Charlie Ferranti

4245 SE Tibbetts St.

Portland, OR 97206

May 1, 2007

Tom Horning

Estacada Ranger Station

595 NW Industrial Way

Estacada, OR 97023

Thank you for this opportunity to comment on the proposed 2007 Clackamas Restoration Projects. I look forward to seeing the full EA.

Management of Reserves

A cardinal issue found within Forest Ecosystem Management Report (FEMAT) and the Northwest Forest Plan (NFP) involves differing management approaches and objectives for Reserves (Late Successional and Riparian) and Matrix. Management plans for Reserves would benefit from the differing management objectives found in a “decadence management” project being implemented after a timber sale. While the Clackamas River Ranger District of the Mt. Hood National Forest has made substantial and impressive progress in their approach to Matrix management, there remain substantive problems with the active management for Reserves. These issues are not about passive vs. active management, but the limited restorational goals that can be included within a timber sale. This project could act to bring clarity to the restoration goals within the Reserves and achieve the objective(s) of the active management.

Decadence management represents an important accompanying component to the other implemented management actions; it would complement the VDT and act to further enhance the Reserves while maintaining its essential ecosystem functions and processes. Reserve restoration demands an assiduous and holistic approach than can be accomplished through logging alone. This project has the potential to significantly enhance more than just one or two late-seral characteristic structure (large trees with diverse spacing), but truly act to restore the robustness of late-seral ecosystem processes, species diversity, and all structural characteristics (living and non-living) within the Reserves. In order to achieve the restoration goals found in the Northwest Forest Plan (and the biological potential goals found in the Mt. Hood LRMP), appropriate decadence management is essential.

Active Management within the Reserves needs to explicitly pursue an objective of restoring native pathogens (fungus, parasitic vegetation, etc.) after thinning operations. Currently most post-thinning Reserves are too healthy to provide snags and downed wood (i.e., No Whisky EA-61). As a forest moves from mid-seral into and through a late-seral/mature condition the structural elements most elusive are those associated with dead and dying trees. While multiple EAs assure that this is for the “short to moderate term,” this assurance runs counter to current scientific literature. In mid-seral plantation Reserves, a primary management objective is to restore late-seral/mature forest characteristics and processes. Active management that pursues a more complete set of late-seral and mature forest characteristics than possible when working with just the living components (as normally is the focus during a thinning project) is possible and should be an imperative. Setting a numerical target for immediate snag creation, while potentially tempting due to its simplicity, should be avoided due to its lack of effectiveness in truly accelerating the restoration of late-seral characteristics in a forest. Decadence management that concentrates on elements of wood decay within living trees is more appropriate due to the importance and lengthy timelines needed for this essential late-seral/mature forest characteristic to develop.

It is typical for mid-seral forests, as they mature, to slowly lose their woody non-living elements and characteristics as legacy snags and large downed wood decay. The relatively younger and structurally more simplistic forests found in many post-thinning Reserves have smaller trees and lower incidents of disease so there is a time-lag in the creation of new snags and replacement of downed wood.[1]

It is of vital importance to the restoration of habitat and ecosystem processes to avoid the danger that thinning appears to create, namely a significant and long-term problem with future numbers of snags/dead wood. Thinning with a “near-exclusive focus on live trees” appears to depress future recruitment of essential late-seral non-living characteristics. While negative impacts due to the logging are unavoidable, the extent and duration of the impact can and should be managed. Proper management can reduce the quantity and duration of this negative aspect of the silvicultural prescription.

Regardless of the benefits of a single entry thin to enhance a singular aspect of the Reserves (e.g., VDT thinning in Riparian Reserves or Late Successional Reserves), by treating them essentially as single-entry matrix units these projects collectively act in a manner that retards or prevents the attainment of various management objectives (such as those found in the Mt. Hood National Forest Plan, Northwest Forest Plan, and Aquatic Conservation Strategy). Additional active management, if planned appropriately offer significant opportunity to accelerate the attainment of late-seral characteristics for the Reserves.

As noted by Carey et al. (1999)[2], not only does it appear that “[a]ctive management may be necessary to maintain decadence in the first 150 years of ecosystem development,” but that these expressions of decadence within a forest are essential components of its structure and process (“coarse woody debris is of central importance in promoting ecosystem stability, habitat diversity, and long-term productivity”).

