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BARK

PO Box 12065

Portland, OR 97212

503-331-0374

December 10, 2003

1

Printed on 100% Kenaf Paper

April 22, 2005

Andrei Rykoff

595 NW Industrial Way

Estacada OR 97023

Tel. 503-630-6861.
EMAILED TO:

Dear Andrei,

We appreciate the opportunity to provide comments on the Collawash project, which are outlined below. Before going into the details of the project, I want to first comment about the process for community involvement for projects being planned using stewardship contracting authorities. I have found our Cloak stewardship collaborative meetings to be useful and productive, and I am looking forward to seeing effective restoration work conducted on the ground as a result of these collaborative efforts. As you know, until Cloak, Bark has not encountered many, if any, projects in the Clackamas District that we did not feel needed to be appealed. While we were uncomfortable with several portions of the Cloak project, we agreed to let it proceed without appeal in order to facilitate restoration activities and to test the collaborative process. During our conversations about Cloak, we also expressed concerns that the project was not launched or carried out in accordance with the generally accepted standards of collaboration.The NEPA had already been completed for the project, and we were simply handed plans to approve—with the implication that we either go along with it or be seen as obstructionists to the “collaborative” process. You acknowledged our concerns about completed NEPA being pushed forward hurriedly under the guise of collaboration, and committed to doing things differently the next time round.

However, we now find ourselves once more in a similar situation as with Cloak. The NEPA for Colllawash is well on its way toward being completed, and we are again being asked to quickly give our feedback to facilitate a NEPA deadline. The collaborative group has not had the opportunity to discuss the project nor visit it. I recognize that a planned trip was thwarted due to a landslide on 224; however, even if that trip had taken place, this would not have allowed the group an adequate opportunity to thoroughly review the sale and discuss the pros and cons. I am sympathetic to the pressures you face as a district ranger to keep to your NEPA schedules; however,the collaborative process cannot and should not be treated as a normal timber sale with the same NEPA time constraints.The entire concept is based on the idea for community involvement and input.

One simply cannot have it both ways. True Stewardship collaboration involves giving stakeholders an opportunity to discuss where good restoration projects should take place and what they should look like, allowingadequate time and opportunity to craft and/or review proposals as a group, visiting areas, and coming to consensus, if possible. If such a process is not followed, then it cannot be considered collaboration. I feel certain that Mt. Hood Supervisor Gary Larsen, who is focusing his Phd doctorate on community involvement in public lands planning, will understand this. Bark has serious concerns about the Collawash Project and we do not feel that it qualifies for stewardship contracting. However, we are interested in working with you to seek out other opportunities for stewardship contracting projects in the district that carry out restoration goals and that result in more monies being put toward restoration in the forest and helps createmore jobs, which are much needed. We are also very interested in working with you to develop a productive process for conducting suchcollaboration.

Introduction

The Collawash project as it has been outlined in the scoping letter is a poor choice for a stewardship contracting project as the impacts of conducting the project would outweigh any potential restorative value. The Collawash / Hot Springs Watershed Analysis (CHSWA)describes this watershed as “the most unstable within the Mt.HoodNational Forest.” Most of the Collawash thinning units are in areas designated as B-8 Earthflow areas, with some B-6 Special Emphasis Watersheds, B-2 Scenic Viewsheds, and others (a small amount of C timber emphasis designation) as well. A GIS layers available from the Mt. Hood Data distribution center also list most of the harvest acreage as ranging from High Risk to Moderate to High Risk of landslides (Collawash Mass Wasting Risk Map). Soil analyses list soils within the harvest area as being highly erosive and unstable.

In addition to being the most unstable watershed on Mt.HoodNational Forest, it is also a Tier 1 watershed, which means that it is prime anadromous fish habitat. The mitigation measures for many of the anadromous fish species discussed in appendix J2 of the Northwest Forest Plan suggest the removal of Tier 1 watersheds from the timber base. Given this, we feel that any actions taken need to be designed with restoration in mind, first and foremost, with both clear short and long term benefits.The Northwest Forest Plan is an ecosystem management plan that requires that biodiversity be maintained and enhanced in these special emphasis watersheds. The Collawash project should specifically address the specific manner in which the proposed thinning will both maintain and enhance biodiversity, with examples from scientific literature relevant to unstable landscapes.

There have been many lessons learned in the aftermath of the Fish Creek watershed fiasco; the lack of actual fish in Fish Creek being the prime indicator of a history of erosion, slides and mass wasting. Fan Creek showsclear signs of recent landslide activity and slides, slumps and debris are clearly present in half of the proposed units. According to the CHSWA, the Collawash project area historicallyhas steelhead in its streams. Instead of conductingcommercial logging and road building within the Collawash watershed, a restoration effort should be undertaken to create conditions that would bring back the steelhead historically present in this area.

