Friday, August 3, 2018

The 2018 Fire Season: A Destructive New Paradigm in Backcountry Fire Suppression, and a Challenge for the Environmental Community

Last year Azalea Lake in the Red Buttes Wilderness burned at mixed severity in the 2017 Miller Complex Fire. 
The 2018 fire season has been very active in southern Oregon and northern California, with both lightning and human caused fires burning across the region. Domesticated landscapes and urban areas, as well as wildlands and wilderness areas have burned, filling the canyons and valleys with smoke. 

At times, the fires have burned slowly, creating low to moderate-severity fire effects. At other times, wind and weather-driven runs have scorched the forest canopy, spread quickly and burned with intensity. The result is a diverse mosaic of mixed-severity fire, creating complex structural conditions, a variety of plant communities, staggered successional stages and uniquely biodiverse and abundant post-fire landscapes. 

Although the 2018 fire season has been tragic due to the loss of life and the burning of many homes, much of the backcountry fire activity, so far, appears characteristic for our region. Fire severity has been moderated by heavy smoke inversions for much of the summer, but when the smoke lifts and the wind blows, fire behavior responds with increased intensity. (For more information on how localized wind affects fire behavior check out this research.)
Wildfire has triggered dynamic ecological changes on the slopes around Lonesome Lake in the Red Buttes Wilderness. Before the 1987 Fort Copper Fire this area supported a high elevation forest. The Fort Copper Fire burned at relatively high severity, and twenty-five years later the 2012 Fort Complex Fire also burned through these once forested slopes. The repeat fires facilitated the area's transformation into beautiful meadow-like slopes filled with native grasses, wildflowers and abundant wildlife. In the canyon below Lonesome Lake the old-growth forest was maintained by wildfire and remains vibrant old forest after the 2012 Fort Complex Fire.

Wildfire is a dynamic natural process driving ecological change, rejuvenating plant communities, diversifying our forests, and reducing fuel in landscapes across the Klamath-Siskiyou Mountains. If managed properly and under the correct weather conditions, wildfires can be suppressed before they impact communities, and used as a tool to restore fire-adapted ecosystems. 

Some fires, for example the Carr Fire currently burning near Redding, California, and the Taylor Fire burning outside Grants Pass, Oregon should be responsibly suppressed to protect communities and public safety. Because fire managers prioritize front country fires during initial attack efforts, many of the fires extinguished by fire crews this summer were located close to communities and important infrastructure. Over 100 fires were extinguished on the Rogue River-Siskiyou National Forest alone, while the most remote and difficult fires continue burning.
The Burnt Peak Fire burned in the Upper Applegate Valley in the 2017 Miller Complex Fire. The fire backed safely to the community below, with no loss to homes or infrastructure. The fire was fully suppressed, but impacts were minimal due to the indirect containment strategy and the patience of fire managers. The long-term effects of the Burnt Peak Fire are profoundly positive for the forest and the nearby community.

Fire managers have the ability to implement the "Appropriate Management Response" during wildfire suppression activities. This means that crews can aggressively suppress some fires or portions of a fire, while suppressing less aggressively on other portions. In some places the fire can be fought indirectly, allowing the fire to burn within predetermined boundaries to prepared firelines. This reduces fuel, restores fire as a natural ecosystem process, and allows fire crews to safely focus their energy where it is most necessary, adjacent to homes and communities.

For example, fires like the Klondike Fire currently burning in the Kalmiopsis Wilderness Area and Illinois River canyon, could be managed by suppressing the eastern flank before it impacts the community of Selma, Oregon, while the southern and western margin in the Kalmiopsis Wilderness could be allowed to burn into natural barriers created by the 2002 Biscuit Fire, 2013 Labrador Fire and the 2017 Chetco Bar Fire footprints. 

These recent fire footprints are likely to either not burn at all, or burn at mostly low severity. In fact, the Klondike Fire's southern and western perimeter is currently hung up at the boundary of the 2017 Chetco Bar Fire, which is acting like a natural fire break. These portions of the fire have hardly moved for over a week and contain very little active heat according to Forest Service infrared maps.
The 2017 Chetco Bar Fire footprint is providing a 190,000-acre natural fuel break west and south of the current 2018 Klondike Fire.

The Natchez Fire burning on the Siskiyou Crest between Takilma, Oregon and Happy Camp, California could also be managed both to protect communities and restore a more natural fire regime in the Siskiyou Wilderness. This fire could be suppressed where it threatens communities and steered southwest into the 2017 Eclipse Fire footprint, the sparse, rocky summits surrounding Preston Peak, and the Siskiyou Wilderness Area. It is highly likely that the fire could stall out in the rocky and recently burned terrain.

The ecological impact of fire suppression activities, such as the use of bulldozers to build fireline, the ignition of high severity backburns, heavy snag removal, and the creation of helipads, safety zones, and hoist sites in Wilderness Areas, Roadless Areas, Botanical Areas, old-growth forests, Late Successional Reserves and other wildland habitats is becoming more significant with each passing year. 

Environmentalists and public land watchdogs need to be aware of the increasing ecological damage sustained in our wildlands during fire suppression activities. Just as we provide public input on other activities that affect the public lands we love, such as timber sales, pipelines, oil drilling, mining, etc., we must also provide land managers with input regarding fire management. (For information on how to track wildfires, wildfire effects and fire suppression impacts check out this link)

In many cases the impact of discretionary fire suppression activities is far more severe than the impact of the wildfire itself. Currently, irresponsible fire suppression is one of the most damaging forms of land management affecting our roadless wildlands and protected Wilderness Areas. Irresponsible, backcountry fire suppression activities are degrading our wildlands, their intact roadless values, and the complex ecosystems they support.
This dozerline was built in the Soda Mountain Wilderness in the Cascade-Siskiyou National Monument through miles of old-growth forests, rocky lithosol meadows filled with wildflowers, rare plant populations, and both across and adjacent to the Pacific Crest Trail. This dozerline is many miles from the Klamathon fire perimeter and did not serve as fire containment line. The impacts from the dozerline on the Soda Mountain Wilderness will be permanent, yet provided no benefit to fire suppression crews.

