Protecting streams on public lands in eastern Oregon: threats from logging

We are opposed to commercial logging in RHCAs because of the well-documented and inherent degradation of water quality and riparian habitats, and the negative effects associated with the removal of larger, commercial-sized trees. We are opposed to the USFS incentivizing logging in these ecologically sensitive and complex areas. We also have serious concerns about ecologically inappropriate non-commercial as well as commercial logging, particularly when it exacerbates water quality degradation; increases road-related impacts such as fragmentation; logs large trees; occurs in mixed-conifer forests; causes a loss of mature forests or connectivity;  degrades wildlife habitat; or threatens ecological integrity.

As part of our work to protect streams in eastern Oregon, we’ve summarized some of the ecological issues, the science, and our concerns and opposition to logging in RHCAs. Part of this summary focuses on the Malheur National Forest, as there have been several recent and very large back-to-back timber sales that include proposed commercial and non-commercial logging within RHCAs in the Malheur. For further detail, we organized a panel discussion on the ecological risks of logging in RHCAs. Click HERE to see the video of Dr. Chris Frissell and Dr. Chad Hanson’s presentations during the panel.

What are some of the problems with logging projects in RHCAs? Issues include the extensive network of roads required for logging projects; negative ecological effects of climate change exacerbated by logging and associated road activities; fragmentation of forests and loss of biodiversity; cumulative effects with past and current logging, livestock grazing; and fish passage barriers such as failed or faulty culverts. These and other concerns are detailed below.

Contents of summary below:

General water quality summary

Stream temperature

Excess fine sediments 

Wildlife habitat, forest density, and related issues

In perspective

Benefits of high intensity wildfire

Efficacy

Precedent

Inclusion of science

Citations

You can also read more about our stream-related concerns about climate change and roads.

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A large body of scientific research shows that logging near streams can have long-term and devastating consequences for stream ecological integrity and water quality. Logging in RHCAs can cause degradation of water quality such as stream temperature increases, changes to stream temperature patterns, increased fine sediment inputs, stream bank instability, and other problems. The USFS has ignored and downplayed the well-documented negative affects and ecological risks associated with logging within streamside corridors. Even non-commercial thinning in RHCAs is, at best, a large scale and ecologically risky experiment in which little is known about the outcome. Risks are considerable, and the outcome can have unintended negative consequences. Rieman et al. (2001) noted that: “…vulnerable aquatic species could be impacted in the short term in ways from which they could not easily recover, even if long-term benefits eventually became evident in later years” (also cited in the USFS proposed Forest Plan Revision (2014)).

When aquatic species such as Bull trout have already fragmented populations, low numbers, and are currently limited by high stream temperatures, creating widespread situations in which their populations cannot easily recover from management effects in miles of streams is extremely risky at best. Logging poses a greater risk to aquatic species than wildfire, even high-severity wildfire. The USFS proposed Forest Plan Revision (2014) vol 2. pg 60: “Redband trout and bull trout have been shown to recolonize severely burned drainages within two years, provided the drainages were physically accessible (i.e., no culvert barriers, and provided that other fish in unburned areas were close enough to discover and move back into the recently burned habitat”

Some studies have found selective logging may be associated with increases of instream fine sediments (Kreutzweiser et al. 2005, Miserendino and Masi 2010), changes in macroinvertebrate community structure or metrics (Flaspohler et al. 2002, Kreutzweiser et al. 2005), alterations in nutrient cycling and leaf litter decomposition rates (Lecerf and Richardson 2010), and increases in stream temperatures (Guenther et al. 2012). Flaspohler et al. (2002) noted that changes to biota associated with selective logging were found decades after logging. While these studies did not take place in eastern Oregon, they strongly suggest that alterations caused by logging within riparian buffer zones may result in significant changes in water quality parameters and stream biota in many areas; these results are likely tied to dynamics that may be common to many forested streams to varying degrees.

Stream temperature

Over 464 miles of streams within the Malheur National Forest are listed as not meeting water quality criteria, largely as a result of past and current land management practices (logging, grazing, and roads). The most common water quality impairment in National forest System lands is stream temperature (USFS 2014, proposed Forest Plan Revision, vol 1, pg. 272). High stream temperatures are a serious and pervasive threat to water quality, and are a result of past and current land management (logging, roads, grazing, and past mining). The number of stream miles violating temperature standards is very likely an underestimate, as many streams are either not monitored or sometimes not reported to ODEQ, even if they are violating water quality standards. Commercial logging in Riparian Habitat Conservation Areas will not improve stream water temperatures, and will very likely to exacerbate the problem.