Purpose & Need

The scoping letter states that, “There are many second-growth stands that are experiencing a slowing of growth due to overcrowding.” How do you define over-crowding? The Pacific Northwest Science Update “Restoring Complexity: 2nd Growth Forests & Habitat Diversity” states that “crowded trees are tall but skinny; little vegetation grows on the forest floor” (4). Most of the Collawash units we explored had a rich diversity of life on the forest floor. There was much Oregon grape, vine maple, and rhodendrum. In many respects, this forest doesn’t not fit into the description of an impaired plantation stand that might benefit from human intervention. Upon reading the scoping letter, I am also are unclear as to what the ultimate goal of this operation will be. Is the Forest Service’s intent, upon completion of the thinning operation, to take these units out of the timber base, or is the ultimate goal of this project to speed up tree growth for future harvest? As stated, the position and geology of these units make them extraordinarily inappropriate for commercial harvest, either now or in the future.That would not compatible with the goals of a Tier I Watershed, where protection of water quality for the sake of anadromous fish is the overriding objective. We would like to see any quantifiable data you have showing how logging and road building will help anadromous fish.

Critical Habitat for Northern Spotted Owl

Unit 10 and a portion of Unit 9 A/B are in federally designated as Critical Habitat for the Northern spotted owl. One of the FWS’ consultation duties is to ensure that other federal agency actions do not result in the destruction or adverse modification of designated critical habitat. 16 U.S.C. § 1536(a)(2). In addition, Forest Service regulations require measures for preventing the destruction or adverse modification of critical habitat. 36 CFR § 219.27 (a)(8). “Critical habitat” is defined in the ESA as “[t]he specific area within the geographic area occupied by a species . . . on which are found those physical and biological features (I) essential to the conservation of the species, and (II) that may require special management considerations or protections.” Id. § 1532(5)(A)(i). “Destruction or adverse modification” of critical habitat is defined as “direct or indirect alteration that appreciably diminishes the value of critical habitat[,] . . . includ[ing], but . . . not limited to, alterations adversely modifying any of those physical or biological features that were the basis for determining the habitat to be critical.” 50 C.F.R. § 402.02. “Conservation” is further defined as “to use and the use of all methods and procedures necessary to bring an endangered species to the point at which measures provided pursuant to this Act are no longer necessary.” 16 U.S.C. § 1533(3). These statutes and regulations provide strict requirements for habitat protection that will be violated under the proposed action. When designating critical habitat for the Northern spotted owl, the FWS recognized that critical habitat is meant to promote recovery of the species by stating that “the Act’s definition of critical habitat indicates that the purpose of critical habitat is to contribute to the species’ conservation, which by definition equates with recovery.” 57 Fed.Reg. 1822 (1992). Both the ESA and the FWS’ Northern spotted owl critical habitat rule reveal that the purpose of designating critical habitat, and thus the FWS’ role in protecting the habitat from activities that might adversely affect the habitat, is clearly for the recovery of the species. How will this project help ensure the recovery of the northern spotted owl?

Steep Slopes & High Risk of Landslides

Nearly all of the units of the Collawash thinning project are on very steep slopes and all occur within “Earth Flow Area,” with many areas which are documented as being Moderate to High Landslide Risk.

Steep Units of Concern:

Unit 423 (3)

Unit 5 (420)

Unit 6

Unit 7 (487) Sign of landslide along northern border

Unit 9B (428) B East side is very steep.

Unit 10 (429)

The proximity of large landslides near units 9, 9A & B, and 10 appears to be associated with previous logging activity, and there is a high probability for increased landslides if these sites are harvested. Dutch Creek, which is at the base of the units 9 and 10 drains directly into the CollawashRiver. Landslides into this drainage could lead to sedimentation of the river and decrease the quality of habitat available for a range of aquatic species.

Roads

With over 3,400 miles of inventoried roads within the Mt.HoodNational Forest and over 1,300 miles of inventoried roads within the Clackamas River Ranger District, it is entirely inappropriate to even consider building new roads. The Collawash watershed hosts 3.5 miles of roads per square mile; the Fan Creek subwatershed hosts an astounding 6.2 miles of roads per square mile. The impact of the existing roads should be the primary objective addressed in a revised proposal.

In order to comment more fully on this aspect of the proposal, we request the following information:

• The status of roads within the watersheds including, open road mileage, closed road mileage and roads listed in previous NEPA documents for obliteration that have not been obliterated;
• An estimation of “ghost roads,” roads not listed as open or closed but exist and are passable by 4-wheel drive motorized vehicles; and
• Current shortfalls for funding of road maintenance and obliteration within these four watersheds.

