March 19th, 2020 BARK PO Box 12065 Portland, OR 97212 www.bark-out.org 503-331-0374

Amber Sprinkle Mt. Hood National Forest Hood River Ranger District 6780 Highway 35 Mt. Hood-Parkdale, OR 97041

RE: Waucoma Huckleberry Enhancement Project PA comments

Dear Amber, As you are aware, Bark’s mission is to bring about a transformation of public lands on and around Mt. Hood 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. Bark has over 25,000 supporters1 who use the public land forests surrounding Mt. Hood, including the areas within the Waucoma project area, for a wide range of uses including, but not limited to: clean water, hiking, nature study, non-timber forest product collection, spiritual renewal, recreation, and more. We submit these scoping comments on behalf of our supporters. We request your active response to these substantive comments, including the scientific and site-specific information herein, to draft a better restoration project for the West Fork Hood River watershed.

Contents ISSUES REGARDING “ACTIVE MANAGEMENT” OF RIPARIAN RESERVES FOR FURTHER REVIEW ...... 2 To enhance water quality and aquatic diversity ...... 3 “Pitfalls” in river restoration ...... 3 The West Fork Hood River watershed ...... 4 Effective methods of complying with the ACS ...... 4

1 Supporters in this case is defined as significant donors and petition-signees which Bark has identified as being active users of Mount Hood National Forest. 1 – Bark’s PA comments on “Waucoma Huckleberry Enhancement Project”

ISSUES REGARDING IMPACTS TO EXISTING AND FUTURE DEAD WOOD FOR FURTHER REVIEW ...... 6 Snags ...... 6 MATURE/FIRE ORIGINATED STANDS ...... 8 The West Fork Hood River WA ...... 8 Mature Stands proposed for logging ...... 9 Units 2, 3 and 4 ...... 10 SHELTERWOOD/REGENERATION HARVEST ...... 12 The overall impact of canopy removal as proposed ...... 13 Units directly above N. Fork Green Point Creek ...... 14 Reduced shelterwood alternative ...... 15 Forest Plan Exceptions ...... 15 SYSTEM ROADS ...... 15 TEMPORARY ROADS ...... 17 DETRIMENTAL SOIL CONDITIONS IN B3 & B12 ...... 19 HUCKLEBERRY ENHANCEMENT ...... 20 Understory Management ...... 21 ISSUES REGARDING RECREATION IN WAUCOMA FOR FURTHER REVIEW ...... 23 ISSUES REGARDING CLIMATE CHANGE ANALYSIS FOR FURTHER REVIEW ...... 24 Impact of Management on Ecosystems Experiencing Climate Change ...... 30 CONCLUSION ...... 31 Highlighted Requests ...... 31

ISSUES REGARDING “ACTIVE MANAGEMENT” OF RIPARIAN RESERVES FOR FURTHER REVIEW

There are approximately 129 acres of treatments proposed within Riparian Reserves between sapling thinning, VDT, and intermediate thinning. The stated primary goals of the Riparian Reserve treatments in Waucoma include improving understory species composition, enhancing structural diversity, and improving future quality of downed wood and in-stream large wood.

In Scoping comments, Bark pointed out that aquatic recovery in the West Fork Hood River watershed is currently degraded because of obstructed passage for 2 – Bark’s PA comments on “Waucoma Huckleberry Enhancement Project”

aquatic organisms, a deficit of large woody debris, an over-sized and deteriorating road network, and unauthorized user access.

To enhance water quality and aquatic diversity Bark recommended including proposals to replace and/or remove culverts which bar fish and aquatic organism passage and/or cause other ecological detriment; in addition to adding large woody debris in streams where it is lacking due to past management.

Since Scoping, the FS sent out a paper to the Stew Crew titled Process-based Principles for Restoring River Ecosystems2 which outlines a tiered way of thinking leading to reestablishing normative rates and magnitudes of physical, chemical, and biological processes in riparian ecosystems. Authors of this paper state that to in order to follow these principals, (1) restoration actions should address the root causes of degradation, (2) actions must be consistent with the physical and biological potential of the site, (3) actions should be at a scale commensurate with environmental problems, and (4) actions should have clearly articulated expected outcomes for ecosystem dynamics.

“Pitfalls” in river restoration, as stated by the authors include “creating habitat types that are outside of a site’s natural potential (opposite of principal #2 above), attempting to build static habitats in dynamic environments, or constructing habitat features that are ultimately overwhelmed by unconsidered system drivers.”

The authors repeatedly emphasize that land managers must be willing address the causes of degradation, rather than the symptoms of it. They define classes of actions efforts often used in riparian restoration efforts as “Full restoration”, “Partial restoration”, and “Habitat creation”. All these actions are valid under process-based principals, but habitat creation should be a last resort since it is rarely self-sustaining. Bark believes this is an excellent framework for the FS to use while planning and presenting actions within environmental analyses, and we encourage the FS to use this template.

The FS anticipates aquatic and riparian communities to potentially benefit from mechanical thinning for “huckleberry enhancement” (if it had to be placed in a category, our understanding would be that this action would be somewhere between “Partial restoration” and “Habitat creation” depending on the location, reach-scale, as well as a side-benefit). As you know, Riparian Reserves (RRs) are part of the NWFP’s Aquatic Conservation Strategy (ACS). RRs generally encompass and parallel aspects of a watershed, streams and waterbodies, where riparian

2 Timothy J. Beechie, David A. Sear, Julian D. Olden, George R. Pess, John M. Buffington, Hamish Moir, Philip Roni, Michael M. Pollock, Process-based Principles for Restoring River Ecosystems, BioScience, Volume 60, Issue 3, March 2010, Pages 209–222, https://doi.org/10.1525/bio.2010.60.3.7 3 – Bark’s PA comments on “Waucoma Huckleberry Enhancement Project”

dependent resources receive primary management emphasis; specific standards and guidelines apply. This system was established to “restore and maintain the ecological health of watersheds and aquatic ecosystems.”3

The West Fork Hood River watershed supports fall Chinook, summer and winter steelhead, coho, Pacific Lamprey, cutthroat trout, bull trout, rainbow trout, and mountain whitefish. Several of these species are listed under the Endangered Species Act. In the WFHR Watershed Assessment, the FS identifies fine sediment generated by roads and management-related debris flows as the greatest risk to these types of improvements, particularly since West Fork watershed is generally unstable and prone to mass wasting. Effective methods of complying with the ACS As we brought up in Scoping comments, maintaining and/or decommissioning roads and completing instream work are effective methods of complying with the ACS. This action is also defined as a “Watershed scale” restoration action under the Process-based Principles for Restoring River Ecosystems. However, in the Waucoma Project the FS has overemphasized the ecological need of logging and roadbuilding in RRs, claiming they are “overstocked” with relatively uniform trees with low levels of diversity which lack mature and late-successional stand conditions. Based on Bark’s field experience, this is an oversimplification of local conditions, especially regarding older plantations and “fire originated” stands that are either in or moving towards a healthy, functioning condition, and meeting the ACS objectives. In stands like these, a logging prescription which removes existing canopy, decreases structural complexity, and adversely impacts soils would not necessarily comply with the ACS.

In many cases, ACSOs could be better met through a “no action” alternative. For example, many RRs in the Hood River Ranger District are currently below the Forest Plan standards for woody debris in streams (which correlates to ACSO #3 and #8). Given that much of this area is entering the stem-exclusion phase, where trees naturally begin to die and structural diversity increases, No-Action would lead to more available LWD. However, the FS typically characterizes the “no-action alternative” as though it is stuck in time and unchanging in condition (a perspective reminiscent of the pitfall above assuming static habitats in dynamic environments). The Proposed Action, which artificially stimulates change, does not fully acknowledge that no-action could effectively allow natural processes to prevail on sometimes slower but more natural timelines.

