Bark letterhead

The CSP “voted” on project priorities based on these categories at the October meeting, and the results were tallied. The top five rated projects were:

Road Decommission- 36

Culvert Replacement- 34

OHV control- 34

Side Channel Creation- 30

In-stream- 28

Remove Vehicles- 28

The result of this prioritization was no surprise, considering that Mt. Hood National Forest documents ranging from the 1990 LRMP to every watershed analysis to the current Invasive Species EIS have identified roads as a focal concern. In the past year the CSP has put significant resources toward moving these priorities forward. First of all, the CSP has provided the Forest Service with recommendations to utilize stewardship contracts to sell over 5,000 acres of timber sales in the Clackamas District, generating approximately $5 million in revenue for restoration work. ALL of these projects have completed the NEPA process, and are either being implemented now or will be awarded soon. It is worth noting that “commercial thinning” was not one of the restoration projects presented in the prioritization list above. The CSP is just beginning in 2007 to tackle the difficult issue of whether or not commercial thinning is in fact restorative in nature, thus attaining the stated goals of the group.

In November, the CSP made recommendations in a formal letter to Forest Supervisor Gary Larsen asking for NEPA analysis to be done on a slate of projects that clearly meet the two top-priority goals of road decommissioning and culvert replacement. Bark has expressed frustration to the CSP in what seems to be the fast-tracking of thinning projects but the lack of resources being dedicated to the group’s restoration priorities. We are excited that this finally happening and look forward to working together to make these projects a reality.

2003 Roads Analysis

While we recognize the 2003 Roads Analysis for Mt. Hood National Forest is not based on enough site-specific data gathering, this document is the only forestwide analysis of the roads. Bark encourages any restoration work, including roads, to be considered in a systemic manner. This is the only approach that can adequately address the cumulative restoration needs in a watershed as large as the Clackamas.

In the brief history of roads in Mt. Hood, summarized in the Roads Analysis, it is stated that approximately 3,000 miles of the current 4,000 were built between 1960 through 1990 (Roads Analysis, 6). With such a high yield of new road building in a short period of time, it would seem useful to recover any existing data on when these newer roads were built and where similar techniques were used. In those decades, significant new practices in logging were developed, including new road construction and building materials. As we begin to look into the restoration opportunities with road obliteration and culvert removal, an understanding of which roads were built in the same period and with the same practices will lead to a more holistic approach to anticipating roads issues occurring in the future and possible efficiency with employing repair efforts.

There are several recommendations in the Roads Analysis that seem particularly applicable to the 2007 Clackamas Restoration work:

· Bark will continue to support the use of the “Low Access Needs and High Environmental Risk” roads as a priority list. Though the Forest Service has discounted this list as computer-generated and not site or scientifically-backed information, it remains a good tool for leading us towards problem areas. As explained by Jim Roden and Bob Bergamini, this analysis did not incorporate field data and is thus not particularly useful. Bark would like to see the roads identified in this list (see Appendix A for list) included in the 2007 Restoration EA so it can be determined if they should be obliterated.

· Avoid use of hard surfaced roads when completing repairs, wherever possible. These not only increase the cost of maintenance, but are worse for runoff and flood events.

· Analyze (if not already done) and complete the recommended culvert removals; Whale Creek and Tag Creek

· In the Wildlife recommendations, the Roads Analysis states that there are currently no records kept about wildlife mortality with regards to roads. Although it seems out of the scope of this project to develop and implement a plan to mitigate the rate of wildlife mortality, Bark supports the minimal effort of devising a reporting and data collection mechanism on this effect of roads on wildlife.

Roads leading to closed campgrounds

Bark was disappointed to see the April posting on Mt. Hood National Forest’s website announcing the closure of several popular recreation sites. Though the storms of November and December 2006 were significant (approximately ten-year flood level), we have concerns that storms of this magnitude are not uncommon and the issue lies in a backlog of road maintenance.

