I really appreciate the opportunity to comment on the “School bus” timber sale through the Oregon Department of Forestry’s Forest Activity Electronic Reporting and Notification System (FERNS) on the central Oregon Coast. I can see that substantial time and resources have been spent putting this logging plan together, and want to share my gratitude for your considerations of the forest practices act and the threatened and endangered species throughout the Drift Creek watershed. As I have communicated in the past, I have personal connections to this area going back over a century and have spent much of my life trying to further my knowledge of the area. The purpose of this correspondence is to share what I have learned, and to see if there are any operational changes you would be willing to discuss with regards to Hancock Natural Resources’ sustainability and responsible investing initiative. I appreciate that the FERNs notification system (NOAP #’s 2021–553–06382 and 2021–553–06383) allowed me to learn about this logging operation in advance of mobilization, and I hope the following background and interconnected issues I raise are constructive. My apologies in advance for the length of this comment.
History:
As is with all lands within the Drift Creek Watershed, this logging proposal is in the homelands of indigenous people which signed treaties with the United States Government to reserve their territory and rights. The decedents are now members of the Confederated Tribes of the Siletz Indians located just a short distance away from the proposed logging, in Siletz, Oregon.
The land was originally a part of the “Western Oregon Treaties” and “Coast Reservation” but was taken away from tribal people through an act of congress in 1862. The original land survey (completed in 1899–1904) denotes Township 8 South, Range 9 West, Sections 17, 18, 19, and 20 to be open to settlers. The original deed of the northern property in Section 17 cites the authority of the Land Act of 1820 to sell public lands for $1.50 an acre through the general land office. President Theodore Roosevelt signed the piece of paper which privatized and deeded ownership for the first time in 1907, with George Huntzicker of Marshfield, Wisconsin buying 160 acres.
I don’t know the land history nearly as well as previous areas I’ve frequented on the mainstem of Drift Creek, but as with most of the tributary names in the area, Sampson, Fowler, Nelson, and Smith Creeks are all named after Lincoln County settlers. The original GLO maps denote the that “H. Meyers” as the first owner of the Northwest corner of section 17 (Township 8S, Range 9W), and “W.E. Lacey” as the owner of the Northeast and Southeast corners of the section. The Southwest corner of section 17 shows that Huntzicker, a white man from Wisconsin, held the original land patent which cost him $240 in 1907 ($6,818 in 2021 dollars). Huntzicker promptly sold the 160 acres for $10 (a loss) to J.H. Fildew of St. Johns, Michigan that same year.
However, by 1930 this land, and the northern half of section 20 had moved into the ownership of Russeltown Timber Company of Seattle, Washington. Adjacent tracts were owned by Boeing in Seattle, and were likely cut for the first time when the price of timber increased because of World War I. Ownership was then assumed by Louis Werner of St. Louis under the Werner Timber Company, until they sold it for $1 to the Columbia River Paper Mills in 1948.
From there, the property was sold to Boise Cascade by 1961 and has since remained in corporate timber ownership under various names including NW Oregon Land and Timber LLC, Meriwether Timber LLC, Tristar Timber (which assumed business as a Delaware LLC), and finally with the John Hancock Life Insurance Company. Their subsidiary, Hancock Natural Resources Group, values the sustainable management of natural resources. In the northwest the HNRG also happens to manage Systems Global, an Oregon Foreign Limited Liability Company which currently owns the southern portion of the forested stand proposed for logging (the portions of the logging operations in section 20).
John Hancock prides themselves as “One of the largest life insurers and fastest growing asset managers in the United States, John Hancock supports approximately 10 million Americans with a broad range of financial products, including life insurance, annuities, investments, 401(k) plans, and college savings plans. As of March September 30, 2019, John Hancock’s assets under management and administration were $478.8 billion.”
Geology:
The dominant bedrock of the site is comprised of Siletz River Volcanics. This igneous geology consists of aphanitic to porphyritic vesicular pillow flows, tuff-breccia, massive lava flows, and sills of tholeiitic and alkalic basalt. Much of the geology is of marine origin and has been interpreted to be seamounts and oceanic crust that collided with the North American Plate — this is unique on the Oregon Coast and is often referred to as “Siletzia”. This accretion is thought to be the dominant force creating the steep terrain, and likely started occurring in the Paleocene to Eocene Epochs occurring between 55–50 million years ago.
