Wednesday, May 10, 2017

Post-Fire Logging on the Siskiyou Crest

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

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

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

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

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

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

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

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

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

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

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

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

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

Tuesday, April 25, 2017

The BLM's Great OHV Trail Giveaway

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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


Friday, April 7, 2017

Progress on Pickett West, But Still More To Do...

A view across the Pickett West Planning Area and the town of Murphy, Oregon. The BLM has proposed a large timber sale in the mountains around Murphy and many other rural communities including Galice, Merlin, Selma, Applegate and Wilderville.
The Pickett West Timber Sale sprawls across a vast 200,000-acre planning area, from Merlin and Galice on the Rogue River, to Wilderville and Selma on Highway 199. Units are located on Deer Creek, Slate Creek, Cheney Creek, above North Applegate Road and surrounding the town of Murphy, Oregon. The Pickett West Timber Sale has the potential to leave a lasting impact on an enormous geographic area. The Applegate Neighborhood Network (ANN), Klamath Forest Alliance (KFA) and other conservation partners have been working for the past six months to minimize or eliminate those impacts by encouraging the BLM to amend their plans and consider a Community Alternative that protects wild habitats, maintains important wildlife habitat, reduces fuel loading, encourages forest health, and addresses the needs of the nearby community.


The Grants Pass BLM originally proposed "regeneration" logging in the Pickett West Timber Sale. Regeneration logging is a euphemism for clearcut logging, and although it sounds better, the end result is very similar. Stands 150-years and older are targeted for "regeneration" by removing the majority of the overstory canopy, substituting mature, fire-resistant trees, for young, dense regeneration triggered by canopy removal and ground disturbance associated with timber yarding practices. Regeneration logging would retain only 16-25 trees per acre, and less than 30% canopy cover. Due to pressure from ANN, KFA and others in the conservation community, all regeneration logging has been cancelled in the Pickett West Timber Sale.

The BLM also originally proposed over 3,000 acres of logging in forest designated as a Late Successional Reserve (LSR). LSR forest is set aside to protect and maintain old-growth habitat and characteristics for species such as the Pacific fisher and the Northern spotted owl. ANN, KFA and others opposed commercial logging in LSR forest. Recently, the BLM has dropped all units located in LSR forest in the Pickett West planning area.

The BLM has also announced they will fully analyze the Community Alternative submitted by ANN as Alternative 3 in the Pickett West Environmental Assessment. The Community Alternative protects wildlands, old-growth and late-seral forest, water quality, and large, old trees over 21" in diameter. The Community Alternative would build no new roads and it maintains all northern spotted owl habitat designations. It also protects the proposed corridor of the Applegate Ridge Trail by deferring or amending units that would impact the experience of recreational trail users. The Community Alternative also serves to promote community and ecological values while encouraging forest health and resilience. In the Community Alternative, timber production is truly a by-product of restorative land management, rather than the driving force behind proposed prescriptions. We encourage folks to publicly support the Community Alternative. If implemented with integrity, Alternative 3 is a win-win alternative that will ensure the quality of life and habitat in southern Oregon is maintained.
Old-growth forest in the Cheney Creek watershed has been proposed for logging in the BLM's Alternative 2. The unit would be canceled in the Community Alternative to protect the ecological value of this ancient mixed-conifer forest.

The Threat Continues...

Although the BLM will consider the Community Alternative for implementation in the upcoming Environmental Assessment (EA), the agency is also considering the BLM's Alternative 2. Many in the environmental community are actively opposing Alternative 2, while embracing the Community Alternative, Alternative 3. The BLM's Alternative 2 proposes to log late-seral and old-growth stands dominated by large, old trees. It will also impact the proposed Applegate Ridge Trail and build many, many miles of "temporary" road. 

Many swales, seasonal wetlands and streams will be impacted by the proposed new road construction.