In light of a three year delay in the repair of Road 57, leading to the popular Timothy Lake recreation area, we are concerned that recreation is enough incentive for the Forest Service to prioritize these roads. While recreation may not be integral to the restoration of Mt. Hood’s forests and waterways, access to world class recreation is integral to the economic replacement of ecological damaging activities such as commercial logging. Rather than investing in the expensive task of adding to the logging road system, Bark supports the allocation of road repairs for popular recreation access be second only to funds for the obliteration of roads causing detrimental impacts to our watersheds.

By continuing to create a system of detours upon detours for people determined to access campgrounds, traffic increases on roads not intended for such high usage. These road detours lead cars onto less maintained routes, increasing safety concerns and further increasing the chance for future problems on the detours, as well.

While none of the closed campgrounds are within the Clackamas District, Bark supports the Clackamas District looking at similar delayed projects from past storm activity or road repair needs and consider the importance of recreation access on towns such as Estacada, benefiting from traveler purchases in the coming summer months.

Bark’s Citizen Inventory

For as long as Bark has monitored logging projects on Mt. Hood National Forest, we have recognized the impact of thousands of miles of roads on forest health. Each new timber sale including new road building has added to a cumulative, forest-wide problem.

Blowout on Road 5720-140 after Gee Zee Quarry

The proliferation of off-highway vehicles and other motorized recreation has taken this immense road system and expanded it further with hundreds of miles of user-created, ecologically damaging trails. With this use, an increase of heavily littered campsites and reckless target shooting has reached into new areas of the forest with uncontrollable intensity. While most of the highest impacted areas remain in large part on the outskirts of the forest (La Dee Flats and Road 45, as examples) we have seen an expansion of off-road abuse in the past few years, particularly in areas with continuation of logging.

We understand the current funding reality prevents the Forest Service from completing even the most basic user-rules enforcement, let alone maintenance and repair for roads leading to other low impact, nonmotorized recreation. The expenses of road improvement projects that are in most immediate need are out of the scope of the Clackamas District. However, the problem of aging, crumbling roads will only get increasingly worse and more expensive to remedy. Bark does not see another way to truly begin restoring the Clackamas District and its key watersheds without immediately putting all available resources into effective road closure, decommissioning and obliteration. As well, Bark supports the Forest Service in making a costless first step, by committing to a new road moratorium until a full analysis and plan is put in action towards putting a significant number of roads to bed, permanently.

Blowout and extended culvert due to erosion on Road 4621 just after closure

Beginning this summer, the Forest Service going through a process called Travel Planning. The result of the Travel Plan will be an analysis of all “motorized vehicle” travel in the national forest. In an effort to educate and activate citizens to be a part of the upcoming Travel Plan process, Bark has begun the work of completing a forestwide citizen inventory of the road system in Mt. Hood National Forest. Since January of this year we have trained over 50 people, in the field, to understand the issues of roads in our forests and how to document their current status. We intend to continue this work throughout the summer, extending over to the eastside of Mt. Hood. Currently we have collected data in the Clackamas District, on over 150 official roads. We document failed stream passage, road sagging and erosion, ineffective closures and OHV access points, as well as other important changes in the original road prism. Citizens have walked and biked hundreds of miles to reach and survey chosen road segments.

The CSP has deemed road decommissioning the top restoration priority. Although the Travel Plan will provide forest-wide NEPA for these projects, the 2007 Restoration EA is the appropriate vehicle for analyzing road decommissioning in the Clackamas River watershed. In addition to analyzing the recommendations from the CSP (as described in the November letter to Gary Larsen) Bark requests an analysis of the following list of problem areas found during our extensive road surveys.

