Saturday, June 3, 2017

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

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

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

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

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

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

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

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

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


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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Please contact the BLM and tell them the following:

Implement Alternative 3 with the following amendments:

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

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

For more information:

Rogue Basin Cohesive Forest Restoration Strategy

Pickett West EA

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