Dear BLM,
Please consider this comment on the proposed Aloha Trout Forest Management Project. This project would log and build roads through up to 1,305 acres of public forests in Oregon’s Coast Range, putting habitat for federally protected imperiled species including marbled murrelet, northern spotted owl, and coastal coho salmon at risk. Thank you for reducing the original proposed project size. Of the proposed alternatives, Sub Alternative 3a is the least harmful because it only conducts commercial thinning without new road construction. However, I still have concerns and recommendations for the BLM.
I am concerned that logging and road building will increase fire risk, which is frequented by community members for educational and recreational purposes including mushrooming, hiking, and birding. I am worried that logging alongside creeks including Honey Grove and Seeley Creeks will introduce sediment, reduce shade, and increase stream temperatures when fish need cool, clean water. Under all alternatives, please consider shifting logging methods from ground based to cable yarding, and implement wet weather hauling restrictions to reduce sediment delivery to streams and improve safety for operators and the community. BLM should utilize existing roads and decommission roads where possible.
The entire Aloha Trout project area is frequented by community members. Students often visit Seely Creek, the headwaters of which would be impacted, and visit nearby Clemens Park to study the water quality of the Alsea River and its tributaries. Logging and road building put forested watersheds at risk by disturbing soils and adding sediment to streams, increasing fire risk, introducing invasive weeds, and damaging habitat for imperiled fish and wildlife species. BLM should conduct direct outreach with community members and the public regarding any logging and associated activities. Signage should be posted physically and digitally with advance notice adequate to notify when any logging, road building, or other associated activities are to occur. A visual buffer of at least 50 feet surrounding the user created trails in the project area should be adopted.
Please also consider the project’s climate and carbon impacts. The project includes areas of older forest and legacy trees, which serve as important habitat and carbon sinks. Coast Range forests are some of the most carbon-dense in the world, with the potential to sequester more carbon on an ongoing basis than almost any other ecosystem. Even if legacy trees are not logged, isolated individual old-growth trees no longer have protected microclimates that provide habitat for older forest dependent species. Legacy trees frequently blow down in storms following the removal of all surrounding trees.
Climate change is resulting in dryer conditions, less predictable weather patterns, and prolonged periods of drought. All these factors increase fire risk to nearby communities. The BLM states in the draft EA that regeneration harvest activities would increase fire risk for at least the next 20 years. The surrounding private lands were recently clearcut (in the last decade) already increasing fire risk locally (slash fuel model). The agency should also analyze increased risk of landslides, similar to those that have recently occurred in the Coast Range during atmospheric river events. Due to the cumulative impacts of nearby clearcuts, the agency should move forward only with commercial thinning in the Aloha Trout project, if any logging is authorized.
Please evaluate the full range of environmental impacts associated with logging and road building and do not treat these forests as a sacrifice zone. Develop an alternative that protects clean drinking water, recreational opportunities, connected fish and wildlife habitat, fire resilience, and carbon sequestration. Incorporate community feedback into project planning efforts and protect forest values beyond timber production.
Thank you.
