Sunday, July 1, 2018

Clean Slate Timber Sale: Old-Growth Forests and Northern Spotted Owl Habitat Targeted for Removal

Unit 3-11 of the Clean Slate Timber Sale contains uncut, old-growth forest on fragile soils. The unit would be logged to between 25%-35% canopy cover and Northern spotted owl habitat would be removed.
Throughout 2017, local residents organized and worked hard to shut down the southwestern portion of Grants Pass BLM's Pickett West Timber Sale outside Selma, Oregon on Deer Creek. This portion of the Pickett West Timber Sale proposed to log over 1,500 acres of old forest habitat and was withdrawn due to significant public opposition, effective community organizing and unacceptable impacts to the red tree vole, a preferred prey species of the threatened Northern spotted owl.

Although this was a significant victory, many of us knew it was not the last struggle over ancient forest habitat in the Deer Creek Valley. Portions of the Deer Creek Watershed have been identified as "Timber Harvest Landbase" in the BLM's 2016 Resource Management Plan (RMP), meaning the BLM intends to log these stands to meet their annual timber quota. Although some of the stands included in the "Timber Harvest Landbase" are old-growth forest, the BLM values them only for the logs they will produce.

Following cancellation of the Pickett West Timber Sale, the Grants Pass District BLM announced a new timber sale in the Deer Creek Watershed called the Clean Slate Timber Sale. An Environmental Assessment (EA) was recently released and is currently open for public comment. 

Unfortunately, the sale is not operating from a clean slate (pun intended), and units from the Pickett West Timber Sale have been included in the Clean Slate project. The Clean Slate Timber Sale targets some of the last stands of complex, old-growth forest at the headwaters of Thompson Creek and McMullian Creek.

The BLM admits in the Clean Slate EA, "Nearly all the BLM administered lands contained in the Clean Slate planning area have had some form of commercial timber management in the last eight decades. About half has undergone some form of clear-cut or regeneration harvest." (Clean Slate EA, P. 65). 

Ancient uncut forest is a rarity in the Clean Slate Planning Area. The BLM is proposing to heavily log some of the last intact forest in the area, including unit 3-11.
The fact that nearly the entire planning area has been previously logged, and about half has been clearcut, makes the remaining late successional forest exponentially more important than ever before. The complex, old forest habitats proposed for logging in the Clean Slate Timber Sale should be canceled to protect, what are admittedly, the last remaining late successional habitats in the area. 

The retention of these last old forests will ensure that habitat for late successional species, such as the Pacific fisher, the Northern spotted owl and its prey species, remain on the landscape. Retaining the last old forests will also protect and preserve the most fire resistant portions of the landscape. 

The Clean Slate EA proposes to heavily log 175 acres of late successional or old-growth forest to between 25% and 35% canopy cover. The EA also proposes 461 acres of commercial logging, 450 acres of which will completely remove Northern spotted owl habitat.  The BLM admits that this habitat will take at least 50 years to recover, and according to the new RMP will then again be ready for additional timber harvest, "therefore closed canopy conditions are not expected to be regained in the foreseeable future." (Clean Slate EA, p. 90). This constitutes a complete loss of old-growth characteristics, and Northern spotted owl habitat. 

Unit 9-5 in the Clean Slate Timber Sale contains complex, old-growth forest habitat, beautiful hardwood groves and minimal fuel loading. 
Proposed logging in currently complex, old forest habitats will disproportionately impact Northern spotted owl prey species. According to the EA, proposed treatments in NRF [Nesting, Roosting, Foraging] habitat contain, "stands that currently have well established middle and top layer structures. Some units have ground and understory cover. These stands many have populations of flying squirrels, red tree voles, and woodrats because of the increased structure such as cavities, platforms and layered vegetation providing cover from predators. These stands would be heavily thinned" and would subsequently not be expected to "maintain stable populations of flying squirrels or red tree voles, or may have reduced density levels, and may not function as secure foraging habitat for spotted owls due to lower canopy cover levels." (Clean Slate EA, P. 94).

Logging these units will also remove large, fire resistant trees while also increasing fuel loads. Logging operations will generate highly flammable slash and drastically reduce canopy cover. The soil disturbance and increased sunlight associated with yarding activities and canopy cover removal will encourage shrubby understory growth, as well as tanoak and young conifer regeneration. The prescriptions for the Clean Slate project were specifically designed to meet annual timber quotas, not to reduce fuel loading or increase forest health.