High stream temperatures are already a limiting factor for fish in many areas, as well as the most common water quality problem. Threatened fish stocks are already struggling due to high stream temperatures and increased fine sediments in many areas. Stream temperature increases, especially in areas that are already in violation of state and Forest Plan stream temperature standards, are especially dangerous to Bull trout and Steelhead populations. Even if temperature increases aren’t detected at larger watershed scales, localized increases at the subwatershed or reach scale can be very important for already Threatened fish stocks—especially if the problem is repeated in multiple stream reaches across the landscape. Especially given accelerated and widespread logging occurring throughout the MNF, effects on Bull trout and Steelhead in multiple individual streams are extremely concerning.

There has been little direct monitoring or studies done regarding the effects of logging in RHCAs on stream temperature in relation to current silvicultural prescriptions. It is well documented that heavy logging within riparian areas will significantly raise stream temperatures, often drastically, as well as negatively impact other water quality parameters (such as fine sediment). There is little reason to conclude that removing some trees from the RHCAs will not have an intermediate negative affect on stream temperatures—likely resulting in an increase in stream temperatures, though not as great as the increases seen in clear cut scenarios. Given that many streams are already in violation of water quality standards for temperature, and that stream temperatures already exceed optimal ranges for fish in many streams– even minimal increases in stream temperatures may pose additional severe threats to fish viability.

Guenther et al. (2012) found increases in stream temperature in relation to selective logging. The Guenther study found increases in bed temperatures and in stream daily maximum temperatures in relation to 50% removal of basal area in both upland and riparian areas. Increases in daily maximum temperatures varied within the harvest area from 1.6 to 3 degrees Celsius.

In addition, current and thorough research indicates that existing regulations may not adequately protect fish viability. This strongly implies that we need to take into account even more subtle and nuanced effects from land management on stream temperature. For example, the study Key findings for Stream Temperature Variability: Why It Matters To Salmon by Steele, A. and Beckman, B. (2014) at the Pacific Northwest Research station include: “Commonly used degree-day accumulation model is not sufficient to predict how organisms respond to stream temperatures. Changes in how the degree days are delivered have the potential to alter the timing of life history transitions in Chinook salmon and other organisms. Emerging from the gravel a few days earlier or later could directly affect their survival due to changes in available food resources, competition for feeding grounds, or strong currents”. Best Management Practices need to be reevaluated and modified to ensure that stream temperature variability is not altered beyond thresholds for Bull trout and other at-risk and aquatic species. It is likely that logging in RHCAs will affect stream temperature variability as well as average stream temperatures– and poses large risks to the continued viability of sensitive fish, such as Bull trout.

The Steele and Beckman (2014) study demonstrates that organisms are more sensitive to subtle and hard to measure changes or shifts in their environments—much more so than is commonly appreciated or than agency monitor protocols account for. The standards and guidelines we have in place are currently insufficient to protect the viability of many sensitive species such as salmon. Allowing for commercial-sized removal of logs is extremely likely to shift baseline conditions in a harmful direction (loss of shade, increase in stream temperature and sediment, loss of biomass, loss of wildlife habitat).

Excess fine sediments

Most BMPs do not require strict adherence, are often very subjective or open to wide interpretation, and are not always clearly communicated. BMP monitoring is inadequate and has not provided robust datasets show that BMPs are sufficiently protecting water quality when logging in RHCAs. There is also evidence to suggest that BMPs may not be sufficient to protect sensitive fish (USFWS 2010; Steel and Beckman 2014).

In addition, effects of logging (including thinning) can be hard to detect despite being persistent, long-lasting, and negative. For example, the Draft Forest Plan Revision for the Blue Mountains (vol. 2 pg. 48): “Timber harvest can influence aquatic ecological condition via such activities as removal of trees in the riparian zone, removal of upslope trees, and associated understory or slash burning (Hicks et al. 1991). These activities can affect wood recruitment, stream temperatures, erosion potential, stream flow regime, and nutrient runoff, among others (Hicks et al. 1991). Effects of harvest are likely to be different at different scales. Hemstad and Newman (2006) found few effects of harvest at the site or reach scale, but found that harvest five to eight years earlier resulted in losses of habitat quality and species diversity at the scale of a stream segment (larger than a reach) or at the subwatershed level. Those losses were revealed in terms of increases in bank instability and fine sediment throughout the watershed and increased water temperatures and sediment problems throughout the channel segment. The cumulative effects of widespread harvest within a single drainage in a short period of time resulted in deterioration of the aquatic and riparian habitats, but evidence of effects lagged harvest by several years and different evidences of deterioration showed up at different spatial scales within the watershed”.