This season we have seen an escalation in the war against fire and smoke, we have also seen a severe escalation in environmental impacts associated with fire suppression activities. Damaging fire suppression tactics have been approved in many of our wildest, most intact landscapes by both the Forest Service and BLM, including the Soda Mountain, Siskiyou and Kalmiopsis Wilderness Areas, the Big Red Mountain Botanical Area and the Cascade-Siskiyou National Monument. 

For the first time in many years the wilderness areas of southern Oregon and northern California have been subjected to the use of bulldozers in designated Wilderness Areas. The approval to bulldoze firelines and access routes inside designated wilderness areas was virtually unheard of until this season, yet fire managers have approved dozer use in all three of our wilderness fires. 

Most egregiously, an estimated 35 miles of dozerline now crisscrosses the Soda Mountain Wilderness and adjacent portions of the Cascade-Siskiyou National Monument. Rare plant populations, the Pacific Crest Trail and other wilderness trails were bulldozed by fire suppression crews, creating extreme impacts to the region's intact plant communities and biodiversity. The impact of suppression activities in the Soda Mountain Wilderness and Cascade-Siskiyou National Monument is both unprecedented and entirely unacceptable. Both ODF and BLM are responsible and need to hear from us.
An estimated 3/4 of a mile of the Boccard Point Trail in the Soda Mountain Wilderness and Cascade-Siskiyou National Monument was bulldozed by BLM and ODF fire suppression crews, destroying a popular wilderness trail and degrading wilderness values. The fireline was miles from the Klamathon fire perimeter and was never used for fire containment.

The environmental movement has spent many decades working to protect Wilderness Areas that are now threatened by irresponsible, environmentally damaging and overly aggressive backcountry firefighting. As a movement we must encourage the use of restorative, low-impact fire suppression tactics and strategies, especially in our wildlands. We must also document and address the impact of heavy handed fire suppression activities on our public lands. In many cases, these impacts could be avoided while safely and effectively suppressing or managing wildland fires.

If these impacts continue to be ignored by the environmental community, many of our most beloved wildlands will be bulldozed, roaded, heavily backburned and riddled in large landings. Wilderness trails and ridgelines will become raw, weed infested dozerlines, habitat for rare plant species will be destroyed, and wild streams will be "snagged" of all large, dead standing trees. As time goes on and these impacts are repeated across our landscape, significant wildlands and important biodiversity will be lost. As environmentalist, we must address these impacts with solutions that include the protection of communities and important habitat values.

After having last year's Miller Complex Fire burn to my own off-grid homestead surrounded by Forest Service land, without the loss of property or the need for damaging fire suppression tactics (only minimal, light backburning was used), I know firsthand that under good weather conditions our rural communities can live with wildfire and our forests can benefit from effective wildfire management. It is our responsibility as rural landowners to create defensible space around our homes and support fire crews so they can be safe while protecting private property in often rugged, remote and difficult terrain. To a certain extent our homes and the lives of firefighting personnel largely depend on our ability to be prepared.
A massive "safety zone" built on the 640 road north of Oak Flat and the Klondike Fire near Flat Top Mountain. The impact of safety zone development on this site will be severe, with permanent impacts to soils and botanical resources. Photo credit: Inciweb

The Klamath Forest Alliance will be publishing a series of fire reports for this summer's wildfires in southwestern Oregon. We will be exploring the mosaic of the fires, evaluating their effects and documenting fire suppression impacts.  Please consider supporting this visionary and challenging work with a generous, tax-deductible donation. We have a lot of research and field monitoring to do across the region and we need your support!

We will be covering the following wildfires in southern Oregon:
  • Klamathon Fire in the Cascade-Siskiyou National Monument and Soda Mountain Wilderness Area
  • Klondike Fire on the Illinois River in the Kalmiopsis Wilderness and the surrounding inventoried roadless area. 
  • Natchez Fire on the Siskiyou Crest in the Siskiyou Wilderness and surrounding Klamath National Forest lands,
  • Taylor Fire on the Rogue River near Merlin and Galice, Oregon.  
  • Hendrix Fire on the Siskiyou Crest near the Big Red Mountain Botanical Area and Research Natural Area.

Look for more information on this blog regarding fire suppression impacts to wilderness areas, roadless areas and botanical areas sustained during the 2018 fire season.

Sunday, July 1, 2018

Clean Slate Timber Sale: Old-Growth Forests and Northern Spotted Owl Habitat Targeted for Removal

Unit 3-11 of the Clean Slate Timber Sale contains uncut, old-growth forest on fragile soils. The unit would be logged to between 25%-35% canopy cover and Northern spotted owl habitat would be removed.
Throughout 2017, local residents organized and worked hard to shut down the southwestern portion of Grants Pass BLM's Pickett West Timber Sale outside Selma, Oregon on Deer Creek. This portion of the Pickett West Timber Sale proposed to log over 1,500 acres of old forest habitat and was withdrawn due to significant public opposition, effective community organizing and unacceptable impacts to the red tree vole, a preferred prey species of the threatened Northern spotted owl.

Although this was a significant victory, many of us knew it was not the last struggle over ancient forest habitat in the Deer Creek Valley. Portions of the Deer Creek Watershed have been identified as "Timber Harvest Landbase" in the BLM's 2016 Resource Management Plan (RMP), meaning the BLM intends to log these stands to meet their annual timber quota. Although some of the stands included in the "Timber Harvest Landbase" are old-growth forest, the BLM values them only for the logs they will produce.

Following cancellation of the Pickett West Timber Sale, the Grants Pass District BLM announced a new timber sale in the Deer Creek Watershed called the Clean Slate Timber Sale. An Environmental Assessment (EA) was recently released and is currently open for public comment. 

Unfortunately, the sale is not operating from a clean slate (pun intended), and units from the Pickett West Timber Sale have been included in the Clean Slate project. The Clean Slate Timber Sale targets some of the last stands of complex, old-growth forest at the headwaters of Thompson Creek and McMullian Creek.

The BLM admits in the Clean Slate EA, "Nearly all the BLM administered lands contained in the Clean Slate planning area have had some form of commercial timber management in the last eight decades. About half has undergone some form of clear-cut or regeneration harvest." (Clean Slate EA, P. 65). 

