Bark
P.O.
Box 12065
Portland,
OR 97212
503-331-0374
www.bark-out.org
August 10, 2007
Jim
Roden
Mt.
Hood National Forest
US
Forest Service
595
NW Industrial Way
Estacada,
OR 97023
Dear
Jim:
We
appreciate the opportunity to continue commenting on the upcoming 2007
Clackamas Restoration Projects. We are hopeful to see the multiple pages of
listed roads. The common understanding that roads must be a part of the
restoration efforts in Mt. Hood is important to Bark and other stakeholders. We
see this list of proposed projects as a good step forward. Thank you for accepting
these comments and considering our position as the environmental analysis
proceeds.
Road 45
As
was pointed out in our preliminary comments, Road 45 is of deep concern to us.
We understand that some of the larger, cultural issues of off-highway vehicle
use, target practice and other illegal uses of the forest will take time to
remedy. The culvert replacements will be a good start to beginning the actual
restorative work.
However,
it was discouraging to see that none of the spur roads on Road 45 were included
for decommissioning. In fact, they have all been prescribed berms which are
notoriously ineffective against OHVs. Please include in the final Environmental
Assessment a more extensive plan to decommission and remove roads along 45. In
particular spur road 340 has multiple sights of poorly constructed culverts and
such intensive OHV use it is hard to imagine how a berm will prevent such a
popular site from being penetrated.
4620, Sandstone
We
included information about 4620 in our preliminary comments:
“A
beaver dam is keeping a pond from draining into the culvert. At the moment,
this culvert has a large drop in the outlet and is creating unnecessary
erosion. If the beaver dam should break, it will likely overwhelm the culvert
and potentially blowout the road with overflow. Because of the steep slope of
the creek on the downhill side of the culvert, a blowout could have significant
detrimental impacts on Sandstone Creek. This culvert should be replaced, or at
the least, reinforcements should be put in place to ensure the road’s
stability.”
In
addition, the segment of road just before Sandstone Creek has raised serious
safety concerns for those driving on the road and the fish below. We were utterly
befuddled that this landslide area was not included in the restoration work.
Road 4620 will be used for extensive logging use in the coming year for the
2007 Thin. Bark strongly encourages the Forest Service to analyze revegetation
of the unstable slope and culvert replacement on this road.
Gates & Berms
The
road mileage in the proposed action adds up to a hefty 100+ miles of road
closure. However, this is potentially deceiving. Based on Bark field surveys,
we have seen all types of closures eventually be ineffective. Therefore, these
closures are not actually achieving much restoration. With regards to many of
these original logging roads, an effective device should be the baseline to
ensure effective closures. We understand that the resources for environmental
analysis of restoration work are not only limited, but take valuable time.
Consider
limiting resources spent assessing the environmental impacts of a gate or berm
and actually analyzing effective road removal, revegetation and permanent
decommissioning where it is most needed. With another impending storm season
around the corner, this time seems better spent ensuring that more productive
restoration work is occurring.
Culvert Replacement
In
the Restoration 2003 Environmental Assessment, one of the mitigation measures
proposed was for concern of fine sediment in the streams through culvert
replacement. "During the culvert replacement projects, stream flow would
be guided or diverted away from the reconstruction site." (Restoration
2003 EA, 12) In the upcoming assessment for roads work in the Clackamas, please
elaborate on this process. In particular, if the road is traversing a
significant slope or the streambed has steep banks this process would be a
complicated measure to take. Although we certainly appreciate mitigation
measures taken to avoid an increase in sedimentation, diverted streams in road
construction often causes further erosion issues. This mitigation measure is a
good example of the shortsightedness in road construction. Road beds do not
just traverse well-behaved streams. Road systems traverse entire watersheds and
impact drainages before we ever see the results in sedimentation of a stream.
In
the environmental assessment for roads work, it seems integral to understand
the geologic makeup of the soil for which the road is built on. The relative
porosity of a rock type has a direct effect on the earthflow and watershed
movement. Recognition of these characteristics will be important for
environmental assessment of how restoration work should be implemented.
