Monday, December 22, 2014

Update: Nedsbar Timber Sale Community Monitoring Program

Unit 14-30 in the Nedsbar Timber Sale. The unit is located in the Buncom Roadless Area and supports open stands of Douglas fir with old-growth characteristics. Structural diversity is high in the unit and fuel loads generally quite low. The unit should be dropped from consideration in the Nedsbar Timber Sale to protect habitat values.

Local Applegate residents, The Siskiyou Crest Blog, The Klamath Forest Alliance, and the good folks at KS Wild have begun monitoring Nedsbar Timber Sale units in both the Upper and Little Applegate Valleys. In our recent timber sale monitoring we have found units that are healthy, fire adapted and in no need of manual thinning whatsoever. We have also found units that are overly dense, fire suppressed stands that would benefit from a restoration based thinning approach.

In our initial forays we have found numerous units which contain old-growth characteristics. Some of these units have been influenced by relatively recent wildfire, while others are located within roadless wildlands that represent some of the most intact ecosystems remaining in the foothills of the Applegate Valley. Logging these units would increase fuel risks to rural residents of the Upper and Little Applegate Valleys, increase future fuel loads, and impact Northern spotted owl, Pacific fisher, and Siskiyou Mountain salamander habitat. 

The Nedsbar Project Area lies within an important connectivity corridor linking the Rogue Valley to the Applegate Valley, and the Siskiyou Crest to the Marble Mountains Wilderness and the vast wildland habitat in the Klamath Mountains south of the Klamath River. The area provides a low elevation corridor that links with the high elevation land bridge of the Siskiyou Crest. The connectivity provided by the Little and Upper Applegate Valleys has been identified in the Applegate Adaptive Management Area Ecosystem Health Assessment published by the BLM and Forest Service in 1994. The area should be protected from regeneration logging and heavy commercial thinning that severely impacts canopy coverage, structural complexity, fire resilience, and the habitat provided by large, old trees.


I will highlight a few units recently surveyed by Community Monitoring Program volunteers that contain old-growth characteristics, open, fire resilient stand structure, and excellent wildlife habitat.

Unit 14-30 
Open Douglas fir stands in the western portion of unit 14-30.



Unit 14-30 lies entirely within the Buncom Roadless Area on the north slope of the low, arid ridge system dropping from Cinnabar Ridge to the confluence of the Little Applegate and Applegate Rivers. Surrounded by chaparral and oak woodland on three sides, the unit supports an isolated stand of late and mid seral Douglas fir with a few ponderosa pine and madrone. The forest represents some of the driest Douglas fir habitat west of the Cascade Mountains. Heavy thinning in this unit will increase light infiltration, allowing for the encroachment of surrounding shrubfields and the regeneration of young conifers in the understory that will significantly increase fuel loads.

The western margin of the unit supports open groves of large, old Douglas fir. The forests are generally not overly dense, but support a relatively closed canopy condition. Large, old trees grow in clumps or clusters around the unit with a few isolated patches of younger regenerating fir and madrone. The central portion of the unit is more dense and even-aged, with a small oak opening supporting large, old oak trees and widely spaced conifers. 

The southeast portion of unit 14-30 supports open, old stands of Douglas fir.

The southern portion of the unit, near the ridgeline, supports scattered older trees growing from rocky substrates that likely harbor populations of the Siskiyou Mountain salamander. The unit's southeastern corner supports beautiful, open groves of Douglas fir with a well developed understory of native grass. The unit is a thriving, diverse community that supports not only old-growth characteristics, but also fire resilient forest habitat.

Unit 15-30
Open, fire adapted forest in Unit 15-30


Unit 15-30 lies entirely within the Buncom Roadless Area. The unit is located at the western margin of the roadless area, above Upper Applegate Road near it’s intersection with Eastside Road.

             
Unit 15-30 is identified by the BLM as a structural retention unit (Ponderosa Pine). It is a very narrow unit within a long, isolated stringer of conifer forest. This narrow band of forest is surrounded by chaparral consisting of buckbrush, silk tassel, manzanita, and oak. The unit is northfacing and moderately steep. Two distinct stand types can be found within the unit: relatively dense pole stands are found on the lower end of the unit, while the upper half of the unit supports late seral stands of mixed pine and fir.