3 Klamath Siskiyou Wildlands Ctr. v. U.S. Forest Serv., 373 F. Supp. 2d 1069, 1092 (E.D. Cal. 2004). 4 – Bark’s PA comments on “Waucoma Huckleberry Enhancement Project”

Several sources point to passive management as an appropriate approach to achieve ACSOs in RRs. Pollock and Beechie4 showed that the few species that utilize large diameter live trees in riparian ecosystems exclusively may benefit from heavy thinning, whereas the numerous species that utilize large diameter dead wood can benefit most from light or no thinning: “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 vertebrates.”

According to the Waucoma PA, “A decrease in potential large wood resulting from silviculture treatments in Riparian Reserves is possible but the units where treatment is occurring are already impaired and will not provide quality downed wood for many decades.” To this point, Spies et al.5 concluded that thinning produces unusually low-stem-density forests and causes long–term depletion of snag and wood recruitment that is likely detrimental in most RRs. According to this work, commercial thinning will generally produce fewer large dead trees across a range of sizes over the several decades following thinning and the life-time of the stand relative to equivalent stands that are not thinned. Generally, recruitment of dead wood to streams would likewise be reduced in conventionally thinned stands relative to un-thinned stands. How does this comply with the ACSOs?

As the FS has acknowledged, large wood plays an important role in stream ecosystems as it modifies both hydrologic sediment and nutrient transport by slowing, storing and redirecting stream water sediments and particulate organic matter. Additionally, large dead wood enhances stream habitat for fish, other vertebrates, and invertebrates by providing physical cover, enhancing habitat features such as pools, backwaters and secondary channels, and creating flow velocity refugia. Having adequate levels of large woody debris is critical for healthy streams in forested ecosystems.

Beechie also modeled wood recruitment on small streams and found that thinning in riparian stands did result accelerate the availability of live trees of pool-forming size over time if the original treated stand was of small diameter. However, the paper also showed that thinning of riparian forests did not increase the abundance of pool-forming wood (i.e. larger diameter green trees) if the riparian area already

4 Pollock, Michael M. and Timothy J. Beechie, 2014. Does Riparian Forest Restoration Thinning Enhance Biodiversity? The Ecological Importance of Large Wood. Journal of the American Water Resources Association (JAWRA) 50(3): 543-559. DOI: 10.1111/jawr.12206 5 Spies, T., M. Pollock, G. Reeves, and T. Beechie. 2013. Effects of riparian thinning on wood recruitment: A scientific synthesis. Science Review Team, Wood Recruitment Subgroup, Forestry Sciences Laboratory, Corvallis, OR, and Northwest Fisheries Science Center, Seattle, WA. 28 January 2013. 46pp. http://www.mediate.com/DSConsulting/docs/FINAL%20wood%20recruitment%20document.p df 5 – Bark’s PA comments on “Waucoma Huckleberry Enhancement Project”

contained trees large enough to form pools. If larger, pool forming trees are already present in Waucoma treatment units, thinning reduces their density and availability, reducing the overall population of potential inputs to streams.6 Further on this point, the Waucoma PA states that “Riparian silviculture has the greatest potential to affect large wood recruitment potential compared to any other proposed project element. Thinning removes standing wood volume from the recruitment zone and reduces exclusion-phase mortality, which can contribute wood to the stream.”

While some aquatic degradation, standing alone, does not constitute ACS noncompliance, the FS must avoid degradation that leads to the non-attainment of ACS objectives at both the short-term, localized scale and the long-term, watershed scale.7 To make a finding that the logging “meets” or “does not prevent attainment” of the ACSOs, the NWFP requires the FS to describe the existing conditions of the watersheds within the project area, the natural variability of important physical and biological components, and explain how the proposed logging would maintain or restore the conditions of the watershed.8 This has not been done. In the Draft Decision, the agency should drop any areas of units within RRs that already contain complex forest structure and functioning riparian habitat, provide a summary of all current stand conditions in remaining proposed units in RRs, provide justifiable, ecological rationale for active management, and predicted short and long-term results of this treatment.

ISSUES REGARDING IMPACTS TO EXISTING AND FUTURE DEAD WOOD FOR FURTHER REVIEW

Bark addressed the current condition of snag habitat in the West Fork Hood River watershed in Scoping comments, along with recommendations of how to address it. We provide further thoughts on this topic here.

Snags When managing for snag habitat in the Waucoma project area, the Forest Service should always consider that artificially created snag habitat varies substantially

6 Beechie, T.J., G. Pess, P. Kennard, R.E. Bilby, and S. Bolton. 2000. Modeling Recovery Rates and Pathways for Woody Debris Recruitment in Northwestern Washington Streams. North American Journal of Fisheries Management 20:436–452. 7 Pac. Coast Fed’n of Fishermen’s Ass’ns v. NMFS, 265 F.3d 1028, 1037 (9th Cir. 2001). 8 Klamath Siskiyou Wildlands v Forest Service, 373 F. Supp. 2d. 6 – Bark’s PA comments on “Waucoma Huckleberry Enhancement Project”

from naturally created snags in the type, distribution, and amount of decay which occurs.9 Retention of existing, naturally formed snags should always be prioritized above artificially created snags (topping, girdling, etc.).

Modeling by Pabst et. al10 (figure below) has shown no difference in the cumulative number of large snags (>19.7” dbh) in un-thinned vs. thinned + snag creation treatments for the first 35 years. But after 100 years, large snags accumulated at a much higher rate in the un-thinned stands. Snags created by artificially killing trees from the thinned understory in Prescription C were small diameter and did not contribute to the large snag totals over time.

50

Control (no thinning) A: thinned 3 times 40 B: thinned 2 times C: thinned 1 time

19.7" dbh

> 30

20

10

Cumulative snags/acre 0 0 20 40 60 80 100 120 140 160 180 200 Simulation years

Because there are significantly less snags (as compared to historic numbers) in the planning area and too few to meet Forest Plan standards in some areas, it is important that the Forest Service buffer and protect all legacy snags where they

9 A.M. Barry, J.C. Hagar,J.W. Rivers, 2017. Long-term dynamics and characteristics of snags created for wildlife habitat. Forest Ecology and Management. Volume 403, 1 November 2017, Pages 145-151. https://doi.org/10.1016/j.foreco.2017.07.049

10 Pabst, R.J., T.A. Spies, M.N. Goslin, and S.L. Garman. 2003. Development of late-successional forest structures after thinning young stands: A simulation study for the Oregon Coast Range. Poster presented at 2003 meeting of the North American Forest Ecology Workshop, Corvallis, OR. Available in PDF document. 7 – Bark’s PA comments on “Waucoma Huckleberry Enhancement Project”

exist, and secondarily, proactively create snags to, at a minimum, meet Forest Plan standards. However, the draft Project Design Criteria create a large loophole that would allow for felling legacy snags. The PDC state “All snags would be retained where safety permits. If snags must be cut for safety reasons they would be left on site.” While we recognize that the Forest Service needs to protect logger safety, it has options beyond felling danger snags. OSHA Regulations specifically state that if a danger tree [including lodged trees and snags] is not felled or removed, it shall be marked and no work shall be conducted within two tree lengths of the danger tree unless the employer demonstrates that a shorter distance will not create a hazard for an employee. 29 C.F.R. § 1910.266(h)(1)(vi). In short, the Forest Service has the option to buffer danger snags, not cut them. In order to meet the Forest Plan standards for snag retention, please exercise this option and change the Waucoma PDC to state ““All legacy snags would be retained by creating adequate safety buffers, as needed.”

