Monday, November 11, 2019

BLM Proposes to Eliminate Public Comment Periods in New Logging and Road Building Proposal

A view down Powell Creek in the Late Mungers Project. The Late Mungers Project is "tiered" to the analysis in the IVM Project and would be the first timber sale approved if the IVM Project is authorized.
As part of their continuing assault on the National Environmental Policy Act (NEPA), the Medford District BLM has proposed the Integrated Vegetation Management for Resilient Lands Project (IVM). Although it sounds benign, in many cases, terms like "Integrated Vegetation Management" are a euphemism for commercial logging and serve only to mask the impacts and objectives of timber management with misleading language.

Under the IVM Project the BLM has proposed to allow up to 4,000 acres of commercial logging and 10 miles of new road construction per year without public comment, public involvement or environmental review. This would include up to 25,000 acres of logging and 90 miles of new road construction in a ten year period. According to the BLM, these authorizations would have "no sunset date," meaning that overtime they could be used to build hundreds of miles of new roads and log many tens of thousands of acres.
Old-forest proposed for logging in the Late Mungers Project near Morgan's Buckhorn.

Yet, this project is even more insidious in that it focuses its commercial logging "treatments" in conservation-based land use allocations like Late Successional Reserves (LSR), Areas of Critical Environmental Concern (ACEC), Lands with Wilderness Characteristics (LWC) and other areas outside the BLM's Timber Harvest Land Base.

The IVM Project proposes to approve commercial logging, prescribed fire and/or fuel reduction on virtually any location throughout the Medford District BLM. Yet, the location of future timber sales, the intensity of logging and the specific logging prescriptions would remain undetermined and would be at the sole discretion of BLM staff. 
The Burton-Ninemile Lands with Wilderness Characteristics (LWC) located in the Upper Applegate Watershed would be open to commercial logging with no NEPA analysis if the IVM Project is approved.

The IVM Project threatens to take away our right as citizens to influence and participate in public land management. If approved, it would provide the BLM with very broad discretion to authorize timber sales with little to no public involvement or accountability. Nearly all checks and balances currently embedded within the NEPA process would become optional, opening the way for a flood of controversial logging projects throughout southwestern Oregon.

The IVM Project includes an over 800,000-acre planning area encompassing all BLM lands in southwestern Oregon except the Cascade-Siskiyou National Monument and existing Wilderness Areas. Logging treatments could take place along portions of the Rogue River, in numerous roadless areas in the Applegate Watershed, and portions of the Illinois River Valley.

Fire adapted forest targeted for logging in the Late Mungers Project.
Despite having no official approval for the IVM Project, the Medford District BLM has already begun planning commercial timber projects "tiered" to the IVM Project and dependent on its ultimate approval. In the mountains outside Williams, Oregon the BLM has already identified its first large timber sale, called the Late Mungers Project.

The Late Mungers Project is focused on a large block of Late Successional Reserve forest located on the ridgeline dividing the Williams Valley from the Illinois Valley near Selma, Oregon. The project proposes commercial logging units on Murphy Creek, Powell Creek, Mungers Creek, and the South Fork of Deer Creek. 

An area proposed for commercial logging on Mungers Butte.
Very little information is available about the Late Mungers Project, but we were able to obtain a draft unit map showing proposed commercial logging and fuel reduction units. According to these maps, the commercial logging component appears quite extensive. It also appears that some of the last remaining corridors of intact forest habitat on the Applegate-Illinois River divide are targeted for commercial logging.

The BLM is accepting public comments on the IVM Project until November 18, 2019. Please consider the talking points below when drafting a public comment.

IVM Talking Points:  
  • Activities such as commercial logging, road construction and large scale fuel reduction have the potential to create significant environmental impacts and effects. These activities should therefore require site-specific NEPA analysis, including the disclosure of impacts, scientific review, public involvement, environmental analysis and public comment.
  • All Programmatic NEPA analysis should be implemented through development of a full Environmental Impact Statement (EIS). The currently proposed Environmental Assessment (EA) lacks the detail and rigor required to consider environmental effects across such a broad, complex landscape. 
  • The agency must analyze and disclose the impact of all logging and road building activities. This should include direct, indirect and cumulative impacts. 
  • Concerns regarding increased sedimentation and water quality impacts, impacts to late successional habitat, Northern spotted owl habitat, increased fire risks, increased fuel loading, standing drying, and accelerated canopy loss associated with commercial logging should be addressed in NEPA analysis. 
  • BLM monitoring data demonstrating the actual, on-the-ground effects of previous commercial timber sales should be analyzed throughout the 800,000-acre IVM planning area. The actual outcome of these timber sales should be compared to previous effects analysis to monitor for compliance and consistency. 
  • Planning on the Late Mungers Project is pre-decisional and additional planning efforts should be discontinued. The Late Mungers Project has the potential to create significant adverse effects and is located in a large block of LSR forest. This project should require site specific NEPA analysis and a full public comment period. 
Submit your comments:

By Mail or Delievery: 

Medford District BLM
3040 Biddle Road
Medford, Oregon 97504 

For more information on the project, click here. 

