Wednesday, September 28, 2016

BLM Shelves the Nedsbar Timber Sale — For Now!

Local residents protest the Nedsbar Timber Sale auction on September 22, 2016.

Last week the Medford District BLM proposed to sell the Nedsbar Timber Sale to the highest bidder, offering some of the last roadless forests in the Applegate Valley to private timber interests for $68 per thousand board feet. The agency was offering 3.4 million board feet of public forest for a minimum bid of $231,014.60.

The community of the Applegate Valley believes these intact forests are priceless, and in response organized a large protest at the timber sale auction on Thursday, September 22, 2016. 

With resistance to the sale growing, 75 residents of the Rogue and Applegate Valleys attended the rally, advocating that the BLM withdraw the sale and protect the area's important biological and recreational values.

Protestors held signs, sang songs, held mock timber auctions, shared information about the timber sale, spoke with media and advocated for protection of the area's ecology and recreation-based economy. Some in attendance wanted to witness the process of the auction and tried to enter the auction. These residents were denied access and public timber was auctioned to private interests behind closed doors. 

Residents expressed their concerns about the timber sale and the lack of meaningful collaboration that led to its approval, airing their concerns with BLM officials and filling the lobby of the Medford District BLM Office. Protestors also spread out across the parking lot and along the main street bordering the BLM office, receiving many honks and cheers of approval from passing motorists.  

Following the protest and timber auction, BLM announced that the Nedsbar Timber Sale received no bidders. Having failed to sell, the BLM announced it would re-offer the Nedsbar Timber Sale under a 30-day sealed bidding process, allowing the industry yet another chance to purchase our public forests for private gain.

Within days of this announcement the BLM reevaluated the situation and has now removed the sale from the sealed bidding process. "We're going to pull it back and see if we can work on the economics of it. We'll look at everything to see if there's some tweeks or changes to improve this sale," said BLM spokesperson, Jim Whittington, to the Medford Mail Tribune. 

The timber industry wants a more economical sale and is pressing the agency to repackage Nedsbar into a sale that includes only the most economical units. 

"I don't see anyone coming up and grabbing it the way it is," said Andy Geissler to the Medford Mail Tribune. Andy Geissler is a timber industry lobbyist from the American Forest Resource Council. "Its good to hear it's getting a makeover," he said.

The "makeover" the timber industry is hoping for will likely include either lowering the minimum bid price or reducing the cost of logging by dropping units with low volume per acre. This would leave only the units with the highest timber volumes and largest trees included in the sale. 

The industry would also like to see prescriptions rely less on helicopter logging which is expensive to implement, Geissler said.  

Local residents are also hoping many of the helicopter logging units will be dropped, especially those in roadless areas or fire resilient, late seral stands. Numerous units on Bald Mountain, in the Little Appleagate River canyon, at the head of Grouse Creek and on Boaz Mountain should be removed from the timber sale.

The BLM is analyzing the administrative "protest letters" they received from the Applegate Neighborhood Network (ANN) and others. We hope this analysis will allow the BLM to amend the Decision Record, withdraw the currently approved Nedsbar Timber Sale and implement the Community Alternative, Alternative 5 through a series of stewardship contracts. The Community Alternative will protect the area's important natural values while reducing fuels, increasing forest health, enhancing our local economy and producing a sustainable supply of timber. 

The BLM has indicated that if the sale undergoes substantial changes during this reevalutation process a new public comment period would be necessary. They have indicated that no work will proceed until next spring or summer.

This is a victory for now, but it is clear that much more work is ahead of us as we urge the BLM to do the right thing and truly listen to and collaborate with local residents opposed to the Nedsbar Timber Sale. 

A community in action: Stop Nedsbar!
All photos courtesy:

Sunday, September 18, 2016

Collaboration? The BLM Ignores Public Input and Moves Forward with Nedsbar Despite Near Unanimous Disapproval

Many Applegate Valley community members participated in the planning process for the Nedsbar Timber Sale. Based on a review of pubic comments received by the BLM, it appears that the vast majority of the local community is opposed to the Nedsbar Timber Sale as it has been approved.

99% Oppose the Nedsbar Timber Sale

In the recent Decision Record for the Nedsbar Timber Sale released by the Medford District BLM, the agency approved Alternative 4 with only slight modifications. Alternative 4 is the sweetheart deal for the timber industry, but has been strongly opposed for over two years by residents in the Applegate Valley community. The project demonstrates the BLM's lack of collaborative capacity and inability to incorporate community concerns into public land management projects. Still stuck in the past, Medford BLM is refusing to move forward with us into a collaborative, more ecologically sustainable future.

The Nedsbar Timber Sale was proposed in the Applegate Adaptive Management Area (AMA), where innovative forestry and significant public involvement and collaboration is mandated under the Northwest Forest Plan. The AMA was designated in 1994 to promote experimental, ecologically based forestry rooted in community values — it is a much-loved component of Applegate culture. 

In the spirit of collaboration and innovation, residents in the Applegate Valley community developed the Community Alternative, an alternative to the Nedsbar Timber Sale, that the BLM agreed to analyze as Alternative 5 in the Nedsbar Timber Sale Environmental Analysis. The community invested thousands of hours in the "collaborative" process to develop the Community Alternative; unfortunately, our concerns and desires feel upon deaf ears. 

