Roads

Are there uninventoried roadless areas over 1000 acres in this project? Is there planned logging or road building within them?
The FS, especially in the La Dee (Ladee) Flats area, has not able to effectively block any road due to high OHV abuse. Therefore the assurance that any temporary roads not obliterated by year’s end would be “effectively blocked” can be viewed as nothing more than a capricious assertion without some significant additional discussion.
More roads in an area with that many rogue/illegal roads is ridiculous.
If a subwatershed exceeds the Mt. Hood National Forest Land Resource Management Plan’s (LRMP) standards for road density – no new roads should be constructed or reconstructed. The guidelines of the LRMP were certainly written with logging in mind, so the idea that you need to exceed the LRMP to log is logically absurd. Since the system roads don’t take into account the rogue roads, the total road density in this area is even more extreme than is likely to be admitted.
The illegal OHV roads need to be included in any road density discussion.
Landings attract illegal dumping. This is a particular problem in this area. With the large number of landings planned, and the FS unable to address the current illegal dumping problem, this project will just act to aggravate a problem that is intractable at this time.
Any economic analysis of this project needs to include the costs of added law enforcement for new illegal dumping sites (as many landing traditionally become) and the costs for temporary road closures.

New Density Calculations

I can see how the basal area calculator makes more sense if the trees are different sizes, but since they are even aged plantation what is gained by its use?
Along the same lines as the previous question, while it makes sense to use the RD number if the tree dhb sizes are different, but when the area is going to be thinned in a manner which reduces the heterogeneity of tree diameter, does it still make sense?
Why use same basal area numbers for stands 15 years different in age and between stands that have and haven’t been thinned?
Do basal area numbers convey information when we are not given some idea of the range of dbh found there?
When under the variability entry it lists leave tree spacing as being between 20 and 35, is that within a unit or between various units?
Why are the relative density numbers the same for the “single entry” riparian areas and the multiple entry areas?

Looking for more clarity on local history

The area is described as “plantations ranging in age from 40 to 70 years old.” Just to be sure that there is no misunderstanding on my part it would be helpful if it is confirmed that “plantation” is being used to describe active planting of the trees done under the authority of the USFS rather than passive reseeding by adjacent unburned stands.
Local old-growth density number is not cited or backed-up with historical data. I would expect this type of data to be important when trying to set some sort of RD targets for the Riparian Reserves.
Do the density numbers take into account local “old-growth” conditions that change with watershed, elevation, slope aspect, riparian reserve, dominant species, etc.?
It can be inferred that the replanting after the fire took place over 15 years (“the trees are now approximately 55 to 70 years old”). With the fire occurring in 1929, that would make the final plantings being done in 1950, are we to understand that 20 years after the fire there was no natural (native) regrowth?
Are current dbhs different between riparian and upland?
Are current densities different between riparian and upland?
How much of the North Fork landscape, both FS and BLM will be in a thinned condition after this project is finished? All thinnings of the past 10 years should be added together to get an aggregate “disturbance” picture for the watershed.
How much of the original 15,000 acre burn was transferred to the Forest Service and how much of that has been thinned in the last 10 years?

Purpose and Need

How can the FS cite under the Purpose and Need “enhance and restore diversity” when the thinning is going to remove the smallest diameter trees thereby reducing the structural diversity within the stands?

Wetlands<1 acre

How are wetlands under 1 acre going to be treated? Of particular concern is the statement that “fewer and smaller skips” will be used in the matrix when these are the only listed practice to protect wetlands under 1 acre.
“Skips” for ephemeral streams, streams which are categorized as wetlands < 1 acre, are potentially inappropriate since streams may be longer than the skip size.
A simple spreadsheet listing wetlands under 1 acre and gps coordinate is expected.
Are all wetlands under 1 acre smaller than the skip size?