· http://www.fs.fed.us/pnw/pubs/journals/pnw_1999_carey003.pdf

…Four factors (crown-class differentiation, decadence, canopy stratification, and understory development) accounted for 63% of variance in vegetation structure. Decadence contributed to variation mostly in late-seral forest.

…The 4 structural factors each represented an important ecological process; decadence and canopy stratification apparently had profound influences on other life forms. Carefully timed variable-density thinnings could accelerate crown-class differentiation, canopy stratification, and understory development and increase habitat breadth. Management of decadence is more problematic and may require various interventions, including inducing decay in live trees, conserving biological legacies from previous stands, and ensuring recruitment of coarse woody debris.

…Coarse woody debris (standing and fallen) was a result of 3 separate phenomena: (1) retention of legacies through catastrophic disturbance, (2) recruitment of fallen trees through suppression- mortality, and (3) development of decadence in live trees over time.

…coarse woody debris is of central importance in promoting ecosystem stability, habitat diversity, and long-term productivity…

[emphasis added] …Managing decadence is the most challenging aspect of intentional ecosystem management. Our research shows that decadence is more than snags and logs; it is a process that is influential in multiple aspects of ecosystem development from providing cavities for wildlife, to creating gaps in the canopy, to altering forest floor microclimate and structure. Active management may be necessary to maintain decadence in the first 150 years of ecosystem development. Thinnings without active management for decadence could result in dimunition of decadence, decline in coarse woody debris, and a change in trajectory of forest development away from complexity and resiliency.

As clearly discussed in all the recent thinning EAs (Cloak, South Fork, No Whisky, 2007 Thin) the post-thinned Reserve trees will be stronger and healthier; consequently they will be more resistant to disease. While this may be understandably desirable in the Matrix, it is undesirable in the Reserves because it acts to retard or prevent the attainment of late-seral characteristics (and therefore retards the attainment of various Forest management goals). The essential role of various native pathogens in healthy forest ecosystems has been well documented. These plantations located within the Reserves will continue have reduced incidence of, and effects from, native pathogens. Consequently, these post-harvest Reserves need active management introducing pathogens in order for these areas to setup a system so that later in time these Reserves will be able to inherit the pathogens necessary for proper ecosystem functioning from the currently infected trees. Heart-rot is a significant component of late-seral forest ecosystems and attainment of late-seral characteristics remains an important aspect of active Reserve management for the Clackamas Ranger District (as noted in the No Whisky Appendix E):

Enhance riparian reserves by accelerating the development of mature and late successional stand conditions

It isn’t just forest diversity that needs native pathogens to play their key role; it is over-all forest health. Consider the keystone complex (essential forest functions) that is filled by native pathogens, ecto-mychorrizal truffles, pileated woodpeckers, and flying squirrels. The presence of pathogens within a tree begins the process of creating habitat for keystone species (woodpecker and squirrel) that play essential roles in distributing the truffle spores in “a web of mutual support.” As noted in PNR Science Findings #20 and reinforced in PNR Science Findings #57 and PNR Science Findings #60 in a discussion regarding the ecosystem keystone species the pileated woodpecker and its role in the keystone complex.

Because the hollowing process is quite specific, it has to begin early in the life of a stand, and start on a living tree, according to Parks; an already dead tree not previously infected with heart-rot fungi will not become hollow. (PNR 20)

“One of the reasons roost sites may be more limiting for pileateds than nest sites, is because hollow trees are relatively rare in forests; they are created only by the process of heartwood decay occurring in live trees over a long period of time,” Raley explains. (PNR 57)

Management can have diverse effects on truffle diversity and abundance. In general, managing for biocomplexity—multiple tree species, understory diversity, decaying trees—at fine scales contributes to biodiversity and ecosystem resilience. (PNR 60)

The present course of active management of Reserves needs to include fungal infection since these pathogens act to create structural differentiation over time. This increase in structural heterogeneity increases species diversity and provides the necessary habitat for ecosystem keystone species. Active and passive management of native pathogens is particularly important in post-thinning Reserves as the remaining trees will be more resistant to disease and the initiation of new decadent trees will be delayed – even though decadent trees (and the snags they eventual create) remain vital to the proper operation of the Reserve ecosystem.

Management of the Reserves found in the NFP revolves around objectives that differ from the management objectives for the Matrix. Restoration silviculture (via VDT) allows for an active management approach with projects that are very similar between the two areas, but it does not eliminate the different objectives. In order for the project level planning to appropriately pursue restoration and accelerated achievement of late-seral characteristics within the Reserve the project level planning needs to clearly address where the objectives allow for similar approaches (i.e., VDT) and where the approaches will need to diverge (i.e., decadence management).

