Bark Comments on Cascade Crest PA

Bark PO Box 12065 Portland, OR 97212

www.bark-out.org 503.331.0374

April 23, 2008

Jim Roden Clackamas Ranger District Mt. Hood National Forest 595 NW Industrial Way Estacada, OR 97023

Dear Jim,

Thank you for accepting Bark’s comments regarding the Cascade Crest Fuel Break Preliminary Assessment. Bark is a conservation group focused on the protection of Mt. Hood National Forest and surrounding public lands. For ten years, we have worked to bring about a transformation of Mt. Hood National Forest into a place where natural processes prevail, where wildlife thrives and where local communities have a social, cultural and economic investment in its restoration and preservation. We work in collaboration with the Forest Service and other agencies when possible, holding them accountable to the expectation that the public’s interest always comes before corporate profit. We take every threat to Mt. Hood’s forests as a threat to our air, our water, our way of life and our future generations.

We have serious concerns about the future of this proposal. I joined you, other Forest Service employees, and representatives from Warm Springs and Oregon Wild for a field trip to the area last year. Due to the time of year that the Preliminary Assessment (PA) has been released, I have been unable to return to the area with the information available now. With higher elevation logging projects, we ask that the Forest Service consider waiting for warmer months to release information that is integral to the public understanding and responding to agency actions.

LAND DESIGNATIONS IGNORED, LRMP EXEMPTIONS ARE EXCESSIVE As stated in the PA this project crosses into the following land allocations that emphasize a priority beyond timber harvest and management: Late-Successional Reserves Riparian Reserves Wild and Scenic River Scenic Area Bark’s comments to Cascade Crest Fuel Break Preliminary Assessment 1

Unroaded Recreation Area Developed Recreation Area (Campgrounds) Inventoried Roadless Area Elk Summer Range In addition this project overlaps with the Nationally Registered Pacific Crest Trail and is adjacent to Congressionally proposed wilderness designation for the SiSi Butte area. To be in compliance with the National Environmental Policy Act (NEPA) this list of land allocations warrants a greater range of alternatives than are provided in the PA. As seen by the overwhelming response to Oregon Wild’s email campaign, regardless of the discrepancies pointed out in the PA, the public does not support logging in this area. Rather than pick apart an effort to inform the public about actions taking place in a popular recreation area, we expect the Forest Service to provide an alternative to compare that addresses the valid concerns stated.

In addition the lack of compliance with NEPA’s range of alternatives to consider, the lists of Land Resource Management Plan (LRMP) exemptions are entirely excessive. The PA routinely excuses this project from Standards and Guidelines under the Northwest Forest Plan and expanded under the LRMP, claiming that the Cascade Crest Fuel Break is not a traditional timber sale and thus does not fit into the intentions of the Standards and Guidelines. This is a farcical interpretation of the Northwest Forest Plan. The Northwest Forest Plan was a mandate to create plans that incorporate an ecosystem management approach. (NWFP ROD 5) Fire and pathogens are integral parts to ecosystem balance and do not pose justified exemptions from the environmental impact of an agency action.

THIS PROJECT IS NOT APPROPRIATE FOR STEWARDSHIP CONTRACTING The Forest Service received a request by The Tribal Council of the Confederated Tribes of the Warm Springs Reservation of Oregon (Warm Springs) in April of 2007 under the Tribal Forest Protection Act of 2004. The PA states that Warm Springs and the Forest Service would be entering into a stewardship agreement and the proposal would be implemented as a collaborative project. (PA 1) Please see below our response to the use of the Tribal Forest Protection Act.

In our meeting on the project site last fall, the idea was presented of including the Clackamas Stewardship Partners, an established collaborative group of which Bark is a member. Bark does not support the use of stewardship contracting through Warm Springs or the Clackamas Stewardship Partners for the Cascade Crest Fuel Break. As active groups and individuals work with the Forest Service to establish a working model for collaborative groups and stewardship contracting on national forests, projects such as the Cascade Crest Fuel Break greatly jeopardize the trust the public has with the agency. Using stewardship contracting to get blank check sign-off on projects that override major land designations, exempt large lists of Standards and

Bark’s comments to Cascade Crest Fuel Break Preliminary Assessment 2

Guidelines agreed to under the Northwest Forest Plan and have major landscape impacts on soil, wildlife habitat and aquatic bodies is unacceptable.

