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

Large wood forming pools in Trail Creek in the Camp Lick sale. Mixed-conifer forests along Trail Creek are targeted for commercial and non-commercial logging in streamside corridors. Trail Creek supports ESA-listed Threatened Mid-Columbia River steelhead as well as sensitive-listed Redband trout.

Logging next to streams can harm water quality and wildlife habitat. Blue Mountains Biodiversity Project is committed to upholding beneficial environmental protections for streams and Riparian Habitat Conservation Areas (RHCAs), and ensuring that commercial logging in RHCAs does not gain a foothold on public lands in eastern Oregon. Unfortunately, many ecological protections are now under attack, and the USFS is currently proposing to log in streamside corridors within Riparian Habitat Conservation Areas (RHCAs) in numerous timber sales. Such proposals are now commonly included in many of the large timber sales on public lands in eastern Oregon. Blue Mountains Biodiversity Project staff and volunteers have spent hundreds of hours on the ground, field surveying the proposed logging projects within streamside RHCAs. We use the information we collected to challenge ecologically destructive proposals.

 

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.

The Summit timber sale initially included commercial logging in RHCAs, but the Forest Service later dropped this portion of their proposal.

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, you can also read BMBP’s objection, written in cooperation with Earthrise Law Center, to the Camp Lick timber sale on the Malheur National Forest here. We also 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

Roads 

Wildlife habitat, forest density, and related issues

Climate change

More on fire and forest density

In perspective

Benefits of high intensity wildfire

Efficacy

Historical documents and pictures (You can also link to a more in-depth discussion on historical documents with citations HERE.)

Precedent

Inclusion of science

Citations

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Bracken in RHCA of Cougar Creek in the Camp Lick sale. Note large fir snags and mature mixed-conifer forest structure with natural openings. Commercial logging is proposed within this streamside RHCA corridor.

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)).

Cattle damage to streams and RHCAs is a serious problem across the region. The Summit timber sale initially included commercial logging in RHCAs, but later dropped this portion of the sale.

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.

Cattle trampling and overgrazing in RHCA in Cougar Creek in the Camp Lick timber sale. Commercial logging is proposed within this streamside RHCA corridor.

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.

More cattle trampling along Cougar Creek in the Camp Lick timber sale. Cougar Creek supports ESA-listed Threatened Mid-Columbia River steelhead. The USFS is planning commercial logging within the RHCA.

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.

Cattle trampling adjacent to Cougar Creek in the Camp Lick timber sale. Cougar Creek supports ESA-listed Threatened Mid-Columbia River steelhead.

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. Guenther et al. (2012) 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.

Cattle trampling and overgrazing along Coxie Creek in the Camp Lick sale. Coxie Creek supports ESA-listed Threatened Mid-Columbia River steelhead. Coxie Creek is targeted for both commercial and non-commercial logging.

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.

Slime covered and overgrazed section of Coxie Creek, adjacent to past logging and current cattle grazing.

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

Cattle trampling in RHCA in the Camp Lick sale

In the draft Forest Plan Revision for the Blue Mountains, the USFS discloses that: “[r]esearch has shown that effective vegetated filter strips need to be at least 200 to 300 feet wide to effectively capture sediment mobilizing by overland flow from outside the riparian management area” (USFS proposed Forest Plan Revision vol. 2 pg. 52). It is logical that logging or thinning within 50 to 100 feet from streams (or closer!), as the Forest Service is proposing, would cause fine sediment production and allow for sediment delivery into streams, and potentially contribute to stream temperature increases, increased variability in waters quality and aquatic habitat parameters, alterations to stream hydrology, and other negative impacts. Furthermore, headwater streams and non-fish bearing streams need more, not less, protection, and existing PACFISH/INFISH buffers do not offer adequate protections for these streams. Negative impacts to upstream reaches, such as higher temperatures, increased sediment loading, down-cutting, and altered hydrographs also negatively affect downstream reaches. In order to protect downstream fish bearing reaches, headwater streams need at least as much protection than larger downstream reaches (Rhodes et al., 1994; Moyle et al., 1996; Erman et al., 1996; Espinosa et al., 1997). Both Erman et al., (1996) and Rhodes et al., (1994) concluded, based on review of available information, that intermittent and non-fish-bearing streams should receive stream buffers significantly larger than those afforded by PACFISH/ INFISH. In addition, Best Management Practices (BMPs) may need to be specially designed to ensure protection of Bull trout (USFWS 2010).

Severe cattle trampling along Trail Creek in the Camp Lick sale. Despite cumulative impacts from cattle and roads, this RHCA area is targeted for commercial and non-commercial logging.

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”.