Evidence suggests that current ‘Best Management Practices’ and/or Project Design Criteria may not be sufficiently protective of Bull trout. Bull trout may need special consideration beyond what other fish require, particularly in relation to BMPs. If logging practices such as commercial logging, are allowed in streamside RHCAs, it is highly likely that streams will be more impacted by roads and road-related effects, not less. The Fish and Wildlife Service Final Rule for Bull trout (Department of the Interior Fish and Wildlife Service 50 CFR part 17 2010) states that: “Special management considerations or protection that may be needed include the implementation of best management practices specifically designed to reduce these impacts in streams with bull trout, particularly in spawning and rearing habitat. Such best management practices could require measures to ensure that road stream crossings do not impede fish migration or occur in or near spawning/rearing areas, or increase road surface drainage into streams.”

The current status of Bull trout in eastern Oregon and across the region warrants extreme caution, and logging in RHCAs pose clear and serious risks to this species. Small Bull trout populations make for fragile Bull trout populations (that are subject to declines due to localized events, genetic drift, and other factors). The Oregon Department of Fish and Wildlife (ODFW) (2005) states that:“[P]opulations of bull trout with fewer than 100 spawning adults are considered at risk of inbreeding and fail the interim risk criteria. The sum of interconnected populations also must exceed 1,000 adults to avoid risk of genetic drift.” The two John Day core areas for Bull trout continue to have “substantial, imminent” and “at risk” threat ranks and final ranks (USFWS 2008). The USFWS (2008) shows that in the Umatilla, Malheur, and Walla-Walla National Forests, Bull Trout face substantial or imminent threat on six core areas, and widespread, substantial or moderate non- imminent threat on four areas, and low-severity threat on three core areas.

Wildlife habitat, density, and related issues

Forests located along streams support a disproportionate amount of diversity, and serve as extremely important wildlife corridors. In some areas, over 70% of vertebrate species depend on riparian corridors at various portions of their lives (ISAB 2007). Because streamside areas have been somewhat more protected in the last few decades, they often have some of the last remaining large trees and old growth forest structure in the area. This includes more snags and downed wood. Mixed conifer forests, especially mature and old growth mixed-conifer forests in riparian areas provide critical wildlife habitat—often some of the best remaining habitat or the ONLY remaining wildlife habitat. Logging in mixed conifer forests in riparian areas in order to reduce density is not well supported by literature.

Target densities for forests in many USFS timber sales appear to be based almost entirely on white papers by Powell, a USFS silviculturalist. These are not peer-reviewed or published scientific studies. Powell is one individual with a silvicultural background, and his work has little vetting or transparency. For example, the Summit timber sale target densities appear to have, at least initially, contained faulty assumptions and interpretations based on Powell. Extensive research by BMBP showed that historical documents suggest conditions that do not align with current assumptions about forest densities or species composition. We are very concerned that logging in Riparian Habitat Conservation Areas will have a similar lack of sound basis to inform a “desired future condition”.

Logging in RHCAs to decrease forest density will negatively impact wildlife. For example, Northern goshawk and other accipiter hawks, American marten, Great gray owls, Black-backed woodpeckers, Three-toed woodpeckers, Pileated woodpeckers, Olive-sided flycatchers, and other species that rely on denser forests, mature or old growth mixed conifer forests, and/or will be negatively affected by logging in RHCAs.

A body of scientific evidence is emerging that suggests that numerous species are more negatively affected by thinning than by wildfire. Example include Olive-sided flycatchers, lynx, Pacific fisher, Spotted owls, flying squirrels, and other species. This kind of research strongly suggests that a greater abundance of caution is needed when considering logging in important wildlife corridors such as riparian areas. Robertson and Hutto (2007) provide evidence for the harmful effects of thinning to some species in their study Is selectively harvested forest an ecological trap for Olive-sided flycatcher? The authors state that:

“Human activities that closely mimic the appearance but not the fundamental quality of natural habitats could attract animals to settle whether or not these habitats are suitable for their survival or reproduction. We examined habitat selection behavior and nest success of Olive-sided Flycatchers (Contopus cooperi) in a naturally occurring burned forest and an anthropogenically created habitat type—selectively harvested forest. Olive-sided Fly- catcher density and nestling provisioning rates were greater in the selectively harvested landscape, whereas estimated nest success in selectively harvested forest was roughly half that found in naturally burned forest. Reduced nest success was probably a result of the relatively high abundance of nest predators found in the artificially disturbed forest. These results are consistent with the hypothesis that selectively harvested forest can act as an ‘‘ecological trap’’ by attracting Olive-sided Flycatchers to a relatively poor-quality habitat type. This highlights the importance of considering animal behavior in biodiversity conservation.”

