for exceeding the water temperature standards for various listed fish species, and as logging near the creek and within seasonal wetlands could kill or injure Threatened-listed Oregon Spotted frogs, and harm habitat for water birds using the creek, as well as for Sensitive or Survey and Manage mollusk species. Such logging could also degrade the high recreational values of Crescent Creek including its wild and scenic qualities outside of the designated Wild and Scenic corridor, fishing opportunities, and general recreational enjoyment.

*We are concerned that proposed logging of mature and large trees in the Ringo timber sale is not necessary to decrease fire risk to local communities and would unnecessarily reduce hiding and thermal cover needed by declining deer and the already small elk population. Such logging would also further degrade the area’s recreational values despite recreation in that area being extremely popular.

Please help us show opposition to the Ringo timber sale’s destruction of Northern Spotted owl habitat, habitat for other vulnerable species, and recreational values. Send your comments by May 1st at the latest!

Submit written comments to: Daniel Rife, District Ranger, Crescent Ranger District, P.O. Box 208, Crescent, OR 97733

Send electronic comments to: comments-pacificnorthwest-deschutes-crescent@fs.fed.us

Emailed comments must not be sent to addresses other than the one above, in other formats than .txt, .rtf, or Word .doc, or containing viruses, or they will be rejected. Email messages are o.k. Please include your name, address, phone # if possible, and the name of the document: “Ringo Draft Environmental Impact Statement.”

Comments may also be by telephone to (541) 433-3200 between 8:00 a.m. and 4:30 p.m. Monday through Friday. For more information contact: Joe Bowles (Forest Service) at (541) 433-3200.

Don’t forget to donate to help keep our ecological protection work going with Blue Mountains Biodiversity Project! See our website at: bluemountainsbiodiversityproject.org to learn more or donate electronically.

You can also send donations to: Blue Mountains Biodiversity Project, 27803 Williams Lane, Fossil, OR 97830

Call us at (541) 385-9167 if you want to volunteer with us by helping us field-survey proposed timber sales this summer.