Ancient uncut forest is a rarity in the Clean Slate Planning Area. The BLM is proposing to heavily log some of the last intact forest in the area, including unit 3-11.
The fact that nearly the entire planning area has been previously logged, and about half has been clearcut, makes the remaining late successional forest exponentially more important than ever before. The complex, old forest habitats proposed for logging in the Clean Slate Timber Sale should be canceled to protect, what are admittedly, the last remaining late successional habitats in the area. 

The retention of these last old forests will ensure that habitat for late successional species, such as the Pacific fisher, the Northern spotted owl and its prey species, remain on the landscape. Retaining the last old forests will also protect and preserve the most fire resistant portions of the landscape. 

The Clean Slate EA proposes to heavily log 175 acres of late successional or old-growth forest to between 25% and 35% canopy cover. The EA also proposes 461 acres of commercial logging, 450 acres of which will completely remove Northern spotted owl habitat.  The BLM admits that this habitat will take at least 50 years to recover, and according to the new RMP will then again be ready for additional timber harvest, "therefore closed canopy conditions are not expected to be regained in the foreseeable future." (Clean Slate EA, p. 90). This constitutes a complete loss of old-growth characteristics, and Northern spotted owl habitat. 

Unit 9-5 in the Clean Slate Timber Sale contains complex, old-growth forest habitat, beautiful hardwood groves and minimal fuel loading. 
Proposed logging in currently complex, old forest habitats will disproportionately impact Northern spotted owl prey species. According to the EA, proposed treatments in NRF [Nesting, Roosting, Foraging] habitat contain, "stands that currently have well established middle and top layer structures. Some units have ground and understory cover. These stands many have populations of flying squirrels, red tree voles, and woodrats because of the increased structure such as cavities, platforms and layered vegetation providing cover from predators. These stands would be heavily thinned" and would subsequently not be expected to "maintain stable populations of flying squirrels or red tree voles, or may have reduced density levels, and may not function as secure foraging habitat for spotted owls due to lower canopy cover levels." (Clean Slate EA, P. 94).

Logging these units will also remove large, fire resistant trees while also increasing fuel loads. Logging operations will generate highly flammable slash and drastically reduce canopy cover. The soil disturbance and increased sunlight associated with yarding activities and canopy cover removal will encourage shrubby understory growth, as well as tanoak and young conifer regeneration. The prescriptions for the Clean Slate project were specifically designed to meet annual timber quotas, not to reduce fuel loading or increase forest health.

Instead of reducing fuel loads, the canopy gaps intended to encourage regeneration of young, early-seral vegetation will create a "brush fuel type" (Clean Slate EA, p. 192) that could increase future fire severity and decrease the effectiveness of fire suppression activities adjacent to the community of Selma, Oregon. These canopy gaps are embedded within all proposed thinning units and will represent up to 30% of the stand. 

"For 5 to 20 years following planting, the overall fire hazard would increase in these stands." (Clean Slate EA, p. 192).

Dense understory fuel loads developed in response to previous thinning treatments in unit 3-9. Proposed treatments in the Clean Slate Timber Sale will open canopies even more drastically, encouraging an aggressive understory shrub response and an increase in fuel loading.

The forests of the Deer Creek watershed were not historically dry forests with open stand conditions and a low-severity, high frequency fire regime as the BLM claims. The Deer Creek watershed averages between 50 and 70 inches of rain per year and grows relatively moist, productive forest associations. The Doug fir/tanoak and Doug fir/live oak plant associations grow lush forests dominated by a mixed-severity fire regime. Slopes are often steep and soils very rocky, with outcrops and rocky talus-like slopes, shaded by large old conifers and beautiful groves of hardwoods including tanoak, live oak and madrone.

A view northwest from the Kerby Peak Lookout in 1934.
Early landscape photographs of the Deer Creek Watershed in 1934 show a mixed habitat, with closed canopied forests dominating the landscape, especially on north- and east-facing exposures, in gulches, riparian areas and on the lower 1/3 of the slopes. On south-facing ridges forests often mingle with small, early successional openings located near the ridges, summits and most exposed portions of the landscape. These openings appear to be either associated with serpentine soils — such as the south face of Round Top Mountain — or fire. They contain young, chaparral habitats, early successional forest regenerating from wildfire, and on the lower slopes adjacent to the valley, logged over stands impacted by human settlement. 

The patterns of the mosaic in 1934 show a history of mixed-severity fire and relatively limited human development. The open canopied forest described in the Clean Slate EA is a rarity on the landscape in 1934, when a much more active fire regime influenced the region and much less commercial logging had taken place. The BLM is claiming that these forests were open habitats with large populations of pine and oak, yet the soils, precipitation levels, plant associations and historic photographs demonstrate otherwise. 

Rather than recreating the historic landscape, the BLM will create highly unstable, degraded habitats — novel ecosystems with little resemblance to natural fire-adapted forest communities. The open forest hypothesis, is in this case, is a thinly veiled excuse to justify the heavy timber extraction and excessive canopy cover reduction envisioned in the highly controversial and still heavily litigated 2016 RMP.

Unit 9-5
Unit 9-5 contains a beautiful mix of hardwoods and large, old Douglas fir. The unit is one of the last remaining late successional habitats in the McMullian Creek watershed.

Unit 9-5 is located on an extremely steep, north-facing slope at the headwaters of McMullian Creek. McMullian Creek drains into Lake Selmac and has been heavily logged from top to bottom. The vast majority of this watershed has been converted into fiber plantations, including large swaths of both BLM and private timber land. The upper McMullian Creek Watershed also has the highest road density in the planning area, at an astounding 7.78 miles of road per square mile. The BLM has proposed two new "temporary" roads to access unit 9-5 in the Clean Slate project.

Unit 9-5 is one of the only remaining fragments of old forest in the entire McMullian Creek watershed, surrounded by clearcuts and young, simplified plantation stands, it is also a refuge for wildlife. The unit consists of massive old fir and sugar pine, among dense tangles of tanoak and beautiful groves of mossy live oak. The slopes are incredibly steep and covered in rocky talus, making them particularly slow to regenerate following logging operations. 