Pilliod et al. 2006 examined potential unintended negative effects on wildlife and habitats due to thinning and prescribed fire. We are concerned that similar negative effects on wildlife and habitats will occur in the widespread logging in RHCAs. For example, we are concerned about possible losses of snags and dead wood (both in direct response to the project and decreased future recruitment), negative effects on density-and closed canopy-dependent species, negative effects on alpha and beta biodiversity, declines in mammal populations, and other unintended negative effects on the flora and fauna and habitats in the project area. Highlights from their study include:

“Large-scale prescribed fires and thinning are still experimental tools in ecological restoration (box 1), and unanticipated effects on biodiversity, wildlife and invertebrate populations, and ecosystem function may yet be discovered (Allen and others 2002; Carey and Schumann 2003).”

“Species that prefer closed-canopy forests or dense understory, and species that are closely associated with those habitat elements that may be removed or consumed by fuel reductions, will likely be negatively affected by fuel reductions. Some habitat loss may persist for only a few months or a few years, such as understory vegetation and litter that recover quickly. The loss of large-diameter snags and down wood, which are important habitat elements for many wildlife and invertebrate species, may take decades to recover….”

“Wildlife and invertebrate species that depend on down wood, snags, dwarf mistletoe (Arceuthobium spp.) brooms, dense forests with abundant saplings and small poles, and closed-canopy forests for survival and reproduction are likely to be detrimentally affected by fuel treatments that alter these habitat elements”

“Implementation of any thinning or prescribed burning is likely to result in loss of snags, future snags, and down wood that are important stand attributes of healthy forests and critical components of wildlife and invertebrate habitat”  

Loss of large-diameter snags and down wood can take years to decades to recover, as indicated by wildland fire research (Passovoy and Fule 2006).”

“There is a great need for long-term observational and preferably experimental studies on the effects of a range of fuel reduction treatments at multiple spatial scales (stand or larger).”

Numerous studies have found negative impacts on wildlife habitats from thinning in riparian areas, even when snags removal is not intended. For example, Pollock et al. (2012) found that selective logging may cause riparian forests to develop characteristics outside of normal late seral conditions in reference stands. Pollock and Beechie (2014) study found that:

“Because far more vertebrate species utilize large deadwood rather than large live trees, allowing riparian forests to naturally develop may result in the most rapid and sustained development of structural features important to most terrestrial and aquatic species”.

Essentially, the forest stands within streamside riparian corridors are some of the only remaining areas that appear to be providing well-used wildlife habitat and that are not sterile and homogenous (like most of the many miles of Ponderosa pine plantations that surround RHCA across much of the district and the region). RHCAs are not appropriate for conducting risky land management experiments due to their importance for wildlife and fish, water quality, cold water refugia, terrestrial and aquatic connectivity corridors, and their sensitivity to risks associated with logging.

Livestock grazing, roads, and logging pose far greater threats to water quality and streamside corridors than possible (and likely insignificant in most mixed-conifer RHCAs) alteration of forest species composition or fire regime. In areas where species composition and/or fire regime alteration is posing an ecological threat to a forest stand (especially, for example, in lower elevation Ponderosa pine forests), then the best way to ensure achievement of Forest Plan standards for stream health is to non-commercially thin and leave all material on the ground.

The following quotes are from August 2017 “Science Findings” from the PNW Research Station:

• In dry forests, a mixed-severity fire that kills trees is an important but underappreciated strategy for providing enough snags for cavity-dependent species. Low-severity prescribed fires may not provide enough snags for these species.
• Suitable snags are limited, such that snag availability drives landscape-level habitatselection by some species. For example, white-headed woodpeckers selected severely burned patches for nesting, which was initially puzzling because this species does not characteristically forage in burns.
• Within burns used by at-risk woodpeckers, the majority (86 to 96 percent) of seemingly suitable trees contained unsuitably hard wood; wood hardness limits nest site availability for these declining species.
  • This suggests that past studies that did not measure wood hardness counted many sites as available to cavity-excavating birds when actually they were unsuitable. “By not accounting for wood hardness, managers may be overestimating the amount of suitable habitat for cavity-excavating bird species, some of which are at risk,” Lorenz says.