Soils:
- The soils at this site are andesitic, meaning they are primarily composed of weathered volcanics. This material is lighter weight and contains more pore space (for water or air) compared to almost every other soil order. The soil near the ridge line road is comprised of Formander-Hemcross complex, and includes the Klistan soil further down the steeper regions of the property.
- The depth of soils (measured from solid parent material to the surface) are similarly shallow over the surrounding areas at the backslope (60–80% slopes). There are between a few to ~160 inches of soil on the entire landscape that is both needed for regrowing trees, and at a risk of landslide and more severe erosive forces after logging (more on that below). The ability for trees to grow is heavily dependent the depth of soil they can utilize.
- Invaluable information on soil properties is avalible on the United States Department of Agriculture and University of California Davis SoilWeb database. Erosion potential is Severe-Very Severe in all three soil types. As with previous recommendations on steep slopes with the potential for severe erosion, the Natural Resource Conservation Service considers this poorly suited for forestry purposes. This is for Sections 17 and 20 in the very specific area within the harvest boundary.
Cultural Considerations:
As you read my next section about the landslide concerns for this area, I would urge you to carefully consider the cultural implications of your proposed actions. The Siletz Tribe has a cultural fishing site downstream which targets salmon returning to Drift Creek. This is one of only a few tribal fishing sites that are permitted on the Oregon Coast, and something you may want to consider discussing with the tribe. As you are considering future plans for this property, and your larger ownership within the drift creek watershed, I would encourage you to gain the tribes perspective on desired conditions and for ways you can support tribal fishing, foraging, and hunting opportunities. Sampson Creek is the most important spawning tributary for anadromous fish within the one of the last cultural fishing locations on the Oregon Coast.
Landslides:
Landslides and debris torrents need to be a major concern for land management actions within this logging operation. This is because of the combination of shallow soils, igneous geology, and very steep topography. The Oregon Department of Geology and Mineral Industries denotes this area is rated “high” on the regional landslide susceptibility index, while the Oregon Department of Forestry designates this a “high landslide hazard location”. A technical note related to forest practices in these circumstances can be found on the Oregon Department of Forestry’s website, with additional considerations that should be noted for windthrow —which has been written extensively about in British Columbia
A more detailed analysis has been completed by David Korte, a PhD at Kent State University. His dissertation entitled “Landslide distribution and susceptibility, material properties, and soil loss estimates for the Drift Creek Watershed” notes that annual soil loss from the upper Drift Creek are almost twice what they are in lower Drift Creek — and that the highest landslide derived sediment soil loss occurred in logging areas. I was surprised to learn that the magnitude of average soil loss can be on the order of 65 tons per acre, per year. With the 4 largest landslide prone areas in the basin, that total jumps to 281.5 tons/acre/year.
Recent harvests across the whole of private lands in upper Drift Creek and Sampson Creek have seen both landslides and debris torrents as commonplace occurrences — not just a legacy impact of past forest practices. I’m curious to hear about how these areas in shallow soils that are at risk of sliding intersect with your harvest management plan.
While many people consider landslides to be exclusively negative, their potential to deliver large woody debris and gravel to Coho salmon habitat is often very important to the development of stream channel complexity. This usually happens through debris torrents on forested slopes with large woody debris originating in non-fish bearing streams which mobilize that material into spawning and rearing habitat. Mapping of debris-torrent prone areas has been completed for the whole Siletz Watershed, and this harvest unit has at least 3 areas of high risk that deserve a more thorough analysis. I’m happy to provide more detailed maps of this modeling effort if that would be helpful, but I would recommend that these areas be buffered so that if/when debris flows occur that large woody debris can be deposited into the stream network.
Within the operations layout I am also concerned about mudslides and roads-driven sedimentation to the stream network. Since the previous logging adjacent of this property, surface slides and the destabilization of the road bed has been apparent. I’d be curious to learn more about this from your roads engineer, if a strategy could be implemented to either decommission, or better drain the road network so these impacts can be mitigated in the Sampson Creek sub-basin. As seen in much of the watershed, legacy roads constructed with side-cast material against the basalt bedrock can easily can initiate a landslide if it isn’t properly maintained. Additionally, deep fills with small culverts can easily plug and washout unused roads.