Instead of reducing fuel loads, the canopy gaps intended to encourage regeneration of young, early-seral vegetation will create a "brush fuel type" (Clean Slate EA, p. 192) that could increase future fire severity and decrease the effectiveness of fire suppression activities adjacent to the community of Selma, Oregon. These canopy gaps are embedded within all proposed thinning units and will represent up to 30% of the stand. 

"For 5 to 20 years following planting, the overall fire hazard would increase in these stands." (Clean Slate EA, p. 192).


Dense understory fuel loads developed in response to previous thinning treatments in unit 3-9. Proposed treatments in the Clean Slate Timber Sale will open canopies even more drastically, encouraging an aggressive understory shrub response and an increase in fuel loading.

The forests of the Deer Creek watershed were not historically dry forests with open stand conditions and a low-severity, high frequency fire regime as the BLM claims. The Deer Creek watershed averages between 50 and 70 inches of rain per year and grows relatively moist, productive forest associations. The Doug fir/tanoak and Doug fir/live oak plant associations grow lush forests dominated by a mixed-severity fire regime. Slopes are often steep and soils very rocky, with outcrops and rocky talus-like slopes, shaded by large old conifers and beautiful groves of hardwoods including tanoak, live oak and madrone.

A view northwest from the Kerby Peak Lookout in 1934.
Early landscape photographs of the Deer Creek Watershed in 1934 show a mixed habitat, with closed canopied forests dominating the landscape, especially on north- and east-facing exposures, in gulches, riparian areas and on the lower 1/3 of the slopes. On south-facing ridges forests often mingle with small, early successional openings located near the ridges, summits and most exposed portions of the landscape. These openings appear to be either associated with serpentine soils — such as the south face of Round Top Mountain — or fire. They contain young, chaparral habitats, early successional forest regenerating from wildfire, and on the lower slopes adjacent to the valley, logged over stands impacted by human settlement. 

The patterns of the mosaic in 1934 show a history of mixed-severity fire and relatively limited human development. The open canopied forest described in the Clean Slate EA is a rarity on the landscape in 1934, when a much more active fire regime influenced the region and much less commercial logging had taken place. The BLM is claiming that these forests were open habitats with large populations of pine and oak, yet the soils, precipitation levels, plant associations and historic photographs demonstrate otherwise. 

Rather than recreating the historic landscape, the BLM will create highly unstable, degraded habitats — novel ecosystems with little resemblance to natural fire-adapted forest communities. The open forest hypothesis, is in this case, is a thinly veiled excuse to justify the heavy timber extraction and excessive canopy cover reduction envisioned in the highly controversial and still heavily litigated 2016 RMP.


Unit 9-5
Unit 9-5 contains a beautiful mix of hardwoods and large, old Douglas fir. The unit is one of the last remaining late successional habitats in the McMullian Creek watershed.

Unit 9-5 is located on an extremely steep, north-facing slope at the headwaters of McMullian Creek. McMullian Creek drains into Lake Selmac and has been heavily logged from top to bottom. The vast majority of this watershed has been converted into fiber plantations, including large swaths of both BLM and private timber land. The upper McMullian Creek Watershed also has the highest road density in the planning area, at an astounding 7.78 miles of road per square mile. The BLM has proposed two new "temporary" roads to access unit 9-5 in the Clean Slate project.

Unit 9-5 is one of the only remaining fragments of old forest in the entire McMullian Creek watershed, surrounded by clearcuts and young, simplified plantation stands, it is also a refuge for wildlife. The unit consists of massive old fir and sugar pine, among dense tangles of tanoak and beautiful groves of mossy live oak. The slopes are incredibly steep and covered in rocky talus, making them particularly slow to regenerate following logging operations. 

The western portion of the unit faces northeast and supports a dense tangle of multi-stemmed tanoak and massive, widely spaced Douglas firs. The overstory layer is broken and complex, with groves of old-growth fir towering above the secondary canopy of hardwoods. Portions of the stand are completely unmanaged and contain intact biological legacies not otherwise found in the McMullan Creek watershed. 