             
The stands in the upper half of the unit underburned in 1987, thinning the stand and creating a fire-adapted, open structured forest of ponderosa pine and Douglas fir. The understory is open and somewhat grassy due to a combination of recent fire and northwest exposure; a nicely filtered canopy has enabled the stand to resist shrub encroachment from the surrounding brushfields. Much of the stand supports a very low fuel load with little fuel laddering or pockets of dense understory vegetation.

Unit 15-30

The upper portions of unit 15-30 need no treatment whatsoever for fuel reduction or forest health. In fact, the upper fire adapted portions of the stand could be seen as a “reference condition” for similar dry forest habitats. These conditions include the presence of large ponderosa pine and Douglas fir, open structured, fire influenced stand conditions, and well developed herbaceous understory communities dominated by native plants. 


If logged, the upper portion of the unit could be influenced significantly by shrub encroachment due to the heavy canopy removal proposed within a stand that is surrounded on three sides by dense chaparral habitat. The increased sunlight and ground disturbance associated with logging would likely facilitate the spread of highly flammable chaparral species into the understory of this currently open stand. The results could include a substantial increase in fuels, fuel ladders, and fire risks within the Buncom Roadless Area and the adjacent Wildland Urban Interface (WUI) along Upper Applegate Road. The upper portions of unit 15-30 should be canceled to protect the resiliency, habitat values, and “reference” conditions found within this beautiful stand.

Dense stands in the lower end of unit 15-30.
The lower end of the unit is more dense, even-aged, and vertical in structure. Pole stands with scattered dominant trees grow in a contiguous closed canopy forest. Douglas fir dominates the north facing slope from the little gulch to the ridgetop above. Understory fuels are relatively non-existent due to the density of canopy.
             
The lower portion of unit 15-30 could be thinned to reduce density and fuel loads. Treatments should be non-commercial and focused on small suppressed trees. Canopy closure should be maintained and the stand “thinned from below” to reduce the likelihood of shrub encroachment.  

Unit 33-20
Unit 33-20 lies on the north slope of the long, dry ridge dividing the Little Applegate River from Yale Creek. The south face of the ridgeline consist of manzanita, oak, and pine, while the north slope consists of a mixed conifer forest of fir, pine, and madrone. 

Old-growth ponderosa pine in unit 33-20


The upper portion of unit 33-20 is rather dense with suppressed fir poles, many snagged out or of extremely low vigor. Scattered, large pine grow in clump formation along the ridge itself; some have begun to succumb to drought stress, competition, and beetle outbreaks. Fuel risks are significant due to the density of vegetation.

             
The lower two-thirds of the unit consist of relatively intact stands of fir, pine, and madrone, including many large, old trees. The stand underburned in the 1987 Cantrall Fire, creating relatively open, fire adapted conditions. The canopy is generally closed, yet tree spacing is broad, age class diversity is high, and ladder fuels minimal. A few areas contain more dense and even-aged stands of fir. Douglas fir dominates with large ponderosa pine and wide branching madrone growing interspersed throughout the stand. 

Unit 33-20 is an open and fire adapted forest that burned in the 1987 Cantrall Fire. This unit is located above the Little Applegate River on the ridgeline dividing Yale Creek from the Little Applegate River. The lower two-thirds of this unit are composed of forest with old-growth characteristics.


Roughly one mile of proposed road upgrades will be necessary to facilitate the logging of unit 33-20. The BLM is proposing to upgrade existing decommissioned roads in the area with a clear potential to increase OHV use, noxious weed spread, hunting and poaching pressure, trash, and disruption of relatively isolated wildlife habitat.

             
The lower, more late seral portions of unit 33-20 should be canceled to protect the important wildlife values associated with old-growth habitat. Non-commerical thinning along the ridgeline could be acceptable if implemented with sufficient design features, including the retention of large live trees, snags, tree form oaks, and large madrones. The idea could be to create a backcountry fuelbreak. The unit could extend across the upper 100’ of the north slope within proposed unit 33-20. The goal would be to create a ridgetop fuelbreak from which hand crews could contain wildland fires. The fuelbreak could also be used to light prescribed burns that could be used to maintain healthy habitat and fuel condition in the area. The project would be part of a larger strategy to create fuelbreak and ridgeline trail systems that would provide anchor points for the management of wildland fire and the use of prescribed fire.

