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Dear Paul Tigan and staff of Mary’s Peak Field Office of the Bureau of Land Management,

Thank you for the opportunity to comment on the Wild Goose Timber Harvest Environmental
Assessment. I am concerned about the adverse impacts to fish and wildlife, the nearby Area of
Critical Environmental Concern, recreation, and the climate. I suggest that the thinning
alternative be selected, since it would still achieve the required volume of timber for Northwest
Oregon District’s allowable sale quantity for the Salem sustained yield unit in 2019 while
minimizing negative environmental effects.

The Mill Creek Watershed is one of my favorite places to recreate. I enjoy fishing for cutthroat
trout, snorkeling to view native fish in their environment, and hiking in the remnant patches of
old-growth forest to photograph the large and unique trees. One of my favorite qualities of the
area is the presence of madrone trees and manzanita shrubs. These plants are common in
southwest Oregon but they are also present in the Mill Creek Watershed. Most of the habitat
has been converted into dense timber plantations but I frequently find madrones and manzanita
in the older forest patches and in thinned areas. The conservation of the unique forest type and
the fish and wildlife habitat in the Mill Creek Watershed is important to me. Because I enjoy
exploring public land in the Mill Creek Watershed and other tributaries of the South Yamhill
River, I hope to give back by taking care of the places I love. To help fulfill this goal, I volunteer
for the Native Fish Society as a River Steward for the Yamhill River Watershed, where I identify
and pursue conservation opportunities. I also weigh in on land use actions that will affect my
recreation, quality of life, and the fish and wildlife species I care about.

The project area is in a large block of BLM administered land, not the checkerboard pattern
common for O&C lands in western Oregon. Section 1.3 of the Wild Goose Timber Harvest EA
states that “The contiguous blocks of BLM-administered land provide an opportunity to manage
forests at the landscape-level”. This provides opportunity for habitat conservation over a large
contiguous area. The thinning alternative would retain dispersal habitat and connectivity
between suitable habitat for the spotted owl, marbled murrelet, and red tree vole while providing
timber production. The proposed action of 651 acres of regeneration harvest would cultivate a
timber plantation and waste the opportunity to provide complex and high quality habitat at the
landscape level. The state of Oregon allows regeneration harvest on a maximum of 120
contiguous acres at a time on private forestlands. 651 acres of regeneration harvest seems like
overkill and would be a stark contrast to the numerous, smaller clearcuts on nearby private
timberland instead of helping to mitigate for their intensive management.

Mill Creek Ridge Area of Critical Environmental Concern (ACEC) is a biodiversity hotspot that
lies adjacent to the harvest area. Mill Creek Ridge ACEC has plant and animal life unique to
southwest Oregon as well as plants and animals found in the Oregon Coast Range and
Willamette Valley. It has a similar habitat type to nearby Rickreall Ridge ACEC, which exhibits a
diverse blend of plant and animal species unique to southwest Oregon, the Willamette Valley,
and the Oregon Coast Range. The habitat type represents what may have been more common
in a past, warmer climate and is significant for the preservation of biodiversity and research
(Exeter and Schuller 2010). The proposed action of regeneration harvest around the Mill Creek
Ridge ACEC would compromise the integrity of the unique and rare habitat type. I suggest the
thinning alternative be selected to keep the surrounding area forested. Also, the adjacent road
along the ridge top should be decommissioned. If regeneration harvest occurs, a forested buffer
should be left around the Mill Creek ACEC to preserve its integrity.

The Wild Goose timber sale lies within the Mill Creek-Gooseneck Extensive Recreation
Management Area and the Mill Creek Recreation Site is nearby. The city of Salem is a half hour
away and the area offers recreational opportunities to a large number of people in the form of
swimming, fishing, hiking, horseback riding, and target shooting. The proposed action of
regeneration harvest on 651 acres would severely impact the visual resources. The thinning
alternative would allow about 40% of the canopy cover to remain in the project area and retain
visual resources while providing timber production.

Oregon Coast Range forests have the ability to store a significant amount of carbon because of
abundant rain and low frequency of fire. Reduced logging on public lands in Oregon has been
suggested by researchers at the Oregon State University Department of Forest Ecosystems and
Society as a way to store more carbon. The forestry industry in Oregon is a significant source of
the state’s carbon emissions. Reducing logging on public land requires no new technology and
is an effective way to combat carbon emissions. The length of time that carbon is stored in
Oregon forests is much longer than the time that carbon is stored in wood products (Law et al
2018). The proposed action of regeneration harvest would greatly reduce the ability of 651
acres of public land to retain carbon. While the amount of carbon storage that would be
foregone with the timber sale is probably immeasurable compared to statewide carbon
emissions, It would still contribute to the cumulative carbon emissions of logging on private and
public lands in Oregon. Additionally, it is stated in Appendix C, section 1 that “Climate change
provides uncertainty that reserves will function as intended and that planned timber harvest
levels can be attained, with the uncertainty increasing over time.” Maximizing regeneration
harvest maximizes short-term profits while contributing to carbon emissions much more than the
thinning or no action alternatives. This goes against the duty of the BLM to “manage revested
Oregon and California (O&C) lands for sustained yield timber production under the statutory
requirements of the O&C Act”. If the sustained yield of future timber production is jeopardized by
climate change, of which forestry in Oregon is a significant contributor, timber harvest in the
present should be more conservative and maximize the ability of the forest to store carbon.

Wind throw is expected to affect retained trees after regeneration harvest. In the case of wind
throw after harvest, the tree retention would be reduced and the wind-thrown trees could be
salvaged. According to Appendix C, section 2, “Thinning is not likely to result in a high incidence
of windthrow or broken tops due to wind”. The occurrence of a large wind throw event in the
area is also mentioned in section 2. I recommend that the commercial thinning alternative be
selected to reduce the possibility of windthrow and further loss of forest cover.