The presence of disease is extremely important to the continued health and diversity of the forest ecosystem. Healthy and vigorous stands are a primary goal in maximizing timber production; conversely it is the loss of timber to disease that is a key indicator of a healthy Reserve forest ecosystem. It is the initiation of disease and the results of disease that are missing both from plantations and from the currently planned restoration silvicultural pathway for these Reserves. Managing the Reserves in a manner that explicitly acknowledges its need for decadence is an essential component of the 2007 Restoration EA.

Active Decadence Management (2007 Restoration EA)

Decadence management is an important aspect of post-plantation forest ecosystem restoration. As noted by Rose et. al. (2001)[3] (p.580, 581):

…The ecological importance of decaying wood is especially evident in the coniferous forests of the Pacific Northwest. In this region, the abundance of large decaying wood is a defining feature of forest ecosystems, and a key factor in ecosystem diversity and productivity

…Large accumulations of decaying wood provide wildlife habitat and influence basic ecosystem processes such as soil development and productivity, nutrient immobilization and mineralization, and nitrogen fixation.

…New research over the past three decades has emphasized the significance of decaying wood to many fish and wildlife species, and to overall ecosystem function. The importance of decaying wood to ecosystem biodiversity, productivity, and sustainability is a keynote topic in two recent regional ecosystem assessments in Oregon and Washington. [FEMAT 1993 Chapters III and IV; PNW-GTR-405]

…Intensive forest management regimes have substantially altered the abundance and composition (species, size, decay class) of decaying wood in forest ecosystems in the Pacific Northwest. Managed forests, on average, have lower amounts of large down wood and snags than do natural forests.

…the density of cavity trees selected and used by cavity-nesters is higher than provided for in current management guidelines.

…Effective approaches to managing decaying wood require that dead wood components of wildlife habitats be viewed within the context of the larger interacting ecosystem.

Effective management of decadence in the forest has been demonstrated to not be a simple matter of mechanical snag creation. In short, concentrating on the development of decadence within living trees has shown to be preferable to simple tree death if snag usage is to be linked with “biological potential” and other Forest Plan management goals. Primarily, this is due to the significant role of the pileated woodpecker, the primary cavity excavator of our Pacific Northwest forests. This species has been described as a “keystone species”[4] due to its pivotal role as a habit modifier in the forests of the Pacific Northwest because it is the only animal “…capable of creating large cavities in hard snags and decadent live trees.”

A wide array of species, including many that are of management concern in the Pacific Northwest, use old pileated nest and roost cavities. In addition, pileateds provide foraging opportunities for other species, accelerate decay processes and nutrient cycling, and may facilitate inoculation by heart-rot fungi and mediate insect outbreaks. Because of the potential keystone role of pileated woodpeckers in Pacific Northwest forests, it may be appropriate to give special attention to their habitat needs in forest management plans and monitoring activities.

Beyond the obvious nesting needs of the northern spotted owl and other species associated with the Northwest Forest Plan (common merganser, silver-haired bat, fisher, American marten, the bufflehead, flammulated owl, and Vaux’s swift), pileated cavities provide denning sites for the equally important tree squirrels:

· http://www.fs.fed.us/pnw/sciencef/scifi60.pdf [5]

The flying squirrel is a centerpiece in what’s called a keystone complex, a web of animals and food, predators and prey, that is especially important in defining the ecosystem.

“A keystone species such as the flying squirrel is easy to define: it’s a species that has a disproportionate influence on the ecosystem relative to its abundance within that ecosys-tem,” Andy Carey, a research biologist with the Pacific Northwest Research Station in Olympia, WA, explains. “A keystone complex is a more complicated idea that recognizes a number of essential components that are building blocks of an ecosystem and supporters of its processes.”

· http://www.fs.fed.us/pnw/pubs/journals/pnw_1995_carey001.pdf [6]).

An understanding of the factors governing sciurid abundance in the Pacific Northwest is essential for prescribing forest management practices for second-growth forests where recovery of Spotted Owl (Strix occidentalis) populations and enhancement of biodiversity are objectives….

Patterns of abundance of the sciurids in old- and managed forests suggests that silvicultural manipulation of vegetation and creative snag or den-tree management could be used in a management strategy to accelerate the development of Spotted Owl habitat in areas where old growth is lacking.