Considering that there are 6.2 miles of roads per square mile within the Fan Creek subwatershed of the Collawash watershed, there should be no additional roads in the Fan Creek subwatershed – temporary or otherwise. Evidence shows that there is no such thing as a “temporary” road in terms of hydrological impacts. Nor is the Fan Creek subwatershed the only watershed/ subwatershed that would be affected by these sales that currently endure excessive roading. To paraphrase the Northwest Forest Plan, if funds do not exist to decommission roads in key watersheds, no new roads may be built. What are your plans to decommission roads within this watershed?

Instability of 4620 Road System:

The road system 4620 is highly unstable. On the same south facing slope as new units are proposed for 10 and 9B west, there is a very large wash out in an old plantation (west of intersection bet 4620 and 6322). We feel it is irresponsible to propose logging on this same unstable terrain.6322-170 has been washed out in one spot and at its intersection with Fan Creek the culvert has blown-out. The “road” is not a functioning road. Fixing this road will be a significant expense hardly worth the cost of extracting trees, and the road will very likely just wash out again.And at what environmental cost?

culvert being bypassed on 6322-170

Instability of Road 6321

Road 6321 is a very unstable area. During a previous visit in April of 2002, Road 6321 was cracked and beginning to come apart soon before unit 424. Additionally, old roads entering unit 4 crumbled shortly after leaving that road into landslides. Although the 6321 appears to be repaired, the area clearly has a high potential for landslides.

Deer, Elk & Forage Enhancement Areas:

We are unconvinced by the deer and elk forage justification for creating clearcuts in the unstable terrain that comprises this project. According to the Watershed Analysis, the Collawash is currently already 24% early seral condition. Additionally, the Oak Grove Watershed is 27% early seral, the South Fork is 35% early seral, and the Upper Clackamas is 27% early seral. The Upper Clackamas Watershed Analysis definitively states that the logging practices (highly fragmented watershed in a highly fragmented sub-basin) of the past decades have favored deer and elk. Infact, the Collawash Watershed Analysis states that the “Range of Natural Variability for early seral stages is exceeded in all forest series” (CWHSWA, 1-4). Do we need even more logging that favors dear and elk? What about other species? Where does this deer and elk forage justification originate from? Where is the science? If you are going to continue using this claim for new forage as justification, we would like to see:

• the science showing a lack of current forage with a comparison to historical forage quantity and quality;
• numbers showing a decline in deer and elk populations belowhistoric natural levels;
• science showing a correlation between declining populations and lack of forage;
• evidence that other factors, such as high road density, are not to blame for any decline in populations, if a decline has been documented;
• what plant species you hope to grow for forage in the newly created open areas;
• what plant species deer and elk rely on for forage; and
• evidence that these plant species are currently lacking in the stands proposed for logging.

Our field visits have found that between the recent clearcuts, roadside openings, and edge habitat from clearcuts, there appears to be plenty of forage in planning area. (Thearea west of road 4620 to the north of 9 B is just one example among many of old clearcutsproviding forage).Moreover, the electrical lines running through the project area provide one large forage freeway. How many square miles of forage does the electrical line provide the planning area? Furthermore, evidence of deer is everywhere in the planning area. Every single unit of the sale is littered with deer scat. During our visit, deer and elk tracks were apparent in snow at higher elevations and profuse in the mud at lower elevations. Deer and elk trails winded through all of the units. All four teams saw signs of deer and elk while scouting their sales. I personally experienced four separateactual deer sightings within a two hour period!

Additionally, the Scoping letter and map lacks important information about where the proposed clearcuts would be placed. We are concerned about the incompatibility of such clearcuts with the unstable terrain and riparian areas and wetlands. We arealso concerned about the effect of these new clearcuts in combination with other openings such as new roads, reconstructed roads, skyline corridors, skid trails, helicopter landings (unit 6), landing piles and increased blowdown areas in the aftermath of the thinning. Many of these plantationsare well on their way toward recovery, with healthy understory and natural openings from blowdown. Forage doesn’t appear to be limited the deer and elk population (however, we look forward to getting your science related to this). This proposal would create more fragmentation where hydrologic recovery for the watershed is desperately needed.

The Proposed Units Inappropriate for Forage “Enhancement” Clearcuts

Unit 1 : There is significant sized pond (one acre) south of unit that could be adversely impacted, depending on the placement of the clearcut

Unit 2: west side is very steep, large windowthrow area near unit with a lot of downed wood

Unit 3: steep slopes, cumulative impact to stream. Landing appears to be just upslope from stream

Unit 4: steep slopes, lush understory with sword fern

Unit 6:Entire Northwest part of unit is wet. The soil is loose, wet, and sliding. Too steep and too unstable.