Water:
Drift Creek is listed as 303(d) impaired for high temperature, sediment, bacteria, and dissolved oxygen. The organic carbon tied to sediments, combined with increased light in the riparian zone exacerbates these water quality dynamics. I know the MidCoast Total Maximum Daily Load working group has been ongoing for years. There is a lot more detailed information that you are probably aware of, but from what I understand the nitrogen/phosphorus/carbon fluxes can be significantly altered by forestry activities.
As noted above in the landslide section, the increase in sediment to the stream network has implications far downstream including changes in hyporheic flow, swings in dissolved oxygen, and changes in the basal food web. Water quantity considerations are also of concern, as Drift Creek drops to very low flows in the summertime. Several springs and small forested springs exist within the timber sale boundary (as is common in where headwater streams terminate). Another technical note describing management prescriptions for operations around these features can be found on the Oregon Department of Forestry Website. I would also appreciate any insights you have with regards to management prescriptions you’ve taken in other areas, and what considerations you have for identifying and working around seeps and springs.
In the drinking water source assessment for Drift Creek the streams within the “School Bus” logging operation are listed for high erosion potential. The drinking water intake for Kernville-Gleneden Beach, which relies on an infiltration gallery, has to deal with sediment impacts. Lincoln City’s emergency water intake is also located downstream and is increasingly concerned about low flows during peak use.
Beyond erosion potential, other concerns have been elevated around the depletion of surface water flows by young Douglas Fir plantations. In experimental forests up to 50% of the surface streamflow has been lost, posing a risk to downstream organisms and to communities that rely on scarce drinking water sources in the dry summer and fall months. Anecdotally, Sampson Creek flows have been very low over the past few years after a large majority of the sub-basin’s headwaters have been logged within the last 2 decades.
Habitat Restoration:
With past management actions (stream cleaning, road building, forest management) impacting the surrounding aquatic habitat within upper Sampson Creek, the Salmon Drift Creek watershed council completed an in-stream restoration project downstream in 2004. Large Woody debris was flown in with a Chinook Helicopter to encourage the development of complex aquatic habitat. In total, the project cost upwards of $300,000 with most of the funds coming from the Oregon Watershed Enhancement Board.
Additionally, several riparian plantings have occurred to try to encourage conifer development in alder dominated riparian areas (caused from past logging conducted without streamside buffers). While some of the project goals were met, much of the large woody debris was deposited downstream in flood events. There is additional need to ensure complex habitat develops in Sampson Creek and the upslope delivery of large woody debris vis-a-vie landslides is an important ecosystem function to encourage.
Water Typing
Two determinations of the Fish / Non-fish break occur in the timber sale layout which have implications the size and extent of the stream channel buffer. I have found that the existing water typing methodology can lead to non-detection, or the under-estimate of juvenile fish habitat, especially as it relates to the upper-most extent of fish distribution. From what I understand, it sounds like the last electrofishing survey was completed in 2003, but no information was provided on what species were found or whether the Salmon, Steelhead, and Bull Trout (SSBT) riparian rules are being applied.
From my experience with stream surveys, significant discrepancies exist between the visual field identification of steelhead trout and cutthroat trout, which has been confirmed by peer reviewed genetic analysis. I’m also uncertain of how lamprey, an anadromous species important to tribal communities, are incorporated into water typing determinations (given they can climb waterfalls) and sampling through electrofishing techniques often misses lamprey ammocetes. Given the riparian management differences, I am concerned that the biases of electrofishing are underestimating fish abundance and habitat occupancy associated with this harvest layout.
Endangered Species:
Two endangered species are known to exist adjacent to the property. I know there has been significant discussion about listed species through the board of forestry, the MOU with the Governor’s office, and the future development of a habitat conservation plan on private forestland. I won’t belabor the details here, but instead make a few notes specific to this timber sale:
Coho Salmon
Spawning occurs (October- February) and juvenile rearing takes place all year in closely located downstream reaches. Egg to fry survival is closely tied with sediment loads, and redds (salmon nests) can easily become entombed when fine particulates cutt off subsurface flow below the streambed.
