In Walla Walla, we have always been proud to live in a community that cares about and protects our water resources. We have enjoyed the benefit of generations of nonpartisan collaboration to ensure the continuing stability and prosperity of Walla Walla’s agriculture and commerce.
That’s why we were shocked to hear that the City of Walla Walla supports an unprecedented Forest Service proposal to conduct logging, burning and road construction in 38,000 acres of the Mill Creek Municipal Watershed and surrounding forests.
The logging work, slated to begin this year, carries a high probability of costly disruptions to our municipal water resources, serious implications for public safety and a significant burden on taxpayers for decades to come, as well as grave implications for the environment, including habitat of endangered salmon, steelhead and bull trout.
Under Federal rules, the Forest Service retains profits from the sale of timber from public forests to foreign and domestic private companies. This is clear conflict of interest.
The Forest Service frames the proposed timber extraction as fuels reduction to mitigate wildfire risk and "ecological restoration" of old-growth forest. While there is some debate between ecologists and logging interests on the short-term efficacy of fuels reduction, the overwhelming scientific consensus is that the long-term effects of such intensive forest management strategies are ultimately disastrous and irreversible. What is beyond doubt, as made clear in the project's soil and hydrology analyses, is the effect this will have on the soil and water for decades to come.
The Forest Service is using fear of fire to extract timber from protected forests. They have ignored their own environmental impact findings, deliberately avoided public accountability protocols and are fast-tracking implementation in violation of federal law. The City is so far unconditionally accepting their decision, allowing unsupervised private contractors to charge ahead with implementing a dangerous plan, and our local interests are not being represented or protected.
In the last 15 years, numerous other communities in the Pacific Northwest have faced costly and crippling impacts to their water supplies due to logging in and around their watersheds, with no recourse or accountability for the harm done. We believe that the citizens of Walla Walla deserve greater transparency and opportunity for public comment before allowing federal agencies and unchecked private interests to extract public resources and saddle our residents and local businesses with the bill.
We call upon the Mayor, the City of Walla Walla and its elected and appointed representatives to demand the USFS fulfill its obligations under the NEPA to provide an Environmental Impact Statement, heed public input and consider the foreseeable outcomes to our water before implementing this reckless, shortsighted plan. We ask the City to host a public Town Hall where the interests and views of the citizens of the impacted jurisdictions may be heard, and we require that failsafes be put in place to give the City recourse in the event that the project does not proceed according to plan. We ask anyone who shares these concerns to make them clear to our local representatives.
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The City has a say in this matter, but so far has chosen not to act. Showing up in person or calling in via Zoom is the best way to make your voice heard. Any member of the public is entitled to make a 3-minute public comment at the beginning of every City Council Meeting.
Upcoming City Council Meetings (2nd & 4th Wednesdays):
We ask that anyone who is concerned for the stability and well-being of the Walla Walla watershed and the many residents, industries and institutions who rely on its waters to call, write or email the Mayor, the City Attorney, the City Council, the City Manager, the USFS Walla Walla District and any other local and regional parties and make your concerns known. Instead of a single petition, we believe it will be more effective if everyone reaches out individually.
Here is a sample letter. Feel free to copy-and-paste it or modify it as you like, then send it to the list of emails below.
Here is a list of the email addresses of the relevant parties. You can copy and paste the entire list, or contact them individually using the information below.
tscribner@wallawallawa.gov, tdonaldson@wallawallawa.gov, echamberlain@wallawallawa.gov, smoss@wallawallawa.gov, bcasey@wallawallawa.gov, reskil@wallawallawa.gov, mwillis@wallawallawa.gov, jrobinson@wallawallawa.gov, greyna@wallawallawa.gov, lneissl@wallawallawa.gov, rgwinn@wallawallawa.gov, nchavre@wallawallawa.gov, pfrederickson@wallawallawa.gov, kbealey@wallawallawa.gov, mlaughery@wallawallawa.gov, jwest@wallawallawa.gov, jriley@wallawallawa.gov, asutor@wallawallawa.gov, joseph.sciarrino@usda.gov, sm.fs.umainquiries@usda.gov
For the subject line, consider something general and non-confrontational for the highest chance of being read and considred. If you do not live in Walla Walla, please edit the introduction accordingly. It is just as valuable for local offices to see that this is a matter of broad public concern beyond our little valley.