Also please attend the upcoming BLM open house to discuss the project at the Jackson County Expo, Mace Watchable Wildlife Building 4:30-7:00 PM Thursday, November 14, 2019. 

The green polygons represent commercial logging treatments currently proposed in the Late Mungers Project, blue depicts fuel reduction, while the narrow brown lines following major ridges are proposed as 300' wide fuel breaks which could include commercial and non-commercial treatments.

Tuesday, July 30, 2019

Dismantling NEPA Part 2: Local BLM Efforts to Undermine the Public Input Process

A BLM field trip into a portion of the Nedsbar Timber Sale as part of NEPA planning in 2014. If the Integrated Vegetation Management for Resilient Lands Environmental Assessment is approved, community meetings, field trips and public comment periods would be a thing of the past. 
On a national level the Trump Administration is pushing hard to eliminate or drastically reduce public involvement in federal land management planning, but it is not just a national issue. Local land managers in southwestern Oregon are also working to find ways to cut the public out of the process. This includes our local BLM, who is proposing an extremely large Programmatic Environmental Assessment of Integrated Vegetation Management for Resilient Lands (IVM-RL EA). 

Although the name intentionally sounds rather benign, the goal of this project is to increase timber production without conducting environmental review or soliciting public input. "Integrated Vegetation Management" is often actually commercial logging and "resilient lands," refers to the entire landscape. When translated from industry/agency jargon, Integrated Vegetation Management for Resilient Lands, means, "log the entire landscape."

The Programmatic EA would allow 15,000 acres of commercial logging and 25 miles of new road construction annually on the Roseburg and Medford District BLM. The majority of the project, including 14,000 acres of commercial logging and 20 miles of new road construction, would be proposed annually on the Medford District BLM, including both the Grants Pass and Ashland Resource Areas.

A fire-adapted forest proposed for logging in the Nedsbar Timber Sale and canceled due to public input during the NEPA process.

Under the proposals of the Programmatic EA, the Medford District BLM would no longer be required to conduct site specific environmental analysis and would no longer ask for public input or solicit public comments on up to 14,000 acres of commercial logging each year. Instead, they will notify the public only after approving a timber sale. Project approval would be followed by a mere 15-day Objection period, and barring an objection or lawsuit, commercial logging projects could then proceed to the federal timber auction.

Although the proposal would allow logging in nearly any land management designation, it appears to be specifically designed to implement logging prescriptions in Late Successional Reserve (LSR) forest. LSR forest was set aside to protect the habitat of the Northern spotted owl, to encourage the maintenance and development of late successional forest habitats, and to provide connectivity between old forests. LSR forests are the foundation of Northern spotted owl recovery and are necessary for the Northern spotted owl's continued persistence. 

The IVM-RL EA would allow land managers to downgrade or remove Northern spotted owl habitat within LSR forest by logging large, old trees, removing important habitat elements and significant levels of canopy cover, all with no environmental review or public comment. 

In fact, currently the Grants Pass Resource Area is considering the Late Munger Project in LSR forest. The project is located in the Williams Creek watershed between Mungers and Powell Creeks. Despite having no authorization to do so, the agency is already planning the Late Munger Project under the expectation that the project will be "tiered" to the Programmatic EA and approved without environmental review or public comment.

Given that no EA has been published, no analysis has been conducted and no official decision has been recorded for the Programmatic EA, the Late Munger Project should be canceled. Either the outcomes of the Programmatic EA are predetermined or the development of the Late Munger Project is pre-decisional; either way, the development of the Late Munger Project under the currently unauthorized provisions of the Programmatic EA is unacceptable.

The proposed IVM-RL EA would also build many miles of new roads, create new log landings, drag large logs across mountainsides with tractors, clear vast skyline yarding corridors and increase fire risks, not only in the Late Munger Project, but throughout southwestern Oregon.

The BLM calls thinning like this in the O'Lickety Timber Sale restoration or fuel reduction. It is, in fact, commercial timber production that degrades ecological values and tends to increase fire risks as woody vegetation fills in the canopy gaps created by commercial logging operations.

Although the agency claims to be conducting "habitat restoration and resilience treatments," the Programmatic EA would allow the agency to log virtually anywhere in the Medford or Roseburg District BLM landbase. This could include Late Successional Reserve forests, Riparian Reserves, Lands with Wilderness Characteristics, Areas of Critical Environmental Concern, the Cascade-Siskiyou National Monument and other conservation-based land management allocations. The level of harvest proposed in the Programmatic EA could range from "regeneration" logging, (a form of clearcut logging) to heavy commercial thinning. 

Unfortunately, the concept of restoration is being used as an excuse for the BLM to log virtually anywhere and by any means they deem necessary. Restoration is used as a euphemism to disguise the impact of commercial logging and provide a thick layer of greenwash over BLM timber sales. 

Despite their overly optimistic claims, BLM logging projects are far from restorative and generally include an increase in fire risk, an increase in overstory tree mortality, the spread of noxious weeds, increased soil erosion and stream sedimentation, significant impacts to biodiversity and a loss of late successional habitat used by the Pacific fisher, the Northern spotted owl, the Siskiyou Mountain salamander, and many other important wildlife species. 