The western portion of the unit faces northeast and supports a dense tangle of multi-stemmed tanoak and massive, widely spaced Douglas firs. The overstory layer is broken and complex, with groves of old-growth fir towering above the secondary canopy of hardwoods. Portions of the stand are completely unmanaged and contain intact biological legacies not otherwise found in the McMullan Creek watershed. 

A small headwater fork of McMullian Creek dissects the unit at its center, trickling through moist, fern laden streambanks and down beautiful cascades. The large, old trees and their massive root systems, as well as the downed wood they eventually deposit along the small, swift moving stream provides stability and habitat, while their canopies provide shade, moderating the habitat, creating climate refugia and cooling the stream. This headwater stream provides connectivity for species such as the Northern spotted owl and Pacific fisher, it also provides thermal cover for local ungulates such as deer, and protection for resting and denning habitat for black bear. 

Numerous red tree vole nest sites have been identified within unit 9-5 and populations of other Northern spotted owl prey species, such as flying squirrel are also likely to live here. The forest is currently identified as Nesting, Roosting and Foraging (NRF) habitat for the Northern spotted owl, meaning it provides important habitat for the spotted owl's entire life cycle. Following logging treatments, spotted owl habitat would be "removed," meaning it would not provide even the most basic habitat elements and would likely be avoided by spotted owls and their prey species, including the red tree vole and flying squirrel.
The eastern half of unit 9-5 contains incredible stands of live oak and Douglas fir on steep, rocky slopes.

To the east, the unit faces northwest and supports a distinctly different forest type. Beautiful groves of mossy live oak grow from steep talus slopes and shaded rock outcrops. A complex mosaic of massive old growth fir and sugar pine grow in groupings and as solitary old individuals above a lower canopy of live oak. The soils are harsh and rocky, but shaded by old trees and covered in dense moss beds, that likely support the lungless Del Norte salamander. The species breaths through its skin and lives in the mossy talus, where cold, moist conditions are available year round. The shade and cooling effect of large old trees is essential to this species, and its specific habitat requirements include late successional characteristics, relatively high levels of canopy cover, and often, moss covered talus habitat. All habitat requirements are present in unit 9-5.

The Del Norte salamander also has a very small home range and cannot effectively disperse from damaged habitats. Impacts from the Clean Slate Timber Sale could drastically reduce populations of Del Norte salamanders, significantly impact available habitat and/or create extirpation of localized populations. 

Unit 9-5 should be withdrawn from the Clean Slate Timber Sale.

Unit 3-11
This photograph depicts the logging "mark" in unit 3-11. The two 30"+ DBH trees in the foreground are unmarked, meaning they would be logged in the Clean Slate Timber Sale. The trees in the background contain a red-hash mark and would be retained in logging operations.

Unit 3-11 is located at the headwaters of Thompson Creek. The stand consists of beautiful old-growth forest on extremely steep and rocky slopes. Large portions of the stand have never been logged and contain complex, late successional forest habitat. The stand is also located within an important connectivity corridor linking the ridges to the stream below. The corridor contains mostly mature forest habitat in a sea of plantation stands and relatively fresh clearcuts.

The habitat complexity, high canopy cover, adequate snag and downed wood habitat, canopy layering and thermal cover provide important habitat for the Northern spotted owl and its prey species such as the red tree vole and flying squirrel. In fact, numerous red tree vole nests have been located within the stand. Unit 3-11 should be protected under Recovery Action 32 of the Northern Spotted Owl Revised Recovery Plan, due to its complex forest habitats and intact biological legacies. 

Part of the reason unit 3-11 has never been logged is due to its classification in the Timber Productivity Capability Classification (TPCC). The TPCC is utilized by the agency to identify fragile soils where timber harvest and road construction should be avoided. A large portion of unit 3-11 was considered too rocky and unstable to build roads or sustain timber harvest. Rather than avoid this rocky, unproductive and unstable area, the BLM simply changed the TPCC classification to allow logging the fragile soils formerly identified in unit 3-11 (Clean Slate EA, p. 218).  

The mark in unit 3-11 is a red "leave tree mark," meaning the trees marked with red paint would be retained in logging operations. As you can see in this photograph, the four large trees in the background would be logged while one tree marked red would be retained. Notice the suppressed understory growth and minimal fuel loading associated with closed canopied late successional forest in the area.
The heavily logged stands adjacent to unit 3-11 are choked with heavy fuel loads of brush, regenerating hardwoods and young, highly flammable fir trees. At the same time, the broken, old growth canopy found in unit 3-11 is moderating fuel loads by suppressing understory growth and maintaining cool, moist habitat conditions. These stands and their towering old growth trees, are not only the most productive wildlife habitat in the area, they are also the most fire resistant portion of this heavily altered landscape.

Although the soils are poor, trees over 70" in diameter have managed to grow from the rocky substrate. Moss-covered tanoak and towering old Douglas fir rise above the rugged slopes, creating a cool, protective, multi-layered canopy. Although the large conifers are relatively open spaced and scattered about in majestic old groupings, the closed canopy conditions create a cool, moist habitat, sheltering the stand from heavy winds and temperature extremes. The understory is lush and abundant with tangles of vine maple and more open slopes carpeted in vanilla leaf, Oregon grape and rocky scree.

The slopes are extremely steep, but are punctuated by small, flat benches. These are old depositional sites associated with historic landslides. They are now colonized in spectacular old groves of fir, cedar, tanoak and a few sugar pine. The deep soils, old forests and relatively gentle terrain provides productive growing conditions and additional capacity to retain soil moisture. 

The complex ancient forest in unit 3-11 is proposed for heavy industrial logging in the Clean Slate Timber Sale. Unit 3-11 should be canceled.

Unit 3-10
The previously unlogged portion of unit 3-9 will be heavily logged in the Clean Slate Timber Sale. This photograph was taken after the timber sale mark, which shows that only one tree will be retained in this beautiful grove.