MATURE/FIRE ORIGINATED STANDS

According to the Waucoma Silviculture report (Table 7), the project area contains far below historic amounts of “Late Seral Multistory” stand structure. Currently 2% of the area is within this structure class compared to 40% historically. The best way for the FS to ensure that there is an overall increase of late seral/old growth forest habitat in the future is to let mature forests grow with little to no management. Furthermore, there is new urgency to protect mature forests to store carbon in order mitigate climate change, and to provide additional habitat as soon as possible to increase the chances that the spotted owls can co-exist with the invading barred owl. We provided rationale for keeping mature and old forest intact within our Scoping comments.

The West Fork Hood River WA states that historically in the watershed “major disturbances were rare and stands often reached great age…” WA at 4-4. Figure 4.4: West Fork of Hood River Watershed Vegetation Pattern (Early 1900’s) shows mostly mature stand conditions in Waucoma area (which is a drastically different situation than now). The Watershed Analysis recommends: “Due to its scarcity (19% of the watershed) and location, do not harvest any existing Late Seral Multistory stands until objectives and management strategies have been developed.” WA at 6-6.

8 – Bark’s PA comments on “Waucoma Huckleberry Enhancement Project”

Mature Stands proposed for logging The Waucoma project currently includes 1,328 acres of logging in stands over 80 years old, and 64 acres of logging in stands over 200 years old. Given that the amount of old forest habitat in the project area is so sorely lacking, entering these stands without a clear conditions-based rationale does not appear to be supported by the agency’s own analysis or scientific literature. Added to this, some older units Bark has field-checked contain seemingly appropriate structure for their age and elevation, and do not appear to have the amount of huckleberry understory to make altering this current condition worth the adverse impacts. For the reasons stated above, Bark requests that the FS drop stands over 200 years old from the Proposed Action.

Unit 4 - view of late seral stand character from road 2821 at 45.65052, -121.71700

9 – Bark’s PA comments on “Waucoma Huckleberry Enhancement Project”

Unit 3 – old stand conditions with mountain hemlock and true fir dominating overstory

Units 2, 3 and 4 contain old subalpine stands with interspersed talus, with no sign of past management. Trail #413/413B runs through these units, and unit 2 also includes dispersed campsites accessed by the trails. Subalpine fir and mountain hemlock are common at this elevation (~5,000 feet), and forested stands contain diverse vertical and horizontal structure, along with being riddled with large rock talus areas where no conifers are present. This area experiences deep snow pack, consistently low winter temperatures, high winds, and rocky soils. Because of these current conditions, these stands have a diminished growth rate compared with stands at lower elevations and therefore would not respond well to logging. These units should be dropped from the Proposed Action since they are located on terrain not suitable for logging and conflict with other values present there (recreation, subalpine habitat), in addition to not likely being economically viable (the area is sparsely vegetated where talus is present).

10 – Bark’s PA comments on “Waucoma Huckleberry Enhancement Project”

Unit 2 - talus at Mt. Defiance, representative of what’s scattered about the unit as well

Unit 2 – structure and species showing subalpine, harsh conditions, slow growth

11 – Bark’s PA comments on “Waucoma Huckleberry Enhancement Project”

Unit 3 – talus scattered within unit

SHELTERWOOD/REGENERATION HARVEST The Waucoma proposed action includes 550 acres of “shelterwood”, or 15% retention logging. By the time these stands would be logged, 484 acres of them will be over 80 years old, according to the Waucoma unit table provided by the FS. To understand the impacts of this component of the proposal, one must consider the historic context, and this prescription’s contribution to the impacts of this project as a whole.

Beyond the project area, at a watershed scale, the West Fork of Hood River Watershed is comprised of approximately 36% early-seral stands, 36% mid-seral stands, and 21% late-seral stands. According to Table 7 of the Waucoma silviculture report, the project area itself is already above its historic amount of stand initiation/early seral stand type. This is concerning given that so many acres of shelterwood logging are proposed in older stands – stands which are on their way to contributing to future late seral which the project area is sorely lacking compared to historic conditions (2% compared to historic 40%).

12 – Bark’s PA comments on “Waucoma Huckleberry Enhancement Project”

Unit 87, a proposed sapling thin, was recently clearcut as part of fire suppression for the Eagle Creek fire. It is unclear whether recently logged stands like this were factored into the FS’s calculation of WIAs for the Waucoma project area.

The overall impact of canopy removal as proposed would have a significant footprint on the project area. Treatment acres proposed for this project represent approximately 35% of the total project area. Much of these areas would be taken down to an average between 30-15% canopy cover. As a result, the watershed impact areas (WIAs) on Forest Service lands in the watershed would increase from 23 to 33%. Recovery of these stands to become fully effective and functional hydrologically would be expected in about 20-40 years.

Specifically, proposed “shelterwood harvest” is known to increase the relative amount of Watershed Impact Areas (WIAs)11 in the project area by 5%. Mt. Hood National Forest has a Forestwide standard (FW-064) which reads that “(w)atershed impact areas at the subbasin or area analysis level (i.e. typically 3000 to 6000 acres) should not exceed 35 percent.” Again, in the analysis area the increase of WIAs on USFS land would increase to 33% and would then increase the WIAs on the entire LWFHR subwatershed to 35%, the FS’s stated threshold.

Forestry program staff at Confederated Tribes of the Warm Springs presented findings to the Stew Crew March meeting that in their experience, Shelterwood harvest often results in a lag of increased huckleberry cover and fruiting. At the same time, the Waucoma hydrology report says of these stands: “Within an

11 For the Waucoma analysis, Watershed Impact Areas (WIA) were defined to be previously disturbed forested areas where the average tree diameter was estimated to be less than 8 inches, and the canopy cover less than 70 percent. The area existing as a road surface was also considered in WIA estimates. Forest Plan S&G FW-064 indicates that WIAs at the analysis-area level should not exceed 35 percent. 13 – Bark’s PA comments on “Waucoma Huckleberry Enhancement Project”

estimated 20 to 40 years they would become hydrologically mature, or ‘recovered’, and no longer considered to be a WIA.”12 Given that more heavily logged stands may take longer to produce huckleberries, and that the agency is simultaneously relying on hydrological recovery of these stands in a short time frame to avoid a significant impact, we see the hydrological findings to be inconsistent with the rationale for achieving the Purpose and Need in shelterwood units. Please resolve this inconsistency in the final EA. Units directly above N. Fork Green Point Creek The large area (over 200 acres) of proposed shelterwood (units 1, 68, 70, 57, 121) directly above North Fork Green Point Creek is especially concerning, given the steep slopes on south facing section of the drainage, the risk of blowdown occurring from east-west winds, and the fact that some of of these acres are older stands (unit 57 = 101 years; unit 70 = 87 years).

