Download CSP comments on the Proposed Action

Michelle Lombardo
Mt. Hood National Forest
16400 Champion Way
Sandy, OR 97055
December 15th, 2010
Dear Michelle,
Thank you for the opportunity to provide comments on the Clackamas Road Decommissioning for Habitat
Restoration project, Increment 2. The Clackamas Stewardship Partners (CSP) is a group of diverse stakeholders
dedicated to restoring ecological function of the Clackamas River Basin while benefiting local economies. As a
collaborative group we have ranked road decommissioning as a high priority restoration activity to improve fish and
wildlife habitat, water quality, and create quality local jobs and therefore are supportive of the Mt. Hood National
Forest’s work to remove unneeded roads for habitat restoration. Addressing the impacts of the Forest’s crumbling
and destructive road system is one of the most important actions we can take to help species and communities
adapt to climate change. We appreciate the Mt. Hood National Forest’s efforts at strategically addressing the
minimum road system.
As a stakeholder that has been engaged throughout the development of this project, we are pleased to see the Mt.
Hood National Forest incorporated our earlier comments in developing the proposed action. The CSP
recommended the 6341, 6330, 7020, and 7030 be included in the project. We appreciate the effort and open
communication on the part of the staff—thank you. The expansion of the scope of the project to include terrestrial
wildlife as well as water quality has better addressed the needs of the forest. The inclusion of longer road segments
and where roads are clustered together provides greater benefit to wildlife and we appreciate these road segments
being included in the proposed action. We also appreciate the detail at explaining/defining road decommissioning
and the associated active and passive treatments. In addition, the Washington Office recently issued guidance to
Forests regarding the systematic need to identify a minimum road system. We appreciate the Mt. Hood National
Forest taking a proactive approach and providing leadership and a framework to other Forests in the Nation
regarding the identification of a minimum road system.
The CSP is supportive of the purpose and need of the project and the comments below reflect our thoughts on the
alternatives. The preliminary assessment identifies three significant issues including potential effects to hunting,
potential effects to vegetation management, and potential effects to the management of the BPA powerline. In
regards to hunting we request the Forest balance the various user groups of the Forest with the wildlife and water
quality gains of road removal. We recommend that the Forest Service demonstrate that many of the roads currently
proposed for road decommissioning are not accessible by vehicle and therefore the proposed action does not limit
access for a large number of the roads. Also, we fully recognize and appreciate that by decommissioning a large
portion of the roads, the road system will be better aligned with current maintenance funding. Therefore the
remaining road system will be better maintained for access and limit environmental impacts.
The second issue identified we largely feel was already incorporated into the proposed action and does not require a
separate alternative. Vegetation management for the next ten years has been reviewed and incorporated into the
timing of road decommissioning. The premise provided on page 18 and analysis regarding revenue from timber
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sales sufficiently paying for certain roads in perpetuity fails to take a comprehensive look at the current realities on
the forest. In addition, by decommissioning certain roads it does not preclude future entry into some of the
plantation stands in the second or third decade, but in the meantime allows the area to recover and provide greater
wildlife and water quality benefits, while not requiring road maintenance funding.
The third and final issue regarding access to the BPA powerline seemed to include a large number of roads (listed
on page 13) and some of them are not even included in the analysis. We request the Forest Service take a hard look
at the roads provided by BPA to ensure they are necessary. The Forest Service should decommission as many roads
as possible by combining access points for the powerline. For roads that are determined to be necessary, they
should be closed by a device at a minimum.
We recognize that only a fraction of the 409 miles of roads listed in Appendix C of the Preliminary Assessment are
slated for immediate decommissioning under Alternative 2. Of the 253 road miles identified for decommissioning,
only 34% (86 of 253 miles) are listed as not needed for plantation thinning prior to decommissioning. Relative to
the full set of 409 road miles, only 21% (86 of 409 miles) of the road miles listed in Appendix C are slated for
immediate decommissioning under Alternative 2. Almost twice as many road miles (41%, or 167 of 409 miles) are
identified for delayed decommissioning because of access needed for plantation thinning prior to decommissioning.
Of these 167 delayed decommissioning road miles, 32% (53 of 167 miles) are needed for existing contracts, 14% (24
of 167 miles) are identified as needed for the Jazz restoration thinning currently being developed in the Collawash,
and 47% (78 of 167 miles) are identified as needed for plantation thinnings in the next 5-10 years.
The CSP would like to participate in the implementation phase of this project by discussing the prioritization of
road decommissioning, identifying and securing funding sources for implementation, and providing multi-party
monitoring. To better enable our ability to partner on this phase we request the Forest Service provide a timeframe
and implementation schedule for road decommissioning.
Thank you for your work to develop the Collawash Road Decommissioning for Habitat Restoration project. We
support the goals of this project and look forward to the project moving forward. Please contact me with any
questions regarding this letter.
Sincerely,
Lisa Moscinski, CSP
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