What the BLM is proposing is not focused on restoring habitats, it is an attempt to increase timber production and reduce the public's ability to provide feedback or influence the process. 

Intact, old-growth forest was targeted for logging in the Pickett West Timber Sale. Large portions of the project were canceled due unacceptable impacts to the red tree vole, late successional habitat and due to public input provided during the NEPA process. NEPA tends to make land management projects more socially and environmentally acceptable and creates transparency that is important when managing public lands.

Comment now on this project and support the public's right to provide input and influence public land projects. Let the BLM know that all commercial timber projects and road construction projects should undergo a full National Environmental Policy Act (NEPA) process with rigorous environmental review and a full public comment process. 

To read the Scoping Notice and comment on this project, follow this link and hit "Comment on Document":

Sunday, July 28, 2019

Dismantling NEPA Part 1: A National Push for NEPA Rule Changes

Community members and the Forest Service conducting a public field tour during a NEPA process in the Applegate. If proposed NEPA rule changes are approved, public involvement could be a thing of the past.

This summer the Forest Service proposed dramatic nationwide changes to the National Environmental Policy Act (NEPA) process. These revisions to NEPA would allow widespread logging, mining and road building throughout Forest Service lands.

To achieve these goals the agency has proposed sweeping changes that would drastically limit public input and eliminate environmental review for the vast majority of Forest Service projects. These changes would essentially shut the public out of public land management planning.

The National Environmental Policy Act (NEPA) is the foundation of public involvement on our public lands. It is also intended to facilitate a thorough environmental analysis for federal land management projects. The public process required under NEPA has consistently made public land management projects significantly better for natural resources, wildlife, watersheds and local communities. NEPA brings a sense of democracy and accountability into the public land management planning process.

NEPA's bedrock principals include government transparency, accountability, public involvement, and science-based decision making. It is used to analyze the impacts of specific land management projects, disclose those impacts to the public and allows the agency to make more informed decisions. The public's ability to provide comment and demand a seat at the table is dependent on the integrity of the NEPA process.
The Elimination of Public Scoping
The Forest Service's proposed NEPA revisions would eliminate the requirement to conduct public scoping on most federal land management projects. Public scoping is used to inform the public of land management proposals and solicit an initial public comment period. This comment period is used to create proposed action alternatives, document public concerns and identify exceptional values at risk. 

Scoping promotes transparency, accountability and scientific credibility. It also allows land managers to meaningfully address public concerns in an EA or EIS. The proposed NEPA revisions would largely eliminate Scoping requirements for most land management projects conducted on Forest Service lands.

Categorical Exclusions

The agency has also proposed the adoption of seven new Categorical Exclusions (CE) and the expansion of two existing Categorical Exclusions. CE's are used to expedite the planning process by virtually eliminating public involvement and environmental review. 

CE's supposedly identify projects "that do not individually or cumulatively have a significant effect on the human environment and therefore, do not require preparation of an Environmental Assessment (EA) or Environmental Impact Statement (EIS)." Historically, CE's were meant to facilitate the maintenance of existing infrastructure or to authorize very small projects, with minimal environmental effects.

Large Forest Service logging projects, including up to 4,200 acres of commercial logging, could be approved without public input or environmental review under the newly proposed Categorical Exclusions.

The proposed NEPA revisions would allow land managers to  approve large, complex, and potentially damaging projects as CE's. It would also allow land managers to approve numerous associated projects under CE's, creating significant cumulative effects, without analyzing, documenting or disclosing those effects publicly in an Environmental Assessment or Environmental Impact Statment.

Although the Forest Service claims they need these changes "to increase the pace and scale of work accomplished on the ground," and address supposed wildfire concerns, these Categorical Exclusions would include many provisions that have no restorative benefits and do not directly address fire, fuels or community fire safety. These provisions include, but are not limited to:

  • The ability to authorize broadly defined "restoration and/or resilience activities" without public input or environmental review. This would include up to 4,200 acres (or 6.6 square miles) of commercial logging and 7,300 acres of manual thinning in a single CE. 
  • The ability to authorize the construction of up to 5 miles of new road and the reconstruction of 10 miles of existing roads in a single CE, with no public input or environmental review. 
  • The ability to convert currently illegal and environmentally damaging off-road vehicle routes into official Forest Service trails or roads without public input or environmental review. 
  • The ability to authorize damaging land management projects in Inventoried Roadless Areas with no public input or environmental review. 

The proposed rule changes would allow the agency to implement large and potentially damaging projects without site specific environmental review or meaningful public input. In fact, under the proposed rule changes, the public would only be notified of a project after it has been approved.

Determinations of NEPA Adequacy

The proposed NEPA revisions would also encourage the use of another internal review process, known as a Determination of NEPA Adequacy (DNA). A DNA allows Forest Service land managers to use their "experience" with past projects to authorize a project of similar nature without public comment or environmental review, again cutting the public out of the process and avoiding site specific environmental review. 