A small headwater fork of McMullian Creek dissects the unit at its center, trickling through moist, fern laden streambanks and down beautiful cascades. The large, old trees and their massive root systems, as well as the downed wood they eventually deposit along the small, swift moving stream provides stability and habitat, while their canopies provide shade, moderating the habitat, creating climate refugia and cooling the stream. This headwater stream provides connectivity for species such as the Northern spotted owl and Pacific fisher, it also provides thermal cover for local ungulates such as deer, and protection for resting and denning habitat for black bear. 

Numerous red tree vole nest sites have been identified within unit 9-5 and populations of other Northern spotted owl prey species, such as flying squirrel are also likely to live here. The forest is currently identified as Nesting, Roosting and Foraging (NRF) habitat for the Northern spotted owl, meaning it provides important habitat for the spotted owl's entire life cycle. Following logging treatments, spotted owl habitat would be "removed," meaning it would not provide even the most basic habitat elements and would likely be avoided by spotted owls and their prey species, including the red tree vole and flying squirrel.
The eastern half of unit 9-5 contains incredible stands of live oak and Douglas fir on steep, rocky slopes.

To the east, the unit faces northwest and supports a distinctly different forest type. Beautiful groves of mossy live oak grow from steep talus slopes and shaded rock outcrops. A complex mosaic of massive old growth fir and sugar pine grow in groupings and as solitary old individuals above a lower canopy of live oak. The soils are harsh and rocky, but shaded by old trees and covered in dense moss beds, that likely support the lungless Del Norte salamander. The species breaths through its skin and lives in the mossy talus, where cold, moist conditions are available year round. The shade and cooling effect of large old trees is essential to this species, and its specific habitat requirements include late successional characteristics, relatively high levels of canopy cover, and often, moss covered talus habitat. All habitat requirements are present in unit 9-5.

The Del Norte salamander also has a very small home range and cannot effectively disperse from damaged habitats. Impacts from the Clean Slate Timber Sale could drastically reduce populations of Del Norte salamanders, significantly impact available habitat and/or create extirpation of localized populations. 

Unit 9-5 should be withdrawn from the Clean Slate Timber Sale.

Unit 3-11
This photograph depicts the logging "mark" in unit 3-11. The two 30"+ DBH trees in the foreground are unmarked, meaning they would be logged in the Clean Slate Timber Sale. The trees in the background contain a red-hash mark and would be retained in logging operations.

Unit 3-11 is located at the headwaters of Thompson Creek. The stand consists of beautiful old-growth forest on extremely steep and rocky slopes. Large portions of the stand have never been logged and contain complex, late successional forest habitat. The stand is also located within an important connectivity corridor linking the ridges to the stream below. The corridor contains mostly mature forest habitat in a sea of plantation stands and relatively fresh clearcuts.

The habitat complexity, high canopy cover, adequate snag and downed wood habitat, canopy layering and thermal cover provide important habitat for the Northern spotted owl and its prey species such as the red tree vole and flying squirrel. In fact, numerous red tree vole nests have been located within the stand. Unit 3-11 should be protected under Recovery Action 32 of the Northern Spotted Owl Revised Recovery Plan, due to its complex forest habitats and intact biological legacies. 

Part of the reason unit 3-11 has never been logged is due to its classification in the Timber Productivity Capability Classification (TPCC). The TPCC is utilized by the agency to identify fragile soils where timber harvest and road construction should be avoided. A large portion of unit 3-11 was considered too rocky and unstable to build roads or sustain timber harvest. Rather than avoid this rocky, unproductive and unstable area, the BLM simply changed the TPCC classification to allow logging the fragile soils formerly identified in unit 3-11 (Clean Slate EA, p. 218).  

The mark in unit 3-11 is a red "leave tree mark," meaning the trees marked with red paint would be retained in logging operations. As you can see in this photograph, the four large trees in the background would be logged while one tree marked red would be retained. Notice the suppressed understory growth and minimal fuel loading associated with closed canopied late successional forest in the area.
The heavily logged stands adjacent to unit 3-11 are choked with heavy fuel loads of brush, regenerating hardwoods and young, highly flammable fir trees. At the same time, the broken, old growth canopy found in unit 3-11 is moderating fuel loads by suppressing understory growth and maintaining cool, moist habitat conditions. These stands and their towering old growth trees, are not only the most productive wildlife habitat in the area, they are also the most fire resistant portion of this heavily altered landscape.