 


           
Contribute to the Nedsbar Community Monitoring Program


Donate online, or by mail.
Klamath Forest Alliance
P.O. Box 21
Orleans, CA
95556
(Please specify your donation is for the Nedsbar Timber Sale.)





Friday, December 12, 2014

Nedsbar Timber Sale: Regeneration Unit 28-22B

Unit 28-22B in the Nedsbar Timber Sale. The unit supports open, fire-adapted late seral habitat conditions due to the influence of recent, low severity fire. The stand sustained understory fire in 1987 and remains a healthy example of late seral, old-growth forest in the foothills of the Applegate Valley. The unit needs no treatment whatsoever to reduce fuels or address forest health concerns and should be canceled.

           The Nedsbar Timber Sale is located in the Upper and Little Applegate Valleys on public lands administered by the Medford District BLM. The BLM has proposed a large, landscape scale timber sale focused solely on producing timber for private industry. The proposed timber sale includes over 100 units spread across thousands of acres of public land, including the Dakubetede Roadless Area, the proposed Dakubetede Primitive Area, and an important connectivity corridor connecting the foothills of the Applegate Valley and the Siskiyou Crest. The forests proposed for logging include some of the driest forest habitat in Oregon, west of the Cascade Mountains. They also include important late seral habitat for species such as the Pacific fisher and Northern spotted owl, as well as the threatened coho salmon. 
           As part of the Nedsbar Community Monitoring Program I recently visited numerous  commercial units proposed for logging in the Nedsbar Timber Sale. Although numerous of the units I visited supported healthy, fire-adapted stands and should be canceled, unit 28-22B was by far the most egregious I have seen so far.
           Unit 28-22B is located directly above the confluence of the Little Applegate River and Yale Creek on a very steep, north-facing slope. The unit lies within an unroaded portion of the proposed Dakubetede Primitive Area. The area burned in the Cantrall Fire of 1987, creating a mosaic of habitat types and stand structures, ranging from brushfields, to hardwood stands and oak woodlands, to various conifer habitats of pine and fir. Unit 28-22B represents some of the older, more complex and fire-adapted forest habitat in the area. 
            The 1987 underburn created a spacious and open forest of large Douglas fir, madrone, black oak, and in the draws, bigleaf maple. The unit has a relatively closed canopy, discouraging the development of understory fuels. In fact, fuel concerns in the unit are minimal, at best. Fire risks to surrounding communities would be greatly increased through the proposed “regeneration” logging prescriptions in unit 28-22B. These prescriptions would leave only 16-25 trees per acre, logging large, fire resistant trees and drastically opening the canopy to increased light infiltration. This increase in light will in turn create “regeneration,” or an increase in young growth, creating increased fuel loads and fire risks to the surrounding communities and forest stands. The stand would also be exposed to drying winds, increased sunlight, and shrub encroachment due to the large levels of canopy removal proposed. The complex structural conditions and layered canopy necessary for the Northern spotted owl would also be heavily degraded. 
Take note of how low the fuel risk is within Unit 28-22B. Regeneration harvesting in this unit would drastically increase fuel risks in a Wildland Urban Interface, adjacent to rural homes in the Little Applegate Valley

           The unit currently provides important features that would be damaged by regeneration logging, including old-growth characteristics, Northern spotted owl habitat, thermal cover for the area’s ungulate population, extremely low fuel risks, fire adapted forest habitats and scenic values. Unit 28-22B is not a stand in need of treatment; in fact, it could be seen as a “reference” ecosystem, as it still supports large, old trees and fire influenced stand conditions.
            To make matters worse, the BLM has proposed to construct roughly 1 mile of new road to access unit 28-22B and a handful of other commercial units on the ridgeline dividing Yale Creek and the Little Applegate River. With this new road would no doubt also come large landing construction, noxious weeds, OHV use, litter, and other disruptions to local wildlife and habitat conditions. The creation of new road in otherwise inaccessible areas will also increase the risk of human caused fire. Much of the proposed road construction would impact chaparral and oak woodland habitat. The combined effect would create a significant disturbance in this otherwise small, unroaded area.
            Unit 28-22B, and the new road construction proposed to access the unit, should be canceled. The residents of the Little Applegate should not be exposed to increased fire risks for the benefit of private industrial timber. Important habitat should not be sacrificed due to the demands of private industry placed upon public lands. It is our land; lets get out and defend it. 
Unit 28-22B

