The Siskiyou Crest : Keep the Klamath River Wild!

Westside Fire Recovery Project Draft Environmental Impact Statement (DEIS) Public Comment Period

Low-severity fire from the Happy Camp Fire Complex in the Marble Mountain Wilderness at the headwaters of Wooley Creek, one of northern California's wildest old-growth habitats.

This past summer three large fires — the Happy Camp, Whites and Beaver Fires — burned over 218,600 acres in the Klamath River watershed. The Happy Camp and Whites Fires burned in a natural mosaic, including over 70% low to very low severity fire. These fires burned in roadless wildlands, Late Successional Reserves (LSR), botanical areas, logged-over matrix lands, and both the Russian and Marble Mountain Wilderness Areas. The Beaver Fire, on the other hand, burned in forests largely converted to tree plantations, large portions of which are private timber land. Consequently, the fire severity was highest in the Beaver Fire, with 40% of the fire area effected by high severity fire; nearly double that of the Whites or Happy Camp Fires.

Many private timber lands supporting plantation stands burned at high severity in the Beaver Fire. The Westside Fire Recovery Project proposes to create tens of thousands of plantation stands through salvage logging and tree planting, both activities that will impair natural recovery and increase fuel hazards in the post-fire landscape.

The Klamath National Forest has responded to these fires by proposing the Westside Fire Recovery Project, a massive "salvage" logging project that would convert tens of thousands of acres into highly flammable tree plantations. The Draft Environmental Impact Statement (DEIS) has been released and the agency is accepting public comment until April 27, 2015.

Although the agency is calling this a "recovery project," it is unclear what the project will recover beyond timber volume (i.e. financial recovery) through clear-cut salvage logging in fire-effected forests. The clear-cut logging and conversion of fire-effected stands into tree plantations will not only drastically increase fire hazards, but will also significantly impact watershed values, at-risk salmon populations, wildlife, natural forest habitats, post-fire recovery and old-growth forest reserves.

Naturally regenerating post-fire habitat in the Kalmiopsis Wilderness Area. This area was effected by high severity fire, but was not salvage logged in the Biscuit Fire Recovery Project.

This stand, directly adjacent to the photo above, was salvage logged in the Biscuit Fire Recovery Project.

The Proposed Action is identified as Alternative 2 in the Draft Environmental Impact Statement. Alternative 2 proposes 11,700 acres of salvage logging, the majority of which would be clear-cut logging. The proposal includes roadside hazard logging on 650 miles of road, equaling 16,600 acres of linear clear-cuts along Forest Service roads. In past salvage logging projects the agency has logged 200' swaths on both sides of the road; however, in the Westside Project, the agency now proposes widening the logged area to 250' on either side of the road, making a 500' swath of clear-cut forest that winds across 650 miles of road on the Klamath National Forest. The project would also build 23 miles of "temporary" roads to facilitate salvage logging. Conversely, those units not accessed by roads will be helicopter logged, a logging system that the agency admits will create the largest fire hazard due to a significant increase in logging slash.

The proposal includes significant impacts to sensitive wildlife species, including the removal of 1,205 acres of nesting, roosting, and foraging habitat for the northern spotted owl. There will also be impacts to bald eagle nesting sites, connectivity and home range habitat for the Pacific fisher, marten, and wolverine, as well impacts to key watersheds and highly erosive watersheds such as Elk Creek, Grider Creek, Tompkins Creek, and other salmon bearing tributaries of the Klamath, Salmon, and Scott Rivers.

The Klamath National Forest has declared an “emergency situation determination” to expedite clear-cut logging and reduce the public’s and non-profit organizations’ abilities to appeal, protest, or litigate the project before cutting begins. The agency has fast-tracked large-scale logging in the Klamath River watershed in LSRs, key watersheds, and geologically unstable areas, and they apparently don’t want to hear what you have to say about it. Perhaps they should hear loud and clear why many in the local bioregion value the Klamath River, its forests, wildlife, and fisheries. Please consider commenting on the project; we need your support to stop one of the largest salvage logging proposals in the Klamath Mountains since the equally dishonest misnomer, the Biscuit Fire Recovery Project, which came out of the 2002 Biscuit Fire in the Kalmiopsis area.

Is this what "recovery" looks like? The result of salvage logging and road building at the Babyfoot Lake Trailhead following the Biscuit Fire of 2002. The Rogue River-Siskiyou National Forest salvage logged this once magnificent old-growth forest, illegally cutting within the Babyfoot Lake Botanical Area and to the edge of the Kalmiopsis Wilderness Area.

Consider the following recommendations when providing public comment on the Westside Fire Recovery Project.

· No salvage logging on sensitive granitic soils, active landslides, earth flows, geologic riparian reserves, and other erosive soil types.

· No salvage and/or no tree planting units in Late Successional Reserves.

· No salvage units in Riparian Reserves.

· No salvage units in special habitat designations such as northern spotted owl (NSO) activity centers, peregrine falcon or goshawk activity centers.

· No salvage units in Bald Eagle Management Areas.

· No salvage in Critical Habitat for NSO.

· No salvage logging in designated or recommended Wild and Scenic River segments including N. Fork Salmon River, Grider Creek, Elk Creek, Klamath River, and S. Russian Creek.

· No salvage units in the Grider Creek drainage to protect roadless values, watershed values, scenic values — such as the Pacific Crest Trail (PCT) — and connectivity between the Marble Mountains Wilderness and the adjacent LSRs.

· No salvage units should be proposed in the following watersheds or areas to protect ecological values, scenic values, and recreational qualities within and adjacent to large Inventoried Roadless Areas or Wilderness Areas. This would include the following areas:

Happy Camp Fire: Grider Creek, N. Fork Kelsey Creek, McGuffy Creek, McCarthy Creek, Kuntz Creek, Mill Creek, Tom Martin Creek, Tom Martin Peak Area, Lake Mountain Botanical Area, Tyler Meadows Trailhead, Pacific Crest Trail, Cold Spring Trailhead.

Whites Fire: E. Fork Whites Gulch, Sixmile Creek, South Russian Creek, Tanners Peak area

· No salvage units in endemic or rare conifer stands (and their adjacent available habitat) to allow for natural regeneration. This would include foxtail pine (Pinus balfouriana), Baker’s cypress (Cupressus bakeri), and Brewer spruce (Picea breweriana).

· No new roads, either permanent or temporary.

· No tree planting units; natural regeneration is adequate due to generally small patch size from high severity fire effects. Seed trees are nearly always present and regeneration adequate. Plantation style planting will only increase future fire hazard and should be avoided at all costs.

· No helicopter units. Activity slash left from helicopter units is very difficult to cleanup and will increase fire activity in future fires. Likewise, the economics of helicopter logging necessitates the removal of large, old trees and snags.

· No salvage logging should take place in partially burned stands that sustained minimal (less than 70%) mortality. Undamaged or partially fire damaged stands provide disproportionately important roles in ecological recovery and refugia for the survival of particular biota.

· No salvage logging in high elevation sites above 6,000’, including mountain hemlock (Tsuga mertensiana), red fir (Abies magnifica), and white fir (Abies concolor) plant communities. These habitat types are adapted to long fire return intervals and relatively high severity fire effects. Scattered snag patches are natural, and due to the landscape location and short growing season, will recover slowly and create minimal fuels as succession takes place.

· Retain all trees with green foliage. No “bycatch” logging of green trees should occur in any salvage unit.

· No salvage units on slopes exceeding 60%

· Burn all activity slash.