Cattle trampling along Trail creek in the Camp Lick timber sale. Trail Creek supports ESA-listed Threatened steelhead, and is targeted for commercial and non-commercial logging.

Evidence suggests that current BMPs 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 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.

Large wood and hardwoods in Cougar Creek in the Camp Lick timber sale.

Roads

By logging in RHCAs areas, threats to water quality from roads are exacerbated. Roads are a primary if not the primary threat to water quality in public forests. Logging projects make this problem worse through increased maintenance and use of roads adjacent to and crossing streams and RHCAs, and through building “temporary” roads and skid trails. In many instances, projects claim to reduce road density but instead the actual road density (existing road density) is increased rather than reduced. Road-related activities in timber sales create lasting effects from “temporary” roads, skid trails, landings, re-opened roads, and closed and decommissioned roads, and increased erosion. Actual on the ground impacts are often not accurately considered. Road density, even for “temporary” use, should not be allowed to increase in areas already exceeding road density standards and existing biological thresholds, especially not in RHCAs and subwatersheds with Bull trout and other listed fish. Effects from roads are almost never “temporary”, and may last for many decades; this can include negative affects on water quality.

Erosion caused by road and poorly fitted culvert on Trail Creek in the Camp Lick sale. Trail Creek supports ESA-listed Threatened steelhead. The USFS is planning both commercial and non-commercial logging along Trail Creek.

The effects of sediments and roads on stream integrity and aquatic habitats affect Bull trout, Steelhead, and other fish. From the Federal Registrar, Department of the Interior Fish and Wildlife Service 50 CFR part 17 (2010) Final Rule for Revised Designation of Critical Habitat for Bull Trout states:

“Sedimentation negatively affects bull trout embryo survival and juvenile bull trout rearing densities (Shepard et al. 1984, p. 6; Pratt 1992, p. 6). An assessment of the interior Columbia Basin ecosystem revealed that increasing road densities were associated with declines in four nonanadromous salmonid species (bull trout, Yellowstone cutthroat trout (Oncorhyncus clarkii bouvieri), westslope cutthroat trout (O. c. lewisi), and redband trout (O. mykiss spp.)) within the Columbia River basin, likely through a variety of factors associated with roads. Bull trout were less likely to use highly roaded basins for spawning and rearing and, if present in such areas, were likely to be at lower population levels (Quigley and Arbelbide 1997, p. 1183). These activities can directly and immediately threaten the integrity of the essential physical or biological features described in PCEs 1 through 6.”

The Malheur National Forest already has extremely high road densities. The average road density in the Malheur is 4.2 miles per square mile. Priority watersheds in the MNF currently contains 4.8 mile per square miles average road density. There are currently 10,990 miles of existing roads on the MNF and 4,798 miles of hydrologically connected roads (USFS 2014). Average road density is far exceeds both Forest Plan Standards and thresholds for proper watershed functioning. Logging requires access, and so increases and exacerbates road-related impacts on streams.

Erosion and sedimentation caused by poorly fitted culvert in Trail Creek (same culvert as above picture).

Fish stocks are stronger and better distributed in areas of little or no management and low road densities, even in fire suppressed areas, and even if severe fires occur. Numerous studies and reports show that many benefits are gained by leaving forests unroaded, and to their own ecological processes (including processes involving fire, insects, and disease). (Bader 2000, Bradley et al. 2002, DellaSala et al. 2011, Frissell and Carnefix 2007, Public Lands Initiative 2004, Reiman and Clayton 1997, Reiman et al. 2000, Thurow et al. 2001, Public Lands Initiative/Trout Unlimited 2004, Western Native Trout Campaign 2001).

Timber harvest, grazing, and the synergistic impacts of the two activities combined have significant negative impacts on aquatic habitats. From NOAA 5-Year Review of Snake River Salmonids:

Downed wood and hardwoods along a stream in the Camp Lick sale.

“Information from the [PACFISH Biological Opinion Monitoring Program] PIBO monitoring program indicates that unmanaged or reference reaches (streams in watersheds with little or no impact from road building grazing, timber harvest, and mining) on Federal lands in the Interior Columbia basin (including the Snake River basin) are in better condition than managed streams (Al- Chockhachy et al. 2010b). In particular, managed watersheds with high road densities or livestock grazing tend to have stream reaches with worse habitat conditions than streams in reference watersheds. When roads and grazing both occur in the same watershed, the presence of grazing has an additional significant negative ffect on the relationship between road density and the condition of stream habitat (Al-Chockhachy et al 2010b).

