FANs Response to BLM Scoping Letter on the Steelhead Falls Fuels Reduction Project
September 4, 2020
BLM Prineville District Office
3050 NE Third St.
Prineville, OR 97754
Re: DOI-BLM-ORWA-P060-2020-004-EA
Dear Mr. Chamness:
Friends and Neighbors of the Deschutes Canyon Area (FANs) appreciates the opportunity to
respond to the above referenced scoping letter dated August 7, 2020.
Established in 2012 has a 501(c)3 non profit organization, FANs mission is:
...to preserve and restore the wild landscapes of the Middle Deschutes and Lower Crooked
Rivers and Lower Whychus Creek through stewardship, outreach and education.
Based at Crooked River Ranch, FANs has been a partner with the BLM Prineville District since
our founding. During the last four years, our involvement has included stewardship projects,
guided hikes and educational programs. During that period, FANs has provided 4,000 hours of
volunteer service to the BLM, valued at over $100,000. We have raised and will spend over
$27,000 on native plant restoration and reconstruction of the Steelhead Falls Trail.
FANs supports the purpose of the Steelhead Falls Fuels Reduction EA as defined in the Dingell
Act of 2019. We believe that juniper removal is appropriate within Wild and Scenic River
corridors to reduce wildfire risk and to improve habitat conditions for native plants and wildlife.
We hope you will consider the following specific issues as you further develop the project.
1. The Dingell Act requires that unauthorized motorized vehicles be excluded from the 688
acres of public land removed from the WSA. Signage alone is not sufficient in some areas to
stop unauthorized vehicles from entering the excluded areas. FANs would like to see boundary
fencing to ensure the intent of the Dingell Act is met.
2. There are several parcels of BLM managed land that are not included in your scoping map
for fuels reduction. A prominent example is the 40-acre parcel at the southern end of Meadows
Drive which is owned by the Oregon Game Commission and managed by the BLM. We would
like to see that area and others near Scout Camp and Shelf Court included in your proposed
treatment area.
3. There is BLM managed land that borders private landowners along Horney Hollow Rd. Is
there a way to include that land in the fuels reduction plan?
4. We have heard from residents of Crooked River Ranch, whose properties border the
proposed fuels reduction area, about the importance of visual and noise screening if too many
trees are removed within 50 to 100 feet of their homes. Is it possible for a private landowner to
flag select trees near the property line that they believe should be left to provide an adequate
privacy screen?
5. There are many places in the treatment area where there are no public or private roads. We
oppose the creation of new roads during the treatment process unless they are physically
closed whenever workers are not using the area, and permanently closed when the work is
completed.
6. We are concerned about weed incursion from vehicle use of roads during the project, as well
as in the treated areas themselves. Hand cutting and piling of cut vegetation wherever possible
will help reduce the spread of noxious weeds. In any case, all disturbed sites need to be
evaluated for weed prevention. Cheatgrass, a winter annual weed, should be the primary focus,
and pre-emergent treatment with amazapic is only effective when sprayed in the late fall.
Spraying will also help improve the overall condition of the sagebrush steppe habitat.
7. How will the BLM dispose of removed fuels? In treatment areas that are smaller and near
homes or roads, we would recommend that trees and branches be removed from the site rather
than piled and burned.
8. Removal of fuel on the canyon slopes may have unintended consequences, such as soil
erosion and golden eagle nest disturbance. How does the BLM plan to address fuels reduction
on the steep canyon slopes?
9. Will any hiking trails be closed during fuel treatment?
10. With respect to your purpose “to restore and promote old-growth juniper ecosystems where
present,” we would like to know the criteria used to define “old-growth juniper.” How do you plan
to identify the trees that meet your criteria to prevent them being removed?
11. With respect to your purpose “to reduce the amount of young juniper encroachment into
mule deer habitat which will also help restore and promote shrub steppe ecosystems where
present,” we would like to see areas specially identified where smaller trees are totally removed
rather than just their lower branches to increase the amount of water available to native shrubs,
bunchgrasses and wildflowers that anchor the sagebrush steppe ecosystem. We oppose any
ground scrapping that would remove these.
12. The sagebrush steppe habitat includes the lithosol zone along the Deschutes Canyon rim.
This habitat has no junipers and few shrubs. The shrubs that grow in the lithosol zone are
generally quite small. We are particularly concerned that this sensitive area be completely
protected from fuels reduction.
13. It will be essential to maintain fencing, monitor violations, and continue active weed
management in treated areas. What is the BLM’s post-project monitoring and maintenance
plan?
14. FANs believes that the highest priority areas for fuel reduction should be those nearest
highly populated areas of Crooked River Ranch. Knowing that it will take time to treat all of the
identified areas, what are the priority areas to be treated first? Friends and Neighbors of the
Deschutes Canyon Area is available for consultation on the priority list.
15. FANs has been trying to get the BLM to close access to motor vehicles in Coyote Canyon,
a BLM roadless area located at TRS (township/range/section system: T14SR12ES2NW). Since
BLM crews will be in the Steamboat Rock Recreational Area could they post signs for firearm
restrictions (no shooting except for lawful hunting) and move large boulders to block access to
unauthorized motor vehicles? The regulatory basis for installing vehicle barriers is that the area is
clearly shown as roadless (except for Quail, Rainbow and Dove roads) on RMP Map 23B
(Steamboat Rock Recreational Area, South).
We look forward to an opportunity to comment on a draft EA prior to finalization.