“Currently, the best solution we can recommend is to provide large numbers of snags for the birds, which can be difficult without fire,” According to the researchers’ calculations, if one of every 20 snags (approximately 4 percent) has suitable wood, and there are five to seven species of woodpeckers nesting in a given patch, approximately 100 snags may be needed each year for nesting sites alone. This does not account for other nuances, like the fact that most species are territorial and will not tolerate close neighbors while nesting, or the fact that species like the black-backed woodpecker need more foraging options. Overall, more snags are needed than other studies have previously recommended.”

“Based on their results, Lorenz and her colleagues see the critical role that mixed-severity fires play in providing enough snags for cavity-dependent species. Low-severity prescribed fires often do not kill trees and create snags for the birds. “I think humans find low-severity fires a more palatable idea. Unfortunately or fortunately, these birds are all attracted to high-severity burns,” Lorenz says. “The devastating fires that we sometimes have in the West almost always attract these species of birds in relatively large numbers.” Many studies have shown that a severely burned forest is a natural part of western forest ecosystems. Snags from these fires attract insects that love to burrow beneath charcoal bark. And where there are insects, there are birds that love eating these insects. Lorenz and her colleagues stress that providing snags that woodpeckers can excavate is crucial for forest ecosystem health in the Pacific Northwest, where more than 50 wildlife species use woodpecker-excavated cavities for nesting or roosting.”

The Forest Service claims that Grand firs and other less fire-resistant trees are present in larger numbers and higher densities across the landscape than they were historically, as a consequence of fire suppression. The Forest Service abuses this rationale by applying it overly broadly and aggressively, including to areas with ample evidence of historic mixed-conifer and high-density forests, such as those in north and east facing slopes; deep gulches and narrow valleys; forests on soils that hold more nutrients and moisture (such as ash soils); and other areas that show historic evidence of supporting mixed-conifer forests in general and Grand fir in particular. The Forest Service is using flawed assumptions that lack adequate scientific backing in order to log in streamside corridors and to large trees across many thousands of acres—despite the documented deficit in large trees across the landscape and their importance to wildlife. Over the last 26 years, we have repeatedly documented evidence of historic high-density, old growth Grand fir in areas where the Forest Service wants to extensively log in RHCAs and to log large trees. In some projects, the USFS is proposing logging of large trees within RHCAs (as well as outside of RHCAs).

The USFS claims that all trees less than 150 years old are “young”. Additional logging of commercial sized trees within RHCAs, including those the next size class down from 21” dbh trees, will result in fewer trees available to become mature and large-sized snags, or large living trees. In situations where some clearing of younger trees may be ecologically appropriate, this can be accomplished by non-commercial logging. In addition, the Van Pelt guidelines are wholly inadequate for Grand fir, and do not contain guidance that can be used in the field to reliably identify Grand fir older than 150 years. They are also beside the point. It is large trees that are necessary for wildlife habitat, and those are in extreme deficit across the region due to logging—regardless of age. The Ursus EA on the Deschutes NF discusses the inadequacies of the Van Pelt guidelines for determining age (pg. 77):

“A size or a diameter limit was chosen as the best metric to measure effect on trees that are old or large on the landscape. Other considerations were made, such as using Van Pelt’s guide to identify old grand (white) fir, but due to the characteristics of white/grand fir it was determined to not be an accurate metric. Bark on white/grand fir never develops the thickness of its fire-tolerant associates. The transformation that many trees experience from young gray bark to increasingly more colorful mature bark does not occur with white/grand fir. Even in giant old trees, bark characteristics reveal little about age. Like Douglas fir and western larch, white/grand fir is an opportunist, and has epimoric branch formation. As the stand matures and conditions change around a tree, light penetration may allow new branches to grow where they had been previously lost. Crown condition, tree form, and bark fissures are not an accurate way to tell age. Other than size, there is little else on white/grand fir that indicates age.”

When USFS districts do their own in-house coring of trees to determine age of tree species in a given timber sale, the diameter limits or lack thereof are not adequate to protect trees of the diameters that the USFS deems likely to be 150+years. For example, the Starr Aspen sale on the MNF and the Melvin Butte sale on the Deschutes NF both included USFS logging of trees that were, by their own coring data, likely 150+ years old. In addition, these sample sizes are often extremely small, lack clear or standard scientific protocols, and are a wholly inadequate basis for determining protective standards. In addition, the larger the sample size, the clearer it is that a 21” dbh limit is needed to protect trees 150+ years. Serious cumulative impacts to wildlife are likely throughout the region due to the repeated and widespread practice of logging large trees. For example, the Forest Service has not estimated the combined total of large ≥21”dbh trees planned for logging within the Big Mosquito, Ragged Ruby, and Camp Lick timber sales, and other timber sales on the Malheur, such as the Elk 16 sale and Starr Aspen sale. The USFS has not addressed such questions or considered the cumulative ecological ramifications. Large trees are at a deficit across the landscape and are needed by wildlife. Large and mature or commercial-sized trees should not be logged within RHCAs. While thinning may in some circumstances cause remaining individual trees to ‘grow bigger faster’, it harms other healthy forest processes and functions (large tree recruitment, snag and large wood recruitment, “defective” trees due to disease and insects, water quality, soils, etc).

