Comment on Timber Sales & Other Projects!

Satellite view of the Lex timber sale area. Note the extreme past heavy logging. The previously logged areas are targeted for additional logging, as are the few denser and green patches of forest that remain.

Action Alert! The Lex Timber Sale in the Deschutes National Forest includes industrial-style logging practices, and proposes logging in: moist mixed conifer forests, high elevation areas, forests adjacent to roadless areas, forests with no or minimal previous logging, dispersal habitat for Northern spotted owls, and over recreation trails (including mountain bike, hiking, and skiing trails). Please send comments to the Forest Service to help us stop destructive logging in this sale! Comments are due December 18th.

Email comments to: comments-pacificnorthwest-deschutes-bend-ftrock@fs.fed.us or mail to: Kevin Larkin, District Ranger, Bend-Ft. Rock Ranger District, 63095 Deschutes Market Road, Bend, Oregon 97701. Mailed comments must be postmarked by Monday December 18th.

Lex timber sale units as proposed under Alternative 3. Additional non-commercial logging, burning, and mastication of shrubs and understory structure would take place as part of all action alternatives in the sale.

Major concerns and talking points are below. Personalized comments are most effective. Even short comments or copy and pasted comments will help us fight this sale. You can click here to see our fact sheet with pictures of the Lex timber sale.

Industrial, retrograde forest management practices such as “seed tree cuts” (clearcutting with a few seed trees remaining) and “overstory removal” logging have no place on public lands, and need to come to an end on all national forests.

  • The Lex sale is approx 10 miles south of Bend, and proposes between 5,101 and 6,465 acres of commercial logging.
  • This sale proposes clearcutting, logging of overstory trees (the largest and most mature trees in the stand), logging in mature forests, and logging in never-before logged or very minimally logged areas. Forest stands will be moved away from mature and late and old forest structure.
  • Areas proposed for “overstory” logging are already heavily logged, and have suffered extensive cumulative damage. These areas should be left to recover, not logged again for their last remaining trees for their commercial value.
  • Clearcutting and overstory removal logging are proposed over multiple trails, including hiking, biking, and skiing trails. Some of the proposed logging is adjacent to designated roadless areas, and overlaps with recreational trails going into Inventoried Roadless Areas.
  • The Forest Service should not be logging in areas that are designated to be managed for values such as intensive recreation, winter recreation, scenic views, or administratively withdrawn areas.
  • The Forest Service is proposing to use herbicides (glyphosate and hexazinone), gopher trapping, and borax treatments after logging and replanting to protect the unnatural and industrial-style tree plantations which will be created as a result of this project.

Wildlife and habitats threatened by this sale:

  • Northern spotted owls: This sale proposes logging in Northern spotted owl dispersal habitat, which will destroy the current habitat value for spotted owls, potentially violating the Endangered Species Act. Dispersal habitat is crucial for connectivity between blocks of nesting habitat, and is important for the movement of young spotted owls away from nests and for adults moving from one territory to another.
  • The Lex sale threatens multiple at-risk and special-status species: Species that are at particular risk from logging in this sale include: Northern spotted owl, Northern goshawk, Sierra Nevada red fox, Pacific fisher, Ringed myotis bat, Pallid bat, Townsend’s big-eared bat, Johnson’s hairstreak butterfly, Western bumblebee, Great grey owl, Olive-sided flycatcher, Neotropical songbirds, Lewis’s woodpecker, Three-toed woodpecker, and Primary Cavity Excavators (species that create holes in standing dead trees that other species then use for nests). The USFS’s environmental assessment admits that for many of these species, the project would have negative impacts such as loss of nesting and reproductive habitat, loss of mature forest habitat and other necessary wildlife habitat; mortality of individuals from logging; and disturbance from road activities.
  • Deer and elk: This project proposes to violate its own Forest Plan management standards for hiding cover for deer and elk. Logging planned in the Lex project would further reduce hiding cover for deer and elk that are already below standards. Further, the Forest Service has provided no evidence of unique site-specific conditions– as required for the use of the site-specific amendment loophole that they are attempting to use to exempt themselves from their own standards.
  • Northern goshawk: This sale proposes to log between 1,119 and 1,459 acres of goshawk reproductive habitat (35-46% of goshawk habitat in project area). Logging would severely degrade or destroy the ability of goshawk to use these areas for reproduction.
  • Snags (standing dead trees) and downed wood provide extremely important wildlife habitat that a disproportionate number of species depend upon, many of which are listed, at-risk, or sensitive. Different species depend on differing snag sizes, decay classes, and densities. Snags should be left on the landscape, protected, and at the very least buffered. Proposals to remove snags through “salvage” logging are unacceptable, except in clearly defined circumstances involving public safety, such as major transportation corridors- and only when unavoidable. Areas of high snag densities are important for black-backed woodpeckers (a species which is petitioned for uplisting on the ESA), as well as for other woodpeckers, birds, and wildlife species. Mountain pine beetles are a native insect, and a necessary disturbance in forest ecosystems, and their larvae are a primary food source for certain woodpeckers and other birds.
  • Sensitive ecological areas: During our extensive field-checking of the sale, we documented that most sale units on buttes have never been logged before, or had minimal firewood cutting. In addition, the vast majority of the forests on the buttes are mixed conifer or moist mixed conifer, which are naturally dense and provide high value wildlife habitat for species such as deer, elk, grouse, marten, goshawk, and black-backed woodpeckers. The Forest Service should not log in mixed conifer and moist mixed conifer areas, in buttes or otherwise, as these areas provide critical wildlife habitat for numerous species.