           The Siskiyou Crest blog and the Klamath Forest Alliance (KFA) are organizing a community-monitoring program for the Nedsbar Timber Sale. If you have a unit in your backyard or are motivated to go visit one, please go check it out and report back to us to help identify where units of concern are located. Email siskiyoucrest@gmail.com Pictures and unit descriptions are very helpful.
           Please contribute to the campaign to protect the Applegate Valley from the Nedsbar Timber Sale with your time, energy, and perhaps a few dollars. The Klamath Forest Alliance will be working with the local community and environmental organizations to oppose the Nedsbar Timber Sale and promote a sustainable management strategy that will emphasize fuel reduction, habitat protection, and the restoration of forest and watershed values in the Siskiyou Mountains.

Send donation to:
Klamath Forest Alliance
P.O. Box 21
Orleans, CA
95556
(Please specify your donation is for Nedsbar Timber Sale)

Nedsbar Timber Sale map depicting the location of unit 28-22B and the new road construction proposed to facilitate logging the area.

       

Sunday, December 7, 2014

Update: Nedsbar Timber Sale


Open, fire-adapted mixed conifer forest in unit 15-30 of the Nedsbar Timber Sale. The unit is located within the Buncom Roadless Area, a portion of the proposed Dakubetede Primitive Area. Logging this unit would impact habitat and ecological values while increasing fuel risks. The unit should be canceled and eliminated from the sale. 


The Nedsbar Timber Sale is a large BLM timber sale located in the Upper and Little Applegate Valleys. The planning area includes some of the last roadless terrain in the foothills of the Applegate Valley. It is also located in an important connectivity corridor the leads from the Rogue Valley, near the towns of Talent and Ashland, Oregon, across the Applegate Valley to the Siskiyou Crest, and into the wilderness complex of the Marble, Salmon, and Trinity Alps of Northern California. Environmentalists and local citizens in the area have begun working to either stop or significantly alter the project as it is currently proposed.

Over 30 Applegate Valley residents attended the BLM field trip on Nov. 19, 2014.
 On November 19, 2014 the BLM led a field trip to a few of the more accessible units in the Nedsbar Timber Sale. Over thirty local citizens concerned about the timber sale attended the tour to inform themselves of what is truly at stake. The community provided a lively discussion of the issues and voiced strong opposition to the agency's timber heavy prescriptions and proposal. To our surprise, the BLM did announce that they were dropping 31 units throughout the planning area, including older stands, quality nesting, roosting, and foraging habitat for the Northern spotted owl, as well as numerous units located in small roadless areas. They also reduced, but did not eliminate, the acreage proposed for "regeneration harvest," a sivicultural technique where only 16-25 trees per acre remain after the area is logged. There are now only three units proposed as "regeneration harvest."

BLM field trip into 19-20A, a regeneration unit.
Additionally, the BLM's initial proposal for Nedsbar included "disease management" prescriptions — that would have targeted mistletoe "infested" stands, leaving only 6-9 trees per acre — that have now been canceled. This is especially important because all known spotted owl nest sites on BLM land within the Little Applegate have been documented in mistletoe brooms.

Although the sale has been altered, numerous units remain that will impact the proposed Dakubetede Primitive Area, a number of small roadless areas, and many acres of previously uncut forest. Many more units need to be canceled and a new management approach promoted that will restore functional connectivity corridors, reduce fuel hazards in the wildland urban interface, retain wildlife habitat, and facilitate the production of high quality water throughout the watershed for threatened coho fisheries and thriving local farms.

The currently narrow and limiting "purpose and need" of the Nedsbar Timber Sale, as defined by the BLM, emphasizes timber management over all other social, economic and ecological values. In a watershed designated as a key watershed for the threatened coho salmon, that supports unusually high density populations of the Northern spotted owl, harbors exceptional levels of biodiversity, provides popular recreational opportunities, and is developing a thriving local economy based on scenic values, tourism, outdoor recreation, as well as organic farms, ranches, and vineyards, such a timber heavy approach is unacceptable.


Looking into Nedsbar unit 14-30 in the Buncom Roadless Area. A new road is proposed to be constructed on the ridge in the foreground, extending onto the knoll above unit 14-30, in the center of the photo. See map below.