Another euphemism, "temporary road," is anything but temporary. Developing "temporary roads" has lasting impacts to the land and our waterways. In many situations new road construction will take place in riparian reserves and will include stream crossings. "Temporary roads" create real sediment and turbidity in important salmon strongholds like the Rogue River, the Applegate River, the Illinois River, Deer Creek, Slate Creek and Cheney Creek. Temporary roads will increase opportunities for unauthorized OHV use, which will further exaggerate the issue of sedimentation and turbidity. Temporary roads will also spread noxious weeds, impact native plant communities and scar otherwise undisturbed public lands. A few sections of new, temporary road are proposed to be constructed in the proposed trail corridor of the Applegate Ridge Trail, significantly degrading the non-motorized trail experience. Another large portion of temporary road will be built through unique low-elevation serpentine woodland and prime pollinator habitat on Southside Road. Numerous seasonal wetlands, streams and riparian reserves will be crossed with temporary roads, creating chronic sedimentation concerns. Unique and intact native plant communities filled with spring flowers will be bulldozed to access commercial timber to the southeast. Significant new roads will be constructed to access uncut timber in the mountains above North Applegate Road on Oscar Gulch. New roads will be constructed by the BLM near the Wild and Scenic Rogue River, on tributary streams that feed into Hellgate Canyon,

Old-growth forest adjacent to the Applegate Ridge Trail is proposed for logging at the headwaters of Rocky Gulch.
Numerous commercial timber sale units are located within the corridor of the proposed Applegate Ridge Trail, including the spectacular old-growth forest at the headwaters of Rocky Gulch. Other units are proposed in fire resilient and/or old-growth stands, including the large Rocky Gulch unit, units on lower Chency Creek, near Fort Hay, above the Rogue River and on lower Deer Creek.

ANN and KFA will be working to not only support the Pickett West Community Alternative (Alternative 3), but we will also be working to oppose those portions of the BLM's proposal (Alternative 2) that will degrade our environment, recreational opportunities, fisheries and quality of life. Please stay tuned for more information on the Pickett West Timber Sale, opportunities to influence the process and comment on the upcoming Environmental Assessment.

For now, please contact Grants Pass District Manager Allen Bollschweiler with the following requests.
Contact for District Manager Allen Bollschweiler:
  • Do not build new roads, temporary or permanent in the Pickett West Planning Area, especially within Riparian Reserves. Road density is already very high in numerous watersheds in the Pickett West Area.
  • Do not build temporary roads on or near the proposed corridor of the Applegate Ridge Trail.
  • Maintain all Northern spotted owl habitat designations in the Pickett West Planning Area.
  • Institute a 21" diameter limit for tree removal.
  • Defer units in fire resilient, late-seral or old-growth forest stands.
Incredible botanical resources and pollinator habitat on unique low-elevation serpentine soils will be impacted by new road construction on Southside Road.

Sunday, February 26, 2017

Comment Now! Siskiyou Crest Public Lands Grazing

Public lands grazing is impacting important high-elevation habitat for native pollinators and other wildlife, while creating erosion and water quality issues that have long-lasting impacts.

Siskiyou Crest Public Lands Grazing 
Have you backpacked on the PCT on the Siskiyou Crest and stopped to filter water from a spring or creek, only to find a big cow pie in the water and the smell of cow urine wafting in the air? Are you a butterfly or native bee enthusiast that cringes every time you see a productive wildflower meadow turned from pollinator paradise into a mowed down feedlot for cows? Are you a hunter that finds more forage and habitat consumed by cows than is available to elk or deer? Or are you birder who watches willow flycatcher habitat disappear on the Siskiyou Crest from cattle impacts in the flycatcher's sensitive riparian habitat?

Now is your chance to have your opinion regarding public lands grazing in the Siskiyou Mountains heard! The River-Siskiyou National Forest, Siskiyou Mountains Ranger District is beginning an Environmental Analysis (EA) process to update four grazing allotments in the Siskiyou Mountains.