Regarding the contiguous area proposed for shelterwood above N. Fork Green Point Creek, the agency has stated that “(c)ontiguous treatments of this type would be limited to no more than 60 acres and would be separated by a blocks of land that are not classed as created openings and that contain one or more logical harvest units. (Forest Plan p. Four – 89)”. It is not clear however how these treatments will be laid out and what size/shape the “blocks of land not classed as created openings” will be. Some of the stands in question were surveyed by Bark staff & volunteers who found previously thinned stands with evenly spaced overstory trees, and a very small amount of down wood. There was not the presence of big huckleberry in the understory that was present in some of the flatter units, and even if there was this presence, berries would not be accessible to pickers or much terrestrial wildlife given the steep slopes and lack of road access. If we had to choose a type of active management for these stands (not all of which need active management), we would recommend a light thin on the downward slope off the 409B trail, in order to create slightly more spatial heterogeneity and put some wood on the ground. For this we recommend moving these south-facing stands out of shelterwood and into a light thin prescription. Along with this change, and to better respond to the need to increase/maintain late seral habitat across the planning area, we recommend dropping shelterwood units over 80 years old that would move naturally toward late seral structure if left to grow.

12Waucoma Project Hydrology Resource Report at p. 23. For a Watershed Impact Area (WIA) to become hydrologically recovered, the canopy must have begun to close. 14 – Bark’s PA comments on “Waucoma Huckleberry Enhancement Project”

Reduced shelterwood alternative We request that the FS consider an alternative which removes shelterwood from units 57 (101 years), 13 & 14 (122 years), 81 (122 years), 95 (110 years), and 69 & 70 (87 years).

Forest Plan Exceptions The Waucoma Project as proposed would include Forest Plan exceptions related to the following:

• FW-306: Timber stands should not be regeneration harvested until they have reached or surpassed 95 percent of culmination of mean annual increment measured in cubic feet • FW-307: Exceptions may be made where resource management objectives or special resource considerations require earlier harvest (Regional Guide for Pacific Northwest Region, 1984).

The FS states that the proposed action requires an exception to FW-306 to help meet other resource management objectives including the creation of early-seral habitat for huckleberry enhancement. Given that there is not a need for early-seral habitat compared with other seral stages across the planning area, and that shelterwood harvest will likely not produce a significant increase in huckleberries during the timeframe it will likely take for the canopy to begin to begin to close again (20-40 years according to the hydrology specialist report), Bark finds this Exception to be unsupported to the degree in which it should not be granted as part of this project.

SYSTEM ROADS Through the Waucoma proposed action, about 10 miles of open system roads would be closed. Another 0.5 mile of road would be decommissioned. Overall, open-road density would decrease from 2.3 to 1.5 miles per square mile. The FS has stated that for the following roads, the Objective Maintenance Level would be changed from from Closed/ML1 to ML2 (these Roads are ML2 currently, and Waucoma would propose to keep these roads as ML2 rather than move them towards the current Objective ML1). All of these roads are on the TAR list of roads to Close, Convert, or Decommission, and all have zero access score in INFRA roads table. We provide comments/questions on some of these roads for the agency to consider:

15 – Bark’s PA comments on “Waucoma Huckleberry Enhancement Project”

• 2821630: FS proposes to keep open for “Visitor Access”. However, this appears to be a redundant road accessing Mt. Defiance. • 2821621: FS proposes to keep open for “Visitor Access”. However, this appears to be a redundant road accessing Mt. Defiance. • 2821620: FS proposes to keep open for “Visitor Access”. However, this road appears to only access a small sliver of FS land, adjacent to Mitchell Pt. trail. • 2820634: Proposed 0.3 miles of maintenance. However, this road has been converted to a trail, and it is not clear where this 0.3 miles would be located. • 2820630: Road accesses two irrigation diversions. We recommend considering installing gate for an administrative closure

Bark generally supports changing the roads listed in the PA from Open/ML2 to ML1. Some of these roads appear to be already closed (2820631, 2820680, 2821640, 2820620, 2820621, 2820622), all on TAR list of roads to Close, Convert, or Decommission & all have zero access score in INFRA roads.

FSR 2821-640 already blocked off but could use a better closure and rehabilitation

We recommend a seasonal wildlife closure on at the end of the 2821 road to Mt. Defiance. Currently, there is a gate there that isn’t used but presumably was at some point.

The WA recommends obliteration of the 2810650. This road is inside Administratively Withdrawn area with no proposed Waucoma units, adjacent to an Inventoried Roadless Area. No rationale has been provided by the Forest Service to keep this road open. We request that 2810650 be decommissioned.

16 – Bark’s PA comments on “Waucoma Huckleberry Enhancement Project”

The FS proposes to decommission the 2810660. This appears to be a redundant road, and the WA recommends “obliteration”. We support decommissioning the 2810660.

The Forest Service provided a list of roads to the Stew Crew titled “Other Decommissioned Roads that may be proposed to use as temporary roads, and then returned to previous Decommissioned condition”. We based our following comments off this list:

• 2820690: The agency says they will only use 0.25 - 0.5 miles to access unit 39. – Question: The road needed to access this unit this looks like less than that amount. Would this road actually access unit 43? • 2820640: “Road is 0.08 miles; may need whole road” – Unit 25 appears to have plenty of road access, can the FS justify that this action is necessary? • 2820014: “Road is 0.05 miles. May need whole road” – We are concerned about impacts to talus habitat in this unit, as well as wildlife concerns, given the high diversity in this area. Please address these concerns.

TEMPORARY ROADS The Waucoma Proposed Action includes approximately 8 miles of temporary road construction. However, it is not clear whether these roads are existing alignments or if they will be newly constructed roads. The locations of these roads are not included in the Proposed Action. To fully understand the impacts of this project on the environment, the agency and interested public should be able to come to a shared understanding of where and how the effects of roadbuilding will occur within the Waucoma project area. This should happen before the decision is signed.

The Hood River Stew Crew, of which Bark is a member, worked hard to bring shared recommendations to the FS related to temporary roads. If the locations of temporary roads as they relate to the issues Stew Crew members are concerned about are not disclosed, the collaborative will have no way of knowing to what extent their recommendations were or were not followed. For example, collaborative members who advocated for the recommendation of minimizing temporary road stream crossings will read PDCs that contain language like “generally”, “wherever feasible” and “wherever practical” as a response to their concerns, but will not know how many stream crossings will be built, where they will be built, or if there are alternatives that exist elsewhere. In past projects it has been very useful to know the locations of proposed temporary roads and has prompted substantive feedback from the public.

In Bark’s recent memory there has not been a NEPA analysis which does not include locations of proposed temporary roads. While the agency has made it seem like putting these roads on a map is premature, in our experience the proposed 17 – Bark’s PA comments on “Waucoma Huckleberry Enhancement Project”

locations vary little overall from their ultimate locations within units. The new “conditions-based management approach” to NEPA analysis was recently rejected by the Ninth Circuit and we advise against relying on it in the final EA. For reasons stated above and at recent Stew Crew meetings, Bark requests that the agency disclose locations of proposed “temporary” roads and specify whether these roads are new or rebuilt.

As in past projects, the FS is planning to re-use previously decommissioned roads. Many of these roads have been passively decommissioned and we expect the agency will claim a net reduction in road density after the project when these roads are “rehabilitated”. Bark has long suggested that, while this approach appears good on paper, it is not what always happens on the ground. We have brought up specific examples in previous comments and in collaborative group meetings that illustrate this point.

