Via March 31, 2017

Transcription

1 Via March 31, 2017 Casey Gatz, Team Leader Barlow Ranger District Mt. Hood National Forest 780 NE Court Street Dufur, Oregon Dear Casey: On behalf of the American Forest Resource Council (AFRC) and its members, thank you for the opportunity to comment on the Crystal Clear Restoration (CCR) Project. AFRC is a regional trade association whose purpose is to advocate for sustained yield timber harvests on public timberlands throughout the West to enhance forest health and resistance to fire, insects, and disease. We do this by promoting active management to attain productive public forests, protect adjoining private forests, and assure community stability. We work to improve federal and state laws, regulations, policies and decisions regarding access to and management of public forest lands and protection of all forest lands. Many of our members have their operations in communities within and adjacent to the Mt. Hood National Forest and management on these lands ultimately dictates not only the viability of their businesses, but also the economic health of the communities themselves. The CCR project is located at the southern end of both the Barlow and Hood River Ranger Districts approximately 12 miles west of Government Camp on the Skyline road. The project shares several miles of boundary on the south end of the project with the Warm Springs Reservation and to the east by privately owned lands. Past management activities, fire suppression efforts, and favorable climatic conditions have altered vegetation growth resulting in the accumulation of dead fuel, highly dense and homogenous stand conditions throughout much of the planning area. The high density of the stands contributes to mortality of trees because of competition for nutrients, water and sunlight. Densely stocked non-fire resistant trees, diseased trees, large scale tree mortality areas, and down fuel are creating continuous fuel ladders from the ground to the tree crowns. This has increased the risk of epidemic insect and disease-related morality as well as the risk of uncharacteristic wildfire behavior. The planning area is in close proximity to three Wildland Urban Interface units two of which are on the Warm Springs Reservation and one to the east near the community of Pine Grove. Both the Warm Springs WUI and Pine Grove WUI areas have Community Wildfire Protection

2 Plans developed and have identified the adjacent National Forest lands as being in Fire Regime Condition Class 2 or 3 and at high risk of uncharacteristic wildfires. AFRC supports the purpose and need for the Crystal Clear Restoration Project which is to provide forest products where there is an opportunity to restore resiliency to forested areas and reduce the risk of uncharacteristic wildfire behavior. The need for action in this project area is consistent with Forest Plan direction, which is to promote the overall sustainability of vegetative systems. Sustainability would be enhanced by increasing the resiliency of the area to withstand severe, uncharacteristic fires, or widespread occurrence of mortality from insects and disease. There is also a need to provide forest products consistent with the Northwest Forest Plan s purpose of maintaining a sustainable supply of timber and other forest products that would help maintain the stability of local and regional economies on a predictable and long-term basis. Further justification for the purpose and need can be seen by looking at the Forest Plan Land Use Allocations in the project area. The table below was created using the values found in Table 1 of the Scoping Notice. While the Scoping Notice states that there are approximately 24,000 acres in the planning area, the acreage found in Table 1 shows there are 25,578. Table 2 is reproduced further in these comments and the total area depicted in this table is 24,010. Land Use Allocation Planning Area Treatment Area Untreated Area Acres Percent Acres Percent Acres Percent of Total A7-Special Old Growth % 0 0% % A9-Key Site Riparian Area % 0 0% % B1-Wild & Scenic River Corridor % 0 0% % B2-Scenic Viewshed 9,388 37% 5,064 37% 4,324 46% B10-Deer Winter Range 3,307 13% 2,161 16% 1,146 35% C1-Timber Emphasis 10,814 42% 6,046 44% 4,768 44% B5-Woodpecker/Marten Overlay 1,568 6% 460 3% 1,108 71% Total 25,578 13,731 11,847 Percent of Total 100% 54% 46% The main land use allocation of the planning area (approximately 42% of the planning area and 44% of the treatment area) is within Timber Emphasis (C1) land use allocation. The goal for this land is to provide lumber, wood fiber, and other forest products on a fully regulated basis, based on the capability and suitability of the land. A secondary goal is to enhance other resource uses and values that are compatible with timber production. The state of Oregon s forest sector employs approximately 76,000 Oregonians, with AFRC s membership directly and indirectly constituting a large percentage of those jobs. Rural communities, such as the ones affected by this project, are particularly sensitive to the forest product sector in that more than 50% of all manufacturing jobs are in wood manufacturing. Many of our AFRC comments come not only from reading the scoping letter, but also from a field trip that was held on July 21, 2016 with USFS staff and AFRC members to look at part of the CCR project and discuss management options. Also along on the trip were members of the Warm Springs Tribe who were very interested in management activities being planned on USFS lands adjacent to their Reservation.