Sincerely,
Marilynne Keyser, President
Friends and Neighbors of the Deschutes Canyon Area (FANs)
fansofdeschutes.org
541-923-0558
[email protected]
BLM Prineville District Office
3050 NE Third St.
Prineville, OR 97754
Re: DOI-BLM-ORWA-P060-2020-004-EA
Dear Mr. Chamness:
Friends and Neighbors of the Deschutes Canyon Area (FANs) appreciates the opportunity to
respond to the above referenced scoping letter dated August 7, 2020.
Established in 2012 has a 501(c)3 non profit organization, FANs mission is:
...to preserve and restore the wild landscapes of the Middle Deschutes and Lower Crooked
Rivers and Lower Whychus Creek through stewardship, outreach and education.
Based at Crooked River Ranch, FANs has been a partner with the BLM Prineville District since
our founding. During the last four years, our involvement has included stewardship projects,
guided hikes and educational programs. During that period, FANs has provided 4,000 hours of
volunteer service to the BLM, valued at over $100,000. We have raised and will spend over
$27,000 on native plant restoration and reconstruction of the Steelhead Falls Trail.
FANs supports the purpose of the Steelhead Falls Fuels Reduction EA as defined in the Dingell
Act of 2019. We believe that juniper removal is appropriate within Wild and Scenic River
corridors to reduce wildfire risk and to improve habitat conditions for native plants and wildlife.
We hope you will consider the following specific issues as you further develop the project.
1. The Dingell Act requires that unauthorized motorized vehicles be excluded from the 688
acres of public land removed from the WSA. Signage alone is not sufficient in some areas to
stop unauthorized vehicles from entering the excluded areas. FANs would like to see boundary
fencing to ensure the intent of the Dingell Act is met.
2. There are several parcels of BLM managed land that are not included in your scoping map
for fuels reduction. A prominent example is the 40-acre parcel at the southern end of Meadows
Drive which is owned by the Oregon Game Commission and managed by the BLM. We would
like to see that area and others near Scout Camp and Shelf Court included in your proposed
treatment area.
3. There is BLM managed land that borders private landowners along Horney Hollow Rd. Is
there a way to include that land in the fuels reduction plan?
4. We have heard from residents of Crooked River Ranch, whose properties border the
proposed fuels reduction area, about the importance of visual and noise screening if too many
trees are removed within 50 to 100 feet of their homes. Is it possible for a private landowner to
flag select trees near the property line that they believe should be left to provide an adequate
privacy screen?
5. There are many places in the treatment area where there are no public or private roads. We
oppose the creation of new roads during the treatment process unless they are physically
closed whenever workers are not using the area, and permanently closed when the work is
completed.
6. We are concerned about weed incursion from vehicle use of roads during the project, as well
as in the treated areas themselves. Hand cutting and piling of cut vegetation wherever possible
will help reduce the spread of noxious weeds. In any case, all disturbed sites need to be
evaluated for weed prevention. Cheatgrass, a winter annual weed, should be the primary focus,
and pre-emergent treatment with amazapic is only effective when sprayed in the late fall.
Spraying will also help improve the overall condition of the sagebrush steppe habitat.
7. How will the BLM dispose of removed fuels? In treatment areas that are smaller and near
homes or roads, we would recommend that trees and branches be removed from the site rather
than piled and burned.
8. Removal of fuel on the canyon slopes may have unintended consequences, such as soil
erosion and golden eagle nest disturbance. How does the BLM plan to address fuels reduction
on the steep canyon slopes?
9. Will any hiking trails be closed during fuel treatment?
10. With respect to your purpose “to restore and promote old-growth juniper ecosystems where
present,” we would like to know the criteria used to define “old-growth juniper.” How do you plan
to identify the trees that meet your criteria to prevent them being removed?
11. With respect to your purpose “to reduce the amount of young juniper encroachment into
mule deer habitat which will also help restore and promote shrub steppe ecosystems where
present,” we would like to see areas specially identified where smaller trees are totally removed
rather than just their lower branches to increase the amount of water available to native shrubs,
bunchgrasses and wildflowers that anchor the sagebrush steppe ecosystem. We oppose any
ground scrapping that would remove these.
12. The sagebrush steppe habitat includes the lithosol zone along the Deschutes Canyon rim.
This habitat has no junipers and few shrubs. The shrubs that grow in the lithosol zone are
generally quite small. We are particularly concerned that this sensitive area be completely
protected from fuels reduction.
13. It will be essential to maintain fencing, monitor violations, and continue active weed
management in treated areas. What is the BLM’s post-project monitoring and maintenance
plan?
14. FANs believes that the highest priority areas for fuel reduction should be those nearest
highly populated areas of Crooked River Ranch. Knowing that it will take time to treat all of the
identified areas, what are the priority areas to be treated first? Friends and Neighbors of the
Deschutes Canyon Area is available for consultation on the priority list.
15. FANs has been trying to get the BLM to close access to motor vehicles in Coyote Canyon,
a BLM roadless area located at TRS (township/range/section system: T14SR12ES2NW). Since
BLM crews will be in the Steamboat Rock Recreational Area could they post signs for firearm
restrictions (no shooting except for lawful hunting) and move large boulders to block access to
unauthorized motor vehicles? The regulatory basis for installing vehicle barriers is that the area is
clearly shown as roadless (except for Quail, Rainbow and Dove roads) on RMP Map 23B
(Steamboat Rock Recreational Area, South).
We look forward to an opportunity to comment on a draft EA prior to finalization.
Sincerely,
Marilynne Keyser, President
Friends and Neighbors of the Deschutes Canyon Area (FANs)
fansofdeschutes.org
541-923-0558
[email protected]
