Comment on Timber Sales & Other Projects!

Action is needed to help stop the timber sales and other projects detailed here. Please call or write to voice your opposition to these projects! Contact information for appropriate persons to call or write to are listed below. Need help writing comments? Check out our Public Comments 101 info!

 

Summit Timber Sale Action Alert

Please help us show public opposition to this ecologically destructive timber sale by sending in written comments with your name, address, and signature before or by January 20th to: Comments-pacificnorthwest-malheur-prairiecity@fs.fed.us

You can also send written comments, postmarked by January 20th, to: District Ranger Joseph Rausch c/o Amy Mathis, Prairie City Ranger District Office, PO Box 337 SW Front St., Prairie City, Oregon 97869

scan-2-copySummary of the“Summit Creek Landscape Restoration Project” (timber sale):

* Up to 15,500 acres of commercial logging (includes 7,782 acres of mixed-conifer forests); 11,364 to 11,595 acres of pre-commercial and non-commercial thinning

* 234 acres of commercial logging (thinning) along designated streamside corridors ( aka “riparian habitat conservation areas” or “RHCAs”); 1,950 to 2,184 acres of non-commercial thinning in RHCAs, including fish bearing streamsscan-2

* 291 miles of road maintenance for log haul (including 56 miles of reopening of currently closed roads); 10 miles of “temporary” road construction

* 6.7 – 8.2 miles of road decommissioning; 25.3 – 16.6 miles of road closures on currently open roads

* Forest Plan Amendments, including those to circumvent restrictions on logging large trees and logging in mature and old growth forest stands

Water quality and Bull trout: We are very concerned that logging, especially along streams, will negatively affect water quality, damage critical habitat for Bull trout, and threaten the viability of already struggling Bull trout populations. No commercial logging should occur in designated “Riparian Habitat Conservation Areas” (streamside corridors). We are also very concerned that logging in riparian areas will Redband trout, Columbia spotted frogs, and Western ridged mussels. Please ask the Forest Service to drop all commercial logging within RHCAs, and all logging in mixed conifer areas within RHCAs.

scan-3We are opposed to the construction of “temporary” roads, and to the many miles of re-opening of closed roads that the Forest Service is proposing– both of which create lasting impacts of increased access for fur trappers, illegal firewood cutting, livestock, off road vehicles, and invasive exotic plant introduction and dispersal. High road densities also impair soil conditions and threaten water quality and aquatic species. We are requesting that the Forest Service eliminate all proposed new “temporary” road construction, and that they drop or significantly scale back the extensive (291 miles) and costly road maintenance and repairs they are proposing in order to access proposed logging areas within the sale.

The Forest Service’s proposed logging in mixed-conifer forests is not supported by scientific literature. The Forest Service should drop all logging in mixed-conifer forests, especially in naturally more moist and productive forests such as those within riparian corridors, on noscan-4rth and east facing slopes and steep drainages, on ash soils, or with historical evidence of mixed-conifer forests. These forests are naturally denser, and support numerous species that require complex forest structures and denser forest cover.

Other wildlife concerns: We ask that logging in Northern goshawk reproductive areas and post-fledging areas (PFAs) be dropped, as there have been many timber sales and much non-commercial thinning already degrading and eliminating suitable goshawk habitat and PFAs across the Malheur, and as goshawks are very sensitive to human disturbance. We are also concerned by proposed removal of multilayered forest canopy and denser forest where it would naturally exist (e.g. in cool moist and cold dry forest types and on North slopes, high elevations, and in riparian areas), as such removal could contribute to declines in Neotropical migratory songbirds adapted to such denser habitat, as well as harming other bird species adapted to denser habitat, such as Flammulated owls and accipiter hawks. In addition, logging and the loss of “snags” will have negative impacts to Blackbacked woodpeckers and many other species that are dependent on snags. Snags are standing dead trees that are crucial for many wildlife species.

The Forest service should drop all proposed logging within the Malheur Wild and Scenic River Corridor. Logging will damage the natural beauty, character, outstandingly remarkable values, scenic views, water quality, and wildlife habitats of the Wild and Scenic Corridor. Management requirement of these areas note that fisscan-5heries and watershed improvement projects are allowed which stimulate natural processes and use native materials. Logging would obstruct the natural processes of the area, which include native diseases, wildfire, and other natural agents of disturbance that are essential to forest health and the creation of wildlife habitats. Logging within the Wild and Scenic River Corridor will degrade water quality through increasing sediment loading and stream temperatures, and negatively affect Bull trout, Redband trout, Columbia spotted frogs, and Western ridged mussels.

We are strongly opposed to all Forest Plan amendments that would effectively violate Forest Plan standards, and are being used as loopholes to log large trees over 21” dbh (diameter at breast height) and to log in mature and old growth forest stands (the Forest Service refers to these stands as “late and old structure” or “LOS”). Using Forest Plan amendments to violate Forest Plan standards effectively moots the Forest Plan, the only Forest-specific source of standards and guidelines to protect wildlife, soils, water quality, etc. The proposed Forest Plan amendments would viscan-6olate existing Forest Plan standards that were designed to protect important wildlife habitat and ecological functions. The violations of these protective standards are cumulatively very significant, as they are repeated with almost every timber sale proposed across the Malheur National Forest. These are obviously not really site-specific Forest Plan amendments, as they are used across the Forest to allow for more heavy logging than legally allowed. These repeated Forest Plan amendments have significant cumulative effects to species and wildlife habitats across the Forest.

