Tuesday, July 30, 2019

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

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

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

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

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


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

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

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

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

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

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

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

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

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

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

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

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

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

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


https://eplanning.blm.gov/epl-front-office/eplanning/planAndProjectSite.do?methodName=dispatchToPatternPage&currentPageId=187116

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