Stream Passage:

(Individual crossings, where noted. Otherwise, these roads have shown to have a considerably higher rate of culvert problems and may require looking at the road construction as a possible source for the problem)

5410, Pup Creek crossings and nearby tributaries

4621, extensive culvert replacement, in particular spur 140 and 180

6320-120 and 123, Pink Creek crossing

5720-140, Kelley and Kink Creek drainage

4620, first culvert after Sandstone Creek crossing

6311-170

6311-140

6311-160

6340-130

6300-170

4500-280

4500, approx. 1/2 mile passed spur 320

4630-120

Road Repair and Stabilization

5410, from spur 130 to Dog Creek

4620, from spur 140 to Sandstone Creek (see further notes in comments)

4621-174

4621-175

4621-180

6320, from 6322 to spur 120

6320-120, near the Pink Creek crossing

5720-140, road blowout near Gee Zee Quarry, see photo

6300-015

6300-185

6340-130

6340, from spur 130 for ¼ mile west

6330, last ¼ mile

6311-160

Road Closure

The following roads are intended to be closed, but have signs of vandalism or unlocked gates resulting in an ineffective closure.

5730-140

4645

4671-120

4671-153, OHVs traveling around gate

6311-150

ATVs creating a trail at 4500-340 junction

4500-340, see photo to right

4630-120

5800-135

5410-134

6320-120

The following roads are intended to be closed by earthen berms. Currently, they are ineffective. Earthen berms are often an enticing motorized recreation feature and allow for further access on the closed road with no oversight from law enforcement.

5730-130

4645-130

6300-170

4670-170

4670-012

4671-150

4671-170

4500-045

4620-175, an abandoned truck has been left about 100 yard down the road from the berm

Highlighted Problem

Road 45

The last time Bark sent a volunteer out to Road 45 to take a look at culvert issues, they returned pale and asked, “Were you trying to get us killed?”

Text Box: This truck was stuck on a user-created route off Road 45 for several weeks while the owners continued to impact the area trying to remove it. Road 45 has become our staging ground for everything a person needs to know about the negative effect of roads in the Clackamas District. Road 45 is cracking, sagging, eroding and filled with ineffective stream passage. The many spur roads have consistently plugged culverts, user-created trail systems connecting them and innumerable sites of dumping, reckless bonfire pits, and target shooting unlike anything else in Mt. Hood National Forest. Areas punching out from the road have fooled us to believe clearcutting has occurred without our knowledge of a timber sale. On closer look, we were actually witnessing the puzzling sport of shooting at trees until they fall. The Torch and Helion quarry have been overrun by motorbikes, shooters and an unsettling feeling of lawlessness.

Road 45 is planned to be used for the South Fork thinning project. We urge you to use this opportunity to take serious stock of the situation on this route. Road 45 and the extending roads system is in need of a strategic and extensive restoration plan. This steep and heavily impacted area is stated in the 2003 Roads Analysis to be the most expensive road to maintain in the entire forest (Roads Analysis, 44). Although the 1997 South Fork Clackamas River Watershed Analysis gives recommendations for closure and obliteration along Road 45, we have witnessed many issues that have resulted within the past ten years and these recommendations may not be extensive enough.

Should the Forest Service decide to turn this road system over to an OHV playground, the other users of the area (hikers, campers, mushroomers, birdwatchers, fauna, flora, etc.) will effectively be pushed out of this forest.

Thank you for your consideration of our suggestions. We look forward to hearing which restoration projects the Clackamas District hopes to accomplish in the coming year. This is a truly unique and beloved area of Oregon and we hope to one day see it return to its natural splendor.