In
Bark's data collection, we have witnessed a repeated issue with road
engineering; inadequate ditch relief. Roads intercept the hydrology of a forest
in many ways. Rainfall collects on the roads and is channelized. Groundwater is
deterred by the compressed soil of fillslope. Waterways become so narrowly
channeled that pooling begins to occur. All of these factors can lead to water
diverting off a road and into the road ditch. Repeatedly we have seen these
ditches leading to culverts that are intended to allow a stream or natural
hydrology feature pass beneath the road. The use of stream culverts, doubling as a
ditch relief culvert is completely unacceptable. We urge you in all
culvert repair and replacement to ensure that an additional ditch relief
culvert is placed in the road allowing runoff to filtrate through topsoil, at
least before entering into the watershed.
The
most critical factor in erosion control, particularly around culverts, is
vegetation. If there are any signs of discernable erosion or fluvial impact to
the road such as plugged culverts, ditches created by a diverted streamflow or
gullies on the hillslope and in the road, planting of native grasses and soil
mending species such as alder or other appropriate vegetation is absolutely
necessary for the recovery of these areas. The proposed action includes almost
no mention of revegetation. Please include this road restoration technique as
an action in the forthcoming EA.
Closure & Decommissioning
In
the scoping notice, there are a number of acknowledged decommissioning and
closure project types. As well, it seems there is a range of reasons and
determinations for work to take place on chosen roads. The proposed action
brushes on these reasons and options, which is helpful to understanding the
scope of the proposal. However, as opportunity for restoration work becomes
available, in particular with regards to road issues, we ask the Forest Service
to present a clear definition of what actions these project types include.
Culled
from the proposed action, we understand the following project types to include
some of the following actions:
Road Closure – an impediment to
unauthorized travel would be placed or replaced at the entrance to a road. This
may include a range of removable impediments for future use from a locked gate
to berm placement.
Road Decommissioning – removal of gravel surface,
culvert removal, scarification of road surface, pulling back unstable fill
slopes, berm placement (gates or debris, boulder or root wad piling), planting
on disturbed soils and removing the road from the system.
From
these definitions we have questions and concerns we hope to see answered in the
upcoming EA. With regards to road closure, we have consistently seen berms made
with piled soil be a passable point of access for off-highway vehicle (OHV) motorists.
Should dirt berms be an option in these projects, how will the Forest Service
ensure their success in stopping use of the “closed” road? Though boulders may
have an additional upfront cost of hauling material from another place in the
forest, they appear to be more effective and require less maintenance in the
long run.
With
regards to road decommissioning, we take this opportunity very seriously. We
see the decommissioning and, more specifically, the obliteration of roads from
the national forest as integral to the restoration of Mt. Hood's forests. Many
of the roads causing the most egregious threats to watersheds are those
originally built for the purpose of logging and were never conditioned for
regular citizen use or properly removed from the landscape. Indeed, this past
year's storm events revealed weakness in roads throughout the national forest. The
Clackamas District bears the burden of not only a legacy of intense road
density, but also a prolific hydrological landscape. We do not see signs of progress
should the district continue to only reserve restoration work for funding
through the commercial timber program. Almost every proposed logging project
necessitates new road construction, furthering the very problem we are hoping
to remedy.
In
the list provided in the Proposed Action, there are several points where we
wonder if there is simply a lack of data and field data on the part of the
Forest Service. For instance, the proposed action for road 6300-170 is to “reinforce
a breached berm.” In May we sent volunteers out to that road. We sent you a
short description of our findings in a preliminary response to this Restoration
work:
“Out
of the 25 culverts, most are in poor condition, plugged or buried. Vehicles are
passing around an earthen berm, taking advantage of the spur road access from
the road. The Peat Creek crossing is acting as a ditch relief culvert and now
has a 4ft. drop on the outlet. The Paste Creek crossing has a 6ft. drop and
pooling on the inlet and outlet. This culvert is either an oval or a crushed
circular culvert. Either way, it appears compromised.”
To
elaborate:
·
There
are five undocumented roads stemming from this road, added to the two official
roads leading from the road.
·
Besides
the 3 active creek crossings, most of the culverts channeling the water from
the ditches are plugged.
·
Scotchbroom
lines much of the road
·
There
are unstable slopes in an area that appear to have had repair work done in the
past
·
Our
experienced tracking volunteer identified coyote, deer and bear scat, as well
as seeing elk and grouse while on the road.
·
This
road goes through a meadow and a wetland
·
Peat
and Paste Creek have 4-6ft. drops on the outflow, causing pooling and the
potential for erosion and sedimentation. Both of these creeks are direct
tributaries into an anadromous rearing area of the Collowash River.