Prescription

Clearcuts for deer should be done in pre-commercial thins, doing it in mid-seral stands is a deceitful way of clearcut logging without public awareness.
Any assertion that forage areas need development need to include analysis of private timber lands. With the significant amount of clearcutting done on those adjacent lands, the assertion that more forage is needed within the project area is suspect.
Any assertion that forage areas need development need to include analysis of BLM lands. Logging on those BLM adjacent lands may have already created the forage that is needed within the project area is suspect.
The inclusion of some Federal or State documentation regarding the need for forage is long over due since this same claim has been made since 2002. The South Fork Preliminary Analysis may have given a reference (USDA 2004c, p. 72) but I was unable to determine the what the actual reference was and what was being referenced (i.e., that there was declining estimated forage or actually declining deer population numbers).
It is claimed that the need to log previously thinned units is because the previous thinning was homogenous. It also appears that it is being claimed that these same stands will need to be re-thin in the same amount of time as those stands being entered the first time using variable thinning as they would using homogenous thinning – that doesn’t make sense. In other words, if stands thinned “in the past” need to be re-thinned to compensate for the style of thinning previously used, why would these same stands using the new style of thinning need to be re-thinned in the same time frame?
Fertilization is unnecessary because, as noted, these stands are growing so well that they need to be thinned.
How will even the full Riparian Reserves be able to block transmission of the fertilizer at all? If sedimentation modeling in the North Fork Watershed Analysis assumed a 10% sediment delivery from roads 200’ from the stream, there must be an even higher expectation that the far more mobile nitrogen would have a significantly higher delivery to adjacent streams. Further, the mobile nitrogen fertilizer is unlikely to respect the different Riparian Reserve (i.e., perennial vs. intermittent) widths, never mind the non-existent reserve widths for ephemeral streams (termed wetlands under 1 acre) which could act quite effectively in delivering the nitrogen load downstream.
Thinning smallest trees leaves units more homogenous not less homogenous.
While the past and present logging plans occur on the more level terrain (such a La Dee/Ladee Flats), this is also the terrain that is most need by terrestrial mammals, especially in the winter. Added logging will continue the serious degradation of this important habitat.

Riparian

Heavy Riparian Reserve logging has unknown consequences for how well the Riparian Reserves will continue to function as connectivity corridors. What are the references and citations for this approach?
Any patches of laminated root rot that occur in riparian areas should be left untouched since they naturally act to create canopy openings. Not only do they create these openings, but the disease acts to enhance deciduous growth (very important to creating more diversity within conifer forests) by targeting confers (deciduous maple and alder are immune).
Any patches with native tree disease in addition to laminated root rot that occur in riparian areas should be left untouched since they naturally act to create canopy openings and increase structural heterogeneity.
What is meant by “falling any trees within the no-harvest buffer..?” Does this mean that no cut trees would be allowed to fall into the no cut buffer or does this mean that you will be logging within the no-cut buffer?
You need to eliminate the caveat on the 30’ no-cut buffer for intermittent streams. All intermittent streams need a full no-cut buffer with zero reductions in width without any “or less” wording.
The concept that intermittent streams don’t need as large a no-cut buffer as perennial streams is logically flawed. Air-borne dust, rain, and rain-on-snow events – primary non-catastrophic mechanisms for sediment transport into local streams operate equally well for both perennial and intermittent streams. Simply put, intermittent streams (streams with enough water flow that they show either annual deposition or scour) are running when you get either rain or rain-on-snow and need the same level of protection as the perennial streams. Airborne dust from summer road travel deposits in intermittent stream beds and on the surrounding vegetation – this dust will mobilize when it rains and the intermittent streams flows again. There is little difference in terms of sediment transport between perennial and intermittent streams and the use of the smaller -or zero- no-cut buffer appears illogical and poorly reasoned.
The North Fork Watershed Analysis specifically states that on slopes greater than 30%, “vegetation is key” and the difference between perennial and intermittent streams is lost once again, making the reduced protection for the intermittent streams illogical and poorly reasoned.
The North Fork Watershed Analysis states that road segments within 200’ of a stream are assumed to deliver 10% of the potential sediment to the stream through overland flow (p. 2-9). This casts strong doubt on the 50’ no-cut buffer and significantly more doubt on the 30’ or less no-cut buffer.
Under no circumstances are landings appropriate in riparian reserves.
Fertilization is a danger since it is so mobile the changes are that it will end up in the local waterways adding to the nitrogen loading in local streams.
There is a sign on 4610 that indicates that the area has a damaged watershed and people should stay on established roads. There is an extensive number of illegal OHV roads that intersect 4610, what is that illegal road count?
With a damaged watershed, should there be a timber sale of this size adding to the degradation?

Soil

Forest plan standards on detrimental soil conditions were written with logging in mind. If the area exceeds LRMP then there should be no further disturbance in those areas until they are recovered to the LRMP standard.
It is reasonable for the ARP to include past, present, and future BLM and private land use planning, since this information would be required for both FS and FWS to adequately address the impact of the sale on ESA listed species (e.g., northern spotted owl, various anadromous species). Since it is reasonable to assume that the FS has this information, it is reasonable to assume that any ARP numbers that are run include them.