Sincerely,

Amy Harwood

Program Director

Bark

APPENDIX A

Figure 19 – Roads with Low Access Needs and High Environmental Risk

Road #		Begin and End Mile Post			Environmental Risk Factor			Access Rating			Length
4620150		0.00 - 0.88			10.00			2			0.812
4630120		0.00 - 0.55			10.00			2			0.518
4621160		0.00 - 0.47			10.00			2			0.433
4621162		0.00 - 0.40			10.00			2			0.334
4600032		0.00 - 0.20			10.00			2			0.197
4631120		0.00 -0.26			10.00			2			0.188
4620160		0.00 - 0.16			10.00			2			0.154
4600031		0.00 - 0.25			10.00			2			0.14
7010025		0.00 - 0.13			10.00			2			0.097
4600028		0.00 - 0.20			10.00			2			0.085
4600265		0.00 - 0.05			10.00			2			0.073
4620013		0.00 - 0.23			9.92			2			0.282
4600267		0.00 - 0.14			9.53			2			0.136
4621150		0.00 - 1.49			9.46			2			1.397
4600038		0.00 - 0.30			9.44			2			0.174
4621017		0.00 - 0.13			9.37			2			0.423
4600030		0.00 - 0.66			9.33			2			0.83
4640011		0.00 - 0.68			9.24			2			0.623
4620014		0.00 - 0.20			9.18			2			0.213
4621015		0.00 - 0.20			8.99			2			0.18
4640120		0.00 - 1.02			8.94			2			1.104
4630140		0.00 - 0.15			8.94			2			0.432
4621014		0.00 - 0.22			8.56			2			0.207
4600242		0.00 - 0.32			8.53			2			0.179
6340120		0.00 - 0.36			8.49			2			0.329
4600037		0.00 - 0.16			8.47			2			0.339
4630031		0.00 - 0.50			8.39			2			0.438
4810140		2.33 - 2.93			8.31			2			0.521
6311140		0.00 - 1.12			8.15			2			1.053
4621140	0.00 - 0.56			8.14			2			0.558
4645000	0.00 - 1.13			8.02			2			1.109
6300170	0.00 - 2.70			8.00			2			2.595
4621000	0.45 - 2.46			8.00			2			1.857
4640150	0.00 - 1.85			8.00			2			1.455
4830120	0.00 - 1.50			8.00			2			1.44
4645130	0.00 - 1.10			8.00			2			1.167
6311160	0.00 - 0.96			8.00			2			0.938
6300185	0.00 - 0.96			8.00			2			0.896
4620130	0.3 - 1.20			8.00			2			0.883
4645120	0.00 - 0.86			8.00			2			0.856
6311150	0.00 - 0.83			8.00			2			0.809
6300183	0.00 - 0.20			8.00			2			0.8
4630150	0.00 - 0.46			8.00			2			0.755
2110260	0.00 - 1.03			8.00			2			0.699
4621022	0.00 - 0.54			8.00			2			0.664
6321150	0.00 - 0.66			8.00			2			0.646
1340640	0.00 - 0.23			8.00			2			0.627
4630012	0.00 - 0.82			8.00			2			0.606
4640012	0.00 - 0.45			8.00			2			0.585
4621130	0.00 - 0.62			8.00			2			0.571
4640016	0.00 - 0.35			8.00			2			0.556
4640140	0.00 - 0.565			8.00			2			0.53
4600203	0.00 - 0.66			8.00			2			0.515
6322140	0.00 - 0.33			8.00			2			0.482
1340011	0.00 - 0.81			8.00			2			0.463
4621200	0.33 - 0.80			8.00			2			0.463
4640130			8.00			2			0.453
4620140	0.00 - 0.43			8.00			2			0.416
4621220	0.00 - 0.57			8.00			2			0.375
1330620	1.70 - 2.10			8.00			2			0.372
4620174	0.00 - 0.37			8.00			2			0.368
4620187	0.00 - 0.33			8.00			2			0.367
4810016	0.00 - 0.61			8.00			2			0.362