Unit 3-10 consists of mature and late successional forest habitat in the same connectivity corridor as unit 3-11. Although most of the stand was commercially thinned, much of the habitat still contains mature forest and relatively large, old trees. A small portion of the unit at its northeast corner has never been logged and contains a concentration of large, old trees with relatively closed canopy conditions. The heavy canopy cover has suppressed understory growth, naturally limiting fuel loads and increasing fire resilience. 

Other portions of the stand have been heavily thinned, and have responded with increased fuel loading. The fuel loads are now extreme and the stands are so heavily choked with understory growth that they can hardly be walked through. The impenetrable understory of dense shrubs, tall regenerating hardwoods and highly flammable conifer regeneration will significantly increase future fire severity and impact fire suppression crews' ability to manage or control a fire while it is still small. 

The current condition in large portions of unit 3-10 does consist of extreme fuel loading and overly dense understory conditions, yet this condition is more associated with previous logging than fire suppression. Prescriptions proposed in the Clean Slate Timber Sale appear more intensive than those previously implemented in unit 3-10 and will only make the problem worse.

The stand should be deferred from commercial harvest to allow canopy conditions to recover and again suppress understory growth.  

Unit 3-9
Unit 3-9 lies directly below unit 3-11 on very steep, rocky slopes above Thompson Creek. The unit has been previously logged, but still contains large, old-growth trees, significant heterogeneity and relatively healthy forest habitats. Unit 3-9 is also located in the same connectivity corridor as unit 3-11.

The eastern portion of the unit consists of healthy mid-seral/mature forest habitat, with natural decadence and complexity, as well as minimal fuel loading. The western portion contains many large, old Douglas fir trees towering above a secondary canopy of live oak. The stand is developing naturally into complex, mid to late successional habitat and should be maintained for connectivity, late successional wildlife habitat, and to encourage fire resilience. 

The level of canopy reduction proposed in the Clean Slate Timber Sale will drastically increase fuel loading by encouraging a heavy understory shrub response and removing large, fire resistant trees. 

Unit 3-9 is currently not in need of management to maintain the stand in a desirable condition and should be withdrawn from further consideration in the Clean Slate Timber Sale.  

Unit 21-12
All the trees in this photograph will be removed in logging operations in unit 21-12. The mark in this unit is extremely heavy and will increase fuel loading directly adjacent to residential properties on Thompson Creek.

Unit 21-12 is located on a west-facing slope above Thompson Creek and represents an important low-elevation forest habitat. The stand consists of mid to late successional Douglas fir, sugar pine, live oak, madrone and tanoak. 

Much of the stand is dominated by large, relatively fire resistant Douglas fir, but significant populations of sugar pine colonize the western-most portion of the unit. On this western face, numerous large, old sugar pine and Douglas fir grow in groupings and scattered groves. The BLM has proposed extremely heavy logging in this portion of the stand, retaining very little but the scattered pine trees. Many large, old fir trees between 24" and 32" DBH are marked for removal and the hardwood component is likely to be badly damaged during logging operations. 

The sugar pine marked red would be retained while Douglas fir (including large trees over 30" DBH) would be virtually eliminated from the western half of unit 21-12.
Fuel loading is likely to increase adjacent to private residential properties on Thompson Creek Road due to the excessive levels of large tree removal and canopy reduction. The reduction of canopy cover to between 25% and 35%, with large, 1-4 acre openings scattered throughout the stand will encourage a dramatic understory response. The EA admits that harvested stands will experience increased fuel loading for between at least 5 and 20 years, putting the residents on Thompson Creek at risk. 

The eastern portion of the stand is more closed and is dissected by a number of small draws. The forest contains closed canopy groves of Douglas fir and sugar pine. The more piney eastern portion of the stand is dispersal habitat, while this more productive eastern portion is classified as Nesting, Roosting and Foraging habitat. The area is also located within the home range of two Northern spotted owl nest sites. All Northern spotted owl habitat will be removed due to canopy cover loss and the removal of large trees and other essential habitat elements.

A large section of road reconstruction is necessary to access unit 21-12 and portions of the unit will be subjected to ground-based yarding. The proposed logging prescriptions in unit 21-12 will significantly impact soils, fuel loading, community fire safety and wildlife habitat. Unit 21-12 should be withdrawn from further consideration in the Clean Slate Timber Sale. 

Unit 22-5
Unit 22-5 consists of lush forest on a north-facing slope. Portions of the stand has been previously logged, but also contains many large, old fire resistant trees. Other portions have never been commercially harvested. 

Large Douglas fir dominate the stand, with a secondary canopy of mossy tanoak and a dense understory of evergreen huckleberry. The canopy structure is relatively open and has naturally developed a dense woody understory.

The stand will simply not benefit from the proposed logging treatments and canopy reduction; understory huckleberry and tanoak response will make conifer regeneration extremely difficult. Fuel loading will significantly increase as brush and stump sprouting hardwoods species already present will further dominate the stand.  

Unit 22-5 is located within the home range of two Northern spotted owls and on the boundary of a third home range. The unit is currently classified as dispersal habitat, but would be removed due to canopy reduction and the loss of habitat complexity. Many large, old trees would be removed to achieve the proposed canopy cover targets, opening new ground for brush conversion.

Unit 22-5 should be withdrawn from further consideration in the Clean Slate Timber Sale

Please Comment Now on the Clean Slate Timber Sale!