Should the Forest Service and Warm Springs move forward on stewardship contracting for this project, we expect to see full disclosure regarding any expenditure of returned receipts or use of goods-for-services. The PA states, “The intent is to use stewardship contracts or stewardship agreements to meet the purpose and need.” (PA 7) The PA does not make the argument that restoration work is a part of the purpose and need. While the PA does include, “It is expected that the cost of fuel break construction would be greater than the value of the removed material” (PA 115) and the continued maintenance of the fuel break would be covered by Hotshot crews seizing the opportunity for “on-the-job training and physical conditioning” (PA 10), we do not feel the dots have not been connected.

THE REMOVAL OF BIOMASS FROM PUBLIC LANDS FOR ENERGY CONSUMPTION IS NOT ACCEPTABLE “The removal of biomass would be encouraged where feasible.” (PA 8) “Cost would be partially offset by value of removed biomass.” (PA 16)

Warm Springs is currently in a Memorandum of Understanding that half of the needed woody debris (biomass) for their energy plant would originate from national forest lands within 75 miles of the plant. Although it was not explicitly mentioned in the PA, we understand from conversations with the Forest Service and the tribes that this project would be fulfilling this commitment in part. In addition, we have heard from Forest Service personnel that the growing market for woody debris biomass presents an opportunity for the future of restoration and the commercial timber sale program.

The removal of biomass for commercial profit is not restoration. Additionally, the future of biomass removal as a resource for domestic energy supply will quickly become a target of controversy without thorough analysis of appropriate levels of extraction and supply BEFORE projects are implemented. In the Cascade Crest Fuel Break PA, the assessment on Climate Change includes “utilizing biomass removal in the construction of the fuel break to generate electricity would result in reduced reliance on fossil fuels to generate electricity” as a mitigating indirect cumulative effect of this project. Citing a lecture program on the internet as reference for this claim rather than pick from the plethora of academic literature being produced on this topic, the effect of additional trucks to transport biomass material, running on fossil fuels, is not factored into this potential mitigation opportunity. Bark is not denying the possibility that biomass as an energy source is a viable, domestic option to our current energy crisis. However, if such excessive exemptions from the current Land Resource Management Plan are needed to protect both tribal and national forest future timber harvests, but have not warranted the revision of this outdated document, we should

Bark’s comments to Cascade Crest Fuel Break Preliminary Assessment 3

consider biomass as the incentive to go back to the drawing board for how to prioritize our public land resources.

TRIBAL FOREST PROTECTION ACT DOES NOT MANDATE THE FOREST SERVICE TO LOG We understand that this is one of the initial projects, nationally, to be conceived under the Tribal Forests Protection Act since its inception in 2005. Without much precedence to see the effects of this act or how it will be used by the tribes and the agencies, Bark hopes to convey the flexibility that agencies have under this bill in determining whether a project moves forward. By enacting the environmental review process with this assessment, the Forest Service has complied with the Act. Should environmental impacts be determined to be too great, denying the request is also in compliance with the Act. Bark does not believe that this Preliminary Assessment has even nearly justified the risk to habitat, water quality and recreation priorities in this area to create a fuel break. Based on the inadequate assessment that has been done so far and our own site-specific concerns from visits to the area, we feel the environmental risks of extending the artificial break in the forest that already exists in the form of a road is not only unnecessary, but outside of the legal flexibility of public lands guidelines.

A FUELBREAK ALREADY EXISTS IN THE FORM OF A ROAD This project is not the creation of a fuelbreak. Roads 4220 and 4230, as well as other logging roads left from past harvest activity already act as fuelbreaks. This is more accurately a widening of existing fuelbreak and we question its efficacy. Known fuel breaks or treated areas are useful for fire crews when deciding where to establish bases and/or lines of attack, and it is possible that using a fuel break such as Cascade Crest could allow a crew to light backing fires toward an oncoming wildfire to prevent its spread. However, this area has built up fuels and is known to be naturally prone to high-intensity fires. (PA 20) Using backfire in an area that has build-up of ground and ladder fuels would not be effective. Major wildfires, in unfavorable conditions (which is most of the time), will send out "leaders", which are essentially giant fireballs of burning woody material, into the air anywhere from several meters to a couple of miles ahead of a fire, which renders fuel breaks useless, especially if you cannot light a backing fire to meet the oncoming wildfire. A fire of the intensity predicted by the PA will likely create those conditions and the proposed width of the fuel break and debris removal will not be sufficient.