4645135	0.00 - 0.57			8.00			2			0.356
6321016	0.00 - 0.40			8.00			2			0.354
4620170	0.00 - 0.35			8.00			2			0.347
4621000	0.00 - 0.35			8.00			2			0.331
4621200	0.00 - 0.33			8.00			2			0.327
6300176	0.00 - 0.25			8.00			2			0.319
4630015	0.00 - 0.18			8.00			2			0.314
6300180	0.00 - 0.31			8.00			2			0.291
4621125	0.00 - 0.27			8.00			2			0.266
6321015	0.00 - 0.26			8.00			2			0.246
6310115	0.00 - 0.27			8.00			2			0.245
4885142	0.00 - 0.30			8.00			2			0.237
2130281	0.00 - 0.23			8.00			2			0.229
4640027	0.00 - 0.22			8.00			2			0.219
4640014	0.00 - 0.22			8.00			2			0.216
4600324	0.00 - 0.26			8.00			2			0.214
4621011	0.00 - 0.20			8.00			2			0.213
4621190	0.00 - 0.46			8.00			2			0.212
4621120	0.00 - 0.16			8.00			2			0.203
6311012	0.00 - 0.20			8.00			2			0.199
4620130	0.10 - 0.30			8.00			2			0.197
6310162	0.00 - 0.20			8.00			2			0.195
6300016	0.00 - 0.18			8.00			2			0.193
6322012	0.00 - 0.20			8.00			2			0.184
1020016	0.00 - 0.10			8.00			2			0.181
4621028	0.00 - 0.18			8.00			2			0.176
4621210	0.00 - 0.17			8.00			2			0.174
6350200	0.00 - 0.27			8.00			2			0.163
6322122	0.00 - 0.17			8.00			2			0.162
4620017	0.00 - 0.05			8.00			2			0.161
4620019	0.00 - 0.15			8.00			2			0.157
7010114	0.00 - 0.20			8.00			2			0.155
4620180	0.50 - 0.64			8.00			2			0.153
6330011	0.00 - 0.10			8.00			2			0.15
6321017	0.00 - 0.17			8.00			2			0.149
4645012	0.00 - 0.21			8.00			2			0.148
1020022	0.00 - 0.17			8.00			2			0.143
4640017	0.00 - 0.12			8.00			2			0.136
4621023	0.00 - 0.21			8.00			2			0.135
4620175	0.00 - 0.10			8.00			2			0.133
4620011	0.00 - 0.14			8.00			2			0.131
4885151	0.00 - 0.13			8.00			2			0.126
2130021	0.00 - 0.30			8.00			2			0.124
6321014	0.00 - 0.16			8.00			2			0.123
4621170	0.00 - 0.13			8.00			2			0.122
4620018	0.00 - 0.11			8.00			2			0.121
6300175	0.00 - 0.17			8.00			2			0.12
4640013	0.00 - 0.13			8.00			2			0.116
6321130	0.00 - 0.20			8.00			2			0.116
7010134	0.00 - 0.08			8.00			2			0.115
4640015	0.00 - 0.13			8.00			2			0.106
4620130	0.00 - 0.10			8.00			2			0.099
4645000	1.13 - 1.23			8.00			2			0.099
4631017	0.00 - 0.32			8.00			2			0.098
4621013	0.00 - 0.12			8.00			2			0.097
6320014	0.00 - 0.04			8.00			2			0.094
6300015	0.00 - 0.15			8.00			2			0.087
4620012	0.00 - 0.14			8.00			2			0.086
4630011	0.00 - 0.16			8.00			2			0.086
2630241	0.00 - 0.25			8.00			2			0.084
6300173	0.00 - 0.07			8.00			2			0.084
7010016	0.00 - 0.60			8.00			2			0.077
4600019	0.00 - 0.10			8.00			2			0.076
6300015	0.15 - 0.28			8.00			2			0.075
7000111	0.00 - 0.07			8.00			2			0.07
6322011	0.00 - 0.13			8.00			2			0.065
6311011	0.00 - 0.15			8.00			2			0.063
6350200	0.27 - 0.37			8.00			2			0.058
6300170	2.70 - 2.75			8.00			2			0.047
4621030	0.00 - 0.15			8.00			2			0.039