Send Comments To: 
Allen Bollschweiler
Grants Pass Interagency Office
2164 NE Spaulding Ave. 
Grants Pass, Oregon 97526

or via email at:

Talking Points:
  • The EA states that nearly the entire planning area has been logged and about half has been clearcut. Unlogged and late successional stands like those found in units 3-11 and 9-5 should be canceled to protect the last remaining late successional habitat in the project area.
  • Unit 3-11 meets all the criteria of Recovery Action 32 and should be protected as complex, late successional habitat. 
  • Units 3-11, 3-9, 3-10, 9-5, 21-12 & 22-5 should be canceled to maintain late successional and connectivity habitat. These units also contain fire resistant, old forest that should be deferred from treatment in the Clean Slate Timber Sale.
  • The portions of unit 3-11 previously classified as "Fragile Soils," and therefore not allocated for timber harvest or road building, should be deferred from treatment and appropriately reclassified as "fragile" to protect soil resources and avoid reforestation failures.
  • The level of canopy reduction proposed will increase fuel loading and encourage an aggressive understory shrub response. The Clean Slate EA admits that openings created in all timber sale units will increase fuel loads for at least 5 to 20 years. These opening will be embedded within all logging units in up to 30% of each unit.
  • Fire safety for the community of Selma, Oregon should not be compromised for timber production. The 2016 RMP claims that active management will increase resilience to wildfire effects, the findings in the Clean Slate EA demonstrate that logging operations will increase fuel loading in all treated stands due to canopy reduction and gap creation.
  • The BLM is proposing to remove 450 acres of Northern spotted owl habitat and assumed that they will not regain suitable habitat conditions in the foreseeable future. This is inconsistent with the Revised Recovery Plan for the Northern spotted owl that recommends active management to create and maintain NSO habitat. The BLM has proposed a total long-term loss of NSO habitat in the Clean Slate Timber Sale.  

Wednesday, May 30, 2018

The Upper Briggs Restoration Project: Old forest logging proposed on Briggs Creek! Please comment now!

Old-growth forest proposed for logging in the Upper Briggs Restoration Project on the Secret Way Trail, south of Sam Brown Campground.
Upper Briggs Restoration Project: Old forest logging proposed on Briggs Creek! Please comment now, the comment period ends May 31st!

Briggs Creek is a beautiful stream flowing south into the Illinois River canyon from its headwaters near Onion Mountain Lookout, Taylor Mountain, and to the west, Chrome Ridge. The region contains steep forested slopes, gentle green meadows at Briggs Valley, serpentine ridges, and clear flowing streams. Briggs Creek is an important cold water tributary of the Illinois River with runs of coho salmon and steelhead trout. It is also an important recreation area just west of Grants Pass, Oregon with the world's tallest ponderosa pine trees.

The region has a rich human history of indigenous land management, and later, of mining, logging, ranching and recreation. The creek is named for George Briggs who packed supplies into the area for local miners with a team of mules. Starting in the late 1860s, the creek was heavily mined for gold. Most of the mining was taking place in the streams and fishery habitats on Briggs Creek and smaller tributaries. 

By the 1920s new roads led out to chromium mines on aptly named Chrome Ridge, and placer mining continued in the streams. Around this time settlers farmed and ranched the small meadows near Sam Brown Campground and Horse Creek Meadows. Later logging roads were built throughout the watershed and both clearcut and selective logging was common from the 1940s to the 1990s. Today, over 170 miles of road have been built within the Briggs Creek Watershed and roughly 7,000 acres have been clearcut by the Rogue River Siskiyou National Forest. 

Old-growth forest proposed for logging to 40% canopy cover in unit 23 along the Secret Way Trail.
Although portions of the Briggs Creek Watershed have been badly damaged by mining, logging, road building and ranching, other portions remain as intact remnants of the once vast uncut forests, rocky, unroaded ridges, verdant meadows and clear salmon streams found on Briggs Creek.  

Since at least the 1960s the Forest Service has also managed numerous recreation sites in the Briggs Creek area, and generations of southern Oregon residents have fallen in love with the region for camping, hiking, and more recently, mountain biking.

The Sam Brown Campground and adjacent recreation sites continue to be extremely popular with area residents, and recently the Forest Service invested in maintenance, renovation and trail construction in a large, interconnected trail system leading from the Illinois River, up Briggs Creek and over the ridge to nearly the banks of the Rogue River on Taylor Creek.

A remnant grove of old Douglas fir trees growing in unit 35 of the Upper Briggs project. The stand is mostly mid-seral Douglas fir forest, but the agency has proposed to drastically reduce canopy cover, remove large trees and implement pine-oak restoration treatments. The proposal to convert Douglas fir forest to pine-oak structural conditions is inappropriate and will degrade forest habitats rather than "restore" them.

Unfortunately, the Forest Service has proposed the Upper Briggs Creek Restoration Project, a large landscape-scale timber sale that would log over 4,000 acres around the Sam Brown Campground, along recreational trails, in the Horse Creek Meadows Wildlife Area and in Critical Habitat for the Northern spotted owl. 

Klamath Forest Alliance has been monitoring proposed timber sale units and has prepared a detailed public comment advocating for old-growth forests, Northern spotted owl habitat and the protection of beautiful meadows in the Horse Creek Meadows Wildlife Area. 

We are especially concerned by the proposal to log old forest habitats and to conduct so-called "meadow restoration" treatments. 

Horse Creek Meadow Wildlife Area will be subjected to heavy industrial logging both in the meadow itself and in the forest surrounding the meadow.
The Forest Service is using aerial imagery from 1940 as a "reference ecosystem" despite eighty years of mining, logging, ranching and boom towns in the Briggs Creek watershed. They are using post-settlement era aerial photographs to define the extent of meadow habitats and have proposed to recreate them with "meadow restoration" treatments. The concept is that fire suppression has led to a decrease in meadow habitat due to conifer and shrub encroachment. Unfortunately, it was settlement and land clearing that may have accentuated these large meadows in the historic  photos. 

The supposed meadow restoration treatments proposed in the Upper Briggs Restoration Project would clearcut large swaths of forest adjacent to existing meadow habitats in the Horse Creek Meadows Wildlife Area and around Sam Brown Campground. The proposal also advocates logging all trees within the meadows that are less than 120 years old. 

Klamath Forest Alliance supports non-commercial meadow restoration measures that may include non-commercial thinning, prescribed fire, invasive plant removal, and native pollinator plant restoration. 

Beautiful old forest proposed for logging on the Secret Way Trail in unit 23B.
The project also includes units in beautiful, fire resistant, old-growth and late successional forest habitats on Myers Creek, Secret Creek, and Horse Creek. These forests contain important habitat for the Northern spotted owl and its primary prey source, the red tree vole. Some of the units also contain robust populations of the rare clustered lady's slipper (Cypripedium fasciculatum). Other units are located on popular recreational hiking, equestrian and mountain biking trails, including the Taylor Creek Trail, Onion Way Trail and Secret Way Trail. Logging these stands will degrade important late successional habitat, impact rare plant habitat, and damage beautiful recreational trails. 