Proposed road construction for three units of the Nedsbar Timber Sale. These roads will be constructed in currently unroaded areas.


The heavy and unsustainable extraction of timber in the Upper and Little Applegate areas has the potential to heavily impact the quality of life and the developing economy of the region. The Nedsbar Timber Sale would also have substantial impact to the region's natural values such as fisheries, wildlife habitat, water quality, etc. There is currently a subgroup of the Applegate Neighborhood Network that is working on a "community alternative" for the Nedsbar Timber Sale. The BLM has promised to analyze the community alternative as part of it's Environmental Analysis (EA) process. The BLM's EA is due to be released to the public for comment in March, 2015.

Community monitoring in unit 30-20





The Siskiyou Crest blog is trying to organize a community monitoring program for the Nedsbar Timber Sale. If you have a unit in your backyard or are motivated to go visit one, please check it out and report back to us to help us identify where units of concern are located. Email: siskiyoucrest@gmail.com Pictures and unit descriptions are very helpful.

Unit 15-30




 


Please contribute to the campaign to protect the Applegate Valley from the Nedsbar Timber Sale with your time, energy, and perhaps a few dollars. The Klamath Forest Alliance will be working with the local community and environmental organizations to oppose the Nedsbar Timber Sale and promote a sustainable management strategy that will emphasize fuel reduction, habitat protection, and the restoration of forest and watershed values in the Siskiyou Mountains.

Send donation to:
Klamath Forest Alliance
P.O. Box 21
Orleans, CA 
95556
Klamath Forest Alliance
(Please specify your donation is for Nedsbar Timber Sale)

This map is hard to read here, but can be viewed easier on the BLM's Nedsbar Web Page if you click on "Public Involvement," and then "Field Trip Draft Map."  BLM's Nedsbar Web Page









Thursday, December 4, 2014

Applegate Dam hydroelectric project terminated by FERC

            
Applegate Dam and Reservoir
          The tale of the proposed hydropower generation facility on the Applegate Dam is one of corporate mergers, joint ventures and acquisitions, and less about actually generating electricity. 

            Symbiotics LLC originally obtained the license and permit from the Federal Energy Regulatory Commission (FERC) in 2009, then later Ag Hydro LLC took over the license. Symbiotics and Ag Hydro are now both subsidiaries of Riverbank Power Corporation. Based in Toronto, Canada, Riverbank Power is a developer, constructor and operator of hydropower generation facilities in North and South America, with offices in Toronto, Oregon, Utah, Idaho and Lima, Peru.

            After all the efforts of the federal government; after all the corporate financing poured into the project; after all the energy of local Applegaters to attend public meetings and write public comments about the proposal, and after more than a decade, the project has been officially terminated by FERC. The reason as stated in FERC’s Order Terminating License issued October 16, 2014: “…we find that AG Hydro failed to commence project construction by the deadline established pursuant to section 13 of the Federal Power Act (FPA). We therefore must terminate the license.” However, after reading this Order it appears to me that Ag Hydro just completely dropped the ball. Read FERC'S Order Terminating License yourself; it is an interesting read.

The Applegate River emerging from the Applegate Dam

       Some of the reasons stated for the termination of the project within the Order are: 
  • Ag Hydro filed drawings stamped “Not for Construction."
  • Ag Hydro failed to submit a formal project financing plan. 
  • Ag Hydro’s steel liner design was considered unacceptable and the National Marine Fisheries Service (NMFS) asked for major modifications to the project design, but Ag Hydro did not file an amendment application to address the issues. 
  • Ag Hydro did not meet the deadline to start project construction on December, 17 2011, and after being granted a two-year extension they didn’t meet the final deadline to start project construction on December, 17 2013. 
  • Ag Hydro submitted inadequate documentation to prove manufacturing of turbine components at its manufacturing facility in China. 
  • Ag Hydro submitted photos of blueprints that were ineligible and in Chinese, and the only dates on the drawings referenced 2006, predating the FERC license. 
  • Ag Hydro failed to complete other pre-construction requirements. 
  • Ag Hydro ordered turbines differing from those authorized in the license.

            It’s clear that it was in the best interest of Applegate Valley residents, the Applegate River and public coffers that this project was terminated by FERC. Despite being told by Symbiotics at public meetings here in the valley that they wanted to “work with the community,” it appears that Symbiotics/Ag Hydro didn’t even want to work with the agency, let alone the community, and they completely mismanaged this project.

