Monday, November 11, 2019

BLM Proposes to Eliminate Public Comment Periods in New Logging and Road Building Proposal

A view down Powell Creek in the Late Mungers Project. The Late Mungers Project is "tiered" to the analysis in the IVM Project and would be the first timber sale approved if the IVM Project is authorized.
As part of their continuing assault on the National Environmental Policy Act (NEPA), the Medford District BLM has proposed the Integrated Vegetation Management for Resilient Lands Project (IVM). Although it sounds benign, in many cases, terms like "Integrated Vegetation Management" are a euphemism for commercial logging and serve only to mask the impacts and objectives of timber management with misleading language.


Under the IVM Project the BLM has proposed to allow up to 4,000 acres of commercial logging and 10 miles of new road construction per year without public comment, public involvement or environmental review. This would include up to 25,000 acres of logging and 90 miles of new road construction in a ten year period. According to the BLM, these authorizations would have "no sunset date," meaning that overtime they could be used to build hundreds of miles of new roads and log many tens of thousands of acres.
Old-forest proposed for logging in the Late Mungers Project near Morgan's Buckhorn.

Yet, this project is even more insidious in that it focuses its commercial logging "treatments" in conservation-based land use allocations like Late Successional Reserves (LSR), Areas of Critical Environmental Concern (ACEC), Lands with Wilderness Characteristics (LWC) and other areas outside the BLM's Timber Harvest Land Base.

The IVM Project proposes to approve commercial logging, prescribed fire and/or fuel reduction on virtually any location throughout the Medford District BLM. Yet, the location of future timber sales, the intensity of logging and the specific logging prescriptions would remain undetermined and would be at the sole discretion of BLM staff. 
The Burton-Ninemile Lands with Wilderness Characteristics (LWC) located in the Upper Applegate Watershed would be open to commercial logging with no NEPA analysis if the IVM Project is approved.

The IVM Project threatens to take away our right as citizens to influence and participate in public land management. If approved, it would provide the BLM with very broad discretion to authorize timber sales with little to no public involvement or accountability. Nearly all checks and balances currently embedded within the NEPA process would become optional, opening the way for a flood of controversial logging projects throughout southwestern Oregon.

The IVM Project includes an over 800,000-acre planning area encompassing all BLM lands in southwestern Oregon except the Cascade-Siskiyou National Monument and existing Wilderness Areas. Logging treatments could take place along portions of the Rogue River, in numerous roadless areas in the Applegate Watershed, and portions of the Illinois River Valley.

Fire adapted forest targeted for logging in the Late Mungers Project.
Despite having no official approval for the IVM Project, the Medford District BLM has already begun planning commercial timber projects "tiered" to the IVM Project and dependent on its ultimate approval. In the mountains outside Williams, Oregon the BLM has already identified its first large timber sale, called the Late Mungers Project.

The Late Mungers Project is focused on a large block of Late Successional Reserve forest located on the ridgeline dividing the Williams Valley from the Illinois Valley near Selma, Oregon. The project proposes commercial logging units on Murphy Creek, Powell Creek, Mungers Creek, and the South Fork of Deer Creek. 

An area proposed for commercial logging on Mungers Butte.
Very little information is available about the Late Mungers Project, but we were able to obtain a draft unit map showing proposed commercial logging and fuel reduction units. According to these maps, the commercial logging component appears quite extensive. It also appears that some of the last remaining corridors of intact forest habitat on the Applegate-Illinois River divide are targeted for commercial logging.

The BLM is accepting public comments on the IVM Project until November 18, 2019. Please consider the talking points below when drafting a public comment.

IVM Talking Points:  
  • Activities such as commercial logging, road construction and large scale fuel reduction have the potential to create significant environmental impacts and effects. These activities should therefore require site-specific NEPA analysis, including the disclosure of impacts, scientific review, public involvement, environmental analysis and public comment.
  • All Programmatic NEPA analysis should be implemented through development of a full Environmental Impact Statement (EIS). The currently proposed Environmental Assessment (EA) lacks the detail and rigor required to consider environmental effects across such a broad, complex landscape. 
  • The agency must analyze and disclose the impact of all logging and road building activities. This should include direct, indirect and cumulative impacts. 
  • Concerns regarding increased sedimentation and water quality impacts, impacts to late successional habitat, Northern spotted owl habitat, increased fire risks, increased fuel loading, standing drying, and accelerated canopy loss associated with commercial logging should be addressed in NEPA analysis. 
  • BLM monitoring data demonstrating the actual, on-the-ground effects of previous commercial timber sales should be analyzed throughout the 800,000-acre IVM planning area. The actual outcome of these timber sales should be compared to previous effects analysis to monitor for compliance and consistency. 
  • Planning on the Late Mungers Project is pre-decisional and additional planning efforts should be discontinued. The Late Mungers Project has the potential to create significant adverse effects and is located in a large block of LSR forest. This project should require site specific NEPA analysis and a full public comment period. 
Submit your comments:


By Mail or Delievery: 

Attn: IVM-RL EA
Medford District BLM
3040 Biddle Road
Medford, Oregon 97504 

For more information on the project, click here. 

Also please attend the upcoming BLM open house to discuss the project at the Jackson County Expo, Mace Watchable Wildlife Building 4:30-7:00 PM Thursday, November 14, 2019. 



The green polygons represent commercial logging treatments currently proposed in the Late Mungers Project, blue depicts fuel reduction, while the narrow brown lines following major ridges are proposed as 300' wide fuel breaks which could include commercial and non-commercial treatments.
 

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