Based
on our findings, we would like clarification of how a road with this many
problems could be neglected in restoration work. The notes for this road
include “need for thin.” The EA should provide justification for continuing to
put resources into keeping a road like 6300-170, when deciding against total
road and culvert removal. Although Bark has provided cursory data, we are
hoping to utilize a database in the future to share our findings which are
currently in hard copy and difficult to synthesize in an effective and larger
representation.
It
seems within the scope of this environmental assessment to include any and all
known plans for closed and decommissioned roads in the future. Surface erosion
from roads, which is one of the greatest risks to water quality, is more tied
to the use of the road than even the time elapsed since construction. Therefore
if closure plans are to leave this road accessible to future logging, it should
be analyzed whether this area will actually be able to handle logging trucks on
the road. Years of weathering will leave the original structure of the road
much worse off than the current status, but nothing compared to a fully loaded
down logging truck pushing the road wider, weighing down the fillslope and
creating airborne particles and dust. Of course, not to mention that previous
rill erosion in the roadways ideal for the introduction of invasive plants from
the wheel treads of a poorly washed truck.
Moving
forward with road-related restoration work, the public must be clear on the
Forest Service definitions of road decommissioning. Total road removal is not
included anywhere in this document. But why not? For the scope of this effort
it seems entirely appropriate to assess the best restoration action possible.
We understand that improper road removal can create short-term detrimental
effects that may be more adverse and risky than simply leaving the road to
recover. Would decommissioning a road be a commitment from the Forest Service
that it would not be used again? Understanding that the work could mean
different things site-specifically, the anticipated future needs of these areas
is integral to determining the success of their recovery.
The
National Forest Management Act, 16 USC 1608(b) and the Forest Service
Manual 7703.1 state that the agency is
required to “reestablish vegetation cover on any unnecessary roadway or area
disturbed by road construction on National Forest System lands within 10 years
after termination of the activity that required its use and construction.” We
see this restoration work as a good first step in compliance with this mandate.
In order to fully comply with this rule, it seems important to:
·
be
explicit in why a road is necessary to keep past that 10 year age
·
include
revegetation in all road decommissioning and
·
include
in the EA the age and usage status of roads
Data Collection
In
Northwest Ecosystems Alliance v. USFS, Case No. C96-0451-R, the decision
confirmed that the Forest Service is required to inventory all roads within a forest, even non-system roads with are no longer
used. In response to page 6, “decommissioning would be a data-keeping exercise
to remove the road from the Forest’s road system data base,” Bark could not
disagree more. It is a reasonable expectation that the Forest Service keep
record of road building, maintenance and removal of past, present and future
roads. With the GIS resources available to the Forest Service, this should, in
no way be a hindrance to the process.
In
fact, Bark feels strongly that poor record-keeping has been an impetus to the
problem. There is little doubt or disagreement that road density is a threat to
our forests and watersheds. And yet there appears to be absolutely no efforts
being made to make longterm plans to ensure the recovery of these forests. With
the list provided in the Proposed Action we see virtually no addressing of the
site-specific needs beyond a generic proposed action. The Notes section gives a
grim insight into the actual data that exists about these roads.
Looking Forestwide
Bark
has been spending much of our summer working to inventory the roads in Mt. Hood
National Forest. This data-collection effort has been an amazing opportunity to
get citizens out onto the roads and begin to understand the issues firsthand.
We feel confident that our education efforts will result in support for
congressional representatives to begin to take action in allocating restoration
and road removal funding. We continue to confirm that the problem of roads in
Mt. Hood National Forest is a forestwide issue, and true restoration will only be
successful with a broader commitment by the forest to stop building new
roads, implement more stringent expectations for road repair and begin to
prioritize the roads the roads that provide safe access to world-class
recreation and those roads that should be permanently removed.
Thank
you for considering our comments. We look forward to hearing how this
opportunity will move forward.
Amy
Harwood
Program
Director
Sources:
Forman,
Richard T.T., et al, Road Ecology:
Science and Solutions. Island Press,
Washington
DC, 2002.
Wemple, B.C., Frederick J. Swanson
and Julia A. Jones, Forest Roads and Geomorphic Process Interactions,
Cascase Range, Oregon, Earth Process
and Landforms. John Wiley & Sons, Ltd., 2000.
Gucinski, Hermann, Forest
Roads: A Synthesis of Scientific Information, United States Department of
Agriculture Forest Service, 2000.