The Forest Plan amendments in the Summit sale include the violation of the 21” dbh logging limit, which is designed to protect and restore large tree structure (live trees, future large snags and logs) across the landscape. Large trees are at a great deficit regionally compared to historic conditions due to past (and now proposed) logging of large trees and past clearcutting. Large tree structure is needed by many species, and is crucial to create large snags for woodpeckers such as Pileated and Lewis’; nest trees for Northern goshawk and Great Gray owl; denning trees for Pacific fisher and American marten; and large trees for foraging for White-headed woodpecker and other bird species; present and future pools for fish refugia; and for soil nutrient cycling, carbon sequestration, and recreational aesthetic values.scan-7

The Forest Plan amendments in the Summit sale also include the violation of restrictions on logging in mature and old growth forest stands (“i.e., “late old structure” aka “LOS” stands). Cumulatively logging of LOS stands can eliminate their suitability as LOS habitat—especially in naturally denser mixed conifer habitat, or may remove these stands from LOS designation, and thus from any protection for associated species. Commercial size-logging in old growth stands degrades the quality of the old growth habitat by removing mature and large trees needed by wildlife and birds for denning and nesting, removing canopy cover needed by interior forest-dependent species and species that need denser forest habitat. Wildlife species at risk to heavy logging and loss of suitable or old growth habitat in the project area include: Bull trout, Pileated woodpecker, elk, potential accipiter hawks (Northern goshawk, Cooper’s hawk, Sharp-shinned hawk), potential Pacific fisher, dispersing Gray wolves, foraging or dispersing Canada lynx, Great Gray owl, Northern Pygmy owl, Rocky Mountain elk, Blackbacked woodpecker, and Neotropical songbirds dependent on denser forest and mixed conifer forest with multiple canopy layers and large trees.

scan-8Cumulative Impacts: We are very concerned about the cumulative impacts of current and past logging, roads, and ongoing livestock grazing in the Summit timber sale. Blue Mountains Biodiversity Project field surveyed this sale during the field season; we found extensive soil compaction, widespread cattle damage to streams, degradation of stream bank stability and wildlife habitats due to logging and roads. More logging will exacerbate these problems. The Forest Service should instead focus on road decommissioning, eliminating fish passage barriers, preventing the establishment and spread of invasive species, and other trulyrestorative actions.

Climate change: We are concerned that logging may make forests more susceptible to the negative effects of climatscan-9e change. Many of the negative impacts on forest ecosystems and wildlife species are likely to be exacerbated by climate change. This includes drying out of microclimates, altered hydrology, shifts and/or contraction in species’ ranges, genetic isolation, degradation of wildlife corridors and barriers to species’ migrations or movement, and decreased biodiversity. Logging may also impede forests’ ability to adapt to climate change due to the loss of individual trees that are genetically adapted to better deal with drought, fire, and Bark beetles. Logging can damage stream ecosystems and hydrology and decreased resilience to climate change. For example, climate change is predicted to result in widespread stream temperature increases that exceed biological limits for aquatic species such as Bull trout and Steelhead. It is crucial for core habitats that currently provide the cleanest, coldest water be preserved to protect species vulnerable to climate change. If we continue to allow water quality to be degraded, then the ability of many sensitive aquatic species to persevere in the face of climate change will be severely diminished. The preservation of healthy, functioning streams with clean, cold water needs to be taken seriously and prioritized. Stream shade in riparian areas needs to be preserved.

scan-11Many birds that are threatened by climate change-driven range shifts are also threatened by logging and other practices on public lands. Bird species that rely on denser forests and complex canopy structure are also suffering widespread habitatloss due to logging that targets mature mixed-conifer forests—these provide needed complexity and forest density. Logging in the Summit timber sale may negatively affect birds that breed in eastern Oregon and rely on denser mixed-conifer forests and/or old growth mixed-conifer forests that have been determined to be climate-endangered and cscan-3limate-threatened. This includes species such as: Boreal owl; Northern pygmy owl; Northern saw-whet owl; Pine grosbeak; Vaux’s swift; Hermit thrush; Three-toed woodpecker; Varied thrush; Evening grosbeak; Hammond’s flycatcher; Townsend’s warbler; Cordilleran flycatcher; Winter wren; Hairy woodpecker; Great gray owl; and Pine siskin (Csuti et al. 1997; Langham et al. 2015). The Summit timber sale and multiple large timber sales across the Malheur National Forest and other National Forests in eastern Oregon are targeting denser mixed-conifer forests. This represents a significant portion of mixed-conifer forests in the region, and has resulted in widespread degradation and elimination of wildlife habitat for species that depend on these forests. The Forest Service needs to analyze and avoid cumulative impacts to wildlife and aquatic species and their habitats from logging and climate change.

Logging, roads, and livestock grazing are the primary threats to forest health and water quality on public lands. On the public lands that we monitor in eastern Oregon, logging and roads are fragmenting and degrading habitat for birds, fish, and other wilscan-2dlife and plant species that are at risk from climate change.

Thank you for commenting!

Blue Mountains Biodiversity Project

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References:

US Forest Service, Summit Creek Landscape Restoration Project Webpage (click here to link to their webpage). 

Csuti B, Kimerling J, O’Neil T (1997). Atlas of Oregon Wildlife: Distribution, Habitat, and Natural History.

Langham GM, Schuetz JG, Distler T, Soykan CU, Wilsey C (2015) Conservation Status of North American Birds in the Face of Future Climate Change. PLoS ONE 10(9): e0135350.