Mixed-severity fires (including high severity fires) create habitat that is necessary for species within the MNF and eastern Oregon, suggesting that high severity fires are natural and historically present, as well as necessary. High severity fires create important habitat that is very high in biodiversity, and may be rare compared to historic norms.

The evolutionary history and very existence of Black-backed woodpeckers suggests that large high-severity fires must regularly occur within their range. We are concerned that current fire suppression efforts through the region will continue to exclude high-severity wildfires (and continue despite project implementation) and threaten the viability of Black-backed woodpeckers and other species that depend on high-severity wildfire. Hutto et al. (2008) noted that:

“Without embracing an evolutionary perspective, we run the risk of creating restoration targets that do not mimic evolutionarily meaningful historical conditions, and that bear little resemblance to the conditions needed to maintain populations of native species, as mandated by law (e.g., National Forest Management Act of 1976).”

“The degree to which the black-backed woodpecker is restricted to burned forest conditions in the intermountain west is truly remarkable. Although this species has been detected outside burned forest conditions, particularly in unburned, beetle-killed forests, the numbers therein are small, and nest success therein is substantially lower than in burned forests (Saab et al. 2005). Neither Powell (2000) nor Morrissey et al. (2008), for example, found any black-backed woodpeckers in surveys of mountain pine beetle-infested mixed-conifer forests even though they located northern flickers and three-toed, hairy, downy, and pileated woodpeckers. Similarly, a regionwide bird survey across a series of unburned, beetle-infested conifer forests within the Forest Service Northern Region (Cilimburg et al. 2006) yielded only two black-backed woodpecker detections (0.46 % of 433 point counts). This is less than one-tenth of the frequency of detection in forests burned 6 yr (Saab et al. 2007), so the probability of a severe fire occurring somewhere within an entire watershed in any given 6-year window is very high. Thus, when viewed on a landscape scale, it becomes easy to imagine that a sufficiently mobile plant or animal species (e.g., fire morel [Morchella angusticeps]; jewel beetle, Buprestidae; blackbacked woodpecker) could become specialized to use a burned forest condition that is ephemeral on a local scale but always present somewhere in the larger landscape.”

“…[T]he patterns of distribution and abundance for several other bird species (black-backed woodpecker [Picoides arcticus], buff-breasted flycatcher [Empidonax fulvifrons], Lewis’ woodpecker [Melanerpes lewis], northern hawk owl [Surnia ulula], and Kirtland’s warbler [Dendroica kirtlandii]) suggest that severe fire has been an important component of the fire regimes with which they evolved. Patterns of habitat use by the latter species indicate that severe fires are important components not only of higher-elevation and high-latitude conifer forest types, which are known to be dominated by such fires, but also of mid-elevation and even low-elevation conifer forest types that are not normally assumed to have had high-severity fire as an integral part of their natural fire regimes. Because plant and animal adaptations can serve as reliable sources of information about what constitutes a natural fire regime, it might be wise to supplement traditional historical methods with careful consideration of information related to plant and animal adaptations when attempting to restore what are thought to be natural regimes.”

“In addition, two lines of evidence suggest that it is the more severe fires that are needed to create conditions most suitable for this fire specialist: (1) not only is the black-backed woodpecker restricted to burned forests, but its distribution within burned forests is also relatively restricted to the more severely burned conditions (Kotliar et al. 2002, Smucker et al. 2005, Russell et al. 2007, Hutto 2008); (2) black-backed woodpecker nest sites occur in locations that harbor significantly larger and more numerous trees than occur around randomly selected sites within a burn (Saab and Dudley 1998, Kotliar et al. 2002, Russell et al. 2007). Such nesting locations would be difficult to find in forests maintained as low-density, open, park-like stands due to frequent, low-severity fire.”

“How could a species evolve to depend on a condition that occurs only infrequently? The answer lies with the distribution and abundance of such fires across space and time. The return interval for severe fire in one location may be several hundred years, but black-backed woodpecker populations persist in a particular re for >6 yr (Saab et al. 2007), so the probability of a severe fire occurring somewhere within an entire watershed in any given 6-year window is very high. Thus, when viewed on a landscape scale, it becomes easy to imagine that a sufficiently mobile plant or animal species (e.g., re morel [Morchella angusticeps]; jewel beetle, Buprestidae; black-backed woodpecker) could become specialized to use a burned forest condition that is ephemeral on a local scale but always present somewhere in the larger landscape.”