Within the west-side forests of the Pacific Northwest the “keystone ecological functions” of the pileated woodpecker and the various squirrel species necessitate that the implementation of restoration management keeps a focus on their needs. The reason decadence management needs to focus on the needs of the pileated woodpecker is because not all management actions have the same level of success for the pileated. A number of snag creation studies have shown that for creating snags that would be used by pileateds, simple girdling or topping are not effective:

· http://www.eglimpse.org/Assets/APNpdf/Deadwood%20Symposium/CHAPTERELEVENMANAGEMENT/056_Boleyn.pdf [7] (of 1,267 snags, 85% were topped & 11% were girdled or inoculated, 1.5% of created snags showed pileated excavations)

· http://www.fs.fed.us/psw/publications/documents/gtr-181/014_Shea.pdf [8] (“Six years after pheromone-baiting, 44 percent of the trees in both diameter classes had full cavities compared to no cavities in the girdled treatment groups…”)

While the majority of snag creation studies lump pileated woodpecker usage together with other woodpecker use,[9]^{, [10]} doing so acts to obscure the specific relevancy of management actions on habitat needs of the pileated. As noted by Rose et. al. (2001):

Woodpeckers, sapsuckers, and nuthatches are highly specific in their selection of tree species for nesting and roosting, and this selectivity is attributed to the presence of decay fungi.

What is it about the pileateds that need specific management actions that are different from those of other, less “keystone” woodpecker species? It appears that the specific driver needed for snags to be of interest to pileateds is the presence of heartwood rot. As noted by Bull, 2002:

· http://www.fs.fed.us/psw/publications/documents/gtr-181/016_Bull.pdf [11]

…Hollow trees are a unique structural feature in forests. The heartwood in these trees is decayed by heart-rot fungi while the tree is alive (Bull and others 1997). Ninety-five percent of pileated woodpecker roost sites in northeastern Oregon were in hollow trees, and 5 percent were in vacated nest cavities (Bull and others 1992).

…A strong relationship exists between the kind of decay in a tree and what species can use it, particularly for nesting and foraging.

As noted in PNR Science Findings #20 and reinforced in PNR Science Findings #57 in a discussion regarding the pileated woodpecker:

· http://www.fs.fed.us/pnw/sciencef/scifi20.pdf [12]

· http://www.fs.fed.us/pnw/sciencef/scifi57.pdf [13]

Also noted by Rose et. al. (2001):

…strong excavators, such as Williamson’s sapsuckers, pileated woodpeckers, and black-backed woodpeckers, select trees with a sound exterior sapwood shell and decaying heartwood to excavate their nest cavities.

…The soften heartwood of trees colonized by heart-rot fungi provides suitable conditions for excavating a nest chamber, and the living sapwood functions to maintain the tree’s structural integrity.

Beyond the needs of the pileated, heart rot fungi have an important role in forest development independent of their interaction with pileated woodpeckers:

· http://www.fs.fed.us/r10/spf/fhp/top20/Heart-rot.pdf [14]

Heart rot fungi may also facilitate the change from the maturing even-aged stage (i.e., understory reinitiation, to use Oliver and Larson's (1990) terminology) that is in transition to the true old- growth stage. Mortality of dominant trees may be necessary for this transition or at least it speeds the rate of change.

An additional advantage of using heart-rot inoculation is the slow speed of the fungus growth. This allows the tree to continue growing, this is of great importance when inoculating trees in the 12”-20” dbh size range typically found in mid-seral plantations. This is important because in order for pileated excavations to occur and be of value they need trees at least 20” dbh – a tree in short supply in most mid-seral Doug-fir plantations.

Further, recent research has shown that once established the excavating and sounding behavior of the pileateds will act to further spread the fungal spores, making subsequent snag creation activities in the same project area unnecessary (assuming an original inoculation was successful). Removing the need for multiple similar projects in the same area is a clear advantage over mechanical snag creation that would need to be revisited again. The financial incentive to work towards an ecosystem that manages itself is obvious (in spite of inoculation costs that appear to be similar to those for mechanical snag creation[15] without the safety concerns involved with topping trees), and the rewards can be fully realized in those management areas where further active timber management is not anticipated, such as Riparian Reserves and Late Successional Reserves. If topping of trees is going to be pursued, it should be in addition to heart-rot inoculation and following the guidelines developed in the Siuslaw National Forest described by Rose et. al. (2001):

Trees topped above two branch whorls survive and develop new tops. Continued diameter growth in these trees provide higher values as wildlife snags. Large crooks formed in these trees also provide platform nest sites and create future breaking points to form a tall snag.