Please also send a copy to us for our legal records, using the BCC line to prevent recipients from contact filtering: connect@wallawallawatershed.com
Logging, burning and road construction destroys soil stability. Landslides, sediment runoff and erosion increase water turbidity, biological contamination and pushes the ambient particulate load beyond regulatory safe levels. These are especially serious concerns in the unusually steep slopes of our Blue Mountains.
Numerous Northwest communities who have seen logging in their watersheds have spent millions and taken on debt to upgrade their pre-treatment and filtration facilities, excavate new water sources, and repair critical infrastructure to remain compliant with mandatory safe drinking water regulations. This debt has fallen on the shoulders of local taxpayers, in one instance driving property taxes so high that many of the decades-long homeowners can no longer afford to live in their own houses.
High turbidity requires substantial increases in chemical sanitation, a practice which has caused excessive concentrations of carcinogens in the residential drinking water of post-logging communities. In combination with the heavy applications of herbicide involved in logging operations, the City will be fighting an uphill battle to maintain drinking water quality compliant with federal standards.
In other communities, the increased sedimentation and water contamination has caused a litany of plumbing problems throughout the entire municipal grid, requiring countless residential upgrades and repairs, while also increasing the wastewater treatment demand (called the “burden of oxygen”). In Walla Walla, this will certainly expedite the need to replace our already-overburdened wastewater treatment systems.
While the City is scrambling to apply for grants, increase rates and approve levies to address these treatment shortfalls, we will inevitably fall back on the municipal wells, as we did following the 2020 floods, placing undue burden on the subsurface aquifers.
Nowhere in any of the project documents is there any consideration of the very real risk of a high-water event causing landslides and mass movement in the years following the logging activities. In the last 15 years alone, we have seen three such "100-year" flood events.
Prescribed burning carries its own risks. We learned just last fall that prescribed burning can get out of control, when a USFS ignition burned 200 acres by mistake in the Watershed, requiring millions in wildfire response actions and producing ash residue that disrupted water treatment, triggering a $50 million grant application for a new filtration facility, which was canceled due to rescinded federal funding.
This new Forest Service proposal calls for several hundreds of acres to be burned every year.
These easily foreseeable and costly disruptions to our municipal water resources and the resulting public health implications are minimized or utterly unaccounted for in the Forest Service Assessment.
Considering the complexity of the issue and the potential for widespread, irreversible consequences for Walla Walla residents and taxpayers for decades to come, we believe that there should be much greater care and deliberation in this decision, with safeguards, contingencies and a much more thorough analysis of the environmental impacts, before approving the plan.
The stated purpose of the project is to mitigate the potential for catastrophic wildfire damaging our municipal water systems. Judging from the impact of similar timber extraction projects in comparable forest types, it is likely to ensure the very thing we hope to avoid: hydrological instability, landslides, soil degradation, critical habitat and biodiversity loss, decreased wildfire resistance, reduced drought tolerance, and—further downstream—irreversible damage to drinking water quality and inevitably costly changes to our municipal water treatment and management systems—costs which will fall on the taxpayers, residents and future generations, not the USFS or its private-interest and commercial partners.
There is minimal evidence to support the position that fuels reduction through logging decreases short-term wildfire risk. On the other hand, the Forest Service proposal ignores a large body of evidence and peer-reviewed, independent scientific research showing that all commercial logging, be it thinning or clear-cutting, ultimately increases the likelihood, frequency and severity of wildfires, and will inevitably require more frequent and more costly intervention in the future. This fact holds doubly true in cold- and moist-type forests like those within the Tiger-Mill timber sale, whereas much of the agency’s rationale and data center around studies of very different dry forests, where fire is much more common.