Fire:

  • Assumptions and rationales about fire used by the Forest Service to justify this project do not reflect current and best available science. The Lex project area includes high elevation, subalpine forests, hemlock forests, mixed conifer and moist mixed conifer forests, never-logged areas, and many areas of naturally dense and complex forest types and habitats that are critically important for wildlife. Current science provides ample and mounting evidence that fire regimes were historically more complex, and included more and higher intensity fires than what is often recognized in the assumptions and rationales upon which land management decisions are based. Particularly in higher elevations, naturally dense moist mixed conifer forests, north/northeast facing slopes, and other microclimates and topographic variations across the landscape, forests naturally and historically included more dense stands, patchiness, and complexity than is recognized by Forest Service logging proposals.
  • Shifting the tree species composition in mixed conifer forests is controversial, not supported by current and best available science, and will degrade and destroy important wildlife habitat throughout the project area. For example, this project proposes to favor Ponderosa pine in certain mixed conifer areas through heavy logging of other naturally occurring species such as White fir, Lodgepole pine, and Grand fir. Ponderosa pine is tree preferred by the timber industry because of its straight growth and tighter grain. Many fir species, such as Grand fir, have softer wood, and more often exhibit irregular growth features (which are great habitat for wildlife).

Climate change:

  • The Forest Service must prioritize protection of core habitats and connectivity corridors in order to protect species viability and biodiversity, especially in the face of climate change.
  • Logging in this project would contribute to greenhouse gas emissions and exacerbate climate change. The environmental assessment for this sale is woefully inadequate and bias in its analysis of greenhouse gas contributions due to logging in this sale, and does not incorporate best available current science. The Forest Service is not considering science showing that mature and unmanaged stands store the most carbon, and is instead claiming that heavy logging will help sequester carbon.

Soils:

  • Sensitive soils: Logging is proposed on steep slopes and sensitive soils, including on slopes greater than 30%, cinder cone buttes, and on areas with lava flows and cold air basins.
  • Severe soil disturbance: Virtually every unit in this +5,000 acre project is projected to be at the upper limit for soil disturbance standards under the Forest Plan. Many units are already at the upper limit for soil disturbance conditions, and are not projected to increase their disturbance condition despite planned heavy industrial logging in those units. We are skeptical that overstory logging and road-related activities will not increase the soil disturbance beyond Forest Plan standards.

We are asking the Forest Service to:

  • Drop all “seed tree” (clearcutting) and overstory logging
  • Drop all logging in areas designated under the Forest Plan to be managed for intensive winter recreation, or that are administratively withdrawn
  • Drop all logging in Northern spotted owl dispersal habitat, especially the highest quality dispersal habitat and dispersal habitat serving as connectivity between higher quality habitat areas
  • Drop all logging in Northern goshawk reproductive areas
  • Cancel all planned herbicide use, gopher trapping, and borax treatments—all of which are proposed to protect unnatural and industrial-style tree plantations which will be created as a result of this sale, and which have no place on public lands
  • Drop all logging on buttes, never-logged forests, mixed conifer and moist mixed conifer forests, on steep slopes, sensitive soils, frost pockets, adjacent to or in roadless areas, and in wildlife corridors
  • Drop all logging that impedes natural forest succession
  • Drop all logging that targets the largest and most mature trees in sale units
  • Drop all “salvage” logging of beetle-killed lodgepole
  • Cancel plans for building between 18.8 and 20.4 miles of “temporary” roads. These roads would further fragment forests and disturb many species such as elk, Sierra Nevada foxes, goshawk, marten, and others.

Thank you for commenting!

You can click here to donate and help keep our ecological protection work going with Blue Mountains Biodiversity Project!

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.

 

 

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