SPECIFIC CONCERNS AND QUESTIONS FROM THE PRELIMINARY ASSESSMENT RECREATION The PA lists other impacts to the current recreation experience in the Olallie Lake area, as if to show that the feeling of back country wildlands is much more impacted than visitors realize. This is not how cumulative impacts are determined. The environmental review process is not intended to justify a project. These other uses of Bark’s comments to Cascade Crest Fuel Break Preliminary Assessment 4

the forest are conflict of use with the priority to have a scenic, recreation area and should be taken into consideration and comparison to the No Action alternative, not a justification for why more impact to the recreation experience is negligible. The popularity of the area is well-established and the presence of past and future wildfire does not appear to have actually negatively affected recreation interest.

Bark is encouraged to see the inclusion of current planning around off-highway vehicles (OHV) in the recreation assessment. Although the OHV trails are still in the early stages of environmental review, we know that the problem of lawless riding exists and can be exacerbated by logging projects and opening of forest floor. With consideration of likely high-intensity fire and the increased potential of sparks from OHV engines, this seems like an inadequate consideration of the impacts caused by this user-conflict. For instance, if debris is removed from the forest floor at an increased level than usual, this would create an opportunity for OHVs to enter the forest more easily. This has been a well-documented consequence of logging near to popular motorized recreation areas and can be expected to increase with the new Peavine area implemented.

LOSS OF SNAGS AND OLD-GROWTH WILL PERMANENTLY EFFECT HABITAT Bark does not support the removal of snags and loss of habitat at the level considered in the PA. The assessment repeatedly describes the need to remove snags and late- successional forest, in perpetuity. “Most snags would be cut down during creation of the fuel break.” (PA 82) The effect determination for the proposed action on northern spotted owl critical habitat is “May Affect, Likely to Adversely Affect.” (PA 75) Elk summer habitat would be “downgraded to non-habitat.” (PA 87) And yet, the PA pushes on with the needs of a fuel break.

SOIL, EROSION AND WINDTHROW ANALYSIS The soil structure is already significantly thin in this area. In Section 4.6.4.2 the Direct and Indirect Effects are summed up well; “When a forest floor is exposed through timber removal or wildfire, there is a sharp increase in solar radiation and an accompanying reduction of transpiration....Timber harvest activities can reduce ectomychorrhizal populations which are important for nutrient and water uptake by plants and root pathogen resistance.” (PA 99) In the analysis for Alternative B (the Proposed Action), the PA claims that “additional disturbances would occur from firefighting operations.” (PA 100) So while Alternative A (No Action) would have a diverse range of impact due to anticipated wildfire (PA 99), Alternative B would have “disturbance of duff layer” from timber harvest and fuel treatment, then effects from the less intense “4-ft” fire and then continued impact from firefighting options. Considering the high likelihood of windthrow in current shallow soil conditions and the erosion rates from existing fire patterns, how could the soil ever recover and begin to promote a naturally contained forest fire?

Bark’s comments to Cascade Crest Fuel Break Preliminary Assessment 5

CLIMATE CHANGE WILL NOT FIT ON THIS CHECKLIST We appreciate the Forest Service beginning to seriously incorporate climate change into the environmental assessments. However, the issue of climate change will never be an easily quantifiable issue. Challenges with climate change bring into question entirely new ways of finding solutions that go far beyond the scope of any project. While environmental laws such as the Clean Air Act, offer the beginning steps for standards (for instance, using firewood to heat homes is an air quality hazard that is actively being mitigated or banned entirely in many parts of Oregon as part of Oregon's regional haze plan, which may challenge some of the goals under the Northwest Forest Plan and the LRMP), Bark uses this opportunity to once again remind the Forest Service that planning projects under a Land Resource Management Plan that is outdated and legally mandated to be revised will not stand. Wildfire is a significant contributor to annual carbon emissions, but deforestation, industry, and automobiles are a far greater source and a more appropriate focus for carbon emissions reduction. Mt. Hood National Forest is not only one of this region’s most important water sources, but is also quickly becoming our most important carbon sequestration source, and should be managed as such.

In conclusion, we do not support the Forest Service moving forward with this project request. The impact on a popular recreation, the removal of biomass without environmental review and the loss of snag and old-growth habitat are major concerns for Bark.

We also submit support for all concerns and claims sent in by Doug Heiken with Oregon Wild.