Condition-Based Management

Proposed NEPA revisions also propose the use of "condition-based management," which allows land managers to implement projects across broad landscapes based on a particular environmental condition, rather than on site specific needs. Environmental conditions such as high fuel loads, dense forests, bark beetle outbreaks, post-fire landscapes, and a broad range of other perceived and highly subjective conditions, would trigger specific management actions including logging, road building, and fuel reduction. 

Land managers would approve a range of generalized activities to address environmental conditions existing on the landscape. These activities would then be implemented across the landscape without public input or environmental review.


If these rule changes are approved it is estimated that roughly 75% of the projects currently requiring a more thorough EA or EIS would be implemented utilizing the newly proposed CE's. It is also estimated that an astounding 98% of federal land management projects would not include any level of public input before they are approved. 

    The proposed NEPA revisions will eliminate or limit important  requirements intended to protect public resources and encourage public involvement. If these provisions are approved, NEPA will be functionally dead, community-based collaboration will be a thing of the past, and science-based management will disappear from our federal lands.

    According to the official Forest Service website, the agency motto is, "Caring for the land and serving the people." The proposed NEPA rule changes will neither care for the land or serve the people. Instead they will serve the industries and ignore the people.
    Although local communities will be affected by federal land management planning decisions and often actively participate in the planning process, proposed NEPA rule changes will almost completely exclude the public from the process.

    Please Comment

    Please use the public process, while it is still available, and send in a comment opposing these unreasonable rule changes. The NEPA process should be used to front-load projects with public input, collaboration, and science. When implemented effectively NEPA can be used to find common ground, create better projects and implement non-controversial land management activities. The proposed NEPA revisions will do the opposite.

    Comments can be submitted until August 12, 2019. Please stand up for the NEPA process. The future of our National Forest lands depend on your contribution. Speak up for the science-based management, environmental review and rigorous public involvement process that NEPA currently requires. These are our public lands, please use your voice to protect them.

    To comment please follow this link and click on "Comment Now"

    Public meetings to discuss land management proposals and solicit feedback from community members are part of the NEPA public process and would be eliminated under new proposals by the BLM and Forest Service.

    Monday, June 17, 2019

    The Upper Briggs Restoration Project: The Wrong Treatments, in the Wrong Place, at the Wrong Time!

    A view across the Briggs Creek watershed in the spring of 2019 following the 2018 Taylor/Klondike Fire.
    Recently the Rogue River-Siskiyou National Forest approved over 4,000 acres of commercial logging in the Upper Briggs Restoration Project. The Upper Briggs Restoration Project is located in the Briggs Creek watershed west of Grants Pass, Oregon on the Wild Rivers Ranger District. The project is yet another damaging federal timber sale disingenuously cloaked in restoration language. 

    Briggs Creek is a major tributary of the Illinois River with significant anadromous fisheries and a botanical hotspot with high recreational values including hiking trails, mountain biking trails, Botanical Areas, Designated Wildlife Areas and popular campgrounds. 

    The area also burned in the 2018 Taylor/Klondike Fire and according to the Decision Notice for the Upper Briggs Project, "the fire effects were generally very low intensity mostly burning ground fuels with occasional torching of individual trees." Despite these restorative mixed severity fire effects, the Rogue River-Siskiyou National Forest has approved commercial logging within fire resilient stands throughout the upper Briggs Creek Watershed. 
    Unit 21 in the Briggs Creek Timber Sale is located along the popular Secret Way Trail and contains important fire-adapted late successional habitat. The unit burned at low severity in the Taylor/Klondike Fire and supports a particularly large population of the rare Clustered lady slipper orchid (Cyprepidium fasculatum). It is also proposed for commercial logging in the Upper Briggs Project.

    Klamath Forest Alliance has filed an Administrative Objection and will continue working to fight for the Briggs Creek watershed, its spectacular forests, rare plant species, and wild habitats. 

    Below is an article being published on June 19, 2019 in the Illinois Valley News by the Siskiyou Mountain Conservation Director for the Klamath Forest Alliance and the author of the Siskiyou Crest Blog, Luke Ruediger. 

    The Upper Briggs Project: The Wrong Treatments, in the Wrong Place, at the Wrong Time
    Low severity fire reduced fuel, thinned understory growth and increased fire resistance in this beautiful old-growth stand below the Secret Way Trail. Despite these beneficial effects, this forest is identified in the Upper Briggs Project as commercial logging unit 23. 

    Briggs Creek is a major tributary of the Illinois River, a hotspot for recreation and a beautifully diverse watershed with important late successional forests, roadless areas and rare plant populations. Most who have visited the area know Briggs Valley, Sam Brown Campground, Big Pine Campground, Horse Meadows and the vast Briggs Creek Trail system. The area has long been a destination for local residents to enjoy for its solitude and beauty. 

    In recent years, the Rogue River-Siskiyou National Forest has been working on the Upper Briggs Restoration Project, a timber sale on Briggs Creek; cloaked in restoration and fuel reduction language. The premise of the project is that without logging and fuel reduction treatments, rare plant populations would diminish, the Briggs Creek watershed would burn at uncharacteristic levels of fire severity and habitat conditions would suffer from fire exclusion. 

