BARK PO Box 12065 Portland, OR 97212 www.bark-out.org 503-331-0374

May 21, 2014

Chuck Burley Interfor PO Box 638 Gilchrist, OR 97737 [email protected] Dear Chuck, Bark’s mission is to bring about a transformation of public lands on and around Mt. Hood into a place where natural processes prevail, where wildlife thrives and where local communities have a social, cultural, and economic investment in its restoration and preservation. This letter is in response to your request that we provide evidence of instances in which Interfor has “broken the rules” during its operations in Mount Hood National Forest. Below are summaries of some instances in which this has occurred. Some of these examples were validated by the Forest Service’s own monitoring program for Best Management Practices (BMPs).

1. “Unauthorized activities” at Bass Unit 37 In November 2013, the Clackamas Ranger District issued a waiver in response to Interfor’s request regarding the use of ground-based equipment for logging operations outside the normal operating season of June 1 to October 31, for the Bass Timber Sale. This was done with the assurance that the soils would be monitored for percent moisture as designated in the sale’s contract, that the equipment used would be certified weed-free, and that the agency would oversee the commencement of operations. However, BMPs for soil protection were not followed when employees of the subcontractor Greenup entered Bass Unit 37 and began logging before the Forest Service knew the company had begun operations. As the primary contract holder, Interfor is responsible for activities that commence under their contracts. 1

From Forest Service emails on Tuesday, Nov. 5th: “A reminder that the FS must authorize cutting to begin under this waiver”. The Forest Service did not authorize cutting before it began. “The sale administrator will be monitoring the rainfall so he will be key to giving you and the loggers permission to start”. Again, this did not occur. “It may be that the soils are too wet right now”. This conversation makes it clear to us that during a time in which it was most important for the agency to be monitoring ground-based operations (wet conditions), Interfor should NOT have started operations preemptively. Forest Supervisor Lisa Northrop, in a Nov. 6, 2013 response to a message from Clackamas River District Ranger Mike Chaveas regarding this situation, stated that “based on the unauthorized activities I agree that suspension [of logging] is appropriate”.

2. Results of January 2012 Forest Service Monitoring: In 2012, agency soil scientist Gwen Collier completed monitoring for Best Management Practices in three units where Interfor did not fully “follow the rules”. Whether or not this resulted in significant damage to water quality is irrelevant to our statement that Interfor broke these rules. See summaries of Collier’s findings below: Rotor Unit 5 A landing was not fully seeded and mulched, and the closure to the area was not effective in preventing increased public access to the unit, resulting in additional damage to soil. Swag Unit 24 Detrimental soil conditions existed before entry, and this entry added to it. Bare soil on skid trails with slopes over 20% was not mulched, and sheet erosion was noted. Swag Unit 23 A processor was operating on slopes greater than 40%, and this was not done on a mat of slash as prescribed in the EA. Detrimental soil conditions existed before this entry, and a greater number of skid trails were created than needed in this unit.

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3. Results of Bark’s 2012/2013 Post-logging Monitoring: Swag Unit 23 Two of 12 skid trail segments we measured in this unit were on slopes greater than 35% The “rule” for this kind of activity is spelled out in PDC C4: The use of ground based yarding and felling equipment is prohibited on slopes greater than 35%. Swag Unit 24 Bark volunteers measured a 21 foot wide buffer on a mapped seasonal stream in the unit, with a skid trail on a 30% slope directly above the buffer. Volunteer pictured at left is in the stream channel, and the stump is 21 feet away from where the steep skid trail turns. This is addressed by PDC A6: Streams within the project area must be protected within the buffers as shown in Table 1. Within these buffers tree felling or yarding is prohibited within a minimum 30 ft. no harvest buffer along the active channel of all intermittent streams. Missouri Ridge Unit 1 (Salem BLM) The Project Design Features (PDFs) section of the Decision Rationale limits “ground based operations to relatively dry soil conditions”. Based on what we saw on the ground we are confident in highlighting that soils were not dry while operations were taking place. Deep ruts and compacted mud are good indicators of this. The degree of soil damage on the roads, skid trails and landings is as well. A Molalla resident reported to us that logging was occurring during rainy conditions when he visited the unit in fall 2013. According to the planning document, erosion control measures were to be placed on the roads post-implementation. We found that the only such measures 3

included shallow earthen waterbars, which were not effective in preventing channelization along the roads, carrying sediment down the roadbed (pictured directly below). This road did NOT appear to be fully stabilized.

In one case (pictured below), the ditch next to a waterbar was eroded to mineral soil, and was directing water downhill toward a buffered riparian area.

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We would like to highlight the fact that there are few, if any, other groups on Mt. Hood National Forest that directly involve so many trained volunteers working so hard in the effort to be engaged with, and have a voice in, forest policy and management. Our volunteers work long hours solely because they care deeply about Mt. Hood National Forest. Many of our volunteers have families, full-time jobs, school commitments, and other responsibilities which make it difficult to volunteer. The time spent on these projects by volunteers is often at great personal expense. That said, we believe there is enough evidence to publicly highlight on our website that Interfor has “broken the rules” in the past. If you would like more information regarding the specifics of said examples, we are willing to provide it. In the meantime, we respectfully disagree with Interfor’s claim that it follows all applicable guidelines, and stand behind our statement that Interfor “broke the rules” in some instances. Lastly, we are attaching an agency email string regarding Bass 37 which we quoted in this document, in addition to Gwen Collier’s 2012 monitoring data.

Thank you, /s/Michael Krochta Michael Krochta Forest Watch Coordinator, Bark

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