It is well-documented that road construction vastly elevates erosion for many years, particularly in the first two years when the construction causes a persistent increase in erosion relative to areas in a natural condition. 13,14,15. Specifically, major reconstruction of unused roads can increase erosion for several years and potentially reverse reductions in sediment yields that occurred with non-use. Id. Available scientific information shows that reconstruction of closed and abandoned roads, could persistently elevate erosion and sediment delivery in several ways. Reconstructed roads cause elevated erosion and sediment for many years after decommissioning.16 The USFS Region 5 method for estimating cumulative watershed effects indicates that even 10 years after road decommissioning, a mile of decommissioned road is equivalent to 0.2 miles of new road in terms of adverse cumulative effects.17 After 50 years, a mile of obliterated road has still has impacts equivalent to 0.1 mile of new road. Thus, as it is apparent that decommissioning will not instantaneously eliminate the persistent impacts of roads on erosion and

13 Potyondy, J.P., Cole, G.F., Megahan, W.F., 1991. A procedure for estimating sediment yields from forested watersheds. Proceedings: Fifth Federal Interagency Sedimentation Conf., pp. 12-46 to 12-54, Federal Energy Regulatory Comm., Washington, D.C. 14 Rhodes, J.J., McCullough, D.A., and Espinosa Jr., F.A., 1994. A Coarse Screening Process for Evaluation of the Effects of Land Management Activities on Salmon Spawning and Rearing Habitat in ESA Consultations. CRITFC Tech. Rept. 94-4, Portland, Or. 15 Beschta, R.L., Rhodes, J.J., Kauffman, J.B., Gresswell, R.E, Minshall, G.W., Karr, J.R, Perry, D.A., Hauer, F.R., and Frissell, C.A., 2004. Postfire Management on Forested Public Lands of the Western USA. Cons. Bio., 18: 957-967. 16 Id. 17 Menning, K. M., D. C. Erman, K. N. Johnson, and J. Sessions, 1996. Aquatic and riparian systems, cumulative watershed effects, and limitations to watershed disturbance. Sierra Nevada Ecosystem Project: Final Report to Congress, Addendum, pp. 33-52. Wildland Resources Center Report No. 39, Centers for Water and Wildland Resources, University of California, Davis. 18 – Bark’s PA comments on “Waucoma Huckleberry Enhancement Project”

sediment delivery, building these roads will likely have adverse impacts to the aquatic and terrestrial environment. Road construction is by far the greatest contributor of sediment to aquatic habitats of any management activity.18,19 Even temporary road construction can cause resource damage including erosion and sedimentation, exotic species spread and disruption of wildlife.20 Unpaved roads and stream crossings are the major source of erosion from forest lands contributing up to 90% of the total sediment production from forestry operations. Bark requests that the FS should strive for no new “temporary” roadbuilding, since it is not debatable that temporary roads have a permanent impact on the forest around them and create a blueprint for future entries resulting in further impacts. Allowing no new temporary roads more aligns the project with being able to meet the land S&Gs for Roaded Rec B3-008 & Backcountry Lakes B12 005 - where “No more than 5 percent of an activity area should be in detrimental soil condition from the combined impact of compaction, puddling and displacement.”

Further, Bark believes that the FS should avoid roadbuilding in >1,000 acre roadless areas. The NE corner of the project area, south of Warren Lake, is adjacent to what is now an Inventoried Roadless Area (IRA). If the IRA were mapped to the true extent of its roadless character, it would include the proposed units in the NE corner of the project. We request that the FS limit roadbuilding in this part of the project area to allow its roadless character to persist and maintain habitat connectivity with the IRA.

DETRIMENTAL SOIL CONDITIONS IN B3 & B12 The Waucoma project includes commercial logging in both B3 Roaded Recreation and B12 Backcountry Lake Area LRMP land allocations. Both of these allocations include specific guidelines for soil disturbance.

B3-008: No more than 5 percent of an activity area should be in detrimental soil condition from the combined impact of compaction, puddling and displacement B12 005: No more than 5 percent of an activity area should be in detrimental soil condition from the combined impact of compaction, puddling and displacement

18 Meehan, W.R. (ed.). 1991. Influences of Forest and Rangeland Management on Salmonid Fishes and Their Habitats. Am. Fish. Soc. Special Publication 19. 19 Robichaud, P.R., L.H. MacDonald and R.B. Foltz. 2010. Fuel management and erosion. Ch. 5 in: W.J. Elliot, I.S. Miller and L. Audin (eds.). Cumulative Watershed Effects of Fuel Management in the Western United States. USDA For. Serv. Rocky Mtn. Res. Sta. Gen. Tech. Rep. RMRS-GTR-231. Fort Collins, CO. 20 Trombulak, S.C. and C.A. Frissell. 2000. Review of ecological effects of roads on terrestrial and aquatic communities. Conservation Biology 14:18-30. 19 – Bark’s PA comments on “Waucoma Huckleberry Enhancement Project”

If the FS is to propose ground-based logging in any units overlapping with these allocations, they must provide site-specific Project Design Criteria (PDCs) to ensure that detrimental soil conditions will not exceed 5% of the activity area. These were not provided in the PA.

HUCKLEBERRY ENHANCEMENT The FS has stated that the purpose of the Waucoma project is to “create and maintain current and future huckleberry habitat across the landscape to benefit cultural and recreational uses.” According to the FS, the Waucoma planning area was identified as an area of emphasis for “huckleberry enhancement” because of the existing ecological site potential and past cultural interest.

The Waucoma scoping letter stated that “Recent treatments on the Mt. Hood National Forest demonstrate that an improved huckleberry response rate can be achieved by opening the canopy and reducing competing vegetation.” Bark requested that these past treatments and their results over time be detailed in the PA, which unfortunately were not.

The agency states that “treatments to reduce canopy cover to approximately 30%, would result in enhanced huckleberry growth and would likely result in additional berry production.” However, it has also been shown that treatment type is a factor in huckleberry response. A recent monitoring effort in the Gifford Pinchot National Forest found that huckleberry cover was significantly lower within units that had been treated with ground-based machinery compared to sites treated with hand- tools. Both measures of fruit production (proportion of plants producing fruit and proportion of fruit-producing plots with high fruit levels) were lower within units that had been treated with ground-based machinery compared to those within units treated with hand tools or left untreated. The FS should incorporate these findings and their implications into the layout of this project and their decisions regarding techniques proposed for achieving increased huckleberry production across different stand types.

In response to public comments, the FS dismissed the idea of “deleting treatments if they were not close to an open road where huckleberry picking would be easy.” Given that open canopy forest types are not what are needed in this project area, this is a valid point made by the public. From a landscape ecology perspective, if huckleberries are not promoted in accessible areas, there is no supported rationale to remove the canopy that has yet been provided by the agency.

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As with other analyses, the FS has created a scenario where disturbance across time does not exist as it relates to changes in stand structure In the Waucoma analysis, it is stated that “if left untreated, huckleberry plant growth in the proposed treatment area would likely continue to decline.” This is a vast oversimplification of what will likely occur in the project area.

Confusingly, the Botany specialist report presents another scenario: “The dense growth of the trees in much of this area results from a lack of natural disturbance and from human fire suppression. As such, there is a risk of a high intensity wildfire occurring within this area. If a fire were to burn through this landscape, the loss of sensitive species individuals and habitat would be likely. Many areas would be returned to early-seral stand conditions, which do not favor the sensitive species of concern and may instead promote the growth of invasive weed species, further reducing the diversity and ecological function of this area.” In this case, early seral is presented as something the agency would like to avoid, and that would not benefit huckleberries. One should also note, that bringing logging and roadbuilding, not natural fire, into an ecosystem is the main cause for an increase in invasive weed species on both the stand and landscape level. This is later recognized in the Invasive Species Report, that “The proposed action has a high risk of weed introduction. The harvesting activities would create disturbed conditions for invasive species growth, and the equipment may introduce seeds or propagules from nearby roadside sources.” Understory Management Related to competition from non-Vaccinium plant species, Bark notes that vast areas of the project area are dominated by shrubs like chinquapin and ceanothus in the understory, which responded to recent thinning efforts more than the Vacciniums. There is no PDC related to understory management, so we would expect to continue to see this trend play out across much of the project area.