Carnefix and Frissell (2009) discussed impacts from roads, and show that significant negative impacts to sensitive aquatic species are present at road densities greater than one mile per square mile:

“Multiple, convergent lines of empirical evidence summarized herein support two robust conclusions: 1) no truly “safe” threshold for road density exists, but rather negative impacts begin to accrue and be expressed with incursion of the very first road segment; and 2) highly significant impacts (e.g., threats of extirpation of sensitive species) are already apparent at road densities on the order of 0.6 km per square km (1 mile per square mile) or less. Therefore, restoration strategies prioritized to reduce road densities in areas of high aquatic resource value from low-to-moderately-low levels to zero-to-low densities (e.g., 1 mile per square mile, lower if attainable) are likely to be most efficient and effective in terms of both economic cost and ecological benefit. By strong inference from these empirical studies of systems and species sensitive to humans’ environmental impact, with limited exceptions, investments that only reduce high road density to moderate road density are unlikely to produce any but small incremental improvements in abundance, and will not result in robust populations of sensitive species.”

The existing road density on the Malheur NF is well above the 2-miles/square mile NOAA (1996) threshold for watersheds to be considered “properly functioning”. NOAA (1996) notes: properly functioning: 2 miles/sq mile; at risk 2-3 mi/sq mi; not properly functioning >3mi/sq mi.

Bracken walking along Cougar Creek in the Camp Lick sale. Note: mature firs and hardwoods along creek.

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.

Hardwoods along Cougar Creek in the Camp Lick sale.

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:

Bracken measuring large fir in RHCA of Cougar Creek in the Camp Lick timber sale. Commercial logging is proposed within this stream’s RHCA.

“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”

The USFS is proposing selective logging (thinning) within RHCAs in the Ragged Ruby timber sale on the Malheur National Forest. We are very worried about the beautiful, complex, and diverse forests we field surveyed in RHCAs in the Ragged Ruby sale. Many of these forests provide high-quality wildlife habitat, support threatened or sensitive species, have never been logged or only minimally logged, and contain mature and old growth mixed-conifer forests.

“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”.

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.

Dandy, a BMBP volunteer, in a magnificent mixed-conifer forest with plenty of large old growth Grand and Doug firs along Bear Creek in the Big Mosquito timber sale on the Malheur National Forest. The Forest Service is planning extensive logging along many miles of streams across the region– including in mature forests with clear evidence of fir dominance or co-dominance.  We are very concerned about the USFS’s plans for intensive thinning to fell thousands of firs and shift tree species compositions in RHCAs–  including planned “openings” or mini clear-cuts in the flood plain across many miles of streams. Even though RHCA logging in the Big Mosquito sale is non-commercial, we remain very worried about streams in this sale.

“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.”

Large wood and pool in Trail Creek in the Camp Lick timber sale.

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):

Bracken measuring large fir adjacent to Cougar Creek in the Camp Lick sale.

“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.”

Large Douglas fir and Engelmann spruce adjacent to Coxie Creek in the Camp Lick timber sale.

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).

Laura in a mature mixed-conifer stand adjacent to a stream with proposed logging in the Green Ridge sale on the Deschutes National Forest. This forest stand includes large old growth fir as well as Incense cedars.

Climate change

We are concerned about the potential negative effects of logging in RHCAs on numerous bird species, especially those likely to be vulnerable to climate change. Many birds that are threatened by climate change-driven range shifts are also threatened by logging and other practices on the Malheur NF and other NFs in eastern Oregon. Bird species that rely on denser forests and complex canopy structure are also suffering widespread habitat loss due to logging that targets mature mixed-conifer forests—these provide needed complexity and forest density. Logging in RHCAs may have disproportionately negative effects on climate- endangered and climate-threatened birds because RHCAs currently provide some of the best remaining habitat for these birds–many of which breed in eastern Oregon and rely on denser mixed-conifer forests and/or old growth mixed-conifer forests. 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). 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. Recommendations need to avoid cumulative impacts to wildlife and aquatic species and their habitats from logging and climate change.

Logging in RHCAs is likely to decrease connectivity, especially connectivity in mixed-conifer areas that currently serve as important corridors and are among the last remaining areas that can provide connectivity for species that are associated with LOS, mixed-conifer forests, denser forests, etc. Commercial logging, in order to be viable, is likely to further incentivize removal of a greater number of trees, and further exacerbate an already concerning situation.

Columbia spotted frog along Bear Creek in the Big Mosquito timber sale.

Increasing connectivity is the most commonly recommended strategy for preserving biodiversity in the face of climate change, according to a review of 22 years of scientific recommendations (Heller and Zavaleta 2009). Increasing connectivity includes actions such as removing barriers to species dispersal, locating reserves near each other, and reforestation. Other commonly recommended connectivity-related actions include creating “ecological reserve networks [i.e.,] large reserves, connected by small reserves, stepping stones”; “protecting the “full range of bioclimatic variation”; increasing the number and size of reserves; and creating and managing buffer zones around reserves (Heller and Zavaleta 2009). Large blocks of habitat that are well-connected to each other are important for the long-term survival for many species in the face of climate change.