In perspective

We are most concerned about areas we’ve seen on the ground during our field surveys that are NOT the pictures of skinny dog-hair forest stands we usually see during USFS field trips or in EA/EIS pictures. The areas we are most concerned about are those which are clearly mature or LOS forests, are providing important wildlife habitat and corridors, are in steep areas, have had comparatively little management or logging, contain moist plant association groups in abundance (such as Queen’s cup or twinflower), and/or contain evidence of historically supporting a relatively high density of density of Grand fir (north/north east slopes, ash soils, many very large fir trees or stumps, etc. In our experience, these areas are often encompassed by the RHCAs, with very little if any of the surrounding landscape supporting such characteristics.

We are very concerned that current assumptions about the Historic Range of Variability regarding fire and tree species composition and density have key flaws, and are being overly broadly applied, especially in mixed-conifer forests. Flawed assumptions and approaches by the Forest Service to justify logging pose great risks to forest health, numerous species, and the ecological integrity of forests across the Malheur and the region—especially in the context of logging within RHCAs. The Forest Service must allow for the full range of and ecological benefits of natural disturbances patterns whenever possible.

Benefits of high-intensity wildfire

High-severity fire patches, including large patches, create very biodiverse, ecologically important, spatially rare and unique habitat, which often has higher species richness and diversity than unburned old forest; many wildlife species use this forest habitat type more than any other, and old forest species select it for foraging, while some very rare and imperiled species, such as the Black-backed Woodpecker and Buff-breasted Flycatcher, depend upon it for all habitat. In ponderosa pine and Douglas-fir forests of Idaho at 5-10 years post-fire, levels of aquatic insects emerging from streams were two and a half times greater in high-intensity fire areas than in unburned mature/old forest, and bats were nearly 5 times more abundant in riparian areas with high-intensity fire than in unburned mature/old forest (Malison and Baxter 2010). Post burn snag forests supported greater bird species richness and abundance compared to unburned old forest for at least 25 years after high-intensity fires; including for woodpeckers and flycatchers for at least 25 years after high-intensity fires (Raphael et al. 1987). Bird species richness increased for up to 30 years after high-intensity fires (Schieck and Song 2006) By 30 years after high-intensity fire, bird species richness increased 56% relative to pre-fire mature unburned forest (Haney et al. 2008). . Even old growth forest species like the Pacific Fisher benefit from such post-fire habitat for foraging (Hanson 2015). The high- intensity re-burn [high-intensity fire occurring 15 years after a previous high-intensity fire] had the highest plant species richness and total plant cover, relative to high-intensity fire alone [no re-burn] and unburned mature/old forest; and the high-intensity fire re-burn area had over 1,000 seedlings/saplings per hectare of natural conifer regeneration (Donato et al. 2009). Fishers used unlogged higher-intensity fire areas at levels comparable to use of unburned dense, mature/old forest. Female fishers demonstrated a significant selection in favor of the large, intense fire over adjacent unburned mature/old forest, and the highest frequency of female fisher scat detection was over 250 meters into the interior of the largest higher- intensity fire patch (over 12,000 acres) (Hanson 2015).

Efficacy

The short-term and temporary nature of the perceived fuels reduction benefits from most project are not likely to result in meaningful changes to fire intensity, size, or severity. Most projects designed to reduce fuels note that perceived benefits are estimated to affect fire behavior for approximately 20 years. If the estimated effectiveness is only approximately 20 years, then the justification for this project is even more tenuous. For example, Rhodes and Baker (2008) found that:

“[u]sing extensive fire records for western US Forest Service lands, we estimate fuel treatments have a mean probability of 2.0-7.9% of encountering moderate-or high-severity fire during an assumed 20-year period of reduced fuels.”

Current forest management is unnecessarily putting firefighters at risk by focusing on remote areas, contrary to peer-reviewed science or common sense. Gibbons et al. (2010) found that defensible space work within 40 meters [about 131 feet] of individual homes effectively protects homes from wildland fire, even intense fire. The authors concluded that the current management practice of thinning broad zones in wildland areas hundreds, or thousands, of meters away from homes is ineffective and diverts resources away from actual home protection, which must be focused immediately adjacent to individual structures in order to protect them. In addition, other studies note that the vast majority of homes burned in wildland fires are burned by slow-moving, low intensity fire, and defensible space within 100-200 feet of individual homes [reducing brush and small trees, and limbing up larger trees, while also reducing the combustibility of the home itself] effectively protects homes from fires, even when they are more intense (Cohen 2000, Cohen and Stratton 2008).