What do you prefer? Camping and hiking among old-growth forests and beautiful mountain meadows, or stumpfields disguised as "restoration?"
These gorgeous meadows surrounding the Sam Brown Campground would be heavily logged in the Upper Briggs Restoration Project. The project calls for removing all trees less than 120 years old both in the meadow and in the forest at the meadow margin. According to Forest Service prescriptions, all conifers in this photograph would likely be removed. Leaving a stumpfield to surround the meadows and the campground.

Please consider commenting on the Upper Briggs Restoration Project Environmental Assessment. The comment period ends on May 31, 2018.

Send your comments to:  

Upper Briggs Restoration Project Talking Points:
  • Cancel all proposed logging units in old-growth or late successional forest habitats including units 2, 9, 20, 21, 22, 23, 23b, 23c, 55 & 70.
  • Cancel logging units with large populations of the rare clustered lady's slipper orchid, including units 21 and 22. 
  • Do not implement meadow restoration that logs trees within or surrounding mountain meadows or campgrounds. Institute non-commercial meadow restoration treatments instead.
  • Do not approve the Red Tree Vole Habitat Conservation Plan and maintain all current protections for the red tree vole, including site protection measures and pre-disturbance surveys.
  • Do not downgrade Northern spotted owl habitat. 
  • Logging the Horse Creek Meadow Wildlife Area and Sam Brown Meadow in Meadow Restoration Treatments is inconsistent with the mandates of the Siskiyou National Forest Plan. 
  • Cancel all new road construction proposed in the Upper Briggs Restoration Project. 
  • Do not implement Oak-Pine Restoration Treatments in Douglas fir plant associations. The proposal will create novel forest conditions and is not restorative in nature.  

Wednesday, May 16, 2018

The Wellington Butte Roadless Area: A Wilderness at Our Backdoor

A view down the Balls Branch of Humbug Creek into the Applegate Valley.
The Wellington Butte Roadless Area is one of the most wild, spectacular, and threatened landscapes in the foothills of the Applegate Valley. It is also perhaps the most accessible wildland in the Applegate Watershed, with immense conservation and recreational opportunities

The region contains a diverse mosaic of plant communities, including sweeping grasslands, dense chaparral, sunlit oak woodlands, intact conifer forests and beautiful, mixed-hardwood stands dominated by madrone.
A flush of annual lupine blooming at the headwaters of the Balls Branch of Humbug Creek.
Spring has arrived in the Wellington Butte Roadless Area, and the slopes are currently ablaze with the colors of spring, buzzing with busy bees, fluttering butterflies, pollinating flies and beetles. Song birds chirp and sing, happily foraging for insects and seeds on the steep mountain slopes and in the brushy chaparral. Deer graze on the fresh grasses and black bear have awakened from their winter semi-hibernation. Lizards dart across the rocky outcrops and snakes slither through the grasslands eating insects, voles, and mice. It is a time of abundance and beauty in the Wellington Butte Roadless Area.

Spring wildflowers abound and fresh green oak leaves have emerged in the Balls Branch of Humbug Creek.
Although the scenery is pleasant and peaceful, the wildlife continue their seasonal patterns and wildflowers bloom as they have for millennia, the future of the Wellington Butte Roadless Area is uncertain. The wild landscape we know and love today could be lost forever.

The Wellington Butte Roadless Area was originally proposed for protection as a Land With Wilderness Characteristics (LWC) in the BLM's 2016 Draft Resource Management Plan (RMP). This designation would have provided minimal, but important interim protections and highlighted the area's wilderness qualities. 

Although the area met all the requirements for LWC designation and is one of the most well-known and well-loved wildlands in the Applegate Valley, the agency withdrew the area from consideration due to scattered stands of marketable timber among a vast mosaic of arid grassland, chaparral, oak woodland, mixed hardwood stands and dry, widely dispersed forest. The only real timber is located in the Deadhorse Fork of Balls Branch (a tributary of Humbug Creek) and Long Gulch, far from any roads, in deep canyons, riparian areas and north-facing slopes. 

The north-facing slopes and canyon bottom of the Deadhorse Fork is likely the largest concentration of uncut forest in the Wellington Butte Roadless Area.
Despite significant public support for protection of the Wellington Butte Roadless Area, the BLM has instead responded by opening portions of the area to off-road vehicle use, and is now proposing the massive Middle Applegate Timber Sale, in and around the Wellington Butte Roadless Area.

The Middle Applegate Timber Sale is a large, landscape-scale timber sale proposed by the Medford District BLM. Although the BLM has not yet released an official proposal, the planning area extends across the Middle Applegate watershed from Forest Creek in the east, to Slagle Creek on the west. As proposed, the timber sale could sprawl across the mountains of the Applegate Valley from the town of Ruch, to beyond the town of Applegate. At the center of the planning area is the Wellington Butte Roadless Area, and to date, BLM has refused to removed the area from consideration in the Middle Applegate Timber Sale. 
Beyond the large grasslands, on the north-facing slopes of Balls Branch and the Deadhorse Fork, is the largest concentration of forest in the Wellington Butte Roadless Area. Residents of the Applegate Valley and conservationists across southern Oregon urge the BLM to withdraw the Wellington Butte Roadless Area from the Middle Applegate Timber Sale.

The social and ecologic cost of removing timber from this area is extremely high, while the quality of timber and the regenerative capacity of the land in question is very low. It is abundantly clear that these wildlands and their minimal timber values are better suited for conservation than timber production, yet BLM pushes forward with plans to log some of the last intact landscapes in the Middle Applegate watershed.

 In early 2017 the Medford District BLM also approved a very controversial Categorical Exclusion (CE) — which means the public was "categorically" excluded from the decision making process — to provide defacto designation of 65 miles of previously unauthorized and illegally built off-road vehicle trails in the John's Peak OHV Area, including the Wellington Butte Roadless Area. They also approved the utilization of public funds and public agency crews or contractors to maintain off-road vehicle trails that have never received formal approval, are creating significant environmental impacts and have never been subjected to the NEPA process or public review. Despite over two decades of significant controversy surrounding the John's Peak OHV Area, the BLM made the decision without a public comment period or public review process. They simply did not want to hear what we had to say. 