It is essential that we preserve core habitats and connectivity corridors because these areas are very important for maintaining genetic diversity, facilitating movement and migration, and providing for range and habitat needs. Connectivity corridors also allow for species to colonize new areas or recolonize after disturbances, which will help species adapt to shifts in geographic range due to climate change. Many species are already facing threats to their viability due to fragmentation and a lack of connectivity; climate change threatens to severely exacerbate risks to their continued survival by further fragmenting habitats.

Mature mixed-conifer forest with natural openings and large downed fir logs in Sulphur Creek in the Camp Lick timber sale. Sulphur Creek is targeted for logging in the Camp Lick sale.

Logging in RHCAs is likely to exacerbate some of the negative effects of climate change on riparian and stream ecosystems. Stream temperature is a primary concern. Actions that minimize increased water temperatures are important for maintaining cold water refugia. The Independent Scientific Advisory Board (2007) states:

“Adequate protection or restoration of riparian buffers along streams is the most effective method of providing summer shade. This action will be most effective in headwater tributaries where shading is crucial for maintaining cool water temperatures. Expanding efforts to protect riparian areas from grazing, logging, development, or other activities that could impact riparian vegetation will help reduce water temperature increases. It will be especially important to ensure that this type of protection is afforded to potential thermal refugia. Removing barriers to fish passage into thermal refugia also should be a high priority.”

Bull trout may lose over 90% of their habitat within the next 50 years due to increased stream temperatures as a result of climate change. Bull trout require very cold headwater streams for spawning, and so are likely to be disproportionately affected by stream temperature increases due to climate change. Recent projections of the loss of suitable habitat for bull trout in the Columbia Basin range from 22% to 92% (ISAB 2007). The US Fish and Wildlife Service notes that:

Hannah examining a non-functioning culvert in the Black Mountain timber sale in the Ochoco National Forest. We are very concerned about logging and roads exacerbating the negative effects of climate change on streams.

“[g]lobal climate change threatens bull trout throughout its range in the coterminous United States…..With a warming climate, thermally suitable bull trout spawning and rearing areas are predicted to shrink during warm seasons, in some cases very dramatically, becoming even more isolated from one another under moderate climate change scenarios….Climate change will likely interact with other stressors, such as habitat loss and fragmentation; invasions of nonnative fish; diseases and parasites; predators and competitors; and flow alteration, rendering some current spawning, rearing, and migratory habitats marginal or wholly unsuitable.”

Salmon face serous threats to their continued existence due to climate change, and are predicted to suffer significant habitat loss. The Independent Scientific Advisory Board (2007) notes that according to some research predictions:

[T]emperature increases alone will render 2% to 7% of current trout habitat in the Pacific Northwest unsuitable by 2030, 5%-20% by 2060, and 8% to 33% by 2090. Salmon habitat may be more severely affected, in part because these fishes can only occupy areas below barriers and are thus restricted to lower, hence warmer, elevations within the region. Salmon habitat loss would be most severe in Oregon and Idaho with potential losses exceeding 40% by 2090.”

Orchid along Bear Creek in the Big Mosquito timber sale.

Commercial logging in RHCAs would likely exacerbate stream temperature issues. Even localized temperature increases may have negative effects on struggling fish populations, especially when repeated in numerous streams across the landscape. Past and current logging, grazing, and roads have increased stream temperatures to ecologically and legally unacceptable extremes. There is little evidence to support that USFS proposals to log in RHCAs and to focus on tree species composition in RHCAs is an appropriate response or will ameliorate stream temperature problems. High stream temperatures, as well as increased fine sediment in many areas, are likely the pressing risks to fish viability and stream ecosystems. The synergistic effects of climate change, high temperatures, and increased fine sediments warrant actions such as protecting shade, ecosystem integrity, and terrestrial and aquatic connectivity. Wildfire is far less of a threat to these parameters than widespread logging in RHCAs.

Hicks et al. (1991) found base flows increased for 8 to 9 years after clearcut logging because rainfall is not intercepted, evaporated, and transpired by trees. Instead, most rainfall becomes surface, subsurface, or groundwater flow once the trees are removed, and therefore contributes to base flow increases. However, the author found that base flow rates declined to lower than normal volumes in areas of hardwood riparian re-growth for the following 18 of 19 years in their study. This was thought to be due to uptake and ET of stream water by the hardwoods, which had a greater effect on lowering streamflow than conifers. Base flow rates in areas without hardwood re-growth continued to be higher than expected 16 years after logging. The authors predicted base flow rates would return to normal in approximately 40 to 60 years. In addition, Jones & Grant (1996) found that watersheds with drier conditions and more intense summer droughts were more sensitive to the effects of logging and roads on increased peak flows. Logging to increase base flows has been widely cautioned against, and is unpredictable and unlikely to increase base flows during the lowest flow periods or for the long-term. In combination with climate change, unintended negative effects may have severe consequences.