Although the soils are poor, trees over 70" in diameter have managed to grow from the rocky substrate. Moss-covered tanoak and towering old Douglas fir rise above the rugged slopes, creating a cool, protective, multi-layered canopy. Although the large conifers are relatively open spaced and scattered about in majestic old groupings, the closed canopy conditions create a cool, moist habitat, sheltering the stand from heavy winds and temperature extremes. The understory is lush and abundant with tangles of vine maple and more open slopes carpeted in vanilla leaf, Oregon grape and rocky scree.

The slopes are extremely steep, but are punctuated by small, flat benches. These are old depositional sites associated with historic landslides. They are now colonized in spectacular old groves of fir, cedar, tanoak and a few sugar pine. The deep soils, old forests and relatively gentle terrain provides productive growing conditions and additional capacity to retain soil moisture. 

The complex ancient forest in unit 3-11 is proposed for heavy industrial logging in the Clean Slate Timber Sale. Unit 3-11 should be canceled.

Unit 3-10
The previously unlogged portion of unit 3-9 will be heavily logged in the Clean Slate Timber Sale. This photograph was taken after the timber sale mark, which shows that only one tree will be retained in this beautiful grove.

Unit 3-10 consists of mature and late successional forest habitat in the same connectivity corridor as unit 3-11. Although most of the stand was commercially thinned, much of the habitat still contains mature forest and relatively large, old trees. A small portion of the unit at its northeast corner has never been logged and contains a concentration of large, old trees with relatively closed canopy conditions. The heavy canopy cover has suppressed understory growth, naturally limiting fuel loads and increasing fire resilience. 

Other portions of the stand have been heavily thinned, and have responded with increased fuel loading. The fuel loads are now extreme and the stands are so heavily choked with understory growth that they can hardly be walked through. The impenetrable understory of dense shrubs, tall regenerating hardwoods and highly flammable conifer regeneration will significantly increase future fire severity and impact fire suppression crews' ability to manage or control a fire while it is still small. 

The current condition in large portions of unit 3-10 does consist of extreme fuel loading and overly dense understory conditions, yet this condition is more associated with previous logging than fire suppression. Prescriptions proposed in the Clean Slate Timber Sale appear more intensive than those previously implemented in unit 3-10 and will only make the problem worse.

The stand should be deferred from commercial harvest to allow canopy conditions to recover and again suppress understory growth.  


Unit 3-9
Unit 3-9 lies directly below unit 3-11 on very steep, rocky slopes above Thompson Creek. The unit has been previously logged, but still contains large, old-growth trees, significant heterogeneity and relatively healthy forest habitats. Unit 3-9 is also located in the same connectivity corridor as unit 3-11.

The eastern portion of the unit consists of healthy mid-seral/mature forest habitat, with natural decadence and complexity, as well as minimal fuel loading. The western portion contains many large, old Douglas fir trees towering above a secondary canopy of live oak. The stand is developing naturally into complex, mid to late successional habitat and should be maintained for connectivity, late successional wildlife habitat, and to encourage fire resilience. 

The level of canopy reduction proposed in the Clean Slate Timber Sale will drastically increase fuel loading by encouraging a heavy understory shrub response and removing large, fire resistant trees. 

Unit 3-9 is currently not in need of management to maintain the stand in a desirable condition and should be withdrawn from further consideration in the Clean Slate Timber Sale.  

Unit 21-12
All the trees in this photograph will be removed in logging operations in unit 21-12. The mark in this unit is extremely heavy and will increase fuel loading directly adjacent to residential properties on Thompson Creek.

Unit 21-12 is located on a west-facing slope above Thompson Creek and represents an important low-elevation forest habitat. The stand consists of mid to late successional Douglas fir, sugar pine, live oak, madrone and tanoak. 

Much of the stand is dominated by large, relatively fire resistant Douglas fir, but significant populations of sugar pine colonize the western-most portion of the unit. On this western face, numerous large, old sugar pine and Douglas fir grow in groupings and scattered groves. The BLM has proposed extremely heavy logging in this portion of the stand, retaining very little but the scattered pine trees. Many large, old fir trees between 24" and 32" DBH are marked for removal and the hardwood component is likely to be badly damaged during logging operations. 