3 While AFRC supports this Project going forward we would like to make the following suggestions on how we believe it could be improved. 1. First, 80% of the project area is located in Matrix lands and 42% of the area is in the Timber Emphasis (C1) land base. AFRC suggests that you treat a maximum number of these acres to fireproof the forest, provide wood products to local mills and create better habitat for deer and elk. The proposed project only treats 55% of the planning area and 67% of the Matrix lands. AFRC requests that the environmental analysis fully discloses why 45% of the project area will be left untreated and shows a tabular acreage breakdown for each category of exclusion. Land Use Allocation Planning Area Treatment Area Untreated Area Acres Percent Acres Percent Acres Percent of Total Matrix 19,167 80% 12,818 97% 6,349 33% Late Successional Reserve 2,056 9% % 1,603 78% Riparian Reserves 2,769 12% 0 0% 2, % Administratively Withdrawn % 0 0% % Total 24,010 13,271 10,739 Percent of Total 100% 55% 45% During the July field trip we looked at several stands in the Matrix land allocation. Some of the stands were fire-generated and had a variety of species and age classes. Some of the stands were plantations and had been replanted with species not native to the area and needed to have some kind of stand conversion work done. Several miles of the project boundary lies adjacent to the Warm Springs Reservation and those lands need to have major fuel reduction work done to prevent the threat of wildfire moving off of USFS lands onto Tribal lands. Within the project area there are many acres of pine and oak habitat that need to be enhanced and restored. AFRC believes that this variety of landscapes will provides numerous opportunities to enhance forest resources, establish healthier stands and fire proof national forest lands while providing a fire break for adjacent land ownerships. 2. AFRC applauds the Forest Service for requesting pipeline money to help plan this project. We greatly appreciate the Forest Service s use of these dollars to accelerate project work by completing surveys and other work. 3. AFRC believes there are other opportunities for mechanical thinning to enhance resources in the Scenic Viewsheds which occupy 37% of the planning area and in the Deer and Elk Winter Range which encompasses 13% of the planning area. The goal for the viewshed is to provide attractive, visually appealing forest scenery with a wide variety of natural appearing landscape features. Since so much of the forest has been overgrown with encroaching timber and brush, creating openings and scenic vistas using thinnings would be appropriate to achieve these goals. 4. The Deer and Elk Winter Range is currently heavy to the cover component and needs more openings for forage. Again, group selection harvest, regeneration cuts, or shelterwood treatments could help open up some of the stands to provide early seral forage for these

4 animals. Regeneration harvests are allowed and expected to be used on matrix lands, and these regimes could enhance early seral forage needed for these winter range areas. 5. A number of streams and drainages are present in the planning area and AFRC strongly encourages the Forest to enter into the riparian areas to remove some of the fuel loading and cover. Recent large wildfires have shown that some of the most severe burns and resource damage have occurred in the riparian areas where the fuel loads are the highest. Creating openings in the riparian areas also allows more sunlight to enter which can enhance other vegetation and insect production for a variety of species that depend on them for food. The Northwest Forest Plan allows for work in Riparian Reserves to control stocking and acquire vegetation characteristics needed to obtain Aquatic Conservation Strategy objectives. Such work would be appropriate for this project. It has been documented by many that most of the wood that naturally recruits to streams comes from within the first 65 feet of the stream channel (Murphy and Koski, 1989; McDade et al Johnson et al. 2011). So if this is where the LWD is coming from then thinning in this region would likely accelerate its creation. We encourage the Forest to design riparian thinning treatments on this project in ways that foster positive changes to large wood supplies that would result in measurable changes. One way to accomplish this is to reduce the no-cut buffers. It has also been documented that vegetated buffers that are greater than 33 feet in width have been shown to be effective at trapping and storing sediment (Rashin et al. 2006). Partial cutting down to one or two conifers from intermittent and perennial stream channels would accelerate the recruitment of LWD with minimal impacts to sedimentation and stream temperature. We would like the Forest Service to consider these trade-offs closely in the planning for this project to improve riparian conditions on the maximum amount of these reserves. We would also like the Forest to consider including some of the following pieces of scientific research into their analysis. Much controversy surrounding any type of thinning in riparian reserves has surfaced, and we think the following information would be useful in justifying the kinds of beneficial treatments the Forest implements. Stream temperature Janisch, Jack E, Wondzell, Steven M., Ehinger, William J Headwater stream temperature: Interpreting response after logging, with and without riparian buffers, Washington, USA. Forest Ecology and Management, 270, Key points of the Janisch paper include: The amount of canopy cover retained in the riparian buffer was not a strong explanatory variable to stream temperature. Very small headwater streams may be fundamentally different than many larger streams because factors other than shade from the overstory tree canopy can have sufficient influence on stream temperature.

