05/01 Update: Rothstein ruling is upheld by the 9th Circuit Court.
03/99 Update: BLM "remanded" (took) this sale back from the IBLA
judges in the fall of 1998.
Also available:
The Broken Buck Timber Harvest proposes to deforest 120 acres of almost 6 million board feet of old-growth forests. It's located near Brush Creek, about half way between Elkton and Yoncalla. The comment period was over May 28th, but if you want to write something to the BLM about this sale - feel free.
This sale is in matrix land, and it should comply with option 9 regulations, including laws on riparian reserves. Riparian Reserve areas reserve not only creeks and streams, but also "unstable and potentially unstable areas including earthflows". (rod c-31). This timber sale breaks this regulation in a big way. The BLM soil scientists recommended several unstable areas be reserved, but BLM is choosing not to comply with this important rule. See pictures of what happens in this watershed when unstable soils are logged on.
Alan James, in the Silviculture report for Broken Buck, says that some of the units contain trees that average over 200 years old. Some sale areas contain:
"very old Douglas-fir, and other mature conifers.... Many of the trees have been excavated and are being used by cavity nesters.... Ideally, we would reserve this stand until it completely falls apart or burns.... Our current plan classifies this land as GFMA, and no opportunity exists to substitute this stand for a stand of equal size."
There is no law that mandates clearcutting of this sale. Regeneration
sales (clearcutting) results in many of the problems detailed below. Good thing for
the fish and other rural residents in this area that BLM is restricted from using
herbicides - because they would be pouring on the poisons otherwise - clearcutting
always results in brush competing with seedlings. James says in his report "Competing
vegetation... The most effective and least expensive control is with chemical herbicides,
and if the injunction on herbicide use is lifted they would be used..." Heaven
help us.
Landslides threaten soils:
The most frightening part of this timber sale is that it is an area of extremely
fragile, land slide prone soils. The soils report of 4/18/96 was written by BLM soil
scientists Dan Cressy. On page 10, he writes: "Landslides were common in the
general vicinity of this sale during large scale logging operations and road building..."
BLM soil classification for these unstable soils is FGNW.
FGNW: Forest land which is fragile and cannot be suitably mitigated: Limitations due to steep slope gradients where high potentials exist for shallow, debris type landslides even when best management practices are applied.
Besides BLM's own rules, option 9 also requires unstable soils to be set aside, similar to a riparian reserve. The soil scientist gave the FGNW classification to parts of two units, 9B and 17B. But illegally, the areas will not be reserved, they will be 'mitigated' instead.
What is the mitigation? To concentrate the required 6 to 8 leave trees per acre in these areas in hopes that they will prevent landslides. This is in not in compliance with the president's forest plan. If an area has unstable soils, option 9 requires the area to be reserved out of the unit (like a stream) - not using valuable retention trees that are needed for other purposes throughout the units. (ROD C-31).
In fact, the soils scientist speaks to the use of retention trees in this mitigation effort (page 16, soils report): "There are potential pitfalls. The validity of using retention trees for slope protection is largely unproven. Blowdown can eliminate the intended protection and may even trigger a slide...." The results of using retention trees could be: "The greatest consequence of a headwall failure would be at the main drainage coming down the north facing slope of Unit 17A [unit 4 on your map] north of the 17.0 road. A failure there could trigger a debris avalanche which would enter a perennial stream which flows into Brush Creek. The steep facing slope of the middle draw of Unit 9B mentioned earlier in this report shows signs of instability which are borderline in requiring full reserve protection".
Did the soil scientist get the reserve reserve status he says is required? No - it's regeneration harvest (clearcut) all the way, through all the units. It is illegal of BLM to mitigate this area, but that is just what they are going to do!
There is additional dissent within BLM to using retention trees for the wrong purpose. Meeting notes from the 11/13/95 ID team discussions of this sale record the discussion of unit 17B.
"The soil is slipping out, primed for failure, in the scarp area.... [therefore] More leave trees would be retained in the west along the scarp. (emphasis theirs) NOTE: A word of dissent was expressed against this option. It entailed the idea that the ROD 'best management practices' should be followed, in regards to the numbers of trees retained. The BLM should not use the technique of clumping trees in limited areas in order to remove (essentially a clearcut) an excess of trees elsewhere."