Despite a claim to have incorporated community concerns into the final decision, the BLM moved forward with the highly controversial Alternative 4 and failed to incorporate or even meaningfully analyze the many ecological, economical, and community based concerns documented by the Applegate community. Although the agency claims to have "blended" Alternatives 4 and 5, not a shred of the Community Alternative can be found in the Decision Record. The community has opposed new road construction, roadless area logging, the removal of large fire resistant trees, excessive impacts to the northern spotted owl and the increase in fire risks associated with the levels of canopy reduction proposed by the BLM. Unfortunately, the BLM approved all of these things in the decision record and is moving forward with near unanimous disapproval in the Applegate community.

The decision demonstrates the futile nature of collaboration with unaccountable, unresponsive, and irresponsible public agencies like the Medford District BLM, who hold our community values in contempt and exclusively serve the interests of the timber industry. Our public BLM lands are being offered up to the highest bidder while the public is offered only token gestures, hollow words and grave environmental, economic and social impacts. The countless volunteer hours and thoughtful public input has been cast aside and our valid concerns disregarded while the agency panders to the demands of the industry to maximize timber production. 

Residents opposed to the Nedsbar Timber Sale on a BLM field trip.
After asking the BLM to openly disclose the public comments regarding the Nedsbar Timber Sale — as many land management agencies do — instead of doing the collaborative thing and releasing the comments, Medford BLM told me I had to FOIA (Freedom of Information Act) the records, which I did. The results from my review of these comments are not surprising, but are altogether unjust, undemocratic and inexcusable. 

The agency received 426 public comments on the Nedsbar Timber Sale Environmental Assessment. A full 99% of these comments (423) were submitted by public citizens that supported the Community Alternative (Alt. 5) and opposed Alternative 4. One other comment was received that did not specifically support of the Community Alternative, but did support many of its basic tenets including a diameter limit, no regeneration logging and cancellation of all units on Bald Mountain. A total of two letters were submitted to the BLM in support of the Selected Alternative (Alt. 4), one from a private citizen and one from the American Forest Resource Council (AFRC), a timber industry lobby group. When compared to the Selected Alternative, the Community Alternative was supported at a rate of over 210 to 1. 

Many Applegate residents took the time to write lengthy, detailed, and site-specific comments rooted in place-based knowledge, science and a collaborative spirit. In comparison, AFRC wrote a total of five pages of public comment, without any site-specific knowledge, but the BLM gave these brief comments from the timber industry lobby group more consideration than those of the local residents.

Instead of working collaboratively with the community, the BLM chose to serve the interests of the industry, fan the flames of controversy and prove themselves incapable of representing the needs of the local people. The Nedsbar Timber Sale should be withdrawn. Logging this sale as it is approved will impact important public resources and harm the future of collaboration in the Applegate Valley.

Please contact the following public official and ask them to withdraw the Nedsbar Timber Sale and commit to the economically sustainable, ecologically appropriate and community based form of land management mandated in the Applegate AMA. 

Secretary of Interior, Sally Jewel

State BLM Director, Ron Dutton

Senator Ron Wyden

Senator Jeff Merkely

Senator Kevin Talbert

Join us on Thursday September 22, 2016 8:00 AM at the Medford BLM Office (3040 Biddle Road, Medford, Oregon) for a rally to Stop Nedsbar! 

The BLM will be auctioning off our beloved forests and the community will be there supporting the wildlands of the Applegate Valley.

Saturday, September 3, 2016

Nedsbar Timber Sale Decision Record Released: BLM Betrays the Applegate Community and Approves Old-Growth Logging

This photograph shows the first Nedsbar field trip with the BLM and the public in November, 2014. Many local residents worked to have their voice heard and their values respected by the BLM in the Nedsbar Planning Process. Interest in the Nedsbar Timber Sale in the Applegate Valley community has been high due to the diverse and important resource values present in the planning area.

BLM Releases the 
Nedsbar Timber Sale Decision Record

After two years of effort and thousands of volunteer hours invested by the Applegate Valley community, the BLM has chosen to disregard the community's comments and concerns about the Nedsbar Forest Management Project (i.e. Nedsbar Timber Sale), as well as the Community Alternative, Alternative 5. The Community Alternative was widely supported in the Applegate Valley where 330 people signed on in support. 

The BLM released its Decision Record (DR) for the Nedsbar Timber Sale on Thursday, September 1, 2016, and unfortunately this decision will implement the most timber-heavy alternative proposed. The BLM has betrayed the Applegate Valley community by failing to adequately consider or even analyze our concerns and comments in the DR or Final Environmental Assessment. Medford BLM field manager, Kristi Mastrofini, signed the DR for the Nedsbar Timber Sale, approving a slightly modified version of Alternative 4, the alternative favored by the timber industry. 

The field manager's decision reflects an inability on behalf of the BLM to meaningfully collaborate with the Applegate community, address our concerns or implement responsible land management decisions. This highly controversial decision will impact our valley, its recreation based economy, our scenic views, our old-growth forests, roadless wildlands, local hiking trails, endangered species habitat, and the future of collaboration in the Applegate Valley. It will also drastically increase fuel loads and fire hazards adjacent to our community and our homes. In short, the decision is a giant step backwards and could reinitiate the timber wars of the 1990s in the Applegate Valley. 

Read the Documents
The Final EA, DR, and FONSI for the Nedsbar Timber Sale are available on the BLM's ePlanning website at:

What's Approved?
The DR approves 1,122 acres of commercial logging, 1.3 miles of new "temporary" road construction, 0.43 miles of new permanent road construction and the creation of 7 new helicopter landing pads. The decision will approve logging in units within late-seral and old-growth forest stands, important northern spotted owl habitat, citizen-identified roadless areas and vital habitat connectivity corridors. The decision includes no upper diameter limit, meaning the BLM is free to log large, old-growth trees. Currently trees up to 42" in diameter are marked for removal in approved Nedsbar Timber Sale units. 

A 42" diameter tree marked for removal in unit 35-32 at the headwaters of Grouse Creek. The unit and the old trees marked within it are now approved for logging by the Medford District BLM.
The BLM Ignores the Community Alternative
Although the BLM claims to have blended "components from Alternative 4 and Alternative 5 [the Community Alternative]," (DR P.9 ) it is very difficult to understand exactly what components of the Community Alternative are approved for implementation. The BLM is apparently just playing lip service to the Community Alternative.

None of the basic principals of the Community Alternative, Alternative 5, will be implemented in the DR. 

  • Not a single unit will be treated with the detailed and scientifically valid prescriptions designed by the community in the Community Alternative
  • No prescriptions in commercial units approved in Alternative 4 will be modified in any way
  • No diameter limit will be implemented 
  • Canopy cover levels will be reduced far below those recommended in the Community Alternative
  • Roadless areas will be logged
  • New roads will be built in watersheds already suffering from high road density 
  • Riparian Reserves recommended for protection in the Community Alternative will be logged
  • Black plastic will be used to cover piles (only OR and NM allow for the burning of black plastic on burn piles)
  • There will be no altered prescriptions for unusual plant species, such as the snow bramble (Rubus nivalis), identified in the Community Alternative
Large Tree Retention
During the supposed collaboration with the Community Alternative Working Group (CAWG), metrics were developed and agreed upon by both the BLM and the CAWG. These metrics would inform and provide transparency to the decision making process. One of the key metrics was to quantify the number of large trees over 20" in diameter removed in timber sale units. The BLM did quantify large tree removal in the initial EA, and when community members identified that the number of large trees listed was highly inaccurate, the BLM addressed this significant error by issuing an errata with updated, yet still highly inaccurate information. 

In public comments to the initial EA, the Applegate Neighborhood Network (ANN) identified significant errors remaining in the analysis of large tree retention laid out in the BLM's errata. Based on on-the-ground field monitoring the estimate was that at least three times as many large trees were marked for removal than were analyzed in the BLM's Environmental Assessment.

The fact that the local Applegate community has performed more on-the-ground monitoring than the BLM to field check the amount of large trees being removed in the Nedsbar Timber Sale, and the fact that the BLM has had to admit that their numbers are so inaccurate, casts doubt on the BLM's ability to accurately quantify and analyze the amount of large tree removal in the DR. 

The BLM is using the numbers in the errata in their Final Environmental Assessment despite considerable doubt in regards to their accuracy. The BLM has simply not quantified the number of large trees to be removed in the majority of timber sale units. In addition, in the DR, they negate the importance of quantifying the number of large trees proposed for removal and they throw this agreed upon metric out the door, refusing to abide by their initial agreement to incorporate this analysis into the DR. 

The DR states, "there are no requirements that mandate the BLM to disclose the precise number of trees to be harvested of any diameter. Public disclosure and Agency consideration of the exact number of trees to be harvested is not necessary for a reasoned choice among alternatives for a project." (DR A-8)

The only alternative that clearly analyzed and quantified large tree removal in the Nedsbar EA was the Community Alternative, where no large trees over 20" in diameter would have been logged. The BLM has not provided accurate information regarding large tree removal in the Final EA or DR.

Fire Resilience and Fuel Reduction
The Community Alternative was focused on fire resilience and fuel reduction; however, the decision in the DR does not emphasize fuel reduction or fire hazard reduction in the Applegate Valley. The DR makes this clear: "Not all treatments are designed to reduce fire hazard. Forest thinning proposed under the Nedsbar Forest Management Project...does not aim specifically to address fire hazard." Instead, the BLM "chose the Selected Alternative as it best meets the 1995 RMP direction for timber resources." (DR A-3)

Field Manager Mastrofini said, "Based on my obligation to implement the intent of the 1995 Medford District RMP, I cannot select the community's Alternative 5 as designed, as it represents an unwarranted departure from the Timber Resources Objectives on the BLM's Resource Management Plan." (DR P.10 )

Clearly, one single objective dominates BLM land management: timber production.

Without specifically aiming to address fire hazard, the BLM is simply logging to benefit the timber industry at the detriment of the Applegate Valley and its residents. The Applegate will be left with increased fire hazards, degraded forests and forever altered wildland habitats after the implementation of the Nedsbar Timber Sale.

Unit 28-10A of the Nedsbar Timber Sale is located in the Bald Mountain Roadless Area and Jack-Ash Trail corridor. The stand includes large, old, closed canopy forest that is naturally resilient to fire, insects and disease. The area is in an important wildfire connectivity corridor and has been approved for logging by the Medford District BLM.

Roadless Areas and the Recreation Economy
A strong emphasis within the Community Alternative was the protection of citizen-identified roadless areas and the enhancement of economic values associated with outdoor recreation in the Applegate Valley. Unfortunately, the BLM will not address or emphasize these important community values in the DR.

Field manager Mastrofini explains her reasoning: "While BLM recognized these areas are important to the Community Alternative Working Group and the community members they represent...these areas do not meet the size criteria as defined in the...Wilderness Act to possess wilderness characteristics. The BLM is directed by the 1995 RMP to manage these areas for sustainable forest and timber production." (DR P.16)

Community values, a recreation economy, and roadless wildlands — supported by many throughout the region and beyond — are simply not considered in the decision framework outlined by field manager Mastrofini in the Nedsbar DR.

"Alternative 5 (the Community Alternative) was strongly influenced by the community's desire to preserve areas within the planning area as unmanaged. This aspect of Alternative 5 is inconsistent with the1995 RMP as the decision to manage these lands for timber production occurred in 1995." (DR P. 9)

New Road Construction
The Community Alternative proposed the development of no new roads; however, the BLM has approved 1.3 miles of "temporary" roads and 0.43 miles of new permanent roads, along with 7 new helicopter landings. Despite the fact that Applegate residents opposed it, a large section of new "temporary" road will be built within and adjacent to the Riparian Reserve on Lick Gulch. The BLM has admitted that this will contribute high levels of sediment to an already impaired stream with high road density. 
Temporary Good News With Lots of Work to Come
On a more positive note, 3 of the 25 controversial units identified by the community have been "deferred from treatment" and 4 others are now proposed for fuel reduction only. Unfortunately, BLM is making it clear that they still intend to log these units in the future. 

"It is important to note that my decision to implement the Selected Alternative for the Nedsbar Forest Management Project does not permanently defer timber harvest for those units not chosen for implementation at this time," Field Manager Mastrofini wrote in the DR. (DR P. 3)

In other words, the fact that these few controversial units have been dropped and/or altered in the sale is only temporary good news, and unfortunately our work is far from done — 450 acres in 18 controversial timber sale units have still been approved for logging!

We did it! BLM canceled unit 28-10B in the Bald Mountain Roadless Area; however, many units have been approved for logging in wild, fire resilient forest just like unit 28-10B. The agency admits in the DR, "not all units are designed to reduce fire hazard." Instead they "chose the Selected Alternative that best meets the 1995 RMP direction on timber resources." We need your help to save the last old, fire resilient forests in our region. Join us!

What You Can Do
Please consider contacting your local congressperson, state representative and regional BLM officials. Express your opposition to the Nedsbar Timber Sale and your support for Alternative 5, the Community Alternative. In the Applegate Valley we are ready for a new era of collaboration and conservation based management on public lands. Will the BLM join us? 

Applegate Neighborhood Network (ANN) and others will be filing a formal protest of this timber sale and will continue working for community and conservation in the Applegate Valley. Consider supporting their efforts with a donation. ANN is fiscally sponsored by KS Wild, please note that the donation is for ANN/Nedsbar.

Write An Official Protest

Anyone who wrote a comment for the Nedsbar Timber Sale Environmental Assessment (EA) can write an official protest of the Decision Record and Final EA. 

Contact Your Public Officials
Ron Dutton, State BLM Director
Senator Kevin Talbert
 Senator Merkely
Representative Peter Buckley:
Sally Jewell, Secretary of the Interior:
Senator Ron Wyden:
Representative Greg Walden

Below is a photo essay of a few of the Nedsbar Timber Sale units approved for logging by the Medford District BLM. 

Units 33-30 & 34-30

The units are located in the Boaz Mountain Roadless Area and include many large, old-growth trees. The stand is open spaced and naturally fire resilient. Unit 33-30 has been approved for "regeneration harvest," a form of timber management that has been shown to greatly increase fire hazards by "regenerating" young understory growth. The unit is located directly adjacent to the most densely populated portion of the Upper Applegate Valley. Unit 34-30 has been approved as a "group selection" unit. Both stands should be canceled. 

Units 33-30 & 34-30 on Boaz Mountain viewed from just above Star Ranger Station. Unit 34-30 has been approved for a "structural retention regeneration harvest," meaning the canopy will be reduced to roughly 30%. Unit 34-30 is a group selection cut, and according to BLM staff will look like "swiss cheese" when logging operations are finished.
Open, fire resilient forest conditions in unit 33-30. The stand will be logged to between 18 and 20 trees per acre. The "structural retention regeneration harvest" proposed in this stand will create increased understory density, contributing to an increase in fire hazards following logging treatments.
Unit 34-30 is a variable density, mid-seral stand with scattered old trees and fire resilient stand conditions. The entire stand of conifer trees in this photo is marked for removal. The removal of overstory canopy will increase fuel risks by creating dense understory fuel. Based on years of monitoring, local environmentalists have documented a vigorous "shrub response" filling in canopy gaps and heavily thinned stands, increasing fuel hazards and understory competition.


  Unit 35-32

Some of the largest trees marked for removal in the Nedsbar Timber Sale are located in unit 35-32. The stand is unusually moist for the Little Applegate watershed and includes the very uncommon snow bramble (Rubus nivalis), a plant species associated with moist forests and high canopy cover levels. The snow bramble growing in the dry foothills of the Little Applegate Valley is a disjunct population at the southern extent of its range. This unusual stand is approved for logging to 40% canopy cover. The BLM states in the DR: "R. nivalis's range is the west coast extending into Canada at higher elevations. The species is uncommon, but not rare, and does not require special attention under BLM policy." (DR )

True community collaboration would include plant buffers or deferred units for important ecological and/or botanical values identified by collaborative partners (i.e. the community). Snow bramble should be provided some special attention to maintain our internationally renowned biodiversity in the Applegate/Klamath-Siskiyou Ecoregion. Without attention to the unique needs of the landscape all claims of "restoration" are unjustified.  Without meaningful alterations to unit prescriptions for community-identified special plants, wildlife, or natural features, collaboration is insincere. 

Unit 35-32 at the headwaters of Grouse Creek contains many large, old trees and resilient stand conditions. All trees not marked yellow for retention would be removed under the DR signed by the BLM and canopy cover would be reduced to 40%.
The two large trees in the foreground are marked for removal in unit 35-32. Trees up to 42" in diameter are marked in the unit. In total, 145 trees over 20" in diameter are marked for removal on 27 acres, a rate of 19 large trees per acre. Canopy cover will be reduced to 40%, badly impacting a unique and disjunct population of snow bramble at the southern extension of its range.


Units 14-30 & 15-30

Located in the Buncom Roadless Area, these late-seral stands provides healthy, fire resilient conifer forest habitat within large stands of white oak and chapparal. Unit 15-30 was burned in a wildfire in 1987, creating open, fire resilient forest conditions. Both unit 14-30 and 15-30 should be canceled.

Unit 14-30 is located in the Buncom Roadless Area, just above the confluence of the Little Applegate and Applegate Rivers. The unit would be logged to 40% canopy cover, removing many large, old, fire resilient trees. The stand is open, spacious and supports very little understory fuel. Logging this stand will impact the area's roadless character, fire resilience and wildlife habitat.
Unit 15-30 sustained an understory fire in a 1987 wildfire and supports open, fire resilient conditions. It is a fire refugia within a sea of chaparral and will serve to moderate future fires. The BLM has targeted the stand for 40% canopy cover and will remove many large, old trees.


 Units 25-20, 25-21, 25-22 & 25-23

Located in the Trillium Mountain Roadless Area and in the viewshed of the Sterling Mine Ditch Trail, these units sustain healthy, fire resilient forests of dry Douglas fir and ponderosa pine. Unit 25-20 would include a new "temporary" road and helicopter landing pad in the Trillium Mountain Roadless Area. Units 25-20, 25-21, 25-22 & 25-23 should be canceled.

Unit 25-23 is a model for forest health in the Applegate Valley. This mixed stand is dominated by open groves of large, fire resilient trees. It is also located in the Trillium Mountain Roadless Area. The stand needs no treatment whatsoever, yet the BLM has approved logging groupings of large fir trees, some well over 30" in diameter.
A right of way will be cleared, a "temporary" road built to haul timber, and a helicopter landing pad will impact this wild, roadless ridge on Trillium Mountain. The new road and helicopter pad will be utilized to log the roadless northern face of Trillium Mountain above the Little Applegate River canyon.

Unit 28-10A, 28-11A, & 28-11B

Located in the Bald Mountain Roadless Area, unit 28-10A includes many of the timber sale's largest trees. 273 trees between 20" & 40" in diameter are marked for removal in unit 28-10A alone. The unit includes a diverse mixture of serviceberry, old-growth Douglas fir, moist mountain springs and rocky outcrops. The area is important connectivity habitat between low and high elevation habitats in the Little Applegate watershed and is important for wildlife migration.

 The stand in unit 28-10A is open, fire resilient and dominated by large, old trees, 273 of which are marked for removal. Trees marked white are marked for removal.

Unit 28-10A is some of the most beautiful forest in the Little Applegate River canyon. It also provides important connectivity habitat. The unit is likely the worst still included in the Nedsbar Timber Sale and should be canceled immediately to protect the roadless area's old forest habitat, scenic vistas and the recreation economy of the Applegate Valley.
Applegate Valley residents enjoy the backcountry of the Bald Mountain Roadless Area in Nedsbar unit 28-10A. Many large trees would be removed and canopy cover reduced to 40%. The logging will forever degrade some of the last intact, old-growth forest in the Little Applegate Valley.

Sunday, August 14, 2016

The New BLM Resource Management Plan and its Impact on the Applegate Watershed

The Wellington Butte Roadless Area and LWC along with many other special places in the Applegate Valley would be open to logging, road building and motorized recreation in the new Resource Management Plan (RMP).

The BLM has released a new Resource Management Plan (RMP), intended to direct management activities throughout western Oregon, including the Applegate Valley. The implications of this new plan for our forests, rivers, wildlife, wildands and communities are concerning to say the least. The plan will turn back many important environmental protections and eliminate land management designations that promote community-based collaboration in the Applegate Valley.

The new RMP would eliminate or reduce many of the environmental protections of the Northwest Forest Plan. The plan would reduce streamside logging buffers by half, impacting 300,000 acres currently protected as Riparian Reserves. Commercial logging in Riparian Reserves will not only harm water quality and our endangered fisheries, but also it will also harm rare and/or endangered species such as the Pacific fisher and northern spotted owl. Riparian Reserves were meant to preserve connectivity on the landscape scale and improve or protect riparian habitat from logging disturbances. In dry regions, like the Applegate Valley, our streams must be protected because our communities rely on them for fisheries, wildlife habitat, sustenance and recreation. They flow through our valley and past our homes.

The plan would also allow logging 278 million board feet of timber annually, an increase of 37% since the last plan was approved in 1995. The new RMP emphasizes clear-cut logging techniques on nearly 500,000 acres of land in Oregon’s moist forests, and proposes a large increase in logging in the dry forests of southwestern Oregon. The increased logging will increase fuel and fire hazards adjacent to our communities and in important forest habitats. It will also degrade important wildlife habitats, impact water quality, log off some of our last intact forests and destroy the viewshed from our communities and homes.

For example, the new RMP will eliminate the proposed designation and protection of two “Lands with Wilderness Characteristics” in the Applegate Valley. Both areas were inventoried and found worthy of LWC protection. Unfortunately, the BLM is removing these areas' LWC status and protections, leaving the Dakubetede and Wellington Butte LWCs open to logging, road building and motorized recreation.

The Dakubetede Roadless Area and LWC will have its LWC status and protections eliminated in the RMP. This important connectivity corridor and recreational hotspot will be open to logging, road building and motorized recreation.

 The Dakubetede LWC is centered around Anderson Butte and the arid slopes of the Little Applegate Valley. The LWC is traversed by the Sterling Mine Ditch Trail and portions of the proposed Jack-Ash Trail. The Wellington Butte LWC, is located near Ruch, Oregon and is the wild core of the proposed Applegate Ridge Trail (ART).  Having become hotspots for non-motorized recreation, both LWCs are well loved by residents of the Applegate Valley and southwestern Oregon. Together the land management practices proposed in the RMP will forever degrade these wildlands and the pristine nature of the proposed ART and Jack-Ash Trails, impacting the quality of life, habitat and the recreation based economy of the Applegate Valley.

Perhaps most important to local Applegate Valley residents is the elimination of the Applegate Adaptive Management Area (AMA). The AMA was designated in 1994 to encourage innovative, ecologically responsible and collaborative land management planning in the Applegate watershed. The AMA was designed to provide the community with opportunities to collaborate and develop “idiosyncratic” methods of land management based on community values and ecological needs.

The Applegate Valley has been a model of community engagement with local land managers. We have worked to create collaborative and socially acceptable land management projects in the AMA. As a community we have worked for 22 years towards consensus, building collaborative capacity and supporting the AMA. Many in the Applegate Valley have invested heavily in the AMA process, working to create a voice for our community and build trust between the BLM and local residents. Removing the AMA designation betrays that trust and will eliminate the BLM’s mandate to work collaboratively with our community and practice innovative forestry practices.

The majority of BLM land in the Applegate Valley would be located within the “Harvest Land Base,” meaning that logging would be the primary form of land management. Timber production would be prioritized over ecological, social or community values within the Harvest Land Base, including within the Dakubetede and Wellington LWCs, numerous Recreational Management Areas, and the corridors proposed for the Jack-Ash and Applegate Ridge Trails.

The majority of the forest in the Applegate Valley would be designated as part of the "Harvest Land Base." This means timber production will be prioritized before ecological needs and recreation.

Some BLM lands in the Applegate watershed will be managed as Late Successional Reserves (LSR). A large block of LSR has been designated in the Williams watershed, Thompson Creek watershed and the western half of the Upper Applegate River watershed. Despite the stated goal of providing large blocks of late successional habitat for the recovery of the northern Spotted Owl, the BLM would mandate the logging of 17,000 acres per decade on the Medford District within these important LSRs.

Although the BLM claims to be emphasizing recreation and conservation in the RMP, nearly all designated conservation and recreation areas would prioritize timber production and motorized recreation. Our two most loved wild areas, the Dakubetede and Wellington Butte LWC will be open to logging, road building and motorized recreation. The corridors of the Jack-Ash and Applegate Ridge Trail will be proposed for timber management and opened to motorized use.   Likewise, our beloved AMA has been axed, along with more than two decades of effort from our community. The new RMP represents old, outdated thinking and a bias towards industrial land management. The residents of the Applegate Valley are looking forward to a more sustainable future. Will the BLM join us?

Please contact your elected officials and tell them that we want our wild places, old forests, clear flowing streams and non-motorized recreation areas protected from logging, road building and OHV use. Ask them to:
  • Revoke the Record of Decision for the new RMP and create a new plan that balances ecological, social and economic values.
  • Maintain streamside logging buffers as proposed in the Northwest Forest Plan
  • Reduce the annual allowable cut by maintaining stream buffers, old forests, LSR habitat, roadless areas and northern spotted owl habitat.
  • Maintain LWC status and protection for the Wellington Butte and Dakubetede Roadless Areas.
  • Reinstate and reinvigorate the Applegate Adaptive Management Area designation. Use this designation to facilitate community collaboration and innovative land management.
  • Reinstate survey requirements for rare wildlife species, plants, lichen and fungi.


Ron Dutton, State BLM Director

Representative Peter Buckley:

Sally Jewell, Secretary of the Interior:

Senator Ron Wyden:

Representative Greg Walden

Monday, July 11, 2016

Nedsbar EA Released! Public Comments Needed.

Nedsbar Timber Sale: Public Comment Guide
Unit 28-10B in the Bald Mountain Roadless Area. Trees up to 42" in diameter are marked for removal. The stand is naturally fire resistant with large well spaced trees, tall canopies, and minimal understory fuels. Logging will remove late seral characteristics while increasing understory fuel loads and fire hazards.
On July 2, 2016, the Medford District BLM released the Nedsbar Forest Management Environmental Assessment (EA). The EA analyzes the predicted environmental impacts of various action alternatives. The primary alternative proposed by the BLM is Alternative 4, which would target some of the most intact, fire resistant forests in our region. The alternative would include 1,500 acres of commercial logging in the Little Applegate and Upper Applegate Valleys.  If implemented, Alternative 4 will increase fire hazards by removing excessive levels of forest canopy and large, fire resistant trees.  

The proposal would log some of the most scenic backcountry in the Applegate Valley along the proposed Jack-Ash Trail and within the viewshed of the popular Sterling Ditch Trail. It would also log forest directly adjacent to our communities in the Little Applegate and Upper Applegate Valleys, impacting the scenic quality of our properties and the view from many of our homes, as well as the region's bourgenoning recreation-based economy, wildlife habitat, wildlands and the beauty of the valley we love.

Fortunately, local residents, the Applegate Neighborhood Network (ANN) and the Community Alternative Working Group joined forces to create a more responsible, sustainable, and fire-wise alternative. Known as Alternative 5 in the Environmental Assessment, the Community Alternative would retain higher levels of canopy cover and large, fire resistant trees, while reducing fuels, prmoting forest health and producing a sustainable amount of timber. 

The BLM has fully analyzed our community-based alternative and acknowledged that it meets the "purpose and need" of this forest management project. Alternative 5 is also consistent with the mandates of the Applegate Adaptive Management Area that was designated to encourage collaboration, innovation and community involvement in public land management planning and implementation. Please consider writing a comment to the BLM. Comments will be accepted until August 1, 2016. Comments can be sent to: 

Below is an analysis of impacts associated with the BLMs Alternative 4, in comparison to the Community Alternative, Alternative 5. 


Fuel increase associated with commercial thinning.
BLM's Alternative 4: Alternative 4 would increase fire hazards adjacent to our communities by removing excessive levels of canopy cover, removing large fire resistant trees and targeting intact, naturally fire resilient forests. The heavy canopy reductions proposed in Alternative 4 will drastically increase fuel loads and fuel laddering by encouraging a dense shrubby understory beneath the remaining "leave" trees. The reduction of canopy will also extend fire season by allowing stands to dry out much earlier in the fire season. This pattern can be seen across the Applegate Valley in stands that were logged in the last 10-20 years. 

The BLM will also be removing many large, fire resistant trees that are the cornerstone of fire resilience and are most likely to survive the effects of a summer wildfire. These large trees are also particularly important for wildlife and contribute to the scenic qualities of the Applegate Valley. 

Finally, Alternative 4 proposes to significantly reduce canopy cover levels and remove large, fire resistant trees in many of our most intact, fire resilient forests. Many of these stands consist of large, old trees with fire resistant characteristics such as closed canopy conditions that suppress shrubby understory fuels, thick insulating bark, high canopies and sufficient space between live trees. The stands are naturally fire resistant and are the most likely locations on the landscape to sustain low to moderate severity fire effects in a summer wildfire scenerio. The relative abundance of intact fire resistant forest contributes directly to our area's fire resilience. Logging these stands will increase fuels and fire risks, potentially encouraging high severity fire effects.

Nedsbar Community Alternative, Alternative 5:

In treated stands, the Community Alternative, Alternative 5, will retain adequate levels of canopy cover to address forest health concerns, suppress shrubby understory fuels and reduce the likelihood of extending fire season by drying treated stands. Alternative 5 will also retain all large, fire resistant stands in our remote and unroaded wildlands. Alternative 5 is also the only alternative to propose the use of prescribed fire to more effectively reduce understory fuels and restore low intensity fire to long unburned areas. The Community Alternative will reduce fuels, maintain fire resistant stands, protect large, fire resilient trees and begin to restore fire to ecosystems in need. 

Unroaded Areas:
Alternative 4 proposes new road construction through these beautiful oak woodlands in the Trillium Mountain Roadless Area. The road would be built to access the uncut forest in units 26-20 and 27-20 on the northern slopes. The road would be built on the ridge in the center of the photograph.

BLM's Alternative 4:

The BLM is proposing to commercially log nearly 1,500 acres in the Nedsbar Forest Management Project. Of this total, 72% or 1,086 acres are proposed in citizen identified roadless areas including the Buncom, Bald Mountain, Boaz Mountain and Trillium Mountain Roadless Areas. These are the last intact ecosystems in the foothills of the Applegate Valley and were recently proposed by Senator Wyden as a large Back-Country Primitive Area. In response to the proposed protection of these areas, the BLM proceeded to target them for logging before they could be protected. Many of the stands proposed for logging are late-seral or old growth stands that provide exceptional wildlife habitat.  

The BLM is also proposing to build 3.2 miles of new road to access commercial logging units. BLM's Alternative 4 will build 2 miles of new road across the western face of Trillium Mountain and in the riparian reserve of Lick Gulch in the Trillium Mountain Roadless Area. This new road would sever the roadless area and badly damage the areas habitat connectivity, scenic qualities, hydrology, wildlife habitat, riparian habitat and native plant communities, while increasing the potential for unauthorized OHV use. 

Currently these unroaded areas provide important wildlife habitat, harbor intact plant communities, sustain old-growth forest habitats, and offer solitude and non-motorized recreationa opportunities to local residents and visitors. These important values will be degraded by the proposed logging in Alternative 4. 

Nedsbar Community Alternative, Alternative 5:

No new roads will be constructed under Alternative 5. The Community Alternative will protect unroaded habitats and the important values they provide. Proposed logging treatments will include roughly 200 acres within unroaded areas, but these treatments will retain all large trees and adequate canopy cover. These units will be located at the edge of unroaded areas with a few hundred feet of existing BLM roads. Their primary purpose is the creation of roadside fuel brakes intended to aid in the containment of wildfire or future prescribed fires. The effect will be an increase in forest health and fire resilience, yet the intact nature of these stands will not be compromised. 

The Community Alternative proposes to eliminate 19 units on over 800 acres in unroaded area that are proposed for logging in BLM's Alternative 4. 

The view from the Sterling Mine Ditch Trail across the Little Applegate River Canyon to units 26-20 and 27-20 proposed for logging in the BLM's Alternative 4. One mile of new road would be built in the Trillium Mountain Roadless Area to facilitate logging these uncut forests.

BLM's Alternative 4: 
The BLM has proposed logging 57 acres of intact old-growth forest on the proposed route of the Jack-Ash Trail. The Jack-Ash Trail is proposed to extend from Jacksonville to Ashland, Oregon and is poised to become a recreational hotspot for residents of southwestern Oregon and visitors to the region. The proposed logging units are located within one of the trails wildest sections in the Bald Mountain Roadless Area. Trees up to 42" in diameter have been marked for removal.

BLM's Alternative 4 proposes to log numerous units directly across from the Sterling Mine Ditch Trail. These units are predominantly located in the Trillium Mountain Roadless Area, an area that currently appears completely undisturbed. The majority of these units would be logged to 40% canopy cover, which would make the logging units very prominent and disruptive to the trail's viewshed. At least 25 units would be highly visible from the Sterling Mine Ditch Trail. 