Applegate Grazing Complex  

Cows damage sensitive dryland habitat on the Siskiyou Crest.
Applegate Grazing Complex
The proposed plan is to update four Allotment Management Plans (AMPs), collectively referred to as the Applegate Grazing Complex, including: Beaver-Silver, Carberry Creek, Elliott Creek, and Upper Big Applegate. The four allotments span across the vast majority of the Upper Applegate and Little Applegate watersheds, affecting hydrology, water quality, wildlife habitat, botanical values, roadless areas and pollinator habitat. The impacts are immense, widespread and far outweigh the benefit of providing income to a handful of ranchers.

The Forest Service issued the Scoping Notice for the EA on February 16, 2107 and they are currently accepting public comments during the 30-day public comment period. The Scoping Notice states: "The purpose of updating the AMPs is to consider the reauthorization of livestock grazing on the four allotments. The intent of the reauthorization is to provide the Forest Service and permittees with an updated legal document that defines how livestock grazing will be managed. Grazing on the allotments have generally been permitted since the early 1900s. This effort would ensure updated information is provided for the sustained health of rangeland and forest ecosystems.

The AMPs for these allotments have not been updated since the 1960s; an evaluation of the condition and trends of vegetation and soils within the allotments needs to be conducted. Based on the results of the evaluation, the Forest Service wold either allow for continued permitted grazing for the established numbers and seasons, adjust the permitted numbers and seasons allowable for grazing, or discontinue the permitted grazing. The analysis would provide updated information that reflects current management direction and resource objectives. Updated AMPs would provide direction that maintain or improve vegetation and riparian conditions through effective livestock management while providing for other uses."

Visible on the right of this photo are historic terraces created by the Forest Service to reduce erosion from overgrazing in the Silver Fork Basin on the Siskiyou Crest at the headwaters of Elliott Creek. Forest Service documents confirm that as early as 1918 Silver Fork Basin was badly overgrazed; unfortunately, impacts from grazing continue in Silver Fork Basin.

The Times They Are A'-Changin
As the scoping notice states, the last time these allotments were updated the Vietnam War raged on, the Beatles, Bob Dylan and the Rolling Stones were the most popular musicians, and no human had yet been to the moon — it's time to bring these grazing allotments in line with current science, ecological knowledge, and societal values. A lot has changed since the 1960s! Unfortunately, little has changed in regard to grazing management on the Siskiyou Crest.

Bovine bulldozers denude important meadow habitat for
declining native pollinator species on the Siskiyou Crest.
Impacts of Public Lands Grazing on the Siskiyou Crest
The Applegate Grazing Complex is located in Upper and Little Applegate watersheds and extends from the low elevation foothills to the high country of the Siskiyou Crest where most of the cows stay for the summer. Cattle routinely reach the Siskiyou Crest before the approved grazing season has begun and are often left to graze later in the season than is allowed under the current AMP, creating severe impacts and over-utilization of forage resources.

The grazing strategy currently employed is referred to as "passive season long grazing," meaning little, if any, management occurs once the cows are placed on federal land. The cows simply manage themselves and congregate at preferred "pastures" in high-elevation wet meadows doing great damage to wetlands, streams and sensitive meadow habitat. Many sensitive habitats are being degraded or denuded by cows. Forage resources (grasses, forbs and shrubby growth) are being over-utilized by grazing cattle, leaving little for native elk and deer who prefer many of the same locations. Numerous springs, streams, wet meadows, and lakes that support populations of rare and sensitive plant species occur within the Applegate Grazing Complex.

According to government recommendations for livestock grazing and pollinator health, "Livestock grazing alters the structure, diversity, and growth pattern of vegetation, which affects the associated insect community. Grazing during a time when flowers are already scarce may result in insufficient forage for pollinators. Grazing when butterfly larvae are active on host plants can result in larval mortality and high intensity grazing can cause local loss of forb abundance and diversity."

Much of the most intensive grazing occurs in designated Botanical Areas, established to protect botanical values; instead, many of these areas are heavily degraded by grazing cattle. Rare plant populations are being impacted by public land grazing and the intact habitats identified by the Forest Service for Botanical Area protection are being compacted, denuded,  and mowed to the ground by unmanaged cattle grazing. Eight Botanical Areas are included within the Applegate Grazing Complex allotment boundaries: Big Red Mountain, Dutchman's Peak, Observation Peak, Scraggy Mountain, White Mountain, Cook and Green Pass, Whisky Peak and Hinkle Lake.