    Ironically, the area has burned four times in the last 10 years, creating a diverse and productive mosaic of mixed severity fire. These fires were restorative in nature and have reduced fuel loading throughout the vast watershed. For example, the Briggs Creek watershed burned at 82% low severity this past summer in the Taylor/Klondike Fire, achieving the stated objectives of the Upper Briggs Project. The 2018 fires reduced understory fuels, maintained Northern spotted owl habitats, and restored the process of fire to fire-dependent ecosystems. In fact, the fire achieved these objectives to such a high degree and across such a broad landscape, that restoration and fuel reduction is no longer needed in the Briggs Creek watershed. 
    Western sophora (Sophora leachiana) is endemic to the Rogue and Illinois River watersheds, is highly adapted to fire, and is more abundant in Briggs and adjacent Taylor Creek than anywhere else in the world. The Forest Service proposed numerous timber sale units to open canopies and restore fire, to fire dependent populations of Western sophora. The 2018 Taylor/Klondike Fire restored fire as a process and has invigorated populations throughout the fire area. These invigorated populations will be impacted by timber harvest in the Upper Briggs Restoration Project.

    Recent fire footprints like the 2018 Taylor/Klondike Fire contain extremely fire resistant conditions, more effective at reducing fire severity and limiting fire spread than any manual logging or fuel reduction treatment. For the next few years, this watershed will be largely fireproof, resisting ignition and limiting fire spread until vegetation burned in the Taylor/Klondike Fire regenerates and builds enough fuel to once again support wildland fire spread. 

    Unfortunately, the project specifically calls for logging stands that burned at low to moderate severity and removing trees that survived the 2018 fires. It is uniquely ironic and hypocritical to see forests recently burned at low severity, logged in the name of "fuel reduction" and "restoration." The Rogue River-Siskiyou National Forest is now using low severity fire as an unprecedented excuse  for logging the post-fire environment. Yet, forests recently burned at low severity are not a priority for treatment and by removing living trees from sensitive fire effected sites, fuel loading and fire risks will increase, as logging slash is deposited throughout the currently fuel-limited landscape. 
    Low severity fire burned through the old forests in unit 63 of the Upper Briggs Project, maintaining important late successional habitats. The 2018 Taylor Fire created beneficial, characteristic fire effects and "restored" fire adapted stand conditions. The logging proposed in unit 63 will degrade rather than restore healthy, fire adapted stands conditions.

    Stands logged in the Upper Briggs Project will also experience stand desiccation and increased fire risks associated with increasing wind speeds, ambient air temperatures, and plummeting fuel moisture contents throughout our fire season. Understory fuels will also increase in direct proportionality to canopy removal. In fact, the loss of overstory canopy will trigger an extensive "understory response" with young trees, shubbery, and increased herbaceous growth filling in the canopy gaps. The result will be an increase in fire/fuel risks and a significant loss of fire resilience. 

    The Upper Briggs Project is far from homes and human communities and provides little to no fire protection for the residents of southern Oregon. Implementation of the Upper Briggs Project is an unjustified waste of limited fuel reduction funding and will reduce, rather than increase fire safety in the Briggs Creek watershed. 

    The exceptional fire resilience of this post-fire landscape will only be impacted by proposed project activities. The project will also impact the natural vegetative recovery, increase sedimentation in streams and erosion on sensitive fire effected soils, spread noxious weeds, impact Special Wildlife Management Areas and degrade Northern spotted owl habitat. 
    Horse Meadows Wildlife Area following the 2018 Taylor/Klondike Fire. The Rogue River- Siskiyou National Forest has approved virtually clearcutting the forest at the margin of Horse Creek Meadows to "restore" the meadow to what is supposedly its former extent.

    There is simply no ecological or fire/fuel related benefit to implementation of commercial logging and fuel reduction treatments in the Briggs Creek watershed, at this time. Furthermore, the conditions created by those logging and fuel reduction treatments will not restore characteristic  habitat conditions. The Upper Briggs Project is an example of the wrong treatments, at the wrong place, and at the wrong time. The project should be canceled and attention placed on reducing fuel around homes and communities where it is most needed, not in the backcountry, where it will impact habitat values and provide little to no fire protection for communities at risk. 

    Sunday, June 16, 2019

    The Klamath National Forest is Clearcutting the Siskiyou Crest near Cook and Green Pass

    A view southeast from near Copper Butte on the Siskiyou Crest. The Copper Timber Sale proposes to clearcut almost the entire burnt ridgeline in the foreground. The sale extends nearly to the Siskiyou Crest and down the east facing slopes into the headwaters of Horse Creek.
    As soon as the smoke cleared from the 2017 Abney Fire, the Klamath National Forest began working to clearcut the region's fire affected forests. As usual, the Klamath National Forest took a very unscientific and opportunistic approach, proposing clearcut, post-fire logging throughout important conservation areas. Klamath National Forest land managers decided to locate much of the proposed timber sale near the spine of the Siskiyou Crest, in and around the Condrey Mountain and Kangaroo Roadless Areas, near the Cook and Green Pass Botanical Area, the Pacific Crest Trail and in a large Late Successional Reserve designated to protect complex, old forest habitat.

