Talking Points for Submitting Comments on the Crystal Clear Timber Sale

Comments must be submitted by Friday, September 22nd by 4:30pm to:

Casey Gatz, Team Leader

Barlow Ranger District

Mt. Hood National Forest

780 NE Court Street

Dufur, OR 97021

comments-pacificnorthwest-mthood-barlow@fs.fed.us

Join us at the Bark office on Thursday 9/21 for a Comment Writing Workshop!

Talking points to consider:

As stated by the Forest Service on numerous occasions, the actual rationale for this project is commercial, not restorative. Re-write the Environmental Assessment’s (EA) “Purpose and Need” for this project to reflect this motivation.

 

This timber sale is 10,000 acres larger than any proposed within the last few decades. Given the size and complexity of this project, prepare an Environmental Impact Statement which fully discloses its effect on the environment.

 

This EA did not contain an adequate analysis of the cumulative impacts of the timber sale, in addition to past, present and reasonably foreseeable future projects. Complete a full cumulative impacts analysis.

 

The 2017 Rim Fire burned approximately 300 acres of forest within the Crystal Clear project area. Remove all forest effected by the Rim Fire from the Proposed Action.

 

Mature trees are important for wildlife habitat, carbon storage, and wildfire resiliency, and are common in units of this timber sale. Implement an 18 inch diameter no-cut limit for this project to protect these values.

 

Much of the CCR project area is in Fire Regime Condition Class 1 (FRCC 1), which is described as areas within the natural range of variability of vegetation characteristics including fuel composition, fire frequency, severity and pattern, and other associated disturbances. Remove all units proposed for logging within FRCC 1, which are healthy forest stands in no need of logging.

 

The Crystal Clear Timber Sale proposes to log in 12,725 acres of Critical Habitat for northern spotted owls, and would remove 2,551 acres of high-quality owl habitat. Remove all proposed logging from areas within suitable habitat for threatened owls.

 

Crystal Clear Timber Sale proposes to log in 100s of acres of mature and old growth forest stands. Remove all logging in stands older than 80 years old, and in forests displaying the agency’s “desired future conditions” of large diameter trees, well developed understory, snags and down woody debris.

 

The Crystal Clear Timber Sale proposes to log mature, high quality habitat in Late Successional Reserves (LSRs), a land allocation which under the Northwest Forest Plan directs the Forest Service to protect and promote old growth forest characteristics. Remove logging proposed in units within LSRs that already include large trees and other habitat needed by species dependent on old growth forests.

 

The Crystal Clear Timber Sale units include species protected under the Northwest Forest Plan’s Survey and Manage program. Buffer all sensitive species on the Survey and Manage list from destructive logging.

 

The Crystal Clear EA includes a page and a half on climate change. Complete a full review of this project’s relationship to climate change in our region, and pursue an alternative that limits greenhouse gas emissions and promotes carbon storage.

 

The Crystal Clear project area includes approximately 555 miles of roads, or 2.59 miles of road per square mile. Reduce road density in the Crystal Clear area though active road decommissioning.

 

The Crystal Clear project area is a popular destination for Off Highway Vehicle (OHV) use, which sometimes results in unauthorized trail creation and illegal use of closed roads. Help reduce OHV impacts on the forest by limiting road construction and thoroughly closing all temporary routes used for logging after the project is complete.

 

The Crystal Clear Timber Sale would severely degrade 233 acres of forest designated by the Mt. Hood Forest Plan for conservation of the American marten. Remove proposed logging from forest designated as Pine Marten Reserves.