Kara in a previously logged stand within the Sunrise timber sale area. Extensive upland logging has resulted in large tracks of land that are severely damaged and fragmented, and are not providing the wildlife habitat that many species rely upon. Consequently, it makes USFS plans to target the remaining mature forests within the project area that much more alarming, as the last remaining habitat in the area will be lost or degraded.

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).”

Previously logged forests within the Green Ridge timber sale in the Deschutes National Forest. Currently proposed logging in the Green Ridge sale targets many of the mature forests within the project area, including in RHCAs. This is particularly alarming given that large tracks of land in the project area have already been heavily logged, and offer little or no high quality wildlife habitat.

More on fire and forest density

We are very concerned that the USFS has and will continue to overly broadly apply flawed assumptions regarding HRV and target “desired conditions” to special habitats, important wildlife habitats and corridors, and forests that have been substantially less-impacted by the negative effects associated with past management. Essentially, the forest stands within RHCAs 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.

Martha on an old growth Engelmann spruce stump within the Sunrise timber sale area.

The conversation and understanding of historic natural conditions and what constitutes HRV continues to evolve. There are still many research gaps; the research that does exist is often from other regions or looks at extremely broad landscapes, consists of very small sample sizes, and/or is contradictory. Livestock grazing, roads, and logging pose far greater threats to water quality and RHCAs 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 RMOs is to non-commercially thin and leave all material on the ground.

Fire suppression efforts were highly unlikely to have been widespread or effective in remote areas such as those within the project area until recent decades. The 100+ year timeframe the FEA puts forth for fire exclusion is an extreme overestimate. Heyerdahl et al. (2002) note that fire suppression was not effective until recent decades:

“…active re suppression by land-management agencies because these efforts were probably not effective until the 1940s–50s when surplus military aircraft became available”.

A recent study from Bradley et al. (2016) challenges USFS assumptions about the fire risk associated with more protected areas—those area that have been less-managed or less-logged, but may still have experienced some degree of fire exclusion (such as Wilderness areas. RHCAs have also, of course, seen much more protection than upland areas). The authors state:

Mature mixed-conifer forests with natural openings along Coxie Creek in the Camp Lick timber sale.

“There is a widespread view among land managers and others that the protected status of many forestlands in the western United States corresponds with higher fire severity levels due to historical restrictions on logging that contribute to greater amounts of biomass and fuel loading in less intensively managed areas, particularly after decades of fire suppression. This view has led to recent proposals—both administrative and legislative—to reduce or eliminate forest protections and increase some forms of logging based on the belief that restrictions on active management have increased fire severity. We investigated the relationship between protected status and fire severity using the Random Forests algorithm applied to 1500 fires affecting 9.5 million hectares between 1984 and 2014 in pine (Pinus ponderosa, Pinus jeffreyi) and mixed-conifer forests of western United States, accounting for key topographic and climate variables. We found forests with higher levels of protection had lower severity values even though they are generally identified as having the highest overall levels of biomass and fuel loading. Our results suggest a need to reconsider current overly simplistic assumptions about the relationship between forest protection and fire severity in fire management and policy”

“Protected forests burn at lower severities: We found no evidence to support the prevailing forest/fire management hypothesis that higher levels of forest protections are associated with more severe fires based on the RF and linear mixed-effects modeling approaches. On the contrary, using over three decades of fire severity data from relatively frequent-fire pine and mixed-conifer forests throughout the western United States, we found support for the opposite conclusion—burn severity tended to be higher in areas with lower levels of protection status (more intense management), after accounting for topographic and climatic conditions in all three model runs. Thus, we rejected the prevailing forest management view that areas with higher protection levels burn most severely during wildfires.”

The USFS is proposing to thin (selectively log) forests within the RHCAs in the Ragged Ruby timber sale– including never-logged mixed-conifer forests providing high quality wildlife habitat. We are very concerned that logging will result in the degradation of water quality and wildlife habitat.