Girdling trees should not be performed since it kills the tree outright and weakens the structural integrity of the snag making it more likely to fall. As noted by Lindenmayer and Franklin (2002):[16]

Girdling is problematic, however, because (1) sap rot occurs before heart rot, and (2) treefall can occur before there is sufficient top and heart rot to make the snag useful for cavities.

Implementing decadence management in previously thinned areas will maximize the restoration effectiveness of those previous thinning projects. Coupling the recent variable density thinning projects in Riparian Reserves and future projects located in Late Successional Reserves will allow those areas whose management objective is the accelerated development of late seral characteristics to have the best chance for success.

In order to maximize the effectiveness of inoculations, a variety of approaches could be pursued. While there is some evidence that indicates “clumping” may be more beneficial for working with pileateds:

· http://www.fs.fed.us/psw/programs/snrc/staff/laudenslayer/1998_laudenslayer.pdf [17]

Clumping of snags in small patches has been shown to benefit some species, especially pileated woodpeckers.

There isn’t really enough data at this point and some hedging of procedures would be prudent.

Road Removal (decommissioning/obliteration)

· Removing roads from recently managed RR and LSR, especially where there is the opportunity to reduce stream crossings and remove culverts that feed streams directly.

· Remove roads that will act to defragment LSRs

· Remove roads that act to separate LSRs, administratively withdrawn areas, Congressionally withdrawn areas, roadless areas, road removed areas (like Fish Creek) so as to actively reduce forest fragmentation.

Sincerely,

Charlie Ferranti

[1] http://www.fs.fed.us/pnw/pubs/journals/pnw_2002_franklin001.pdf; “Disturbances and structural development of natural forest ecosystems with silvicultural implications, using Douglas-fir forests as an example,” Franklin et. al, Forest Ecology and Management, 2002

[2] Ecological scale and forest development: squirrels, dietary fungi, and vascular plants in managed and unmanaged forests; Wildlife Monographs – a publication of The Wildlife Society; Carey et al., 1999

[3] Wildlife-Habitat Relationships in Oregon and Washington, “Decaying Wood in Pacific Northwest Forests,” p580-623

[4] http://www.fs.fed.us/psw/publications/documents/gtr-181/023_AubryRaley.pdf; The Pileated Woodpecker as a Keystone Habitat Modifier in the Pacific Northwest; Aubry and Raley; PSW-GTR-181; 2002

[5] Squirrles cannot live by truffles alone: a closer look at a Northwest keystone complex; PNW-Science Findings, #60, 2004

[7] Created Snag Monitoring on the Willamette National Forest; Bolyn, Wold, Byford; PSW-GTR-181; 2002

[8] Girdled versus Bark Beetle-created Ponderosa Pine Snags: Utilization by Cavity-dependent Species and Differences in Decay Rate and Insect Diversity;Shea, Laudenslayer, Ferrell, Borys; PSW-GTR-181; 2002.

[9] Long-term monitoring of wildlife leave trees in clearcut harvest units on the Siuslaw National Forest, Northwest Oregon, 1987-2000; Schreiber; Unpublished report. Siuslaw National Forest files. 29pp.; 2000.

[10] Cavity-nester habitat development in artificially made Douglas-Fir snags; Brandeis, Newton, Cole; The Journal of wildlife management; vol. 66; 2002

[11] The Value of Coarse Woody Debris to Vertebrates in the Pacific Northwest; Bull; PSW-GTR-181; 2002

[12] Dead and dying trees: essential for life in the forest; PNW-Science Findings; #20, 1999

[13] Coming home to roost: the pileated woodpecker as ecosystem engineer; PNW-Science Findings, #57, 2003

[14] Are Heart Rot Fungi Major Factors of Disturbance in Gap-Dynamic Forests?; Northwest Science, Vol. 69, No. 4, 1995

[15] http://www.ingentaconnect.com/content/saf/wjaf/1998/00000013/00000003/art00006; Creating Snags and Wildlife Trees in Commercial Forest Landscapes; Western Journal of Applied Forestry; Volume 13, #3

[16] Conserving Forest Biodiversity: a comprehensive multiscaled approach; Lindenmayer and Franklin, Island Press, 2002

[17] Califonia Forest Stewardship Coordinating Committee: Forestland Steward; Winter, 1998