Juvenile Coho rearing in downstream obtain a significant portion of their late summer diet from terrestrial macro-invertebrates coming into the creek and floating downstream. Vine Maple leaf detritus also contributes substantially to the base of the aquatic food web through fluvial processes.
Late summer temperature limitations often cause fish to seek out cold water refuges (near tributary junctions, and basalt intrusions) that lead juveniles to make upstream migrations as high into the watershed as is possible. This area of the Oregon Coast has been identified as a climate refuge for these species because it represents some of the best habitat for this evolutionarily significant unit.
The Oregon Coast Coho recovery plan also makes other recommendations regarding buffer sizes, unstable slopes, and road-related sediment impacts — while I know many of those go above and beyond the Oregon Forest Practices Act, I’m curious if you have any other reflections on opportunities and challenges with these best management practices.
Marbled Murrelets
From what I can tell, suitable habitat (trees over 200ft in height) do not exist on this property for Marbled Murrelets. LiDAR data analyzed for tree canopy height shows some developing habitat on United States Forest Service and Bureau of Land Management public land 1/2 mile to the west of this property, but more time is needed to develop nesting platforms on these trees and old growth characteristics.
Spotted Owls
The surrounding federal lands are considered Mapped Owl Conservation Areas, and were created in 2008. I’m unfamiliar with the recommended prescriptions for this species, but I did not see any nests while I walked around the area.
Other species:
Other potentially listed species that occur, or could occur within this watershed in the future are Spring chinook, Humboldt Martin, Red Tree Vole, and Torrent Salamander. While I know there hasn’t been a lot of guidance developed, or surveys for these species — I hope that considerations currently in development through the habitat conservation plan can be incorporated.
Silviculture:
Admittedly, my knowledge of silviculture is limited, and I would love to learn more from you about this topic. I do know that many stands of timber are affected by Swiss Needle Cast, and that species composition is vastly different from surrounding public forests. The baseline forest characteristics of neighboring stands are of mature Sitka Spruce, Big Leaf and Vine Maple, Hemlock, Doug Fir, and Western Red Cedar. There are also a few patches of Yellow-cedar within the Siuslaw National Forest (and a few seed collection trees that are marked). I am curious to learn more about your future management considerations (rotation age, replanting strategies, aquatic strategies, use of fertilizers and pesticides.) From surrounding timber sales on the Hancock property I have seen invasive species such as Scotch Broom and Armenian Blackberry threaten to overtake replanting strategies.
I have really changed my perspective on the need for active management after seeing the restoration thinning work occurring to greatly improve the health of the Siuslaw National Forest. I’m not sure to what extent mixed-age class forest management is practicable on this parcel, and I also understand that there are tradeoffs with thinning strategies — but I am curious to hear about the possibilities. Looking at this stand, it looks to be natural regeneration and may still contain the original genetic traits of the surrounding federal forest. Mixed age-class management could also help retain root structure and reduce the probability of landslides and debris torrents.
I also understand the need for early seral habitat that is rare in the Oregon Coast Range, but I’m not sure about if it is economically, or culturally practical to maintain this kind of habitat in the area like was done pre-settlement.
Operational layout:
Given the sensitivity of riparian management areas and high landslide hazard zones, I’m curious how you plan to operationalize the logging plan. In the written plan it is noted that machine fellers will not be used within 100 feet of the riparian zone, but it doesn’t mention avoiding the operation of machinery on steep slopes, or the placement of yarding and/or skyline cables to avoid damage to riparian management areas as well as seeps and springs higher up on the hillslope.
Last Thoughts:
I have really appreciated the opportunity to submit my thoughts into this notice of application. I’ve also been really impressed with Hancock Natural Resources’ commitment to Diversity, Equity, and Inclusion — as well as sustainability — in the most recent yearly report. While I will continue to monitor the FERNS notifications, it would be great to hear about future environmental and forest management concerns you are seeking input on. Thanks for taking to read this lengthy comment, and please don’t hesitate to reach out with any questions.