Roadless Areas at the headwaters of the Applegate River are also being negatively impacted. Roadless areas within the allotment boundaries include: Big Red Mountain, Glade Creek, Observation Peak, Condrey Mountain, Kangaroo, and Whisky Peak. Low elevation roadless areas, including the Little Greyback, Collings-Kinney, Elliott Ridge and Boaz Mountain Roadless Areas would also be impacted by proposals to release cattle at lower elevations, allowing cattle to migrate upward as the snow melts. The release of cattle at the lower end of Mule Creek, Palmer Creek and Beaver Creek — all fish bearing streams — is proposed under the Applegate Grazing Complex Scoping.

The proposal also includes grazing in the Red Buttes Wilderness, the largest intact wildland habitat in the Applegate River watershed. It has been many years since the Red Buttes Wilderness has been actively grazed.

Low grazing fees leave the federal government with a deficit
for administering public land grazing.
Welfare Ranching
The Federal grazing fee for 2017 is $1.87 per animal unit month (AUM). An AUM is the use of public lands by one cow and her calf. This irresponsibly low fee leaves the federal government with a large fiscal deficit for administering public land grazing, and leaves the American people with degraded water quality, wildlife habitat, soil productivity, floral resources for dwindling pollinator populations, etc. It's a lose-lose situation for everyone but a handful of ranchers.

Typically, grazing fees cover only a fraction of the cost of administering the allotment, and roughly half of the money received by the federal government goes back into "rangeland improvements" meant to facilitate grazing and mitigate the impacts. Thus, the public is paying a high price to subsidize the destruction of our headwater streams and the fouling of our pristine water sources.  The permittees make an easy buck while the public is stuck with the cost of restoration and mitigation

AUM breakdown for the Applegate Grazing Complex

Grass-fed cattle can sell for anywhere between $1,200-$1,700 dollars on the market.

Cow manure and trampled wetland habitat on the Siskiyou Crest.
Provide a Public Comment on the Applegate Grazing Complex
Applegate Grazing Complex Scoping comments are due on March 18, 2017.

Written comments can be sent to:
Donna Mickley, District Ranger, c/o Greta Smith, at 6941 Upper Applegate Road, Jacksonville, Oregon 97530.

Electronic comments may be submitted to:

For further information about the project contact Mark Hocken, Project Team Leader, Siskiyou Mountains Ranger District: or via phone: 541-899-3830.

Sample Scoping Comment

Re: Applegate Grazing Complex Scoping Comment 
Attention: District Ranger Donna Mickley c/o Greta Smith
6941 Upper Applegate Road
Jacksonville, Oregon 97530

The Applegate Grazing Complex is a very significant land management project, encompassing vast acreages of federal land and creating both direct and indirect impacts across the Applegate River watershed and the Siskiyou Crest. Federal land livestock grazing is associated with widespread impacts to riparian areas, water quality, wetlands, fisheries, hydrology, native plant habitat, rare plant habitat, wildlife habitat and pollinator habitat. The scope and scale of the project requires an Environmental Impact Statement (EIS), rather than a less comprehensive Environmental Assessment (EA). 