Appendix C, section 12 details that mid-seral habitat makes up the majority of forestland in the
Mill Creek watershed. According to Appendix C, page 10: “Thinning harvest would have no
effect on the age class distribution.” Thinning would provide timber extraction while facilitating
the development of late-seral forest. For this reason, the commercial thinning alternative would
be preferable to the proposed action.

The presence of ESA-listed Upper Willamette Steelhead in Lower Mill Creek and Gooseneck
Creek is not to be taken lightly. Appendix C, section 15 states that “Historically, the Mill Creek
watershed and tributaries have not supported large numbers of UWR steelhead (ODFW 1990).
Based on the very low number of UWR steelhead currently accessing the Upper Willamette
River system (ODFW 2018), the large area UWR steelhead can distribute in the Willamette
area, and the low historic numbers in Mill Creek, the presence of UWR steelhead in the project
area would be irregular and scarce.” The presence or absence of UWR steelhead cannot simply
be speculated by guessing that there may be few or no individuals in the project area. Low
population numbers leave species more vulnerable to extinction and are not a reason to
discount their significance. I regularly snorkel Mill Creek and other tributaries of the South
Yamhill River. Since the Upper Willamette River steelhead population plummeted in 2017, I
have continued to observe juvenile steelhead in Mill Creek, Willamina Creek, and Rock Creek.
Coho salmon, cutthroat trout, and pacific lamprey are also present in the Mill Creek Watershed.
I have observed a seasonal phenomenon in late summer, when salmonids concentrate below
the anadromous barrier in Mill Creek, perhaps seeking thermal refuge. I intend to monitor this
closely in the future to determine the importance of cold water coming from upper Mill Creek to
the survival of salmonids in the South Yamhill Watershed, especially during drought years. The
effects of a large-scale timber sale on fish, especially ESA-listed Upper Willamette River
steelhead, should be analyzed in detail.

Under Appendix C, section 16, Instream Flow, the hydrologic recovery impact of regeneration
harvest is expected to be less than 1.26%. Also, “The No action and Thinning Alternatives
would result in less or no changes in peak flow risk”. There is a significant amount of
clearcutting on private land in the area that contributes to peak flow risk. The 1.26% would be
added to this. Additionally, Perry and Jones (2016) found that water use by young Douglas fir
trees on timber plantations reduced streamflow by 50% compared to 150+ year old forests of
mixed species. The young timber plantation following regeneration harvest would result in less
water in surrounding streams. This will affect fish in the Mill Creek Watershed, including
ESA-listed Upper Willamette River steelhead. Furthermore, the water rights for Mill Creek
exceed the actual flow for 8.5 months of the year (Bower et al 1999). Gooseneck Creek and Mill
Creek are both 303(d) listed for temperature and dissolved oxygen (Oregon DEQ 2012). By
choosing the thinning alternative for the Wild Goose Timber Harvest and allowing the forest to
grow to a late seral stage, the water quantity and quality will be improved. Even a small
difference is important to fish.
Suspended sediment and its negative effects on salmonids is well-studied (Newcombe and
Jensen 1996). I am concerned about the effects of 651 acres of regeneration harvest on
sedimentation in streams, even with riparian buffers. Due to the size of the project and the the
method of harvest proposed, there would be a large amount of exposed soil prone to runoff and
landslides. The thinning alternative would retain a 35-40% forest density, which would provide
greater soil stability.

The proposed action is considered likely to adversely affect critical habitat for the marbled
murrelet as stated in Section 3.3.2, Issue 3. Since the commercial thinning alternative is
considered not likely to adversely affect critical habitat for the marbled murrelet, I recommend
the thinning alternative.

The culvert where Gooseneck Road crosses Rowell Creek is a barrier to juvenile salmonids and
a partial barrier to adult salmonids (Luke Westphal, Director of Greater Yamhill Watershed
Council, personal communication, 2019). Coho salmon have been observed spawning
upstream of this culvert. Salmonids, especially juveniles, would benefit from improved access.
Replacing this culvert would help mitigate adverse environmental effects of the Wild Goose
Timber Harvest, especially if the proposed action of regeneration harvest is selected.
Also, placing trees with attached rootwads into GooseNeck and/or Mill Creek is an opportunity
to provide habitat for native salmonids. Trees for stream habitat enhancement should be
selected and felled as part of the timber harvest.

Thank you for the time spent reading my comments. I hope they will be taken into account when
deciding between the alternatives proposed in the Wild Goose Timber Harvest Environmental
Assessment. I realize that the BLM is mandated to manage O&C lands for sustained timber
yield and hope that the thinning alternative is selected to provide timber and minimize the
adverse environmental impacts to this unique and beautiful area.


Andrew Chione
Yamhill River Steward
Native Fish Society

Works Cited

2012. Water Quality Assessment - Oregon's 2012 Integrated Report Assessment Database and
303(d) List [Internet]. Oregon Department of Environmental Quality; [cited 2019 Feb 22].
Available from:

Bower RJ, Lupoli C, Quandt T. 1992. Mill Watershed Assessment. Yamhill Basin Council.
p57-58. Available from:

Exeter, R and Schuller, R. 2010. Rickreall Ridge: area of critical and environmental concern -
guidebook. USDI-BLM. p11. Available from:

Law BE, Hudiburg TW, Berner LT, Kent JJ, Buotte PC, and Harmon ME 2018. Land use
strategies to mitigate climate change in carbon dense temperate forests. PNAS 115 (14):
3663-3668. Available from:

Perry TD, Jones JA. 2016. Summer streamflow deficits from regenerating Douglas-fir forest in
the Pacific Northwest, USA. Ecohydrology 10 (2). Available from: