Sunday, June 25, 2017

Pickett West Timber Sale: The Panther Gulch and West Pickett Creek Units

This large Douglas fir tree will be logged in unit 28-4.
 The Pickett West Timber Sale is so huge that it will likely be broken up into numerous timber sales when auctioned off to the highest bidder. The BLM has not even finished the comment period for the Pickett West Timber Sale, but has moved forward with timber sale marking and design in the first timber sale. The first sale proposed by the BLM is called the Pickett Hog Timber Sale and will extend from Pickett Creek on the Rogue River, downstream to Hog Creek and Hellgate Canyon. 


South Fork Panther Gulch
Recently, I hiked into two units in Panther Gulch, a tributary of Pickett Creek and a beautiful little canyon of oak woodland, forests of sugar pine and Douglas fir, bedrock cascades and stark serpentine openings studded with jeffery pine. 

The area is diverse and relatively intact. The lower portion of Panther Gulch was roaded and logged many years ago. The upper portion of the canyon is largely untouched with dense stands of old growth forest and serpentine barrens on the flank of Buckhorn Mountain. The stream runs quietly through clear pools and down bedrock cascades. 

I hiked an old decomissioned road that leads from the still open portions of Panther Gulch Road to a the stream's first major fork.  The area includes units proposed for "density management" retaining 40-60% canopy cover. 

South Fork Panther Gulch: Units 28-3 & 28-4
The conifer forest above the shallow, rocky soils and oak woodland in this photo is a portion of Unit 28-3.

The south fork of Panther Gulch is a beautiful stream running through steep bedrock cascades, sunlit oak woodland and old growth forest of sugar pine and douglas fir mingling with mixed hardwoods such as madrone, black oak, live oak and white oak. 


Unit 28-4 is located near the confluence of the north and south fork, on a low ridge dividing the two streams. The area is deep in the canyon and provides "high relative habitat suitability" for the northern spotted owl. High relative habitat suitability means that the location is one of the most likely portions of the landscape to maintain old-growth conditions over time. The unit is designated as Nesting, Roosting and Foraging (NRF) habitat for the northern spotted owl and was identified by BLM to be a 150 year old stand. The agency claims to be "maintaining" northern spotted owl habitat within this unit, but they will be reducing important habitat elements such as canopy layering, decadence, large downed wood recruitment, snag habitat, and large, old trees.


The unit is listed as a density management prescription in the Environmental Assessment, but appears to include a group selection mark, meaning isolated stands of trees within the unit will be logged while others remain untreated. Logging within each "group selection" cut can be classified as thinning, but includes the removal of large, old fire resistant trees. Douglas fir trees up to 36" in diameter are marked for removal in this unit. These trees are likely to be over 150 years old and thus constitute old-growth. 

Unit 28-4 is marked orange to denote "leave" trees that will be retained. Unmarked trees will be logged. As you can see in this picture, a 36" diameter and likely very old douglas fir tree would be removed to "release" the small pine marked for retention.

The stand is a lush mixture of riparian shrubbery, sugar pine, douglas fir and mixed hardwood habitat. The unit should be canceled. 

Unit 28-3 is located just upstream from unit 28-4. The two units are divided by a small area of oak woodland on shallow, rocky soils. Unit 28-3 is a relatively open mixed conifer stand identified by the BLM to be 150 years old. A large portion of the stand consists of black oak, white oak, live oak and madrone groves, punctuated by groupings of large conifers and open conifer stands. 

The unit is identified by the BLM as NRF habitat and would be downgraded to dispersal habitat due to heavy canopy reduction, the removal of large, dominant and co-dominant trees and a significant loss of habitat complexity. 
 
The large Douglas fir trees in this photo would be logged in unit 28-3. Only the sugar pine marked orange for retention would be maintained following "restoration" logging treatments.

The unit provides highly diverse and important old forest habitat. The area is not in need of "restoration" or "density management" in fact, the stand contains significant structural diversity and naturally fire resilient stand conditions. Logging this stand to 40% canopy cover will encourage the development of dense shrubby understory conditions creating excessive fuel loads and fuel laddering. 

The removal of conifers in this stand will also create significant impacts to the stands abundant hardwood species. Not only will many hardwoods be damaged during falling operations, but many hardwoods and standing snags will be removed to facilitate helicopter yarding. Unit 28-3 should be canceled. 

West Fork Pickett Creek: Unit 29-4
Unit 29-4 is mature conifer forest and is proposed to be logged to 40% canopy cover. The large tree marked red at the center of the photograph would be retained, while nearly all other trees will be logged.

I also recently hiked into unit 29-4 high above the West Fork of Pickett Creek. The unit consists of relatively intact old forest identified by the BLM to be a 160 year old stand. The stand is dominated by Douglas fir with a mixture of ponderosa and sugar pine. Many years ago the stand was high-graded and massive, old ponderosa pine were removed. Today, the stand has recovered, the canopied has filled in, the residual trees have grown old, and habitat characteristics associated with old-growth forest such as decadence, complex structure, downed wood, large diameter trees and snags have begun to develop. 

The stand is identified by the BLM as Nesting, Roosting and Foraging habitat for the Northern spotted owl. The BLM is proposing to downgrade this habitat to dispersal habitat by bringing the canopy cover down to 40%, post logging. The proposed "Density Management" prescription will also remove many large fire-resistant trees. 

Unmarked trees such as these ones will be logged by the BLM in unit 29-4.

 Much of the unit will be tractor yarded, creating extensive soil disturbance and compaction, damaging soils and increasing erosion rates. The combined result of canopy removal and heavy soil disturbance will trigger excessive regeneration, creating dense understory fuel loads and increased fire risks. 

A new road is also being proposed on the the ridgeline above the unit. The road will necessitate the removal of many large, old trees and permanently impact the stands soil resources.

Unit 29-4 should be canceled from the Pickett Hog Timber Sale. In fact, according to the BLM's 1995 Resource Management Plan no stands over 150 years old should be considered for commercial thinning. 89% of the Pickett Hog Timber Sale (25 of the 28 units)  are over 150 years old. The sale is inconsistent with the 1995 RMP and should be canceled. 

BLM is accepting comments on the Pickett West Project until July 17, 2017

Submit comments to: 
Grant Pass Inter-agency Office/Don Ferguson
2164 NE Spalding Ave. 
Grants Pass, Oregon 97526
-or-
                                    blm_or_pwest@blm.gov
 







Monday, June 19, 2017

Lights, Cameras, and Don't Forget to Take Action! Sign on in Support of the Applegate Ridge Trail!

A view into Ruch, Oregon from the East Applegate Ridge Trail (ART).
The Applegate Trails Association (ATA) has released "Walking the Wild Applegate" to viewers online. The film documents the first thru-hike on the Jack-Ash and Applegate Ridge Trails. Together, the non-motorized trail system will connect the communities of Grants Pass and Ashland, Oregon. The trails will extend over 80 miles through the rugged foothills of the Applegate Valley, including the Dakubetede, McDonald Peak and Wellington Butte Roadless Areas.

ATA has also released a link to an online petition in support of the Applegate Ridge Trail. We need a showing of support to continue building trail. We are working to gain approval through the Medford District BLM on the next section of trail. We believe BLM needs a little positive reinforcement. Please sign on in support of the trail!

Please, sit back, enjoy the film and the beautiful scenery of the Siskiyou Mountains. After seeing the potential benefits and beauty of the Jack-Ash and Applegate Ridge Trails I am sure you will want to sign on and let the BLM know you support the trail. 

Lights, camera, and don't forget to take action. Sign on in support now!


To view the film: Walking the Wild Applegate
To sign the online petition: Support the Applegate Ridge Trail

Wednesday, June 14, 2017

Zig-Zag Creek, Hellgate Canyon and the Pickett West Timber Sale: Diverse Ancient Forests Under Attack!

Unit 10-1 of the Pickett West Timber Sale is located on Zig-Zag Creek in beautiful old-growth forest habitat. The unit would be logged to 30% canopy cover under the BLM's so-called "forest restoration" prescriptions.
The Pickett West Timber Sale is a massive BLM timber sale proposed by the Grants Pass Resource Area. The proposed project area extends from southern Oregon's lower Applegate River, to the forests outside Selma, and the wild tributary streams of the mighty Rogue River. The timber sale includes 69 units between 150 and 240 years old. Prescriptions in these units vary, but many would be logged to as low as 30% canopy cover; many large old trees would be removed to meet canopy cover and basal area targets. Ironically, the BLM has defined these heavy industrial logging treatments as "forest restoration," a term now so broadly applied that it has virtually no meaning. Unfortunately, the outcome of such logging will be far from restorative and many of the forests proposed for logging need no restoration at all.

I recently visited a few units in the Hellgate Canyon section of the Rogue River. Directly above this iconic southern Oregon landscape, and adjacent to the Wild and Scenic Rogue River Corridor, the BLM is proposing to log diverse, ancient forests between 150 and 230 years old. Some of these units will be visible from Hog Creek Boat Ramp and Hellgate Canyon Overlook, both are very scenic viewpoints in the highly popular and economically important Hellgate Canyon.

The area is a diverse and relatively intact habitat, consisting of the rugged Hellgate Canyon, broad serpentine flats, sunlit oak woodlands and ancient old-growth forests. I hiked Pickett West units 9-1, 9-2, 9-3 and 10-1 in Zig-Zag Creek, Little Zig-Zag Creek and Blue Canyon. The Zig-Zag and Little Zig-Zag drainages are some of the most intact tributaries in the Hellgate Canyon portion of the Rogue River. Zig-Zag Creek, in particular, is not only highly diverse, but incredibly beautiful, as the stream runs through deep box canyons beneath dark outcrops, oak woodlands and towering old-growth forests. The BLM portions of Zig-Zag Creek need no "restoration" and surely do not need the old-growth logging proposed in the Pickett West Timber Sale.

The Zig-Zag Creek watershed is a diverse and rugged mosaic of forest, woodland, grassland and rock outcrop. The conifer forest in this photograph is identified as unit 10-1 in the Pickett West Timber Sale. 

Zig-Zag Creek: Unit 10-1
Zig-Zag Creek climbs quickly from its confluence with the Rogue River at Hellgate Canyon and into a deep, cool box canyon. Tall bluffs topped in squat oak and the golden grass of summer extend from the clear flowing stream into ancient groves of old-growth Douglas fir, sugar pine, madrone and tanoak. The stream itself is narrowly confined by tall outcrops of bedrock, creating a rugged canyon of clear pools, cascades and lush riparian vegetation. The area is highly diverse and contains significant levels of heterogeneity as plant communities transition from one to another.   
As the long series of bluffs in lower Zig-Zag Creek give way to towering conifer forests, unit 10-1 of the Pickett West Timber Sale reaches from the canyon bottom to the ridge above. The units consist of massive old forest, including sugar pine up to five feet in diameter on incredibly steep, mountainous slopes. According to the BLM the stand is 230 years old. Trees within the stand are likely much older than 230 years, but the general stand condition is clearly old-growth. 

The oldest trees in the stand are relatively well spaced, with a complex secondary canopy of hardwoods, namely madrone, tanoak and live oak. The forest grows in a diverse, patchy mosaic with complex groupings colonizing the steep mountainous terrain. The closed canopy groves protect relatively mesic understory communities of vanilla leaf, Oregon grape and poison oak.

Ancient pine and fir dominate unit 10-1 with a secondary canopy of madrone, tanoak and live oak. The stand is healthy, resilient and provides exceptional habitat for late-seral species like the northern spotted owl, Pacific fisher and red tree vole. In fact, the large Douglas fir at the left hand side of the photograph supports a red tree vole nest. Red tree voles are a major food source for the northern spotted owl.

Numerous small seasonal gulches dissect the unit and many trees have been documented to contain red tree vole nests. Red tree voles are a small rodent living high in the canopy of large Douglas fir trees. Red tree voles, like the northern spotted owl who utilizes the little vole as a major food source, are habitat specialists requiring old Douglas fir trees for their entire lifecycle. They eat Douglas fir needles, line their nest with Douglas fir needles and live in the canopy of old, gnarled Douglas fir trees. They appear to be particularly abundant in this stand and their habitat should be protected. High-quality red tree vole habitat is, in fact, high quality Northern Spotted Owl habitat. Unit 10-1 is identified as Nesting, Roosting and Foraging (NRF) habitat for the Northern Spotted Owl, but the habitat is proposed for removal. This means habitat that currently supports all portions of the owl's lifecycle will no longer provide usable habitat to the owl after logging has occurred.

The unit is proposed for "forest restoration" logging, meaning the stand could be logged to as low as 30% canopy cover. Logging the stand to this level of canopy would require the removal of many large, old-growth trees. Logging this stand will also reduce habitat complexity, destroy the currently multi-layered canopy structure so important to the Northern Spotted Owl and red tree vole. Finally, logging large, old fire-resistant trees in this stand will only reduce the stand's resistance to fire. Opening the canopy will also encourage a dense understory growth of regenerating hardwoods, conifers and shrubs, creating ladder fuels that will overtime drastically increase fuel loading and fire risks.


Unit 10-1 contains naturally resilient and highly complex old-growth forest habitat. The stand is structurally complex, compositionally diverse and in need of no "restoration."

The upper portion of the unit extends to the ridgeline, where it makes an abrupt and interesting transition with serpentine soil types, open grassland and Jeffery pine savanna. A half-mile of new road is being proposed by the BLM to access the unit. The road would extend across a small stream and over the currently un-roaded and spectacular serpentine ridgeline dividing Zig Zag Creek from Serpentine Creek.

The goal of "forest restoration" logging in this stand is to convert the currently closed-canopy, old-growth stand into an open, late-seral forest. Unfortunately, converting this stand to open conditions will provide no benefit to the habitat for late-seral species, the health of the forest, or the resilience of the stand to fire. At the same time logging in this stand will create numerous cumulative impacts including the loss of large, old trees, disruption of snag and large wood recruitment, impacts to water quality in Zig-Zag Creek, a loss of habitat complexity, and the removal of Northern Spotted Owl habitat.

Unit 10-1 is a mosaic of forest habitats including closed canopied mixed conifer forest with a two-tier canopy structure. Massive old growth and mature conifers rise above a secondary canopy of hardwoods such as tanoak, live oak, madrone and pacific dogwood.

The project will also create visual impacts to the Wild and Scenic Rogue River in the popular Hellgate Canyon. Unit 10-1 will be visible from both the Hog Creek Boat Ramp and the Hellgate Canyon Overlook, both very popular recreation sites and scenic vista points along the Galice-Merlin Road. The recreation and economic activity provided by Hellgate Canyon is a significant boost to surrounding communities. The units logged to as low as 30% canopy cover will create severe impacts to these important viewsheds, degrading the quality of recreational experience in the Hellgate Canyon.

Little Zig-Zag Creek: Units 9-2 & 9-3

Unit 9-3 of the Pickett West Timber Sale on Little Zig-Zag Creek. According to the BLM the stand is 190 years old.

Little Zig-Zag Creek, although not as dramatic as Zig-Zag Creek to the east, contains important, relatively undisturbed habitat including serpentine soils, old forest and oak woodland. The area, like Zig-Zag Creek is very diverse and relatively intact. Much of the forest in the area appears unentered by industrial logging. According to the BLM, stands in units 9-2 and 9-3 are 190 years old. Trees over 40" are found in the stand and portions of the stand contain classic, low elevation old-growth habitat. 

Much of the forest is dominated by Douglas fir, with scattered populations of black oak, white oak, madrone and pine. The forest borders oak woodlands and broad serpentine flats colonized by grass, buckbrush and scattered pine before it drops into the canyon of the Rogue River.

Units 9-2 & 9-3, although predominantly closed canopy stands, contain significant diversity in structure and composition. In some areas windthrow has created small canopy gaps and open stands. The stand currently supports Nesting, Roosting and Foraging (NRF) habitat for the northern spotted owl. 

Stands like this one in unit 9-3 of the Pickett West Timber Sale are expressing old-growth characteristics. Downed trees are building complexity on the forest floor and creating small canopy openings. Understory conditions are grassy and diverse. Although closed canopied the forest is diverse, resilient to natural disturbance, relatively open and structurally diverse. The stand is developing late-seral conditions naturally and is not in need of "restoration."

Proposed "forest restoration" logging treatments will reduce the canopy cover in unit 9-3 to as low as 30%. This will convert habitat that currently supports the entire lifecycle of the northern spotted owl into unusable habitat cut to below the threshold for "suitable"  habitat. Logging these stands to as low as 30% canopy cover will also reduce the stand's resistance to high-severity fire by encouraging dense shrubby understory growth, reducing habitat complexity and removing many old, fire resistant trees. The logging will also disrupt snag and large wood recruitment starving the stand of future inputs by removing large portions of the stand for commercial harvest.

Blue Canyon: Unit 9-1
 
Unit 9-1 is the forested ridgeline at the center of this photograph. Notice the incredible diversity of habitat types including oak woodlands, open pine stands, serpentine grassland and closed-canopy old-growth forest. Logging unit 9-1 would provide no ecological benefit and should be canceled.

Blue Canyon is located west of Little Zig Zag Creek in the Hellgate Canyon portion of the Rogue River. The stream is geologically and topographically diverse, including broad serpentine flats with oak and pine habitats, rock outcrops, relatively recent burn patches, chaparral and steep conifer covered ridges. Unit 9-1 is located on a northwest facing slope overlooking the big grassy flats on lower Blue Canyon. 

At the top of the broad meadows buckbrush thickets, grassy oak woodlands and open pine stands transition into lush fern-filled forests of Douglas fir. The stand is structurally diverse with large old-growth trees, mature groves of fir, a rich understory of vanilla leaf, a multitude of ferns, downed trees and hazel thickets. The majority of the area is green and verdant and resilient to natural disturbances such as fire, insect infestations, and the effects of climate change. 

According to the BLM, the stand is 190 years old and represents Nesting,  Roosting and Foraging (NRF) habitat for the Northern Spotted Owl. Roughly a quarter mile of new road is proposed to be built on the currently unroaded ridgeline above. The road will impact intact old forest and would facilitate logging units 9-1, 9-2, & 9-3. 

Unit 9-1 is proposed for "Density Management" logging and is marked with a  "group select" prescription, meaning small isolated groupings would be logged throughout the stand, leaving some areas untreated. The volume produced will be minimal and the benefit of such logging is highly questionable. The old stand is currently healthy and unit 9-1 should be canceled from the Pickett West Timber Sale. 

Unit 9-1 is healthy, diverse, fire resistant and does not need "restoration" or "density management" treatments. The photograph shows a "group select" mark. Roughly half the old trees in this grove will be removed. Trees marked with red paint will be retained, while unmarked trees will be removed.
Protect our economy and our old forest. 
Oppose Pickett West!

The treatments proposed in Pickett West are not restorative in nature, but rather represent an industrial approach to timber production. Logging old-growth stands and removing northern spotted owl habitat cannot be described as restoration, in fact, it can only be described as habitat degradation, fragmentation and forest simplification. The heterogeneity on this landscape is already expressed, due to a combination of diverse geology, stand history, fire history, and aspect. The complexity and value of habitat found in the Rogue River Canyon should be maintained for the region's fisheries, recreation economy, and ecological values.

The habitat found in the Hellgate Canyon portion of the Rogue River attracts visitors from around the globe, looking for a beautiful outdoor experience, incredible river vistas and intact forest habitats to explore. The fisherfolk, whitewater rafters, recreational drivers, hikers, botanists, and others come to this canyon enjoy the place for its scenic beauty. Logging these forests for O&C timber production is shortsighted and counterproductive to the local economy. Recreation on the Rogue River is worth $35 million dollars annually and three out of every four lodging guests in the Grants Pass/Merlin area are associated with recreation on the Rogue River. The economic value of recreation is worth far more than the Pickett West Timber Sale and the logs it will produce. Some forests are worth far more standing. The forests of the Rogue River Canyon surely represent a more sustainable and vibrant asset to our community as intact, old growth forest, than two by fours.


Hellgate Canyon at the confluence of Zig-Zag Creek. Unit 9-1 is visible on the forested knob at the upper left corner of the photograph.

Please contact the Grants Pass BLM and ask for the following amendments to the Pickett West Timber Sale.

Support Alternative 3 with the following amendments:


  • Cancel all commercial logging units over 150 years old.
  • Cancel all new road construction.
  • Cancel all so-called "forest restoration" logging treatments that will reduce canopy cover to as low as 30%.
  • "Maintain" all northern spotted owl habitat.
  • Protect the proposed Applegate Ridge Trail and build no roads over the proposed trail corridor. Cancel units 13-8 and 15-11. 
  • Cancel all Hellgate Canyon units including units 9-1, 9-2, 9-3, 10-1, 10-2 and 15-1.


Submit comments to: 
Grant Pass Interagency Office/Don Ferguson
2164 NE Spalding Ave. 
Grants Pass, Oregon 97526
-or-
blm_or_pwest@blm.gov 

This map shows the Hellgate Canyon units of the Pickett West Timber Sale. The red lines show proposed new road construction. The green polygons show Pickett West Timber Sale units, and the light blue shows riparian reserves within those units. Units 9-1, 9-2, 9-3, 10-1, 10-2, and 15-1 should be canceled from the Pickett West Timber Sale.



Saturday, June 3, 2017

Pickett West Timber Sale: Industrial Old-Growth Logging and the Restoration Facade in the Trump Era

Unit 13-1 of the Pickett West Timber Sale is an isolated stand of old-growth forest in heavily logged and fragmented Cheney Creek, a major tributary in the Lower Applegate River Watershed. The BLM claims the general stand age within the unit is 150 years old, although individual trees in the stand are likely far older. The stand is currently categorized as nesting, roosting and foraging (NRF) habitat for the northern spotted owl, but BLM intends to log the stand to 40% canopy cover, downgrading owl habitat by dropping the canopy cover threshold to the low end of dispersal habitat. Unit 13-1 should be canceled.
The Trump administration has initiated massive rollbacks of environmental regulations that protect clean water, clean air, climate protection, wildlands, and endangered species. Trump's environmental deregulation is also pushing public land managers to increase logging and industrial resource extraction on our public lands, including the forests of southwest Oregon and northwest California.

The Trump Administration has also brought us "alternative facts," blatant political double speak, and an all-out assault on science. We are seeing the same manipulation of science and fact in southern Oregon. "Forest Restoration," now sadly a pseudonym for industrial logging and co-opted by the industry, special interest groups and agencies like the BLM, is being so broadly applied that it has little to no real meaning beyond the "greenwash" it provides. Anything and everything is now called "forest restoration" irregardless of the actual results on the ground, impacts, or intentions. To the BLM "forest restoration" and "resilience" mean little beyond the production of timber to satisfy O&C timber outputs. Forest Restoration is a euphemism used to obfuscate the real motive: industrial timber production. 

The BLM and their industrial partners have used the fear of fire to perpetuate this narrative, stating falsely that all contemporary fires are catastrophic. This is not the case in the Klamath-Siskiyou Mountains where fire histories and fire regimes are very complex. The BLM is also perpetuating the false narrative that all forest habitat that is not logged to low density will succumb to insect infestations, catastrophic fire and excessive competition, creating drought stress and low vigor trees. 

 
The Big Windy Fire burned in 2013 through mostly unmanaged watersheds adjacent to the Pickett West Planning Area in the Zane Grey Roadless Area. The Pickett West EA cites the Big Windy Fire as an example of recent wilfires and their increasing fire severity. The reality, thousands of acres of closed canopy, late-seral forsest burned at low severity. In fact,  90% of the Big Windy Fire burned at low to very low severity. The Big Windy Fire provided far more "restorative" effects than commerical logging would have and the natural forests in the area demonstrated "fire resilience."
In pursuit of the mythical "open forest" we are sacrificing nearly every other resource and value. A more holistic, humble and nuanced approach is needed. The Pickett West Timber Sale is the newest, and perhaps the most egregious, recent example of agency double-speak, misapplied science, and fear-based forestry.

The Pickett West Timber Sale
The Pickett West Timber Sale is a massive BLM timber sale extending from Merlin and Galice on the Wild and Scenic Rogue River, to Selma and Deer Creek in the Illinois River watershed, and across the Lower Applegate River watershed from Wilderville and Murphy to North Applegate Road. The planning area spans over 200,000 acres and includes 145 separate units across southwestern Oregon. The scale of the project is unprecedented and will likely generate numerous large industrial timber sales. 

The BLM has released an Environmental Assessment for the Pickett West Timber Sale and are accepting public comments until June 29, 2017. 

The BLM has proposed two action alternatives: Alternative 2 and Alternative 3. 

  • Alternative 2 is the BLM's proposed action based off the Southern Oregon Forest Restoration Collaborative's (SOFRC), Rogue Basin Cohesive Forest Restoration Strategy
  • Alternative 3 is very loosely based on comments from Applegate Neighborhood Network (ANN), although BLM did not allow Applegate residents representing ANN any opportunity to collaborate or cooperate in the alternative's development. Alternative 3 eliminates new road construction, institutes a 21" upper diameter limit and requires the BLM to maintain all northern Spotted Owl Critical Habitat. 


Alternative 2 (BLM's Proposed Action)
The Rogue Basin Cohesive Forest Restoration Strategy: The Basis for the Pickett West Timber Sale 
An industrial approach to forest restoration, the Rogue Basin Cohesive Forest Restoration Strategy proposes heavy canopy reduction and commercial logging in old forest habitats. The goal of the strategy is to restore forest "resiliency" by supposedly balancing seral stage development on the landscape scale. The approach is built on the assumption that historic fire regimes were high-frequency and low-severity, and that this fire regime created a landscape dominated by open-canopied, late-seral forest throughout southern Oregon in the historic period. However, early landscape photographs, early landscape descriptions, Donation Land Claim Surveys, and natural historic vegetation research do not often support the open forest hypothesis in southwestern Oregon. The fire regime in the area is a mixed-fire regime, that combined with complex geology, creates a pattern of open forest, closed forest, chaparral and grasslands. It is precisely this diversity of habitat types, partially resulting from a mixed-fire regime, that creates the outstanding biodiversity of our region.

The Rogue Basin Cohesive Forest Restoration Strategy prioritizes logging old forest by implementing a "priority multiplier." This multiplier prioritizes late-seral, closed canopy stands on warm ridges and mid-slopes at twice the level of early-seral (young) stands on any slope position. The result is that a full 48% of the Pickett West units (69 of 145) proposed for logging have a stand age of between 150 and 240 years old. The strategy calls for logging in so-called "excess" closed canopy, late-seral forest to create more open-canopied, late-seral forest. The negative effects of this sort of type conversion (i.e. converting one habitat type to another) are well known and cannot be accurately characterized as forest restoration or fuel reduction. 

More accurately, the treatments proposed can be described as landscape-scale forest engineering, forest fragmentation and industrial logging. Reducing canopy cover to as low as 30% will drastically increase fuel loading as dense young stands of hardwoods, conifers, and chaparral develop in response to the canopy opening. 
Does this look like forest restoration or industrial logging? This unit was logged to roughly 30% canopy cover in the O'Lickety Timber Sale on the Little Applegate River. Units proposed for "Forest Restoration" treatments in Pickett West could be cut to a minimum of 30% canopy cover, and could look similar to this.

The scope and scale of the logging proposed in the Rogue Basin Cohesive Forest Restoration Strategy is troubling and has set the stage for the unprecedented scale of the Pickett West Timber Sale.  The Rogue Basin Cohesive Forest Restoration Strategy proposes commercial logging on 1.1 million acres of federal land in a 20-year period throughout the entire Rogue River watershed, from the Pacific Coast at Gold Beach, to the headwaters in the southern Cascade and Siskiyou Mountains. To achieve this level of commercial logging, SOFRC proposes to increase "treatments" on federal land by more than six times the current rate, from 9,000 acres per year to 55,000 acres annually. Individual project areas would be built specifically to create 6 million board feet of timber per project area. 

The Rogue Basin Cohesive Forest Restoration Strategy proposes only four separate treatment types for the entire Rogue Basin. These four treatments would maintain between 42% and 54% canopy cover. Clearly only a paltry four treatment types cannot adequately restore the incredible diversity of habitats found in the Rogue River Watershed on 1.1 million acres of federal land.

The Trump Era: The Return of Old-Growth Logging   
The Pickett West Timber Sale appears to be the first federal project planned to implement the Rogue Basin Cohesive Forest Restoration Strategy's "Forest Restoration" prescriptions. With the anti-environment Trump administration at the helm, the BLM is upping the ante and is pushing hard to increase logging on our public land, including logging in old-growth forests. 

The "Forest Restoration" prescriptions developed by BLM for the Pickett West Timber Sale are intended to create very open forest conditions, reducing canopy to as low as 30%. Many of the units proposed for logging are between 150 and 240 years old, making them old-growth forest by most credible definitions. Although spread throughout the project area, many of the units located on the Rogue River above the Wild and Scenic Rogue River Corridor are old, natural stands. 
The BLM is proposing to log old forest habitats directly above the Wild and Scenic Rogue River near Merlin and Galice.

The proposed prescriptions contain no upper diameter limit (i.e. no limit to the size of the tree cut), meaning large, old, fire resistant trees would be removed to meet canopy cover and basal area requirements and to facilitate the type conversion from closed forest to open-canopied stands. 

Alternative 2 would log 5,251 acres of our public BLM land. Treatments would include commercial logging in northern spotted owl habitat and in riparian reserves. 3,025 acres would be logged with "Forest Restoration" prescriptions.  2,226 acres would be logged with "Density Management" prescriptions, retaining between 40% and 60% canopy cover. Another 754 acres would be logged using "Understory Reduction" prescriptions.

Pickett West Unit 13-8, located on Rocky Gulch above Missouri Flat in the Lower Applegate Watershed contains intact, fire-adapted, old-growth habitat. The BLM claims the stand is only 60 years old, but portions of the stand are much older. The BLM is proposing to build new road into this unit and log the stand to 40% canopy cover. Unit 13-8 should be canceled.

In total, over 4,000 acres of endangered Northern Spotted Owl habitat would be removed or downgraded in habitat quality. The sale would also build 14 miles of new road — BLM calls this road construction "temporary," but the impacts will, in fact, be permanent. 14 more miles of road re-construction and tractor swing roads would also be built to facilitate timber harvest.

Alternative 3 The BLM claims that Alternative 3 was developed in response to public scoping comments submitted by the Applegate Neighborhood Network (ANN) and others, yet BLM did not allow the public any influence on how this alternative was developed, what units were included, or how our comments should be interpreted. The BLM admits that they did not implement a collaborative process to create Alternative 3, and the end result is a so-called "Community Alternative" many in the local community cannot support. 
Unit 15-11 is located above North Applegate Road and is estimated by BLM to be a 160-year-old stand. Many old trees are much older than 160 years old and would likely be logged in the Pickett West Timber Sale. Unit 15-11 should be canceled.

On a positive note, Alternative 3 proposes no new road construction, a 21" upper diameter limit, no riparian reserve logging and maintenance of all northern spotted owl habitat within critical habitat. 

On a not-so-positive-note, Alternative 3 would commercially log 4,213 acres, including 1,028 acres of so-called "Forest Restoration," logging stands to as low as 30% canopy cover. 1,555 acres of northern spotted owl habitat would be downgraded or removed. Many of the units identified by the BLM in Alternative 3 are located in old forest that will not benefit from commercial logging and have been opposed by ANN and other environmental organizations.

The BLM has released an Environmental Assessment for the Picket West Timber Sale and are accepting public comments until June 29, 2017. A public field trip to Pickett West units is being hosted by the BLM on June 17, 2017. Please consider attending.

Please contact the BLM and tell them the following:

Implement Alternative 3 with the following amendments:

  • All commercial units in stands over 150 years old should be canceled to protect old forest, northern spotted owl habitat, and to maintain fire resilience.
  • All northern spotted owl habitat should be maintained. No spotted owl downgrade or habitat removal should be allowed. 
  • No new road construction (temporary or otherwise). 
  • Drop all so-called "Forest Restoration" treatments and maintain adequate canopy cover throughout the timber sale.
  • Cancel unit 13-8 and the new road proposed to access this unit. 
  • Do not build any new roads (temporary or otherwise) on the proposed Applegate Ridge Trail.

Submit comments to: 
Grant Pass Interagency Office/Don Ferguson
2164 NE Spalding Ave. 
Grants Pass, Oregon 97526
-or-
blm_or_pwest@blm.gov 

For more information:

Rogue Basin Cohesive Forest Restoration Strategy

Pickett West EA

Tuesday, May 23, 2017

Snail Gulch Unit of the Pickett West Timber Sale

The forested slope in the foreground is the Snail Gulch unit of the Pickett West Timber Sale.
The Pickett-West Timber Sale is a sprawling proposal by the Grants Pass BLM. The planning area extends across southwestern Oregon, from Merlin and Galice on the Rogue River, to Selma and Deer Creek in the Illinois River area. The sale also extends into the Applegate Valley near Wilderville, Murphy and North Applegate Road. The project would log thousands of acres, build miles of new road, and increase fuel hazards by removing large, fire-resistant trees, dramatically reducing canopy cover and encouraging dense shrubby understory fuel.

Although the Grants Pass BLM claims to be implementing this project under the Applegate Adaptive Management Area — a land-use designation intended to facilitate community collaboration, innovative land management, and a more transparent planning process — the BLM has refused to collaborate with Applegate Neighborhood Network (ANN), other local organizations and private residents in the development of the Pickett West Timber Sale. The agency has held only one community meeting, no field trips, and no opportunities for further dialog. They have also refused to provide basic information on the proposed timber sale to the public, such as basic unit maps and prescription information for various alternatives. The approach has been far from collaborative or transparent and does not reflect the spirit of the AMA. 

The Snail Gulch unit is open, spacious and dominated by large old trees. The forest is naturally fire resistant.

Despite the BLM's lack of transparency, folks at Applegate Neighborhood Network, Klamath Forest Alliance and Siskiyou Crest blog have been working on this timber sale. We have proposed an ecologically based and community-driven alternative that will be analyzed as Alternative 3 in the Environmental Assessment. Alternative 3, is being developed by the BLM based on principals from the Community Alternative and the public comment provided by Applegate Neighborhood Network. We applaud the BLM for this decision, but we are concerned that BLM has not allowed the public to provide input during the process regarding unit selection, unit prescription, road renovations and timber sale layout.

Our coalition has been exploring the Pickett West Timber Sale. We have ground-truthed proposed units and proposed new roads throughout the Applegate watershed above North Applegate Road, Murphy and Wilderville. 

I recently visited the "Snail Gulch" unit of the Pickett West Timber Sale. The unit is currently inaccessible by road, and unfortunately, the BLM is proposing to build roughly 3/4 of a mile of new road to access and log this relatively small patch of intact conifer forest. The forest is an isolated, late-seral habitat surrounded in a sea of manzanita, live oak, buckbrush, and early-seral vegetation.
Snail Gulch unit of the Pickett West Timber Sale.

The proposed new road is being characterized by the BLM as "temporary," but will require a large roadcut due to the steepness of terrain, and the ecological impact will, in fact, be permanent. The road will begin by traversing the steep mountainous slopes, then cross the headwaters of Oscar Gulch and drop down a rugged ridgeline. The proposed new road will impact the currently un-roaded terrain, and encourage the spread of OHV use, irresponsible shooting and garbage dumping, problems that are already rampant in the surrounding area.

A Google Earth image of the Snail Gulch unit. The blue line is the proposed ART heading west from the saddle at upper Savage Creek Road. The red line is the proposed new road and the yellow polygon is the location of the Snail Gulch unit of the Pickett West Timber Sale.

The Applegate Trails Association has proposed a long-distance, non-motorized trail extending from Jacksonville to Grants Pass, Oregon, known as the Applegate Ridge Trail (ART). The western portion of the ART crosses the planning area for the Pickett West Timber Sale. The ART proposal has been submitted to the BLM for consideration and the Applegate Trails Association is working hard to develop a trail that connects wild places and communities in southwestern Oregon. 

The ART is heavily supported by surrounding communities that will be connected by the trail and benefit from its construction. It is estimated that the first quarter mile of new road proposed to access the Snail Gulch unit is being proposed to be built directly on top of the ART. If this new road is developed, the ART would be negatively impacted. The BLM has proposed a similar new road to the east on the divide between Rocky and Miller Gulch.  This new road would also impact the ART and the cumulative impact would be significant.
This photo shows the currently unroaded ridgeline proposed for new road development in the Pickett West Timber Sale. The Snail Gulch unit is the forested summit in the background.

Down the ridge, the proposed road leads to a low saddle where the brush and oak give way to an isolated stand of towering, old, conifer forest. Despite this being the only conifer stand for some distance, it is proposed for logging in the Pickett West Timber Sale. The forest floor is open — in places it is grassy, and in other places it has a carpet of spring flowers. Massive, old Douglas fir, sugar pine, ponderosa pine and madrone create complex, late-seral habitat and highly fire resilient conditions. The stand is an oasis in the rock and brush that surrounds it, and a remnant forest that survived a series of fast-moving wildfires that burned in the 1930s from North Applegate to Ruch. 

This forested stand extends from the low ridgeline, west into Snail Gulch, a small stream lined in wide-branching maple, a drapery of tangled wild grape vines, and open groves of Douglas fir. Trees from 20"-56" in diameter are common throughout the stand, growing in clusters, groupings, or distinct groves. Massive, old snags are scattered throughout the forest, creating opportunities for cavity nesting species and providing abundant insects for foraging song birds and woodpeckers. They also provide commanding perches for raptors, vultures, and ravens, and soft, hollow trunks suitable for Pacific fisher denning habitat, and deep cat-faces for slumbering bears. 

The lower end of the Snail Gulch unit in the Pickett West Timber Sale.

The forest canopy provides thermal cover for local ungulates and a multitude of other species in the winter months, as well as a cool place to bed down in the heat of summer. Small oak openings punctuate the canopy of ancient, old trees, creating heterogeneity, biodiversity and habitat for a variety of wildlife species. The stand is a functional island of late-seral habitat within a broad mosaic of brush, white oak woodland and groves of scrubby live oak. It should not be logged!

Commercial logging in this stand will negatively impact the forest's high habitat value, increase fire hazards and degrade its majestic beauty. Forest health, fire resilience and habitat diversity will not benefit from the removal of large, old trees. Opening of the forest canopy will encourage the dense, shrubby growth surrounding the stand to invade the forest floor, contributing to increased fire hazards. If canopies are reduced heavily, this stand will also be subjected to increased ambient temperatures, drying winds, increased fuel loading, increased fuel ladders, decreased fuel moisture and extended fire seasons.


The Snail Gulch unit is an open, fire-resistant old forest. Commercial logging will only harm this beautiful stand of trees.

In a small percentage of the stand, poles and small doghair thickets have developed in the absence of fire. These younger trees could be thinned with prescribed fire or by implementing non-commercial thinning treatments to reduce understory density. The result would be a generally open, yet diverse forest, dominated by large, fire resistant trees with sufficient canopy cover to suppress understory fuel loads. 

The Snail Gulch unit should be withdrawn from consideration for commercial timber harvest in the Pickett West Timber Sale. The stand is valuable for the habitat it provides. It needs only minimal, if any action to maintain its current trajectory towards continued fire resilience. The Grants Pass BLM should cancel the Snail Gulch unit.
Maple, madrone and fir line Snail Gulch at the bottom of the unit.

Wednesday, May 10, 2017

Post-Fire Logging on the Siskiyou Crest

The Gap Fire burned at particularly low severity on the Siskiyou Crest near Condrey Mountain and Dry Lake Mountain. The upper reaches of Buckhorn and Middle Creek burned in a natural mixed-severity fire mosaic and should be allowed to recover naturally, maintaining habitat values and connectivity on the Siskiyou Crest.
Last summer the Gap Fire burned over 30,000 acres of forest in the Klamath River watershed near the community of Horse Creek. The fire burned at mixed severity from the Klamath River to the Siskiyou Crest near Condrey Mountain. Fire severity was particularly moderate in the high country near the Siskiyou Crest, where the fire burned in a characteristic and healthy mosaic. The fire itself maintained habitat values, restored fire as a natural process, and encouraged natural forest resilience. The Klamath National Forest has responded with a large, post-fire logging project that would log old-growth forest on the Siskiyou Crest and fire effected forests throughout the burn area, including the Johnny O'Neil Late Successional Reserve.

The project will log old-growth forests adjacent to the Condrey Mountain Roadless Area, Pacific Crest Trail and Condrey Mountain Blue Schist Geologic Area. The last remaining old-growth forest in Buckhorn Creek and Middle Creek watersheds would be roaded and logged. The project would impact habitat connectivity on the Siskiyou Crest, fisheries habitat in the Klamath River, and recreational qualities on the Pacific Crest Trail. In all 2,257 acres are proposed for logging under the Forest Service Alternative #2.
Low-severity fire in the high elevation forests near Condrey Mountain, a vital link in the Siskiyou Crest connectivity corridor.

Post-fire logging will increase fire hazards, decrease habitat complexity, impact important wildlife habitat and the natural fire mosaic. The cumulative impact of post-fire logging on federal land and private land has become enormous on the Klamath River and its salmon streams. Following the Happy Camp Fire in 2014, the Forest Service recently implemented the massive Westside Project which clearcut 13,000 acres of fire-effected forest south of the Klamath River. The Fruit Growers Supply Company has also been busy clearcut logging thousands of acres in the Beaver Fire of 2014 and the 2016 Gap Fire. Vast tracks of land have been clearcut, impacting wildlife, streams, soils, forest recovery and slope stability in the Middle Klamath River Watershed. 

We are witnessing the loss of one of our region's last truly wild landscapes. The Middle Klamath River is being carved into pieces by recent salvage logging projects, fragmenting the habitat, reducing forest complexity, increasing fuel loads, and clearcut logging steep, erosive slopes above the Klamath River's last high quality salmon streams. Salmon River, Elk Creek, Grider Creek, Scott River and many others have been impacted by large, post-fire logging projects. The logging has extended to the edge of the Marble Mountains Wilderness and Trinity Alps Wilderness. We cannot allow post-fire logging and road building to impact the Siskiyou Crest. 

The large denuded area in this photograph was logged by a private timber company following the Beaver Fire of 2014. The green forests in the background are proposed for logging in the Forest Service's Gap Fire salvage logging proposal.

The Siskiyou Crest is a regionally important connectivity corridor. Running east to west, the Siskiyou Crest connects the Coast Range to the Cascade Mountains with a single high elevation ridgeline. This important connectivity corridor is the center for biodiversity on the West Coast of North America and allows species migration across broad swaths of the Pacific Coast. For millennia, the Siskiyou Crest has provided a refuge for migrating species as their habitat and range shifted across the region and in response to changing climates. The region will continue to play this role in the face of human caused climate change, providing a migration corridor and repository of biodiversity.

The unique connectivity of the Siskiyou Crest, along with the region's unusual geology and diverse topography has provided small niches for remnant populations stranded in isolated Siskiyou Mountain habitats as they moved across the landscape. Ancient paleo-endemic species surviving only in the Siskiyou Mountains and disjunct plant populations at the far edge of their range, have clung to specific microclimates or unique soil types in the Siskiyou Mountains. The Condrey Mountain/Dry Lake area represents a vital link in this chain of connectivity, providing access between the eastern and western Siskiyou Mountains. 

The Condrey Mountain Roadless Area extends down the northern face of the Siskiyou Crest, into the headwaters of Elliott Creek. The southern face of the Siskiyou Crest burned in the Gap Fire. These southern faces drop from Condrey Mountain and Dry Lake Mountain through intact, high-elevation forests on Forest Service land, and into a sea of clearcut, private industrial forest land above the Klamath River. 

The area represents a significant bottleneck in connectivity and the last significant concentration of private land as the Siskiyou Crest heads west towards the Pacific Ocean and the Coast Range. The high-elevation forests in Buckhorn and Middle Creek contain complex forest habitat near the spine of the Siskiyou Crest and directly adjacent to the Condrey Mountain Roadless Area. 
The meadows and forests of the Siskiyou Crest provide important habitat connectivity and should be allowed to naturally regenerate from the Gap Fire.

Logging these forests as proposed by the Klamath National Forest would significantly impact the connectivity of the Siskiyou Crest. The complex habitat that they provide will become increasingly important in a changing climate. Resilience to climate change for many natural communities depends on maintaining habitat connectivity on the broadest scale possible. Protecting the Siskiyou Crest is absolutely necessary for the resilience of the West Coast.

The Karuk Tribe has proposed an alternative to the Klamath National Forests post-fire logging frenzy. They have offered a plan that would encourage the reintroduction of fire and the development of fire adapted human communities on the Klamath River. The Karuk Alternative would help to facilitate fire resilient communities by conducting non-commercial fuel reduction along strategic ridgelines and around private land boundaries in the Gap Fire Area. 

The Klamath National Forest has released a Draft Environmental Impact Statement and is currently accepting public comment. Please consider commenting on the project, support the Karuk Alternative and advocate for conservation on the Siskiyou Crest.

Click here to sign a letter in support of the Karuk Alternative. 
 



Tuesday, April 25, 2017

The BLM's Great OHV Trail Giveaway

The BLM has created defacto designation for OHV routes in the Wellington Butte Roadless Area without public comment, environmental review, or public disclosure of environmental and social impacts. The damage depicted in this photo is directly adjacent to an unauthorized OHV trail proposed for maintenance.

The Medford District BLM has recently published a Categorical Exclusion (CE) approving maintenance on 65 miles of unauthorized and unapproved OHV trails in the so-called John's Peak/Timber Mountain OHV Area. Despite being promoted and publicized by the BLM as an official OHV Area, not a single OHV trail in the area known as the John's Peak/Timber Mountain OHV Area has ever been legally approved for OHV use. Instead, the BLM has allowed unauthorized OHV use and illegal user-created trails to proliferate throughout the area, creating extreme environmental and social impacts. 

For over a decade, the BLM has gone as far as posting illegal routes as open to OHV use, and they have managed our public lands as an OHV sacrifice area, without authorization or approval. The BLM has also promoted OHV tresspass on adjacent private lands by allowing unmanaged OHV use in a checkerboard of land ownership. Conflicts between OHV users, private land owners and other public land users are reaching an unprecedented level in the area.
Unauthorized OHV routes such as this one should be closed to OHV use, but are instead posted and designated for OHV use as "existing" trails. The BLM has identified this particular trail for maintenance, despite it being an unauthorized, user-created trail, and despite "considerable adverse effects," including erosion gullies over 3' deep.

For far too long the BLM has turned a blind-eye to the mounting impacts of OHV use in the so-called John's Peak/Timber Mountain OHV Area.  The BLM has allowed significant damage to natural resources, wildlife habitat, native plant habitat, endangered species habitat, riparian areas, soils, water quality and hydrology to expand exponentially as OHV enthusiasts reach farther across the landscape in a web of logging roads and user-created trails. This web of unauthorized OHV trails and logging roads bleeds sediment into nearby streams, provides a conduit for noxious weed spread, and disturbs both local wildlife and rural residents.

The unauthorized OHV trails in the area have never been subjected to adequate environmental review, public comment, or public disclosure of impacts. Every time the BLM tries to push the project through, their attempts have been frustrated by citizen outrage, administrative protest and environmental law.

The BLM published a Draft Environmental Impact Statement (DEIS) in 2009. The DEIS proposed widespread OHV use and designation of existing trails. The proposal was never approved or implemented due to persistent public pressure and extreme user conflicts, but unauthorized OHV continued unabated. 

The BLM then tried public mediation with representatives of numerous affected parties. This did not resolve the long-standing controversy either and the BLM could not move forward with a legal OHV Area. Public opposition to the proposed OHV Area has been consistently strong, with nearby residents, private landowners, industrial timber companies, environmentalists, hikers, botanists, hiking groups and others opposed to designation of the John's Peak/Timber Mountain OHV Area.
The unauthorized, user-created Baldy Mountain OHV trail impacts riparian reserves, Northern spotted owl nesting sites and endangered Gentner's fritillary (Fritillara gentneri) sites.

In the face of mounting opposition, user conflicts, private lands trespass and environmental impacts, the BLM has unilaterally decided to allow OHV use in this controversial area and legitimize "existing" unauthorized OHV trails with defacto designation. Recently, the BLM approved a Categorical Exclusion meant to cut the public out of the process and avoid environmental review on nearly 23,000 acres of public land. The Categorical Exclusion approved maintenance and pseudo designation on 65 miles of unauthorized motorized trails.

Through a Categorical Exclusion the BLM is silencing opposition by taking away the public's right to provide comment on the decision. They are also categorically excluding themselves from scrutiny by refusing to allow an objective analysis of impacts. In other words, they do not want to acknowledge the true impacts and they do not want to hear from you, the public, that owns these lands. 

The Categorical Exclusion provides the agency and motorcycle riders the ability and the public funding to maintain unauthorized OHV trails. In an administrative sense, these unauthorized trails simply do not exist. The Categorical Exclusion legitimizes illegally created and environmentally damaging OHV trails by allowing maintenance on unapproved, but "existing" routes.

The Categorical Exclusion is predicated on the BLM's claim that the project is not controversial, will not significantly impact other public land users, the environment, or future land management decisions. All these claims are untrue. 
 
The unauthorized, user-created Bunny Meadows OHV trail is highly controversial, creates significant environmental impacts and facilitates private land trespass on Forest Creek Road.

1,200 local landowners and residents have signed petitions to close the area to OHV use. The so-called John's Peak/Timber Mountain OHV Area has been the subject of significant controversy for over 20 years. 

The environment has been heavily degraded, as is pointed out in the Categorical Exclusion, "trail maintenance is proposed to correct trail rutting, braiding, and associated erosion." The Categorical Exclusion also acknowledges that trails "have and continue to experience damage due to lack of maintenance, the relative wet winter climate of southwestern Oregon and increased visitor use. Trail conditions have deteriorated and are unsafe in specific locations; ruts are developing due to broken erosion controls and trail features." 

Executive Orders 11989 and 11644 require the agency to close all OHV routes creating "considerable adverse effects," such as those described in the Categorical Exclusion. Instead of closing the routes the agency is designating them for OHV use as "existing" trails — no matter how extreme the impacts.

The Categorical Exclusion also fails entirely to account for other existing recreational uses in the planning area, including hiking, bird watching, botanizing, primitive camping and equestrian use. Only motorized use is addressed in the Categorical Exclusion. 

Nearly every other forest user is negatively impacted by OHV use. In fact, implementation of the Categorical Exclusion will dramatically impact non-motorized recreational opportunities on the proposed Applegate Ridge Trail and in the Wellington Butte Roadless Area. 
The BLM is opening the Wellington Butte Roadless Area, its sweeping grasslands and intact habitats to OHV use.

Non-motorized users suffer from an "institutional inequality" in BLM land management. The inequality promotes illegal OHV use over non-motorized recreation. OHV users have been allowed free-reign on BLM lands, to develop unauthorized trails while avoiding public scrutiny, agency enforcement and environmental review. Non-motorized trails have to go through the National Environmental Policy Act (NEPA) process to achieve approval or designation, but motorized trails do not. How is that equal?

Miles and miles of unauthorized OHV trails have been built at no cost, with no red tape, and minimal, if any, trail standards to speak of. The BLM's newest Resource Management Plan (RMP) is being used as an excuse to declare these illegal, unauthorized routes routes as "existing," and attempts are being made to legitimize their use through Categorical Exclusions, defacto designations and the irresponsible signing and/or publicizing of unauthorized OHV trails. The free-for-all, anything-goes management of our public lands has created significant environmental and social impacts. It has also encouraged further unauthorized motorized use.

In stark contrast, there is no loophole for "existing" but not authorized non-motorized trails. Non-motorized trail proposals have been forced by the BLM to wade through significant red tape, conduct full environmental reviews, design sustainable trail and meet stringent trail standards (as we all should). The non-motorized trail community has also been forced to build trails, mostly with privately funded money.

In effect, those with the lightest impact on the land, the non-motorized users, are being forced to meet the most stringent trail standards and jump through the most hoops, at the largest financial expense. Meanwhile, those who illegally build OHV trails and impact the land, benefit by not having to submit to the costly approval process, meet sustainable trail standards or jump through time consuming bureaucracy to achieve approval.

The non-motorized East Applegate Ridge Trail and phase one of the Jack-Ash Trail took hundreds if not thousands of volunteer hours, multiple tens of thousands of dollars to fund and five years of red tape to receive approval. Each group is now building a little over 5 miles of approved non-motorized trail. In the meantime, the OHV community continues to build illegal trails, damage the land, benefit from less stringent trail standards, trespass onto private land, generate massive user-conflicts and significant environmental impacts. OHV enthusiasts are then awarded by BLM with the designation of 65 miles of "existing," but unauthorized motorized trail, free of charge, and with free maintenance. The hypocrisy is deeply entrenched in the Medford District BLM, where two separate standards are applied to motorized and non-motorized use.
This erosive, unauthorized OHV track is proposed for maintenance and designation as an "existing" trail in the Categorical Exclusion, despite clear environmental impacts.

The BLM is claiming that the Great OHV Trail Giveaway is authorized under the 2016 Resource Mangement Plan (RMP). The RMP allows motorized use on "existing" trails for an interim period, yet does not define or inventory "existing" OHV trails, providing a loophole big enough to drive an OHV through. The BLM is claiming that although unauthorized, the trails in question are "existing" and can thus be maintained. 

No other illegal activity conducted on federal land, is condoned by allowing "existing" illegal activity to persist. For instance, the agency has many illegal trash dumping sites on the district. Shall we encourage such illegal activity by designating existing trash dumping sites on public land? How about designating areas for existing illegal marijuana grows on BLM land? A designated area for existing illegal poaching? Get the point?


Stop The BLM's Great OHV Trail Giveaway!  The Applegate Valley is not a sacrifice zone for extreme OHV use!