The proposal calls for 58% reduction of the timber basal area. This is heavy logging. Monitoring efforts of other recent timber sales show that the technical realities of logging lead to actual removal rates far beyond initial projections, effectively resulting in clear-cutting.
The Forest Service retains the majority of the profits from timber sales of public forests for its own staff and operating budgets, which, regrettably, have been severely impacted by recent federal defunding initiatives. It has a clear conflict of interest in presenting this proposal, and bears no accountability to or recourse for the long-term impacts to the members of the local community.
While the sale of the timber may or may not pay for the cost of the logging operations and budgetary shortfalls of the USFS, the financial burden of the subsequent mitigation efforts, particularly for the municipal water systems, will inevitably fall on local governments and the property owners and taxpayers. These local interests were not represented in the development of the Environmental Assessment.
There has been a pointed lack of public awareness or accountability throughout the planning process. This is by design. The Forest Service has disregarded public objections and sidestepped essential accountability and oversight to illegally proceed. The perfunctory public to comment was held during a 3-hour window in Walla Walla, and the only notice provided was published in the Pendleton newspaper, and hour away and across state lines. The Forest Service refused to permit access for an independent biodiversity survey of the proposed logging area, dodging an important accountability measure, ironically hiding behind the longstanding restriction of any human presence in the watershed boundary to prevent a risk to water quality.
The analysis from the Forest Service's own soil and water experts shows that the project carries significant risk. Under federal law, they are required to compile an Environmental Impact Statement, which includes multiple public comment periods, a secondary evaluation from the EPA and more rigorous risk assessment standards. Under the original 1918 Watershed agreement between the City and the Department of Agriculture, the Forest Service can only log in the watershed if it does not cause "injury" to the municipal water supply. The Forest Service has acted in bad faith and in direct violation of Federal law to profit from crippling our most essential resource. By the time the City can catch up to the implications of these actions, it will be too late. The damage will be done.
The Tiger-Mill Timber Sale proposes to commercially log 6,622 acres, including 1,268 acres of commercial logging in the Mill Creek Watershed. The Tiger-Mill sale also proposes “non-commercial” logging on an additional 5,816 acres, overlapping the Mill Creek Inventoried Roadless Area and the Mill Creek Municipal Watershed. Non-commercial logging is described in the proposal as targeting small trees (less than 10" diameter), which are still sold commercially. Additionally, prescribed burning is proposed on 21,325 acres.
According to the project's Environmental Assessment, the slopes over 85% of the project area are 35% or greater. That's steep. As stated in the Assessment, "Mechanical actions on steep slopes pose greater risk to soil erosion due to mineral soil exposure and increased energy potential of surface flow."
According to page 85 of the project Assessment, the proposal defines "thinning" as a 58% basal removal of the timber. Of the 12,438 acres slated for "thinning," 4,944 acres are directly within the Mill Creek Watershed Inventoried Roadless Area (pg. 8). Excluding helicopter logging, 927 acres of which are in the IRA, this leaves 4,000 acres of cutting within the Watershed alone.
For anyone who isn't familiar with the size of logging equipment, the pitch of a 35% slope and the average spacing of trees in a mature, moist-type Douglas Fir and spruce forest, even with cable-haul and "hand-thinning", 58% removal of over 4,000 acres will require in significant "mechanical action," and thus, significant soil erosion.
Walla Walla does not have a membrane-filtration water treatment facility. Our water comes straight off the mountain. Even a small increase in sedimentation will result in significant disruption to the municipal water supply, increase in chlorination (a public health issue) as well as impacts on ASR, watershed ecology and wastewater treatment demand. In this very unique case, any soil disruption will cause significant adverse impacts.