On page 5, the EA considers to "Postpone harvests in areas
of fragile soils." But in a brief paragraph, it quickly dismisses this radical
idea because "The areas of fragile soil in all units are suitable for timber
production." What they mean is that they were suitable for the past thousand
years or so.
Burning threatens soils
Landslides is not the only threat to these soils. BLM is also violating its own 'Best
Management Practices' and plans to burn on recommended no-burn areas.
Dan Cressy (the soil scientist) includes a soil classification of Category One in all units (highly sensitive). This is due to the extreme steepness of the terrain. Clearcuts are typically burned after deforestation (slash and burn technique), and on steep soils, the fire can get so hot, all the organic matter and nutrients are volatilized, preventing any future tree growth. Cressy says (pg. 17) that there is a "higher probability of landslides if broadcast burned" on steeper slopes. "Extensive damage of the surface soil's organic matter content and structure in a hot burn would significantly impact soil productivity and on the steep slopes create a dry ravel problem and greatly increase the chances of a slide."
However, in spite of the soil scientist's recommendation to not burn these areas - they will be burned. Why? Because BLM must clearcut and (pg. 17) "compromise between the best management practices for protection of the soil resource and the needs of silviculture.
Roads:
All together, this sale will produce for U.S. taxpayers, 9,880 feet of NEW roads
- that's almost two miles in this land slide prone country with already too many
roads. 3,275 feet of those roads will be deconstructed afterwards, but the scared
mountain will remain forever. Additionally, 2 miles of old roads will be brought
back to life and reconstructed. All total, we have 4 miles of new and renovated roads
that we don't need to spend our money on.
Wildlife:
Now, let's look at the wildlife effected. Three of the old-growth dependent species
in danger of extinction in Douglas County (and indicators for many more species)
are the Northern Spotted Owl (NSO), the Umpqua cutthroat trout and the Coho salmon.
Both fish species are known to exist in the watershed of this sale. In fact, "Action alternatives are determined to be "likely to adversely affect."".. the Coho salmon, especially in the fish bearing stream that occurs directly below unit 17A" - also a unit with unstable soils! Intermittent streams occur adjacent to all units. Unfortunately, because of the moratorium on listing endangered species, the BLM did not have to consult other agencies about clearcutting an area that will likely kill fish.
Don Rivard, BLM fisheries biologist says in his report that the "Effects of the Proposed Timber Sale on Anadromous Salmonid Habit" will be degraded in areas of Water Quality (sediment), Habitat Elements (large woody debris), Channel Condition and dynamics, Flow Hydrology, and Watershed Conditions (due to road density and location as well as previous disturbance history). I wonder - am I the only person to read these reports? If BLM timber sale administrators read it - do they care? Do they feel anything? The answer must be no, otherwise they could not continually just wipe out more habitat. Where does it stop?
Three owl nests are also losing considerable habitat in this sale. The EA says: "Incidental take would result from removal of suitable habitat..." Unfortunately, the USF&W service gave them "an incidental take permit." What's another owl? Just incidental.
"One hundred years ago, runs of wild Coho in coastal Oregon streams were estimated at 1,400,000 fish per year. In the 1970s, the Coho troll fishery provided from $60 to $70 million per year in direct personal income for Oregon coastal communities. By 1988, the salmon harvest (including Chinook) generated $43 million for the Oregon coast economy. In 1993, salmon harvest (Coho fishery now closed) generated only $3.5 million - an 85% reduction of economic benefits in six years. The average number of spawners in 1991-1993 was estimated at 38,000 fish, about 3% of the historical level stated above.... In July 1995, the Umpqua Coho and four other stocks in Oregon, were officially proposed as Endangered by NMFS....
Recently, the [Cutthroat Trout] run size in the North Umpqua has declined precipitously. The average run size between 1986-87 and 1994-95 was 28 fish at the Winchester dam, with no fish counted in 1992-93 and only one in 1994-95. Sea-Run Cutthroat Trout were proposed as Endangered by NMFS on July 8, 1994 in the Umpqua River Basin, with all life forms included in the proposed listing."