Forest Plan standards require the Forest Service replant in areas where natural regeneration is not occurring within five years post-harvest. It is unclear whether or not the areas treated for huckleberry enhancement will be replanted, and if so, how replanting is anticipated to impact huckleberry production and access to picking opportunities in the future.

It was stated on the July 2018 field trip that the project area is mostly within a stand-replacing fire-regime. The agency shared that prior to the initial logging of the area, there was a combination of disturbance agents which encouraged huckleberry growth and production while maintaining low ground competition and minimal canopy.

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According to the WA, Mt. Defiance area likely experienced “semi-frequent” fire that saw a mix of low intensity under-burning and high intensity stand replacing fire. Fires occurred just frequently enough to promote a more even mix of these two fire types across the landscape. Around Mt. Defiance, the average fire return interval was around 50-100 years, based on the precipitation and current species compositions. The areas of mixed intensity fire are defined by the WA as areas where grand fir is a major stand component.

The FS stated that the authors of the WA did not have a good understanding of some disturbance types within the watershed. For example, they believed that burning was common to maintain travel-ways due to evidence from elsewhere in the western United States. However, they did not know how much burning for travel-ways may have historically occurred in West Fork. In the WA, Table 4.3. Major disturbance types for each sub-watershed and approximate scale and frequency identifies “Burning by American Indians” as “Common” in the West Fork and Lake Branch, and “Semi-common” in Green Point.

Historically, burning of big huckleberry patches by Native Americans was a regular activity in the subalpine zone of the Cascade and Pacific ranges. To enhance production, fires were set in autumn after berry harvest to reduce invasion of shrubs and trees. Fields of big huckleberry in the Pacific Northwest were also created by uncontrolled wildfires that occurred before effective fire suppression. “The huckleberry patches were burned about every seven years in the fall and after collecting the year’s production. They burned when huckleberry production fell off or when tree encroachment reached an undesirable level. Since the fires were spread late in the year, they rarely spread beyond the berry patch…Before 1900, huckleberry field burning may have been a significant and frequent ignition source in the lower elevations of Green Point sub-watershed. This burning would have occurred in association with maintaining travel routes along Hood River and possibly fishing at Punchbowl falls.” WA at 4-12. Although the FS does have some evidence of indigenous burning practices in the Waucoma area, they have not included any burning in the Proposed Action.

In preferred habitats, big huckleberry will generally survive low to moderate severity fires, attaining pre-burn coverage in 3-7 years with stem number and density increasing. Foliage is of low flammability, allowing for survival after low severity fires, with top-kill resulting from higher severity fires. However top-killed plants can resprout from rhizomes. The clonal habit favors ecotypic variation among populations: plants subjected to regular fire intervals may be better suited to

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surviving fire than individuals developed under fire suppression.21 This could mean that if the FS were to burn for huckleberries in Waucoma, not only would they be creating more fire-resilient stands of trees, but they would also be doing the same for stands of huckleberries.

The FS states that this project should be designed to achieve the objective of huckleberry enhancement in an economically viable way. To this point, Bark requested in Scoping that fire use become an integral part of this project. In response, and after several conversations on this topic in the Stew Crew, the FS stated that use of fire was considered but was found to be “infeasible”. They mention the short potential window of opportunity to burn after snow melt and before conditions become too dry and too hazardous.

We recognize that the FS sees several barriers to using this method to achieve their objectives in the Waucoma project area. In this recent University of Oregon investigation, interviews conducted by researchers did not yield clear indications that policy change is needed at the federal level at this time to allow more burning, as most interviewees said there were opportunities to increase the use of prescribed fire that would not require changes to federal law. We encourage the District to review this document and others to more fully assess the obstacles to burning which may be present, and how to potentially navigate them in the future.

ISSUES REGARDING RECREATION IN WAUCOMA FOR FURTHER REVIEW

Since the Waucoma project was first introduced to the Stew Crew in 2016, Bark has advocated for the FS to re-examine the project area for its potential to bring a world-class recreational experience to Hood River County. The Forest Service has responded to this by saying that recreation actions were “considered, but not developed as an alternative. It is not consistent with the theme of huckleberry management and a Forest Plan amendment of this type is outside the scope of project level planning. A Forest-scale recreation management plan or a Forest Plan revision would be better suited to inform that type of effort in the future.” Currently there are approximately 8.5 miles of recognized trail located in the Waucoma planning area: Trail 610, 409 (Rainy/Wahtum), 413 (Mt. Defiance), 413B, 409A (Black Lake), plus portions of Wyeth, Bear lake and Herman Creek Cutoff. As stated in Scoping, Bark believes that the FS has an exciting opportunity to expand recreational opportunities in Waucoma by opening new trails, converting

21 Ecology and Management of Big Huckleberry Literature Review, USFS R6 Ecology Program, 2016. 23 – Bark’s PA comments on “Waucoma Huckleberry Enhancement Project”

some roads to trails, and ultimately changing the land allocations through a Forest Plan amendment to protect these unique recreational values.

We encourage the Forest Service to use the research and recommendations we provided in Scoping to evaluate the magnitude of public benefits provided by recreation in the Waucoma area and gauge the social benefits of investing in recreation planning, programs, and infrastructure there. Over the long-term, Bark believes that there is great potential for the Waucoma project area to eventually be managed as an Unroaded Recreation Area through a Forest Plan amendment. This Land Use Allocation, described in the 1990 Forest Management Plan (Four- 157 to 162), provides for managing for non-motorized recreation in a natural environment where timber harvest and new roads are prohibited. We would recommend that the change in management emphasis and Land Use Allocations only apply to the area from NFS Road 2820 south to the southern boundary of the Waucoma timber sale planning area (approx.. 72% of area). The RRs should remain as an overlay on the Unroaded Recreation Area. In this scenario, the area north of NFS Road 2820 can remain as Matrix land with a timber management emphasis (approx. 28% of area). Additional rationale for this change in land allocations, along with recommendations on how to protect current recreation infrastructure, are included in our Scoping comments.

ISSUES REGARDING CLIMATE CHANGE ANALYSIS FOR FURTHER REVIEW

In recent projects, Bark has observed that the FS has made a choice not to pursue a quantitative carbon analysis, or address current OSU forest carbon research and its recommendations which were supported by the Oregon Global Warming Commission's Forest Carbon Accounting Project Report. These findings highlight the importance of project-level tracking of carbon emissions, and question whether converting standing timber into wood products can be an effective strategy for maintaining or increasing overall forest carbon storage.

To this end, we encourage the FS to engage with and include Land use strategies to mitigate climate change in carbon dense temperate forests, a paper released in 2018 which explores PNW forests’ role in the regional carbon cycle. In this paper, reforestation, afforestation, lengthened harvest cycles on private lands, and restricting harvest on public lands increase net ecosystem carbon balance 56% by 2100, with the latter two actions contributing the most. Resultant co-benefits included water availability and biodiversity, primarily from increased forest area, age, and species diversity. Increasing forest carbon on public lands reduced emissions compared with storage in wood products because the residence 24 – Bark’s PA comments on “Waucoma Huckleberry Enhancement Project”

time is more than twice that of wood products. Hence, temperate forests with high carbon densities and lower vulnerability to mortality have substantial potential for reducing forest sector emissions.