The sugar pine marked red would be retained while Douglas fir (including large trees over 30" DBH) would be virtually eliminated from the western half of unit 21-12.
Fuel loading is likely to increase adjacent to private residential properties on Thompson Creek Road due to the excessive levels of large tree removal and canopy reduction. The reduction of canopy cover to between 25% and 35%, with large, 1-4 acre openings scattered throughout the stand will encourage a dramatic understory response. The EA admits that harvested stands will experience increased fuel loading for between at least 5 and 20 years, putting the residents on Thompson Creek at risk. 

The eastern portion of the stand is more closed and is dissected by a number of small draws. The forest contains closed canopy groves of Douglas fir and sugar pine. The more piney eastern portion of the stand is dispersal habitat, while this more productive eastern portion is classified as Nesting, Roosting and Foraging habitat. The area is also located within the home range of two Northern spotted owl nest sites. All Northern spotted owl habitat will be removed due to canopy cover loss and the removal of large trees and other essential habitat elements.

A large section of road reconstruction is necessary to access unit 21-12 and portions of the unit will be subjected to ground-based yarding. The proposed logging prescriptions in unit 21-12 will significantly impact soils, fuel loading, community fire safety and wildlife habitat. Unit 21-12 should be withdrawn from further consideration in the Clean Slate Timber Sale. 

Unit 22-5
Unit 22-5 consists of lush forest on a north-facing slope. Portions of the stand has been previously logged, but also contains many large, old fire resistant trees. Other portions have never been commercially harvested. 

Large Douglas fir dominate the stand, with a secondary canopy of mossy tanoak and a dense understory of evergreen huckleberry. The canopy structure is relatively open and has naturally developed a dense woody understory.

The stand will simply not benefit from the proposed logging treatments and canopy reduction; understory huckleberry and tanoak response will make conifer regeneration extremely difficult. Fuel loading will significantly increase as brush and stump sprouting hardwoods species already present will further dominate the stand.  

Unit 22-5 is located within the home range of two Northern spotted owls and on the boundary of a third home range. The unit is currently classified as dispersal habitat, but would be removed due to canopy reduction and the loss of habitat complexity. Many large, old trees would be removed to achieve the proposed canopy cover targets, opening new ground for brush conversion.

Unit 22-5 should be withdrawn from further consideration in the Clean Slate Timber Sale

Please Comment Now on the Clean Slate Timber Sale!

Send Comments To: 
Allen Bollschweiler
Grants Pass Interagency Office
2164 NE Spaulding Ave. 
Grants Pass, Oregon 97526

or via email at: 
shicks@blm.gov

Talking Points:
  • The EA states that nearly the entire planning area has been logged and about half has been clearcut. Unlogged and late successional stands like those found in units 3-11 and 9-5 should be canceled to protect the last remaining late successional habitat in the project area.
  • Unit 3-11 meets all the criteria of Recovery Action 32 and should be protected as complex, late successional habitat. 
  • Units 3-11, 3-9, 3-10, 9-5, 21-12 & 22-5 should be canceled to maintain late successional and connectivity habitat. These units also contain fire resistant, old forest that should be deferred from treatment in the Clean Slate Timber Sale.
  • The portions of unit 3-11 previously classified as "Fragile Soils," and therefore not allocated for timber harvest or road building, should be deferred from treatment and appropriately reclassified as "fragile" to protect soil resources and avoid reforestation failures.
  • The level of canopy reduction proposed will increase fuel loading and encourage an aggressive understory shrub response. The Clean Slate EA admits that openings created in all timber sale units will increase fuel loads for at least 5 to 20 years. These opening will be embedded within all logging units in up to 30% of each unit.
  • Fire safety for the community of Selma, Oregon should not be compromised for timber production. The 2016 RMP claims that active management will increase resilience to wildfire effects, the findings in the Clean Slate EA demonstrate that logging operations will increase fuel loading in all treated stands due to canopy reduction and gap creation.
  • The BLM is proposing to remove 450 acres of Northern spotted owl habitat and assumed that they will not regain suitable habitat conditions in the foreseeable future. This is inconsistent with the Revised Recovery Plan for the Northern spotted owl that recommends active management to create and maintain NSO habitat. The BLM has proposed a total long-term loss of NSO habitat in the Clean Slate Timber Sale.  

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