Odion et al. (2014) noted, based on extensive literature review of landscape-scale evidence of historical fire severity patters in Ponderosa pine and mixed conifer forests:

“There is widespread concern that fire exclusion has led to an unprecedented threat of uncharacteristically severe fires in ponderosa pine (Pinus ponderosa Dougl. ex. Laws) and mixed-conifer forests of western North America. These extensive montane forests are considered to be adapted to a low/moderate-severity fire regime that maintained stands of relatively old trees. However, there is increasing recognition from landscape-scale assessments that, prior to any significant effects of fire exclusion, fires and forest structure were more variable in these forests. Biota in these forests are also dependent on the resources made available by higher-severity fire.”

“… most forests appear to have been characterized by mixed-severity fire that included ecologically significant amounts of weather-driven, high-severity fire.”

“….paleoecological studies also support mixed-severity fire regimes for the ponderosa pine and mixed-conifer forests. These studies have found charcoal depositions from major fire episodes in ponderosa pine and interior Douglas-fir forests occurring for millennia in the northern Rockies (central Idaho: [100,101]), Klamath [102], Sierra Nevada [103], eastern Oregon Cascades [104], and southwestern USA [105–107]. These major episodes are generally interpreted as large, severe fire events [101– 107].

“The high-severity fire rotations […] do not support the hypothesis that low/moderate-severity fire regimes were predominant in the majority of ponderosa pine and mixed-conifer forests of western North America. In all the large, forest landscapes for which data covering at least 70 years exist, high-severity fire rotations ranged from about 217 to 849 years [57], and were mostly 200–500 years. This is generally less than potential tree lifespans. For combined moderate- and high-severity fires in the eastern Cascades, rotations were 115–128 years”

“The majority of the evidence did not support the low/moderate-severity fire hypothesis, but, instead, supported the alternate hypothesis that mixed-severity fire shaped these forest landscapes. This finding applies to Pacific states ponderosa pine, Jeffrey pine, and California mixed-conifer forests, as well as ponderosa pine and mixed-conifer forests in the eastern Cascades, Rockies and southwestern USA, where low/moderate-severity regimes have often been applied.”

Mature fir and hardwoods along Cougar Creek in the Camp Lick sale.

“In addition, patch sizes of high severity fire in the central Rockies have not increased [58]. Our assessment of high-severity rotations based upon existing literature also revealed a generally lower incidence of high-severity fire in these forests in recent decades…”

“Based on direct observations of fire behavior, high winds (generally 10 m open wind speeds .32–35 kilometers/hr) may subject virtually any conifer forest, regardless of fuel density, to crown fire [108]. Thus, empirical data call into question a major premise of the low/moderate-severity fire regime: that ponderosa pine and mixed-conifer forests may be completely resistant to crown fire. Fire intensity increases with winds, and at winds of .30 km/hr spot fires may be ignited over 1 km ahead of the fire front [109]. The coalescing of separate spot fires with the fire front can further energize wind-driven fire [110,111]. Severe droughts also intensify fires by reducing fuel moisture to extremely low levels, allowing crown fire under less windy conditions [108,112]. Severe drought years throughout much of western North America occurred from 1856 to 1865, 1870 to 1877 and 1890 to 1896 [113]. The extensive high-severity fires of 1910 (the Big Burn in Idaho and Montana), when large areas of drier forests burned at high severity prior to fire exclusion–much of it in ponderosa pine–illustrate how fire behavior that is rare temporally due to extreme climate and weather can dominate in space [1]. Many fire episodes in the charcoal records that exceed modern fires undoubtedly involve combinations of extreme wind, drought, and mass fire.”

“The importance of multiple lines of evidence has been stressed in determining whether mixed-severity fire regimes applied historically [122]. Our results illustrate broad evidence of mixed-severity fire regimes in ponderosa pine and mixed-conifer forests of western North America. Prior to settlement and fire exclusion, these forests historically exhibited much greater structural and successional diversity than implied by the low/moderate-severity model”

Mature mixed-conifer forest adjacent to Coxie Creek in the Camp Lick sale. The Forest Service is planning both commercial and non-commercial logging in streamside RHCA corridors along Coxie Creek.

“To improve clarity in communication, we propose that ‘‘low/ moderate-severity’’ be applied to those regimes where, as the term implies, high-severity fire is absent. These circumstances appear to be quite rare in the ponderosa pine and mixed-conifer forests of western North America. Therefore, a fire regime with a high-severity component of any amount should not be classified as low/moderate-severity”

“Our findings suggest a need to recognize mixed-severity fire regimes (Table 2) as the predominant fire regime for most of the ponderosa pine and mixed-conifer forests of western North America”

Evidence that Mixed-severity fires are still within historic range of variability in the west is also provided by the research of Pierce and Meyer (2008). They examined the size and frequency of fire-related debris flows within alluvial fans in Idaho dating back approximately 2,000 years. They found that evidence of small frequent fires historically coincided with multi-decadal climatic cycles of greater moister or drought, and that larger fires corresponded to drought cycles. Today’s high severity fires were found to be within natural range of variability.