    The region around Cook and Green Pass has long been cherished for its wilderness quality habitats and incredible biodiversity. In fact, Cook and Green Pass has been identified as one of the most botanically diverse locations in the state of California. It is also at the center of the Siskiyou Crest, one of the most important connectivity corridors in the West Coast. Unfortunately the Klamath National Forest has pushed forward with the Seiad Horse Project, proposing over 1,000 acres of clearcut, post-fire logging in the area. 
    Post-fire regeneration and vegetative recovery has begun in timber sale units throughout the project area. Post-fire logging will damage forest regeneration, vegetative recovery, sensitive post-fire soils, and introduce noxious weeds into currently vibrant post-fire plant communities. This photo was taken in the summer of 2018, just one year after the Abney Fire burned through upper Seiad Creek. The native plant response has been both abundant and beautiful.

    With the Abney Fire literally still smoldering, the Klamath Forest Alliance and our conservation allies began working to stop this atrocious timber sale. Although we are challenging the timber sale with litigation, the Klamath National Forest is rushing forward to log off the Seiad Horse Project before our day in court. 

    Post-fire logging units clearcut by the Klamath National Forest after the 2014 Happy Camp Fire in the Westside Project. This photo was taken in the summer of 2018, four years after the Happy Camp Fire.
    Although this situation sounds unfair (and it is), the Klamath National Forest often rushes forward with post-fire logging projects before legal challenges can be fully resolved in court. This has been done on numerous recent post-fire logging projects including the massive Westside Project, following the 2014 Happy Camp Fire. 

    For the past few decades the Klamath National Forest has largely used post-fire logging as their defacto timber program. By doing so, they have focused their attention on logging conservation areas that would otherwise be off limits to such blatant, clearcut logging proposals. Instead of thinning dense, fuel-chocked plantations or reducing fuel around communities within or adjacent to the Klamath National Forest, the agency has spent much of the last few decades devastating conservation areas and backcountry habitats with industrial, post-fire logging projects. Unfortunately, Cook and Green Pass may be their next victim.
    A forest proposed for logging in the Seiad Horse Project.

    To make matters worse, the plantation stands established after post-fire logging have been proven to increase fire severity in future wildfires. They have also been shown to impact late successional habitats, forest complexity, biodiversity, and wildlife habitat. The sediment produced from clearcut logging, yarding, building new roads and constructing large log landings will also impact both water quality and fisheries habitat in Horse Creek and Seiad Creek. 

    The Seiad Horse Project consists of three timber sales. The Low Gap Timber Sale on Horse Creek has already been logged, logging  has also begun in the Copper Timber Sale and on the flank of the Siskiyou Crest, while the Pitchfork Timber Sale on Seiad Creek has not yet been subjected to industrial, post-fire logged. Unfortunately, the devastation could begin at any time and shamefully the Klamath National Forest is currently working to log off our wildlands as soon as possible. 

    For those of us who love this area, the decision is heartbreaking and for the wildlands of the Siskiyou Crest, it is an absolute tragedy.  Klamath Forest Alliance and our allies will continue our fight for the Siskiyou Crest. We still have hope that legal action can save some of these spectacular fire-adapted forest habitats. We believe the Siskiyou Crest is worth the fight. Please consider making a donation to support our work.

    Much of the old forest near Cook and Green Pass area burned at low to moderate severity in the Abney Fire. Yet, the Klamath National Forest is now targeting Bee Camp Road within the Kangaroo Inventoried Roadless Area for "hazard tree" logging. These large old trees will be logged to within 50' of the Pacific Crest Trail and will damage the natural mixed severity fire mosaic.

    Tuesday, May 28, 2019

    The Impact of Wilderness Bulldozing in the 2018 Fire Season

    A bulldozed fireline built across the PCT in the Soda Mountain Wilderness during the 2018 Klamathon Fire. As you can see the fire never reached this fireline and it played absolutely no role in fire containment.
    With fire season fast approaching, federal land managers and local politicians are promoting aggressive, industrialized, backcountry fire suppression in our most intact, wilderness landscapes. Many residents in the region are concerned that the landscapes we know and love will be damaged in that process. Being generally rugged, remote and far from human communities, wilderness firefighting is often inappropriate, unnecessary, ineffective, environmentally damaging and extremely dangerous for fire crews.

    Last year, fire managers in southwestern Oregon and northwestern California authorized the use of bulldozers in the Soda Mountain Wilderness east of Ashland, the Kalmiopsis Wilderness west of Cave Junction, and in the Siskiyou Wilderness between the Illinois Valley and Happy Camp, California. These authorizations for the use of bulldozers in local wilderness areas demonstrate a trend towards more damaging backcountry firefighting tactics in our region, they also account for as many authorizations as were approved throughout Oregon and Washington over the previous 12 years combined.