5 Riparian reserve gaps Warren, Dana R., Keeton, William S., Bechtold, Heather A., Rosi-Marshall, Emma J Comparing streambed light availability and canopy cover in streams with old-growth versus early-mature riparian forests in western Oregon. Aquatic Sciences 75: Key points of the Warren paper include: Canopy gaps were particularly important in creating variable light within and between reaches. Reaches with complex old growth riparian forests had frequent canopy gaps which led to greater stream light availability compared to adjacent reaches with simpler secondgrowth riparian forests. (1) Small Functional Wood Nearly all wood that falls into stream channels has the capacity to influence habitat and aquatic communities (Dolloff and Warren, 2003). Therefore, smaller woody material that enters stream channels is important to overall channel function because it can store sediment and organic material, contribute nutrients, and provide temporary pool habitat and slow-water refugia. It is important to note, however, that pools formed by smaller wood generally are not as deep or complex as those formed by large wood. In addition, small wood does not persist for long periods of time because it deteriorates quickly and is more likely to be flushed from the system (Naiman et al., 2002, Keim et al., 2002). (2) In smaller streams adjacent to previously harvested stands, field surveys (McEnroe, 2010) indicated that relatively large amounts of existing (in-stream) and potential (standing) small functional wood are present. Field surveys also indicate that the vast majority of the down wood in these areas originated from within 50 feet of the stream channel. This is consistent with findings by Minor (1997), who found that in second-growth coniferous riparian forests, percent of the total in-stream wood was recruited from within 15 meters (49 feet) of the channel. In addition, McDade et al. (1990) and Welty et al. (2002) found that 80 percent and 90 percent, respectively, of the wood loading occurred within 20 meters (66 feet) of the stream channel in coniferous forests. 6. Regarding your specific proposed actions, the Forest suggests using variable density thinnings (VDT) across all landscapes to: Create opportunities for safe and effective fire suppression Add depth to private land boundaries Compartmentalize the landscape into blocks that are spatially representative of natural disturbances Facilitate indirect fire suppression and reduce wildfire costs, and Facilitate landscape restoration that add depth to fuel breaks by using fire and other vegetative treatments. This strategy suggests thinnings in Dry Mixed Conifer stands to a desired tree density of Sq. Ft. of basal area, and in the Moist Mixed Conifer stands to a desired density range

6 from sq. ft. of basal area. AFRC suggests that these amounts of residual basal area are too high and the thinning will not be sufficient to reduce the wildfire risks across the landscape. The Forest should look at using heavier thinning regimes which will provide reduced fuel loadings for at least 20 years. AFRC also suggests that the Forest integrate regeneration harvests throughout the stands that are designated matrix. This will not only help to regenerate the unhealthy stands identified, but it will also aid in fireproofing the Forest and providing early seral forage for deer and elk species. 7. Over the past several years many Forest Service projects have been scaled back in scope to a reduced level of acres treated due to perceived effects to the northern spotted owl, including thinning treatments designed to improve owl habitat. We encourage the Mt. Hood to consider a recently published study conducted by NCASI when assessing treatment areas and their potential affects to owls. Larry L. Irwin, Dennis F. Rock, Suzanne C. Rock, Craig Loehle, Paul Van Deusen Forest ecosystem restoration: Initial response of spotted owls to partial harvesting. Among other findings, this study concluded that partial-harvest forestry, primarily commercial thinning, has the potential to improve foraging habitats for spotted owls. The treatments being proposed will likely affect northern spotted owl (NSO) habitat to some degree. Often this level of effect is quantified by the amount of forest canopy that remains following thinning treatments. AFRC has general concerns with how the Forest has been measuring these effects to NSO habitat, specifically regarding canopy cover/closure. Please see the attached document titled NSO Canopy Condition as an addendum to these comments for consideration in how the treatments on this project are designed and how this design affects the NSO. 8. AFRC is pleased that you will be utilizing system and temporary roads to facilitate treatments of the stands. Constructing and using temporary forest roads is essential if active management is desired, and we are glad that the Forest is proposing the roads that are needed to access and treat as much as the project area as possible in an economically feasible way. Proper road design and layout should pose little to no negative impacts on water quality or slope stability. Consistent and steady operation time throughout the year is important for our members not only to supply a steady source of timber for their mills, but also to keep their employees working. These two values are intangible and hard to quantify as dollar figures in a graph or table, but they are important factors to consider. The ability to yard and haul timber in the winter months will often make the difference between a project selling and not, and we hope that the Forest is working to accommodate this. 9. AFRC also encourages the Forest Service to survey stands in the Special Old Growth, Pileated Woodpecker/Pine Marten designated areas to assess if thinnings or other forest treatments would be appropriate for fire proofing the stands, improving forest health or creating more habitat.

7 10. Finally, AFRC believes that analyzing this project using an Environmental Assessment is adequate since no significant negative impacts were found to occur on the landscape during operations, rather the actions will improve forest health and benefit other resources as well as reducing the threat of catastrophic wildfire to the forest and to adjacent landowners Thank you for the opportunity to provide scoping comments on the Crystal Clear Restoration Project. I look forward to following the implementation of this project as it moves forward. Sincerely, Tom Partin AFRC Consultant P.O. Box 1934 Lake Oswego, Oregon 97035