Hutto et al. 2016 note, in relation to climate change, that increased efforts towards fuels reduction would be an untenable emphasis:

“Any perceived problem with future changes in fire behavior cannot be solved by redoubling our effort to treat this particular climate change symptom by installing widespread fuel treatments that do nothing to stop the warming trend, and do little to reduce the extent or severity of weather-driven fires (Gedalof et al. 2005). Therefore, fuel management efforts to reduce undesirable effects of wildfires outside the xeric ponderosa pine forest types could be more strategically directed toward creating fire-safe communities….Fuel treatment efforts more distant from human communities may carry the negative ecological consequences we outlined earlier and do little to stop or mitigate the effects of fires that are increasingly weather driven (Rhodes and Baker 2008, Franklin et al. 2014, Moritz et al. 2014, Odion et al. 2014).”

What is the long-term plan for these many miles of streams being proposed for RHCA logging? In general, the USFS has often promised not to log a given area repeatedly or within a certain timeframe, and then broken this promise. In terms of possible future reentry—what is the USFS’s plan for these many miles of streams proposed for RHCA logging? Will re-entries be planned across the landscape if wildfire or prescribed fire does not burn the area within 10-35 years? If treatments are only good for 10-15 years, then either re-entry will be needed, or logging is a very costly and short-term endeavor that is not effective. It is not feasible to thin the entire landscape every 10-35 years, and if we could accomplish such a misguided feat, it would likely have unacceptable ecological impacts and not be economically viable.

Precedent

Our concerns are not limited to issues about possible precedent/incentive, though we are also worried about that, too. It is also important to consider things in context. For example, the rollbacks of forest and environmental protections that are likely to be proposed in the near future, in combination with allowing commercial logging in RHCAs, is extremely concerning and sure to have negative impacts on streams and water quality. In past decades, RHCA protections and the prohibitions on commercial logging in RHCAs are widely recognized to have been crucial for protecting streams and water quality, fish, wildlife habitats, and large trees.

We are very concerned that logging, especially commercial logging in RHCAs, will provide precedent and incentive for increased logging in the Malheur NF and across the region.

Inclusion of science

Peer reviewed, primary literature should be most heavily relied upon to inform assumptions and decisions. Technical reports and white papers should not be used as sole guidance or dominant body of information for determining management direction. Research done “in-house” by the MNF Ranger Districts and USFS staff should have sufficiently robust sample size, clearly defined protocols that follow scientific standards (including how sample sites are selected), be transparent and accessible upon request, and have clear and sound rationales for their conclusions. This is not currently the case. Peer reviewed studies are the gold standard because the protocols and research expectations within them were developed in order to avoid inaccurate conclusions. Inaccurate conclusions and other problems are common when data sets that are too small, collected in a manner that does not provide accurate or complete representations conditions, etc. BMBP can name at least three examples of data collected and used as rationales for large timber sales on the DNF and the MNF that do not adhere to these protocols. Such practices can easily lead to confirmation bias, and to faulty conclusions and decisions. When numerous large timber sales rely on such information for key rationales, then the possibility for irreparable ecological harm is very high.

Blanket decisions to exclude peer-reviewed science because the research was conducted outside of eastern Oregon or the Blues is 1) not appropriate in many instances 2) does not allow for broad consideration of a large body of science and 3) is inconsistent– i.e., studies are put forth within the agency as legitimate to consider even when the research they contain was conducted in other areas, but in generally only if they align with resource extraction. While it is appropriate to be cautious about studies in other areas, there are many instances in which the research focuses on specific issues, processes, or drivers are likely to be similar to those in the Blues. Moreover, it is important to consider numerous studies and the entire body of science in order to build on previous information, determine patterns, detect possible red flags, and derive conclusions. It is extremely rare that there are numerous and nuanced peer-reviewed studies on a given issue for a particular area, forest type, or ecosystem. When all studies outside of a particular area are excluded, it precludes the ability to examine a broader and more diverse body of knowledge. It also does not allow for detection of patterns or red flags about, for example, potential problems related to climate change, logging, or other issues. This problem is highlighted by the issue that there are very few peer-reviewed studies that have researched certain topics, especially in relation to potential effects of current silvicultural practices on, for example:

* stream temperature responses

* sediment loading in streams

* possible shifts in nutrient cycling in streams and riparian systems

* long-term trajectory for providing wildlife habitats such as snags and downed wood.

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