    A mortar or grinding stone bulldozed in a Native American archeological site.
    Last summer, during the Klamathon Fire, BLM and ODF fire crews bulldozed roughly 30 miles across the Soda Mountain Wilderness and Cascade-Siskiyou National Monument, bulldozing straight through streambeds, a number of rare plant populations and numerous Native American archeological sites. These dozerlines were driven extensively, providing vehicle access to the heart of the Soda Mountain Wilderness, compacting soils, creating erosion and spreading noxious weeds. Massive landings were also bulldozed on wilderness ridgelines to create helicopter pads, safety zones, medivac and hoist sites. Wilderness trails such as the Pacific Crest Trail, the Lone Pilot Trail and the Boccard’s Point Trail were bulldozed, degrading the wilderness experience for generations of backcountry enthusiasts and damaging natural habitats.

    Ironically, the extensive bulldozing in the Soda Mountain Wilderness played no direct role in fire containment (an estimated 80% was contained with hand built firelines) and numerous bulldozer lines were miles from any fire activity. Yet, while crews bulldozed the wilderness, the weather was shifting, the fire was burning back on itself and had begun running out of steam. This allowed hand crews to “go direct” and build handlines, containing the Klamathon Fire with far less damaging methods than the dozerlines built crudely through the wilderness. 

    Although the Klamathon Fire had tragic outcomes in the town of Hornbrook, California, where regrettably homes burned and a life was lost, the fire later burned at low to moderate severity throughout the Soda Mountain Wilderness, creating beneficial fire effects. It was largely the suppression efforts themselves that impacted ecological values, not the natural fire process.

    The Klamathon Fire was largely a low severity grass fire within the Soda Mountain Wilderness and Cascade-Siskiyou National Monument. This picture was taken on Scotch Creek in the spring of 2019, less than one year after the Klamathon Fire.

    Elsewhere in the region, fire crews for the Klamath National Forest bulldozed the Poker Flat Trail in the Siskiyou Wilderness and portions of the adjacent roadless area during the Natchez Fire. This dozerline was built into some of the most intact habitat on the Siskiyou Crest and again played no role in fire containment. It was built directly through headwater streams, serpentine outcrops, old-growth forests and high mountain meadows. The Natchez Fire burned in a rich and beneficial, mixed severity fire mosaic with substantial low severity fire effects, and once again, the most damaging effects can be attributed directly to suppression efforts.

    Forest Service fire managers also twice authorized the use of bulldozers in the Kalmiopsis Wilderness, proposing to bulldoze a high ridge south of the Illinois River and along the Illinois River Trail to Bald Mountain and beyond to South Bend Mountain. Despite attaining authorization, these dozerlines were never created and the Kalmiopsis Wilderness was spared the raw, bulldozed wounds inflicted on portions of the Siskiyou and Soda Mountain Wilderness last summer.

    A fireline bulldozed across a high mountain meadow in the Siskiyou Wilderness during the 2018 Natchez Fire. This particular dozerline, built within the wilderness, played no role in fire containment.

    Wilderness has become an increasingly rare resource and is important in maintaining clean water, biodiversity and wildlife habitat. It is also loved by many in the region and provides an opportunity to experience wild nature and escape the pressures of daily life. According to recent research in the Journal Nature, 77% of the global land base has been altered by economic development, resource extraction and other forms of industrialized land management. In southern Oregon, we are lucky to have significant wilderness landscapes and these landscapes define our region.

    Wilderness cannot be replaced or recreated, it plays a vital role in sustaining our region’s ecological values, our sense of place and our quality of life in southwestern Oregon. We would be wise to preserve the wilderness we have left and focus on protecting homes when wildfires occur. 
    The Natchez Fire burned beautifully through Twin Valley and the surrounding watersheds in the Siskiyou Wilderness. The fire burned in a mixed severity fire mosaic, with mostly low to moderate fire effects. The wild and intact landscapes of the Siskiyou Wilderness are irreplaceable and should be protected for future generations, not bulldozed and degraded in firefighting operations far from homes or communities.

    This article originally appeared on May 26, 2019 as a Guest Opinion piece in the Medford Mail Tribune

    Monday, May 6, 2019

    Klamath Forest Alliance Field Season

    The snow pack is beginning to melt in the high country of the Siskiyou Crest.

    With the snow beginning to melt in the high country, Klamath Forest Alliance (KFA) is preparing for our upcoming field season. Each season activists with KFA travel across the region monitoring federal land timber sales, grazing allotments, and illegal OHV trails. We roam the backcountry from the Pacific Coast to the interior mountains of the Klamath-Siskiyou. We drive bumpy backroads and hike hundreds of miles both on and off trail, through steep and rugged terrain. We climb mountains and traverse canyons to document proposed project activities and identify potential impacts associated with federal land management projects. 