The Siskiyou Crest is a botanical wonderland and a regionally important connectivity corridor. It is one of the most significant concentrations of biological diversity on the West Coast of North America. For many years this botanical paradise has been subjected to severe overgrazing. Please consider the following substantive issues in the upcoming NEPA analysis for the Applegate Grazing Complex.
  • Consider discontinuing grazing allotments on the Siskiyou Crest, especially in allotments that are not currently meeting water quality standards; in allotments that have severe stream/wetland degradation; in allotments that have significant impacts to Botanical Areas and botanical values; and in allotments that create conflicts with other appropriate uses like the Pacific Crest Trail.
  • End "passive season long grazing" on the Siskiyou Crest and require all permittees to actively herd cattle from "pasture" to "pasture." Do not allow cattle to congregate in preferred locations for more than 14 days.
  • As part of the environmental review, it is essential that qualified Forest Service specialists assess stream, wetland and meadow conditions in order to determine and disclose whether streams, wetlands and meadows are functioning properly ecologically. If there are streams, wetlands and meadows on these allotments which are not functioning properly, Forest Service  managers must determine how cattle grazing is impacting properly functioning condition and adjust grazing practices, including the number of livestock allowed to graze, the season of grazing at different elevations, and the grazing system that will be used to end the degradation and return streams, wetlands and meadows to properly functioning ecological condition.
  • Stream, riparian and wetland exclosures should be established, and where they have been removed, they should be restored. Livestock exclosures are the only valid method to determine if grazing is significantly altering the composition and structure of riparian and wetland vegetation.
  • Analysis must identify all provisions of the Clean Water Act that apply to the grazing allotments and require all grazing allotments to be consistent with the mandates of the Clean Water Act.
  • Analysis must identify impacts to Botanical Areas and require that AMPs are consistent with Botanical Area designation.
  • Analysis must identify impacts associated with early season grazing along low-elevation stream corridors, especially along fish bearing streams such as Beaver Creek, Mule Creek, Palmer Creek and Kinney Creek.
  • Analysis must identify the impact of competition between cattle and the growing elk population on the Siskiyou Crest. Cattle numbers, seasonality of use, intensity of use and the lack of herding must address the issue of competition between cattle and elk for available forage resources.
  • Analysis must identify the existing condition of willow flycatcher habitat (an agency sensitive species) in the EA, document impacts associated with cattle grazing, and limit the number of cattle or seasonality of use to mitigate impacts to willow flycatcher habitat.
  • Implement the recommendations for Livestock Grazing written in the Federal publication, Pollinator-Friendly Best Management Practices for Federal Land. Utilize these guidelines for pollinator habitat and to identify impacts to pollinator habitat from grazing activities. Limit the number of cattle and seasonality of use to mitigate the impacts of grazing on pollinators. Special attention should be taken to restore, enhance and promote the maintenance of habitat for the Sierra blue butterfly (an agency sensitive species), Western bumble bee, Franklin's bumble bee, and the monarch butterfly.
  • Analyze the impact of historic grazing on dry bunchgrass habitat and in "cattle barrens" created by historic and contemporary overgrazing. Review the restoration of dry bunchgrass habitat in vacant or unused areas and compare them to areas that are actively grazed. Create guidelines within the AMPs to address the loss of historic dry bunchgrass habitat and the restoration of these communities due to non-use.  
          [your name and address]                                                                                                                            

Erosion and downcutting from overgrazed riparian areas
on the Siskiyou Crest.
2015 Siskiyou Crest Grazing Report
The Campaign to Reform Public Land Grazing in Northern California has created a must-read 2015 report on grazing allotments on the Siskiyou Crest. This is the most comprehensive report available that details the ecological impacts of public land grazing on the Siskiyou Crest.

Cows on the Siskiyou Crest
Cow Quotes
"Unlike a factory discharging waste through a pipe into a stream, livestock grazing impacts to water quality are non-point sources of water pollution. Other "non-point" sources include logging, road construction, road maintenance and recreation. Because activities which can cause "non-point source" water pollution are widespread across Western landscapes, they are difficult to regulate as compared to distinct "point sources" like sewage plants and factories. For that reason, regulation of non-point source pollution under the Clean Water Act has lagged far behind point source regulation. To control water pollution from non-point source activities like livestock grazing, regulators rely on public land managers and livestock owners to implement Best Management Practices (BMPs) which research and experience have shown are effective in controlling water pollution if applied correctly in the appropriate locations." -Campaign to Reform Public Land Grazing in Northern California

"The ecological costs of livestock grazing exceed that of any other western land use. In the arid West, livestock grazing is the most widespread cause of species endangerment. By destroying vegetation, damaging wildlife habitats and disrupting natural processes, livestock grazing wreaks ecological havoc...causing significant harm to species and the ecosystems on which they depend." -Center for Biological Diversity