In addition, data from the USFS National Report on Sustainable Forests (2010) shows that fire extent was much more prevalent than today across the US:

Paula with yews along Bear Creek in the Big Mosquito timber sale.

Hessberg et al.(2007) found that historically mixed-conifer forests were dominated by dense forests. Many of the mixed conifer forests in the region are closed canopy forests that are highly interwoven complex ecosystems that provide high quality habitat for numerous species such as goshawk, marten, Pileated, Lewis woodpecker, and others. Much peer-reviewed scientific research on mixed- conifer forests has suggested that thinning is likely not needed, effective, nor ecologically beneficial in moist mixed-conifer forest to prevent fire, does not mimic the complex natural fire regime (Noss et al, 2006; Lindenmayer et al. 2009) and threatens to increase fire risk (Lindenmayer et al. 2009). The moist, mixed forest type is fragile and vulnerable to the chronic negative impacts of industrial commercial logging. Mature and old-growth moist mixed conifer stands have dense, moist interiors and little wind, which inhibit the spread of wildfire (Lindenmayer et al. 2009; Morrison and Smith, 2005; Rhodes, 2007). Large fires are climatically driven and fuels reduction treatments can be insignificant to prevent fire spread under these conditions. However, the post-fire habitat is significantly degraded by the logging that happens in the name of fuels reduction prior to the fire. Noss et al. 2006 noted:

“One barrier to better use of ecological science is that individuals involved in developing fire policies and practices have tended to be specialists in fire and fuel management, not ecologists, conservation biologists, or other broadly trained scientists. It is not surprising, therefore, that current forest law does not adequately incorporate ecological considerations in its implementation and tends to promote a narrow definition of restoration that focuses almost exclusively on fuels (DellaSala et al. 2004; Schoennagel et al. 2004).”

Downed wood, pools, and hardwoods in natural openings along Bear Creek in the Big Mosquito timber sale.

“True ecological restoration requires the maintenance of ecological processes, native species composition, and forest structure at both stand and landscape scales. Because forests are highly variable over space and time, few universal principles exist for integrating insights from ecology and conservation biology into fire management policies. Nevertheless, one fundamental principle is that managed forests should not only support the desired fire regime but also viable populations of native species in functional networks of habitat (Hessberg et al. 2005). A common-sense conservation goal is to achieve forests that are low maintenance and require minimal repeated treatment. With time, in a landscape of sufficient size, the right end of the restoration continuum (Figure 4) could be reached, where natural fire maintains the system in the desired state. Indeed, wildland fire use is the cheapest and most ecologically appropriate policy for many forests. We envision a future where fire is seen by land managers and the public as the key to healthy forests, but where each forest and each patch of the forest mosaic is recognized for its individuality and managed accordingly. Above all, a guiding principle of forest management should be a precautionary approach that avoids ecological harm.”

High intensity wildfires produce unique ecological conditions compared to low intensity fires. High intensity fires are historically natural, and unique, and are integral to the biodiversity of flora and fauna in the region. Favoring lower severity fires across the region in management activities may create unnatural ecological situations that are deleterious to the wildlife, ecological processes, and biodiversity of the area. An example of the importance of post-fire areas occurring after high intensity fires include the findings of Donato et al. (2008):

“[S]evere fires are typically expected to be deleterious to forest flora and development; however, these results indicate that in systems characterized by highly variable natural disturbances (e.g. mixed-severity fire regime), native biota possess functional traits lending resilience to recurrent severe fire. Compound disturbance resulted in a distinct early seral assemblage (i.e. interval- dependent fire effects), thus contributing to the landscape heterogeneity inherent to mixed-severity fire regimes. Process-oriented ecosystem management incorporating variable natural disturbances, including ‘extreme’ events such as SI severe fires, would likely perpetuate a diversity of habitats and successional pathways on the landscape.”

Lady slippers along Bear Creek in the Big Mosquito timber sale.