The Medford District BLM is effectively encouraging illegal off-road vehicle trail creation and giving large tracks of land to off-road vehicle interests to utilize for their exclusive benefit, including the Wellington Butte Roadless Area. For decades, the BLM has turned a blind eye to unauthorized off-road vehicle activity and now they are codifying this unauthorized use and excluding the public from the process. The implications for the Wellington Butte Roadless Area are severe and eventually off-road vehicle trails could extend across the most remote portions of the region.
The spectacular wildflower fields of the Wellington Butte Roadless Area should be protected from off-road vehicle use.

If the BLM has their way, the Wellington Butte Roadless Area will be lost forever — the wild character replaced with logging roads, log landings, noxious weeds, stump fields and erosive dirt bike tracks.

Fortunately, residents in the area and local environmental organizations have begun tracking the Middle Applegate Timber Sale and are asking the BLM to remove the entire Wellington Butte Roadless Area from the planning area. We ask that the BLM remove the Wellington Butte Roadless Area from the planning area due to significant public controversy, incredible biological values, highly important low-elevation wildlife habitat, and marginal timber values. 

We also ask that the BLM rescind their recent Categorical Exclusion to allow maintenance of unauthorized  OHV trails in the Wellington Butte Roadless Area, and instead conduct Travel Management Planning as required in the 2016 RMP. 

Finally, Applegate Neighborhood Network, Klamath Forest Alliance and others in the conservation community are organizing a campaign to permanently protect the Wellington Butte Roadless Area. We believe the interim LWC designation should be extended to the entire 7,527 acre Roadless Area, creating the Wellington Butte Lands with Wilderness Characteristics. We also believe local advocates for the Wellington Butte Roadless Area should build a movement towards permanent Wilderness designation for the Applegate Foothills Wilderness, including its most threatened wildland: the Wellington Butte Roadless Area. 

Snowy or cobweb thistle (Cirsium occidentale) blooming on Balls Branch.
In all, nearly 50,000 acres of intact, roadless habitat exists in the foothills of the Applegate Valley. The wildlands are found scattered around the Applegate. They provide the scenic backdrop to our region; they provide incredible wildlife habitat and contain unique native plant communities, and they also provide highly important recreational opportunities in close proximity to nearby towns and communities. Additionally, the Wellington Butte Roadless Area will one day be traversed by the proposed Applegate Ridge Trail, providing highly accessible and highly scenic recreational opportunities for local hikers and equestrians.

We believe that the Applegate Foothills Wilderness should be protected in perpetuity. We also believe the protection of the Wellington Butte Roadless Area is the first step in this process. This uniquely accessible wildland, its scenic beauty and intact habitats are worth far more as they are. We will not let them become another BLM stumpfield riddled in off-road vehicle tracks. Please join us and advocate for the protection of the Wellington Butte Roadless Area!

The Wellington Butte Roadless Area should remain wild for generations to come.

Friday, May 11, 2018

Proposed Logging Along the PCT at Cook and Green Pass!

Proposed logging along the PCT at Cook and Green Pass. The hiker at the right-hand side of the photograph is hiking the PCT, and the Klamath National Forest is proposing to log directly into the trail corridor. Trees marked blue would be logged.
The Klamath National Forest has proposed a large, post-fire logging project in the 2017 Abney Fire footprint. The project would log over 1,200 acres of fire-affected forest in the region surrounding Cook and Green Pass. The project also proposes post-fire logging directly adjacent to the Pacific Crest Trail (PCT) and along the Bee Camp Road (47N80) in the Kangaroo Inventoried Roadless Area. 

Cook and Green Pass is the gateway to the Red Buttes Wilderness Area, the Kangaroo Inventoried Roadless Area and the Condrey Mountain Roadless Area, it is also located within a major connectivity corridor necessary for the dispersal of wildlife and native vegetation in the region — connecting the Marble Mountains and Klamath River area to the Siskiyou Mountains. The area is protected by multiple Botanical Areas and is thought to be one of the most diverse assemblages of native plants in all of California, with over 300 plant species documented. Many rare plant species can be found in the area, including Baker's cypress, Brewer's spruce, mountain lady slipper, splithair paintbrush, Newberry's gentian, Siskiyou fritillaria, Howell's lousewort, white flowered rein orchid and many others. The area contains many important biological values and should be protected for its own sake. It should also be protected for its important recreational values. 
Large, old trees marked for removal along the PCT at Cook and Green Pass.

Recently, the Klamath National Forest began marking timber along Bee Camp Road in a so-called roadside hazard logging unit. The proposal includes logging roughly two miles of Bee Camp Road, including portions of the Kangaroo Inventoried Roadless Area. Some of the logging will occur at Cook and Green Pass in old-growth forests that survived the Abney Fire. Both live trees and dead standing snags are marked for removal.

The logging would impact the Pacific Crest Trail by logging old-growth trees and snags within 30' of the trail and hundreds of feet on either side of Bee Camp Road. Currently, backcountry hikers heading west on the PCT at Cook and Green Pass enter the Kangaroo Inventoried Roadless Area in an isolated stand of old-growth forest before traversing the vast, red rock, serpentine barrens surrounding Red Butte. The experience is memorable and demonstrates the diversity of the Siskiyou Mountains, it will also be significantly degraded by old-growth roadside hazard logging.
A live, green tree marked for removal.

The Klamath National Forest's proposal to conduct "roadside hazard logging" on the PCT and in the Kangaroo Inventoried Roadless Area should be canceled. Bee Camp Road should be closed at Cook and Green Pass to protect connectivity, botanical resources, roadless values and recreational opportunities along the PCT. Close Bee Camp Road!

Please contact Forest Supervisor Patricia Grantham and ask her to cancel post-fire logging along Bee Camp Road (47N80) and close the road at Cook and Green Pass. 

Forest Supervisor Patricia Grantham:

Complex, old-growth forest proposed for logging in the Kangaroo Inventoried Roadless Area and directly adjacent to the PCT at Cook and Green Pass.