"In the United States, livestock grazing has contributed to the listing of 22 percent of federal threatened and endangered species — almost equal to logging (12 percent) and mining (11 percent) combined. Nationwide, livestock grazing is the 4th major cause of species endangerment and the 2nd major cause of endangerment of plant species. No other human activity in the West is as responsible for the decline or loss of species as is livestock production." -Sierra Club Grassroots Network

"Explanation: Livestock grazing alters the structure, diversity, and growth pattern of vegetation, which affects the associated insect community. Grazing during a time when flowers are already scarce may result in insufficient forage for pollinators. Grazing when butterfly larvae are active on host plants can result in larval mortality and high intensity grazing can cause local loss of forb abundance and diversity." -Pollinator-Friendly Best Management Practices for Federal Land

Siskiyou Crest Public Lands Grazing Photo Essay

Cows within the Applegate Grazing Complex eat down available forage, depleting available food for native wildlife, especially elk populations that are struggling to repopulate the Siskiyou Mountains after being extirpated in the early 1900s. Notice that this intensively grazed area has been "over-utilized" and herbaceous species are not setting seed due to intensive cattle grazing.

Cows within the Applegate Grazing Complex trample wetland habitats and denude them of vegetation, impacting aquatic invertebrates, water quality, bird habitat, and creating massive soil compaction that has long-lasting hydrological impacts.

In many areas on the Siskiyou Crest, dry slopes are denuded of all vegetation by cows, eliminating important plants for wildlife and creating erosion. Dry bunchgrass meadows have been particularly hard hit on the Siskiyou Crest, creating "cattle barrens" devoid of vegetation.

Willow welands are important habitat for the willow flycatcher.  This photo demonstrates how cows within the Applegate Grazing Complex are destroying willow habitat in wetlands and along streams.

Cows within the Applegate Grazing Complex trample wetland habitats and denude them of vegetation, impacting aquatic invertebrates, water quality, bird habitat, and creating massive soil compaction that has long-lasting hydrological impacts.

Aspen is an uncommon tree species in the Siskiyou Mountains and within the Applegate Grazing Complex; however, cows are having a major impact on their ability to spread and survive. This photo demonstrates how cows are denuding the new shoots of aspen that are needed for their continued reproduction and survival. 

Cows within the Applegate Grazing Complex trample wetland habitats and denude them of vegetation, impacting aquatic invertebrates, water quality, bird habitat, and creating massive soil compaction that has long-lasting hydrological impacts.

A cattle exclusion fence on the Siskiyou Crest demonstrates the stark contrast between areas where cows are allowed to graze in wet meadows, and what that habitat would look like after a few years of cattle exclusion. 

Within the cattle exclusion fence the native plants are protected from overgrazing.  Marsh grass of parnassus (Parnassia palustris), a flowering wetland species, provides forage for native bees and other pollinators within the cattle exclusion fence. Outside the fence there are no flowers available for bee forage due to overgrazing.

Once overgrazed and barren like you see outside the fence, the area within the cattle exclusion fence has been allowed to heal and provide floral resources for native pollinators again.

The stark reality: Overgrazed versus recovering habitat where native plants can flower and go to seed, ensuring their survival and long-term presence in the area.

Cows on the Siskiyou Crest

Cows on the Siskiyou Crest

Cows on the Siskiyou Crest

Cows on the Siskiyou Crest

Saturday, January 28, 2017

Smokey the Bear Says: Resist!

Image: Alt US National Park Service

President Trump is now in the White House signing Executive Orders and taking unilateral actions to destroy the social fabric of our communities and the integrity of our environment. In my lifetime I have never seen a threat that is so widespread and comprehensive. As a community and as a nation we must stand up for freedom, respect and environmental responsibility. 