    Bolander's lily
    We pack our supplies on our backs, often deep into the wilderness. We sleep on the ground and in the cold. We endure extreme heat, smoke-filled skies, electrical storms, and gully washing downpours. We trip, we fall, we sweat, we bleed; we are drilled by ticks, stung by ground nesting yellow jackets and eaten alive by mosquitoes. Yet, ultimately, we are also privileged to serve and defend the Klamath-Siskiyou! We are grateful for the time we spend in the field, defending the Klamath-Siskiyou and enjoying the region's spectacular beauty and diversity. The hardships endured build bonds with the land and the information gathered strengthens our advocacy. 
    Recent post-fire monitoring in the Soda Mountain Wilderness revealed beautiful fire effects and spectacular vegetative recovery in the Scotch Creek Watershed. 

    Our comprehensive monitoring programs give us intimate knowledge of proposed land management projects. The information gathered during on-the-ground monitoring activities informs our campaigns, outreach efforts, public comments, administrative appeals, and if necessary litigation. Our approach is science-based, site specific, comprehensive and effective. 

    If you appreciate the work we do and the effort it takes, please consider making a generous donation to support our field monitoring season. We will crash through the poison oak and brave swarms of mosquitoes—all you have to do is click on this donation link and contribute a few bucks to be a part of the effort. 

    Deep in the heart of the Marble Mountains Wilderness, the first snow fell on us while conducting fire monitoring for the 2014 Happy Camp Fire Report. Rain, snow or shine, KFA will be out defending our public lands!

    At KFA, we think on-the-ground monitoring is one of the most important things we do. 

    The Siskiyou Field Office of Klamath Forest Alliance will be conducting on-the-ground monitoring for the following federal land management activities in 2019:

    Proposed Timber Sales:

    •  The Middle Applegate Timber Sale: The Middle Applegate Timber Sale is located in the Applegate Valley of southwestern Oregon on Medford District BLM land. The Wellington Butte Roadless Area (also known as Wellington Wildlands) is located within the planning area and KFA is concerned that the BLM may propose logging within the roadless area. The project is in pre-scoping and no formal proposal has currently been produced. KFA will be monitoring the proposed units as soon as they are identified.
    • The Briggs Creek Timber Sale: The Upper Briggs Project is located in Briggs Creek, a major tributary of the Illinois River and west of Grants Pass, Oregon. The entire timber sale burned in the 2018 Klondike-Taylor Fire, sustaining mostly low to moderate severity fire effects. Many timber sale units underburned at low severity, yet the agency tells us they are still at risk of "catastrophic fire." The agency has released a decision on this project and KFA is currently working on an Administrative Objection. We will also be conducting field monitoring to document fire effects and vegetative regeneration following the 2018 fires. 

    Post-Implementation Monitoring:
    • The Seiad Horse Post-Fire Logging Project: This large post-fire logging project is located on the Klamath River above Seiad Valley, California on the Siskiyou Crest. The project proposes to clearcut forests affected by the 2017 Abney Fire. KFA and other conservation allies currently have portions of the project under an injunction and are litigating to stop the project from moving forward. Unfortunately, portions of the project were logged before an injunction could be secured and KFA will be monitoring those units to document the ecological impacts.
    •  Horse Creek Post-Fire Logging: The Horse Creek Project is located on the Klamath River above Horse Creek, California, also on the Siskiyou Creset. The project was implemented by the Klamath National Forest in 2017 and 2018, after the 2016 Gap Fire. KFA will be conducting post-implementation monitoring to document the ecological impacts.

    OHV Monitoring:
    • OHV monitoring on the Rogue River-Siskiyou National Forest and Klamath National Forest: KFA will be working with conservation partners at Applegate Neighborhood Network to monitor OHV activity on the Siskiyou Crest and in designated Botanical Areas. Our monitoring activities will occur on the Klamath National Forest in northwestern California and on the Rogue River-Siskiyou National Forest in southwestern Oregon, and are used to advocate for closure of illegal and ecologically damaging OHV trails.
    •  OHV monitoring on the Medford District BLM: KFA will be working with conservation partners at Applegate Neigborhood Network to monitor OHV activity on the Medford District BLM, including within roadless areas, Lands with Wilderness Characteristics (LWC) and in biodiversity hotspots. Our mointoring is used to advocate for closure of damaging OHV trails.

    Grazing Allotment Monitoring:
    • Siskiyou Crest Grazing Allotments: Along with our partners at the Grazing Reform Project, KFA will be conducting ongoing monitoring of grazing allotments on both the Klamath National Forest in northern California and the Rogue River-Siskiyou National Forest in southern Oregon. Our ongoing monitoring activities document environmental impacts associated with public land grazing. We use this information to advocate for reform of public land grazing practices and prepare for future updates to grazing plans on the Siskiyou Crest. 

    Wildfire Monitoring

    • Klamath-Siskiyou Wildfire Monitoring: Each summer KFA monitors the wildfires burning in the Klamath-Siskiyou Mountains of northern California and southern Oregon. We monitor fire suppression activities, especially in roadless areas, wilderness areas, botanical areas and other important habitats. After the fires have been extinguished we explore the fires and their ecological effects. The information is used to advocate for the reform of fire suppression policy and strategy, as well as to publish detailed fire reports.

    Help us put our best foot forward, donate to KFA! Even when sore, dirty and covered in soot from post-fire monitoring, we are happy to work for the Klamath-Siskiyou.