BLM itself points its finger directly at clearcutting and road building as the cause of this decline. It mentions no other causes. On page 38, we read:
"At present, the majority of the aquatic habitat conditions in the BHY WAU are quite degraded in comparison to natural, properly functioning conditions.
The equivalent clearcut area during the past twelve years ranges from ten to twenty percent per decade, average road density is over 6 miles/mile, with roads along almost all stream valley bottoms, and there are extensive areas of very recent (1994 and 1995) timber harvesting. All these activities have negatively impacted the aquatic ecosystem...."
It is too bad that the planners of the Broken Buck timber harvest, filled with roadbuilding and clearcutting, didn't read its watershed analysis. Broken Buck timber sale is in the headwaters of Brush Creek, of which the watershed analysis says that "Brush Creek is an extremely important Coho salmon production stream." (page 34) Unfortunately, on page 41 it speaks of what poor shape this important stream is:
"Brush Creek: The overall AHR [aquatic habitat ratings] for the mainstem of Brush Creek is Fair/At Risk. ... The ODFW habitat inventory was conducted before a private clearcut was harvested to the streambank (one tree buffer) along reach 3, thus the overall AHR may actually be lower. Instream structures have been placed in reach 3 by ODFW, to mitigate some of the negative impacts of the clearcut mentioned above. ..."
Why do we, the public, pay for this extensive watershed analysis, and then use it to justify more habitat degradation? We can comment all we want, but the timber planners in BLM appear to only listen to industry's pocketbook. It is quite unfortunate that the clearcut logging rider has suspended all environmental laws, as well as forbidden legal citizen appeals. If all we can do is comment - then let's comment. If we don't speak for our fish, they will die in silence.
Decision To Cut Broken
Buck
June 11, 1996
Roseburg BLM has reached a decision on the Broken Buck Timber Sale. They decided to clearcut it, in spite of their alarming soils report that says areas are land slide prone - one of the highest potentials. The sale is in the Brush Creek drainage, an important salmon habitat, in which we have spent much public money in restoration projects.
Now - for the *big surprise*: The Broken Buck Timber sale will NOT be sold. Instead, this sale will be given to Roseburg Forest Products (RFP) in exchange for a clearcut logging rider sale, Wren 'N Doubt.
Wren 'N Doubt, a Coos Bay BLM 318 sale, has Marbled Murrelets known to be nesting in sale units. We can't very well let RFP out right kill Murrelets. Instead, we will let them out right kill endangered fish and owls.
Broken Buck volume will NOT be counted toward Roseburg's PSQ (sustainable cut volume) for 1996. We will have to do ADDITIONAL clearcuts above what is considered sustainable harvesting. Insanely, Broken Buck will be counted toward the PSQ for the 1990 Coos Bay district volume (with all sale planning costs billed to Roseburg BLM).
The Broken Buck timber sale, in addition to playing with potential land slides into a fish bearing stream, is a "likely to adversely affect" the Umpqua Cutthroat Trout, Coho salmon, and an "Incidental Take Permit" had to be issued for the three owl nests that are losing considerable habitat in this sale.
I believe Broken Buck to be an illegal option 9 sale because option 9 clearly says that areas of unstable soils must be reserved out of sale areas, similar to riparian reserves. BLM soils scientist recommended "reserve" status for sale areas with TPCC classification of: "FGNW: Forest land which is fragile and can not be suitably mitigated". Sadly, the decision is to do a regeneration harvest on the entire sale, and not reserve out the unstable soils.
The Umpqua watershed already has more than its share of fish-killing clearcut rider sales on top of our already high PSQ, higher then most other districts. Now, in addition to all this terrible impact, we now have the trade volume for the Murrelet sales.
However, unlike all other 1996 sales under the 'salvage rider', Broken Buck will be open to citizen appeals. This is because it is a trade, not a sale. The logging rider prohibits citizen appeals on new SALES only. We submitted the appeal. (UPDATE: as of May, 1997, the IBLA has not ruled on our appeal, but the sale is being held up anyway because of its potential to jeopardize the continued existance of the endangered Umpqua Trout.)