On January 21, 2017, millions of people around the world joined the Women's March in opposition to the Trump Administration and the Trump agenda. An estimated 8,000-10,000 people from southern Oregon and northern California showed up in sleepy, little Ashland, Oregon to protest Trump, his cabinet, and his agenda. It was the largest gathering of people of any kind in Ashland — ever! Across the continent and across the world people have begun to stand up and speak out against the corporate takeover of our country by Trump and his billionaire cronies. 

Trump has responded to the protests by signing Executive Orders and Memorandums that threaten the rights of women, immigrants and other disenfranchised people, and encourages the development of the Keystone XL, Dakota Access, and even the local Jordan Cove LNG pipeline here in southern Oregon. All these pipelines have been strongly opposed by local communities, affected landowners, tribal governments, and large numbers of the American population. Trump has also declared an open administrative war on climate science, removing information on climate change from government websites and has now imposed a "gag order" on the EPA, the Department of Agriculture, and the Department of Interior so they cannot publicly comment on the disastrous effects of Trump's new climate and energy policy. Although Trump avoids the media, stating that he would rather communicate directly with the people through Twitter and other forms of social media, other government agencies have been barred from such open lines of communication. 

Image: Alt US National Park Service
In response, the folks within the National Parks Service have gone rogue and are posting on Facebook and other sites in opposition to the Trump gag order. Our local government employees, who are entrusted with managing our public lands should do the same. Numerous websites, Facebook pages and twitter accounts have been posted on the web providing opportunities for National Park Service employees to speak out on their own personal time. Thus far, the coalition represents Arches, Shenandoah, Yosemite, Badlands, Yellowstone, Grand Canyon, Blue Ridge Parkway and Great Smokey National Parks. It is time for Crater Lake, Lava Beds and the Oregon Caves to get involved! Check out the Alternative US National Park Service Facebook page, website and twitter feed, support their resistance and encourage other government employees to stand up. As I write this post, government agencies, including the Forest Service, National Weather Service, EPA and others are joining in, forming unofficial twitter accounts to defy the Trump gag order.

Trump is essentially severing the ties between our government agencies and the public, harvesting mistrust and impacting our ability to create meaningful relationships, transparent planning processes and collaboration. Many wonder how this inability to openly communicate will impact local collaborative processes like the Applegate AMA, the Western Klamath Restoration Partnership, management of the newly expanded Cascade-Siskiyou National Monument,  and other federal land management projects heavily supported by local communities. These popular land management projects depend on open, transparent lines of communication, trust and respect between collaborative partners. It appears Trump is working hard to undermine these efforts, while quietly sacrificing our public lands to industrial interests. 

To make matters worse, Trump has instituted a hiring freeze on government employees. Trump's order, initiated on January 23, states, “no vacant positions existing at noon on January 22, 2017, may be filled and no new positions may be created, except in limited circumstances." Exceptions may be granted for reasons of "national security" and "public safety," although no one currently knows how these exemptions are being defined. The idea is to trim the federal workforce through attrition, despite that fact that since 1994 the Forest Service workforce has declined by 45%. Current staffing levels leave many important issues unaddressed and under Trump it will only get worse. Locally, it means positions such a botanists, wildlife biologists, recreation planners, and firefighting personnel cannot be hired by the Forest Service. 
Image: Alt US National Park Service
Together the gag order and hiring freeze further erodes the delicate trust developed between government agencies and local communities. Many wonder if agencies like our local Forest Service can continue collaborating with local communities and provide acceptable levels of transparency. Others are concerned that the local BLM, already puppets of the industry, will be encouraged to log off our natural legacy and ignore the concerns of our communities. The future is uncertain and as long as federal agencies and the public cannot communicate effectively, controversy, gridlock and litigation will prevail. Hiring freezes and gag orders are not solutions and will only bring more dysfunction to an already broken process and underfunded government agencies.

We are being thrust back into the era of corporate dominance, secretive government management and ineffective environmental regulations that will leave a lasting legacy of environmental destruction, impoverished local communities and devastated resource bases. In the short term, corporate and industrial interests will thrive; in the long term, we will all pay the price. Even Smokey the Bear says: "Resist." I for one will be happy to join him!

 Southern Oregon Woman's March — January 21, 2017