Under the NEPA (at least as it was in effect during the development of the project), if an initial Environmental Assessment finds that a given project presents a "significant impact" or "significant environmental effect," the agency must compile an Environmental Impact Statement (EIS), which requires multi-agency review and an actual public comment period. The Environmental Assessment's "Finding of No Significant Impact" is in direct contradiction to the actual findings stated within the Assessment.
The Hydrology Analysis also states: “Changes in forested stand and canopy density caused by harvest, fire, or insect and disease can change the distribution of the snowpack, increase the rate of melt of the snowpack, and cause the timing of the melt to be earlier. These factors may lead to changes in peakflows. In addition, reduction of stocking density reduces the overall vegetative use of water, increasing the amount of water available for runoff. Changes in water yield and in peak flows have the potential to destabilize channels, causing increased erosion and sedimentation in channels. Changes in these parameters would be of concern for aquatic habitat and biota, downstream water users, and for channel morphology.”
Page 85 of the EA describes the total vegetation mass reduction as 38% of total carbon. It states soil carbon accounts for 35% of total carbon stocks. This means a 58% reduction in total vegetation biomass. Forest vegetation retains and slows the release of water from precipitation.
Contrary to the Assessment’s claim that there will be “no measurable increase in water temperature, streamflow, or sediment,” there is an obvious and high likelihood of sediment increase, stream temperature increase and peak streamflow, especially during snowmelt and rainfall. Combine this with the project design criteria pertaining to soils, which allows for up to 55% mineral soil surface exposure following logging activities.
Despite all of the fear of fire, none of these analyses account for the very real risk of devastating mass movement in steep-sloped, logged forests during such a flood event.
These facts must be understood within the context of the Climate Change Specialist Analysis, which states, “Increasing temperatures will result in shifts in precipitation from snow to rain and watersheds like those in the project area … are most sensitive to these changes. This will also lead to increasing risks from flooding driven winter rain events, including rain-on-snow events. With increasing atmospheric and ocean temperatures, atmospheric rivers and rain events will become more intense, delivering more precipitation per system, though there may be longer dry periods in between storms. Earlier snow melts with warmer temperatures and increasingly rarer summer precipitation, low flows during summer months will become even lower.”
Our deep basalt wells are refilled by a combination of the slow infiltration of water from the watershed area and the active Aquifer Storage and Recovery methods used to pump excess surface water underground for use in drier months. With high sediment loading due to erosion during intense precipitation events, the water that washes down will be unusable for municipal water and for ASR. A sharp reduction in snowpack and snowpack retention means we will be leaning more heavily on groundwater during the majority of the year, which we will not be able to restore.
We need only look at our neighbors to the south in California to see what happens when these factors converge. The future of our water supply is at risk.
Logging and burning are separate but interrelated issues. If prescribed burning gets out of control, as it did in the Watershed last Fall, it is designated a wildfire and a state of emergency is declared. Under recent executive orders, normal approval procedures, environmental protections and clear-cutting restrictions no longer apply to forests in emergency status, and the Forest Service has unilateral authority to conduct unlimited commercial extraction.
The forests in question include old growth and mature forests and provide critical habitat to numerous endangered species. Conclusive data show that these forest types are more resilient and resistant to wildfire than logged forests. Mixed-aged forests create higher rainfall and lower soil surface and stream temperatures. Heavy logging exposes soils, dries out the understory and increases average soil and water temperatures, significantly increasing the likelihood and severity of future fires.
This project will involve reopening and constructing new roads. The long-term adverse impacts of forest roads on water quality and ecology are well-documented.
In the last 25 years, countless scientific studies have underscored the growing consensus that forests are among the most important resources for carbon sequestration and climate stability, and there is a direct correlation between deforestation and drought, yet another indication of the ways that short-sighted, extractive forestry practices are exacerbating, not reducing, wildfire risk. We have compiled a list of resources for those who wish to educate themselves further on these matters.
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