Williams and Baker have published several studies suggesting that forests in eastern Oregon were considerably more dense than estimates commonly asserted by agencies (Baker 2012; Williams and Baker 2012; and Baker and Williams 2015). There studies have received criticism by some, such as Fule et al. (2014). However, Williams and Baker (2014) provided in-depth responses to these criticisms and clear rationales and defense of their methods; their response was peer-reviewed and published. Their work should not be discounted; rather, it should be considered part of the ongoing conversation and part of the scientific controversy involved in these discussions. Williams and Baker (2014) note:

“Government wildland fire policies and restoration programmes in dry western US forests are based on the hypothesis that high- severity fire was rare in historical fire regimes, modern fire severity is unnaturally high and restoration efforts should focus primarily on thinning forests to eliminate high-severity fire. Using General Land Office (GLO) survey data over large dry-forest landscapes, we showed that the proportion of historical forest affected by high-severity fire was not insignificant, fire severity has not increased as a proportion of total fire area and large areas of dense forest were present historically….. In response, Fulé et al. …suggest that our inferences are unsupported and land management based on our research could be damaging to native ecosystems. Here, we show that the concerns of FE are unfounded. Their criticism comes from misquoting W&B, mistaking W&B’s methods, misusing evidence (e.g. from Aldo Leopold) and missing substantial available evidence. We also update corroboration for the extensive historical high-severity fire shown by W&B. We suggest that restoration programmes are misdirected in seeking to reduce all high-severity fire in dry forests, given findings from spatially extensive GLO data and other sources.”

Mature mixed-conifer forest along Bear Creek in the Big Mosquito timber sale.

The authors respond to each criticism point by point (I encourage people to read it), and then include the following concluding notes:

“The best possible historical baseline for dry forests is likely to come from systematically combining all sources. Past studies that supported the past incomplete historical baseline, which suggested that low-severity fire primarily maintained historical dry forests, were often spatially limited, incomplete samples of larger landscapes. Tree-ring methods can reconstruct to fine scales back to the late 1800s, but are difficult to complete across large landscapes (but see Heyerdahl et al., 2001). Palaeoecological reconstructions can provide key temporal evidence, but are also difficult to replicate across large landscapes. GLO data, in contrast, can be used to develop reconstructions across hundred of thousands to millions of hectares. New findings from GLO data have challenged past findings about the nature of the historical baseline in dry forests, but it is the role of science to continually test past findings. Refining the historical baseline should help avoid misuse of evidence, false narratives, and misdirected restoration and provide a sound scientific foundation for predicting the effects of climatic change on wildfire and forests.”

Through the lens of species presence and evolutionary history

Giant old growth Grand fir snag with fir scars along Bear Creek in the Big Mosquito timber sale.

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).”

Old growth Grand fir along Big Creek in the Big Mosquito timber sale.

“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.

Hardwoods, downed wood, and pools in Bear Creek in the Big Mosquito timber sale.

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.

The mature fir forest on the right is part of a timber sale unit, and stands above Lick Creek in the Camp Lick sale. The young Ponderosa pine plantation on the left is typical of many areas in the sale outside of RHCAs. In other words, RHCAs contain some of the last mature mixed-conifer forests in the area, and are now being targeted for logging.

In perspective

Another view of young Ponderosa pine plantation near Lick Creek. These plantations are the result of widespread logging. They are relatively devoid of wildlife habitat, and cover a substantial portion of the project area.

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.

This forest, containing mature fir, is across the road from the pine plantation in the picture above. This mature forest is being targeted for logging in the Camp Lick sale.

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

Coral root along Sulphur Creek in the Camp Lick sale

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).

Sandhill Cranes near Big Creek in the Big Mosquito timber sale.

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.

Historical documents

Bee in the Sunrise timber sale, adjacent to a timber sale unit.

The following are the main summary points gleaned from research BMBP did on historic documents dated from the early to mid 1900s. Clumps of higher density forests are natural and documented in early historical accounts—even within Ponderosa pine forests. You can link to a more in-depth discussion on historical documents with citations, as well as historical pictures, HERE.

  • Grand fir and other non-Ponderosa pine species were historically well-represented on the landscape. Historical accounts of mixed conifer stands include descriptions of fir being the most abundant and dominant species in those forest types; Douglas fir and smaller percentages of Western larch were also described. Early seral species were not the dominant or most abundant components of these stands in the majority of historical accounts. Mixed conifer forests comprised large percentages of the forested landscapes in Eastern Oregon. In some watersheds, close to half of the forests were mixed conifer stands. Percentages vary according to historical document and geographic area.
  • Ponderosa pine forests also contained a substantial percentage of other tree species, including Grand fir. Pure Ponderosa pine stands were rare.
  • Grand fir was targeted for removal as per regional direction to foresters working on National Forests. Current estimates of Grand fir density and volume may be erroneously based on anecdotal observations that occurred after substantial proportions of fir were already removed across the landscape.
  • Extensive overgrazing during the turn of the century may have created artificially open forest stands in some areas.

Stream cobbles in Bear Creek in the Big Mosquito timber sale.

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.

Butterfly in Bear Creek in the Big Mosquito timber sale.

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.

Big Creek in the Big Mosquito timber sale.

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:

Big Creek in the Big Mosquito timber sale.

* 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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