The FS asserts that utilizing trees to create “long-lived” wood products sequesters carbon, and that using wood to build houses has a more favorable carbon balance when compared to other building materials such as steel, concrete or plastic. To be clear, while some carbon can be stored temporarily in wood products, these products don’t sequester carbon. Pacific temperate forests can store carbon for many hundreds of years, which is much longer than is expected for buildings that are generally assumed to outlive their usefulness or be replaced within several decades. Recent analysis suggests substitution benefits of using wood versus more fossil fuel-intensive materials may have been overestimated by at least an order of magnitude. While product substitution reduces the overall forest sector emissions, it cannot offset the losses incurred by frequent harvest and losses associated with product transportation, manufacturing, use, disposal, and decay. The recent OSU research has identified forests in the western conterminous United States with highest potential carbon sequestration and lowest vulnerability to future drought and fire and found that these high‐carbon‐priority forests exist in the westside cascade mountains. According to the authors of Carbon sequestration and biodiversity co‐benefits of preserving forests in the western USA,43 the pacific northwest’s high‐productivity, low‐vulnerability forests have the potential to sequester up to 5,450 Tg CO2 equivalent (1,485 Tg C) by 2099, which is up to 20% of the global mitigation potential previously identified for all temperate and boreal forests, or up to ~6 yr of current regional fossil fuel emissions. Additionally, these forests currently have high above‐ and belowground carbon density, high tree species richness, and a high proportion of critical habitat for endangered vertebrate species, indicating a strong potential to support biodiversity into the future and promote ecosystem resilience to climate change. These results show considerable potential for forests in the western United States to sequester additional carbon over the coming century and demonstrate that protecting high‐carbon‐priority areas could help preserve components of biodiversity. Preserving high‐carbon‐priority forests avoids future CO2 emissions from harvesting and mitigates existing emissions through carbon sequestration.

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Forested land in the western conterminous United States classified into priority for preservation to mitigate climate change based on the spatial co‐occurrence of low vulnerability to drought and fire and low, medium, and high potential carbon sequestration. WA, Washington; ID, Idaho; MT, Montana; OR, Oregon; CA, California; NV, Nevada; UT, Utah; CO, Colorado; AZ, Arizona; NM, New Mexico. This is supported by recent research showing that growing existing forests intact to their ecological potential—termed proforestation—is the most effective, immediate, and low-cost approach that could be mobilized across suitable forests of all types. Proforestation serves the greatest public good by maximizing co- benefits such as nature-based biological carbon sequestration and unparalleled ecosystem services such as biodiversity enhancement, water and air quality, flood and erosion control, public health benefits, low impact recreation, and scenic beauty. For example, a study of 48 undisturbed primary or mature secondary forest plots worldwide found, on average, that the largest 1% of trees [considering all stems ≥1 cm in diameter at breast height (DBH)] accounted for half of above ground living biomass (The largest 1% accounted for ~30% of the biomass in U.S. forests due to larger average size and fewer stems compared to the tropics). Each year a single tree that is 100 cm in diameter adds the equivalent biomass of an entire 10–20 cm diameter tree, further underscoring the role of large trees. Intact forests also may sequester half or more of their carbon as organic soil carbon or in standing and fallen trees that eventually decay and add to soil carbon. Some older forests continue to sequester additional soil organic carbon and older forests bind soil organic matter more tightly than younger ones.

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Proforestation has the potential to provide rapid, additional carbon sequestration to reduce net emissions in the U.S. by much more than the 11% that forests provide currently.44 The agency claims that the "Forest Plan, as amended, does not contain direction related to climate change.” While this may be true, environmental law arguably does. In responding to comments, the Forest Service has recently claimed that “climate change is a global phenomenon” with the implication that it is impossible to assess the impact of any given project. This excuse was thoroughly rejected by the Ninth Circuit, which found the fact that “climate change is largely a global phenomenon that includes actions that are outside of [the agency's] control . . . does not release the agency from the duty of assessing the effects of its actions on global warming within the context of other actions that also affect global warming.” The impact of greenhouse gas emissions on climate change is precisely the kind of cumulative impacts analysis that NEPA requires agencies to conduct. Ctr. for Biological Diversity v. Nat’l Highway Traffic Safety Admin., 538 F.3d 1172, 1217 (9th Cir. 2008).

The Ninth Circuit established a rule in Hapner v. Tidwell that NEPA analyses must consider a project's “impact on global warming in proportion to its significance,” 621 F.3d 1239, 1245 (9th Cir. 2010). Because of the importance of mature Cascadian forests to the carbon cycle, local forest management decisions on MHNF have a disproportionately high impact on climate change. Indeed, studies have found that decreasing logging on National Forests in the Pacific Northwest is one of the top land use strategies to mitigate climate change.

In 2016, the Council on Environmental Quality (CEQ) released final guidance for federal agencies on how to consider the impacts of their actions on global climate change in their NEPA analysis. This final guidance provides a framework for agencies to consider both the effects of a proposed action on climate change, as indicated by its estimated greenhouse gas emissions, and the effects of climate change on a proposed action. However, on March 28, 2017 the Trump Administration issued an executive order titled “Presidential Executive Order on Promoting Energy Independence and Economic Growth” which attempts to relieve agencies from the requirement to consider the effects of GHG emissions and climate change. Among other things, this executive order rescinds the CEQ guidance regarding consideration of climate change in federal decision-making, but the E.O. also recognizes that “[t]his order shall be implemented consistent with applicable law” and “all agencies should take appropriate actions to promote clean air and clean water for the American people, while also respecting the proper roles of the Congress and the States concerning these matters in our constitutional republic.” While the guidance was finalized in August 2016, it followed a series of court rulings addressing the issue of greenhouse gases and NEPA, which found that whenever greenhouse gases are

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significant or rise from the project, either directly or indirectly, they much be analyzed in a NEPA document. Thus, despite the E.O., the FS must continue to carefully consider the effects of GHG emissions and climate change in all its decisions.

Newly released draft guidance from CEQ states: Agencies should attempt to quantify a proposed action’s projected direct and reasonably foreseeable indirect GHG emissions when the amount of those emissions is substantial enough to warrant quantification, and when it is practicable to quantify them using available data and GHG quantification tools.5 Agencies should consider whether quantifying a proposed action’s projected reasonably foreseeable GHG emissions would be practicable and whether quantification would be overly speculative. If an agency concludes that quantification would not be practicable or would be overly speculative, it should explain its decision. Where GHG inventory information is available, an agency may also reference local, regional, national, or sector-wide emission estimates to provide context for understanding the relative magnitude of a proposed action’s GHG emissions.45

And, when an agency determines that the tools, methods, or data inputs necessary to quantify a proposed action’s GHG emissions are not reasonably available, or it otherwise would not be practicable, the agency should include a qualitative analysis and explain its basis for determining that quantification is not warranted.