Nedsbar Community Alternative, Alternative 5:

The Community Alternative would protect the viewshed of the Sterling Mine Ditch Trail. Only 4 units would be visible from the Sterling MIne Ditch Trail, but these units would reduce canopy cover far less drastically that proposed in the BLM treatments, making the units less visible and more naturally appearing. 

The Community Alternative proposes no logging in the Bald Mountain Roadless Area, eliminating the impact of old-growth logging on the Jack-Ash Trail. 

In a era of diminishing opportunities to hike in areas unmarred by logging, road building and other industrial impacts, it is vital to retain the natural characteristics of the Applegate landscape for the economic importance of our growing recreational economy. 

Northern Spotted Owl Habitat

BLM's Alternative 4:

Alternative 4 would impact Northern Spotted Owl (NSO) habitat and complex, late seral forest habitat by "removing" or "downgrading" NSO habitat. Removing habitat means that habitat conditions following logging operations have been degraded to the extent that NSO will no longer use the area for nesting, roosting and foraging (NRF) or dispersal. Downgrading habitat means that the quality of habitat following logging operations will be less useful to the owl than it was prior to logging treatments. 

For example, habitat currently, identified as suitable for nesting, roosting and foraging would be "downgraded" to dispersal, meaning that the habitat conditions would no longer support nesting, roosting, or foraging habitat and will only function for NSO that are "dispersing" or migrating through the area. Dispersal habitat can be downgraded to "capable" habitat, meaning it is currently not useful to the NSO, but the soils and climatic conditions could support the complex forest that in turn supports the NSO. 

BLM's Alternative 4 proposes to remove 109 acres of NRF habitat and 217 acres of dispersal habitat. The proposal includes 269 acres of NRF downgrades to dispersal habitat. In total, 595 acres, or 40% of the commercial logging acres are proposed to have negative impacts on the Northern Spotted Owl. 

Nedsbar Community Alternative, Alternative 5:

Alternative 5 would protect and promote high quality NSO habitat by deferring many of the most complex, old forest habitats from logging treatments. Habitat conditions would be maintained in harvested units by retaining canopy cover levels at between 50% and 60% for the majority of uniti, as well as retaining all large, old trees. This is an important component of the Community Alternative because it is important for the NSO that its habitat is protected within treated areas. 

Although the Community Alternative Working Group developed the alternative with guidelines to protect NSO habitat, the BLM analysis of the Community Alternative, Alternative 5, has shown a supposed downgrade of 26 acres of NRF habitat. We have requested information regarding where these supposed downgrades will occur in the Community Alternative, but we have not yet recieved a response from BLM.

BLM's Environmental Analysis shows that NRF downgrades and removals are nearly 15 time more prevalent in BLM's Alternative 4 than in the Community Alternative, Alternative 5. 

New Road Construction:

BLM's Alternative 4: 

Alternative 4 proposes 3.24 miles of new permanent road construction and 1.28 miles of temporary road construction. According to BLM nearly 1/4 mile of new road would be built in the bottom of Lick Gulch, potentially creating significant levels of sedimentation. Road reconstruction would take place on 4.45 miles of road. Alternative 4 would also build 12 new helicopter landing sites. 

Nedsbar Community Alternative, Alternative 5:

The Community Alternative proposes no new road construction, temporary or permanent. Road reconstruction would take place on 0.31 miles of existing road and no new helicopter landings would be built. 

The BLM already has an enormous backlog of deferred road maintenance because of budget constraints and the sheer size of the current road system. It is fiscally irresponsible to build new roads with public money when there is no funding for long term maintenance. Roads are a major source of sediment in our streams. The chronic sedminentation created by logging roads have long lasting and detrimental impacts to anadromous fish populations. The financial and ecological impacts of road building are just too high. 

Large Tree Retention:
A large, old tree over 40" in diameter marked for removal in unit 35-32 located at the headwaters of Grouse Creek. Unit 35-32 is proposed for logging to 40% canopy cover in the BLM's Alternative 4.

BLM's Alternative 4:

The BLM has refused to impose a diameter limit on Alternative 4. Community monitoring has documented trees up to 42" in diameter marked for removal. According to the BLM timber tally, 501 trees over 20" in diameter are proposed for removal. This number excludes 24 units that were "leave" tree marked, making quantifiable numbers more difficult to produce. This is extremely significant because numerous units with large, old trees marked for removal are currently not included in this estimate. In many units basal area and canopy cover targets necessitate the removal of large trees over 21" in diameter. 

Update: Although you will not find the information in the EA, after publicizing our findings, the BLM has published an Errata Sheet admitting that the numbers presented in the Nedsbar Forest Management Project EA were inaccurate. The have increased the number of trees over 20" in diameter marked for removal in Alternative 4 to 1,826, over three times the original estimate in the EA. 

Unfortunately, this new estimate is also suspect. The number is based on estimates that do not include any of the Group Selection units and does not actually quantify many other units due to the way they were marked. This means that the remaining 81% of the units are not quantified. The BLM is claiming that only 501 large trees or 27% of their current estimate are marked for removal in these final 62 units. We are working to verify these numbers because many of these 62 remaining units contain significant numbers of large trees marked for removal. 

Nedsbar Community Alternative, Alternative 5:

The Community Alternative identifies a 20" diameter limit across the entire project area. No trees over 20" in diameter would be removed under the prescriptions outlined in Alternative 5.   

Public Comments can be sent to:   
 Subject: (Attention: Kathy Minor-Ashland Resource Area-Nedsbar)