Recently, in the North Clack EA, the FS made an unsupported claim that “Rapidly growing forests are recognized as a means of carbon sequestration” (the source “FAO 2007”, is not included in the References). This unsupported claim is also outdated and false. Removal of biomass from any forest limits its ability to sequester carbon for a period after the disturbance and subsequently turns the forest into a carbon source.46 Not only that, but also the act of removing trees requires carbon emissions. Moreover, reducing tree densities increases weatherization of dead biomass, which would increase the rate of carbon emissions from decay. The Oregon Global Warming Commission states in its 2018 Forest Carbon Accounting Project Report: “Based on credible evidence today, forest harvest does not appear to result in net carbon conservation when compared to carbon retention in unharvested forests…Current analysis suggests that treatments which include medium to heavy thinning result in reduced carbon stores that do not recover in any meaningful time periods.” The FS has often claimed the short-term carbon emissions and the difference in long-term carbon storage that could be attributable to the Proposed Action are of such small magnitude that they are unlikely to be detectable at global, continental or regional scales. Additionally, it has asserted that changes in carbon stores are unlikely to affect the results of any models now being used to predict climate change. The same thing could be, and is, said about every individual timber sale 28 – Bark’s PA comments on “Waucoma Huckleberry Enhancement Project”

in National Forests in the Pacific Northwest. The failure of federal agencies to place projects within the context of emissions from logging on a regional or statewide level has led the public to thinking that the forestry sector is no longer a contributor to global greenhouse gas emissions. Again, the FS insists that the scale of climate impact is inherently global, ignoring the fact that all emissions are local and the point sources of impact on global climate trends. It is absolutely possible to quantify the amount of carbon sequestered in the Waucoma project area (see, for example, the BLM’s Hole in the Road EA in which did just that). To take a hard look at climate change, the questions that the FS should be answering are: How many tons of carbon will the Waucoma Timber Sale emit into the atmosphere during and after project implementation from logging operations and decay? How much carbon sequestration does the project area currently sequester? How much sequestration capacity will be lost, and for how long? How will the forests’ resiliency to a changing climate be affected by the logging and road building? The FS should quantify climate change emissions from its projects and take the analysis a step further to examine the carbon tradeoffs, including carbon emitted from the project and the loss of future carbon sequestration because of the project. The CEQ guidance also requires the FS to consider alternatives that would make the action and affected communities more resilient to the effects of a changing climate. The FS should also choose mitigation measures to reduce action-related GHG emissions or increase carbon sequestration in the same fashion as they consider alternatives and mitigation measures for any other environmental effects. A recent California case discussed the government’s failure to take a hard look at how a changing climate exacerbates the adverse impacts of the proposed project, finding that to meet the hard look requirement, “NEPA requires an evaluation of the impact of climate change.”AquAlliance v. U.S. Bureau of Reclamation, 287 F.Supp.3d 969, 1028 (E.D. Cal. 2018). The court in AquAlliance found that failure to consider climate change is a “failure to consider an important aspect of the problem” facing the proposed action. Id. at 1032, citing Wild Fish Conservancy v. Irving, 221 F.Supp.3d 1224, 1233 (E.D. Wa. 2016) (Biological Opinion was arbitrary and capricious for failing to adequately consider impacts of climate change). In your PA, please recognize that mature forests are the most climate-resilient ecosystems and provide important habitat refugia for organisms stressed by a changing climate. In this context, old-growth forests take on new significance, thus logging them has greater impact. We request you analyze the impacts of the Waucoma project in the context of a rapidly changing climate, and not rely on the results of past logging to inform your analysis as the baselines are rapidly changing.

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Impact of Management on Ecosystems Experiencing Climate Change Human-caused climate change will not only affect natural systems, it will also intensify the impacts of human activities such as off-road vehicles, roadbuilding and logging. Looking at climate impacts in National Forests, one report concluded that, “climate change will directly affect the ecosystem services provided by national forests and will exacerbate the impacts of current natural and anthropogenic stress factors.”47 Climate change is predicted to result in more flood events and fires across the Pacific Northwest.48 Many Oregon streams will experience higher winter flow and reduced summer flows as temperature rises and the variability of precipitation increases. The well documented shift from snow to rain, coinciding with increases in temperature, affects hydrologic trends. Snow cover typically accumulates at temperatures close to the melting point, and thus is at risk from climate warming because temperature affects both the rate of snowmelt and the phase of precipitation. With a projected 2°C winter warming by mid-century, almost 10,000 km² of currently snow-covered area in the Pacific Northwest could receive winter rainfall instead.49 Climate change, combined with effects from past management practices, is exacerbating changes in forest ecosystem processes and dynamics to a greater degree than originally anticipated in the NWFP.50 This includes changing patterns of fire, insect outbreaks, drought, and disease.51 Land managers need to consider this uncertainty and how best to integrate knowledge of management-induced landscape pattern and disturbance regime changes with climate change when making spotted owl management decisions. In a recent study, the influence of weather and climate on spotted owl populations was evidenced in northern California, Oregon, and Washington. Climate related factors accounted for 84% and 78% of the temporal variation in population change of spotted owls in the Tyee and Oregon Coast Range study areas, respectively. Climate and barred owls together accounted for nearly all (~100 percent) of the changes in spotted owl survival in the Oregon Coast Range.52 The presence of high- quality habitat appears to buffer the negative effects of cold, wet springs and winters on survival of spotted owls as well as ameliorate the effects of heat. The high-quality habitat might help maintain a stable prey base, thereby reducing the cost of foraging during the early breeding season when energetic needs are high. In general, climate change can increase the success of introduced or invasive species in colonizing new territory. Invasive animal species are more likely to be generalists, such as the barred owl, than specialists, such as the spotted owl and adapt more successfully to a new climate than natives.53 In order to pursue a climate-informed action alternative at Waucoma, the FS should take a hard look at the climate science and design an alternative which uses precaution as a guiding principle, along with the prioritization of protecting climate refuges, as well as identifying forest types vulnerable to ecosystem change.

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CONCLUSION

Bark has several suggestions for improving the Waucoma project to better meet its existing Purpose & Need, and to expand the Purpose & Need to better address the need for more recreation in the area. We request that the agency review these suggestions and create alternatives that meaningfully incorporate them – singly or together – to assess their ecological and community impacts and benefits: Highlighted Requests • Provide specific stand information for units proposed for logging within RRs, and the ecological rationale for the actions proposed within these stands; • Exclude stands with high snag and large live-tree densities from logging and apply buffers on key snags and relatively large trees within proposed units; • Drop logging in stands over 200 years old from the Proposed Action; • Drop units 2, 3, and 4 from the Proposed Action; • Move south-facing stands above North Fork Green Point Creek out of shelterwood and into a light thin prescription; • Consider an action alternative which removes shelterwood from units 57 (101 years), 13 & 14 (122 years), 81 (122 years), 95 (110 years), and 69 & 70 (87 years); • Address Bark’s finding that a Forest Plan Exception to FW-306 is unsupported and inappropriate for this project area; • Look for additional opportunities to reduce the road network in the watershed and include road decommissioning in the Proposed Action; • Disclose locations of proposed “temporary” roads and specify whether these roads are new or rebuilt; • Significantly limit the mileage of “temporary” road construction; • In both B3 Roaded Recreation and B12 Backcountry Lake Area land allocations provide site-specific Project Design Criteria (PDCs) to ensure that detrimental soil conditions will not exceed 5% of the activity area; • Provide a robust, quantitative carbon sequestration and climate change analysis as part of the PA; and • In order to pursue a climate-informed action alternative at Waucoma, take a hard look at the climate science and design an alternative which uses precaution as a guiding principle, along with the prioritization of protecting climate refuges, as well as identifying forest types vulnerable to ecosystem change. In the comments above, Bark has provided ample suggestions to improve this project – based on our survey of both the project area and the scientific literature

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pertaining to aquatics, wildlife, roads, and forest health. We anticipate a thorough review of these comments and look forward to the necessary changes made to both the forthcoming decision and the project itself.

Thank you,

Michael Krochta Forest Watch Coordinator, Bark

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