            Unfortunately, we are still left with an uncertain future regarding the health of salmonid fish (fall chinook, coho, steelhead, and cutthroat trout) in the Applegate River. When the Applegate Dam was constructed in 1980 it blocked an estimated 35-80 miles of spawning and rearing habitat above the Applegate dam according to the National Oceanic and Atmospheric Administration (NOAA) Fisheries. Coho salmon in the Applegate River belong to the Southern Oregon-Northern California Coast Evolutionary Significant Unit, which is listed as a threatened species under the Endangered Species Act. The 242 foot dam would require a fish ladder that would be 3.5 miles long to maintain the maximum 1.3% slope needed to keep the water velocity in the range of 6 to 12 feet per second to achieve the right conditions for upstream fish migration.

            Over and over the public has been told such a fish ladder would be financially unfeasible. That is why Ag Hydro had to include a plan within their proposal to trap adult steelhead at the dam’s base and truck them upstream above the dam, and retrofit the existing dam structure to allow fish to get back downstream on their own through a kind of chute. Hopefully the Army Corps of Engineers, which operates Applegate Dam, and the Oregon Department of Fish and Wildlife can still find funding to restore fish to their original spawning streams above the Applegate Dam.

Suzie Savoie

Monday, November 10, 2014

KLAMATH NATIONAL FOREST PROPOSES MASSIVE POST-FIRE LOGGING PROJECT IN 2014 FIRES


View of the fire mosaic from the Happy Camp Fire in the Grider Creek Roadless Area. Numerous salvage logging units proposed in the Westside Fire Recvoery Project can be seen in this photo. All salvage logging in the Grider Creek watershed should be canceled as it is an important wildlife connectivity corridor.

The wildfires this past summer on the Klamath River burned in the Marble Mountains Wilderness, Russian Wilderness, Salmon River, Lower Scott River, and along the Klamath River between Happy Camp and Hamburg. In all, 215,371 acres burned in the Mid-Klamath watershed, creating a mosaic of mixed severity fire. The fires burned in a characteristic pattern, including roughly two-thirds low to very low severity fire. Many areas burned in the understory, clearing back fuel beneath a canopy of trees; some areas burned in a mixed pattern, thinning the overstory, while others sustained canopy fire, creating snag fields of fire-scorched timber. The result was the landscape-scale restoration of fire in a region with one of the west's most intact fire regimes.

Despite the regenerative nature of this summer's fires, the Klamath National Forest has proposed a massive salvage logging project — the Westside Fire Recovery Project (WFRP) — that would log over 40,000 acres of important post-fire habitat on public lands. The treatments proposed would log both green, live trees and fire killed trees. According to the agency's scoping notice, it is anticipated "that the majority of trees within salvage units will be harvested," including trees that survived the fire but the agency has decided are likely to die.

In my initial field research I have found numerous WFRP units that include high elevation species adapted to high to moderate severity fire, and stands that sustained less than 50% mortality. In many of the units I have visited, many large, green trees have survived the fires of 2014, but will they survive the logging frenzy to follow? 

Unit 511-Proposed for salvage logging in high elevation mountain hemlock (Tsuga mertensiana) forest adjacent to the Lake Mountain Botanical Area and the world's northern most stands of foxtail pine (Pinus balfouriana). The unit burned at low to moderate severity.

Unit 508- Partially burned red fir (Abies magnifica) forest at over 6000' proposed for salvage logging

Unit 508- A very large unit on the south face of Tom Martin Peak. Much of the unit burned at low to moderate severity, including this interesting transition zone between serpentine woodland and high elevation forest.
Unit 535- This unit in the Grider Creek watershed and adjacent to the Grider Roadless Area contains many live, old-growth trees of fire adapted species such as jeffery pine and incense cedar. Much of the unit burned at moderate to low severity and natural fire effects helped to maintain an open, fire adapted condition.

Currently the Klamath National Forest is accepting public comments on the Westside Fire Recovery Project. It is important that they hear from you. Below is a list of exclusion zones, project design features, and minimum prescription guidelines that could be incorporated into a public comment on this important issue. 


Exclusion areas
·      No salvage logging or planting units within Inventoried Roadless Areas, including the Grider, Tom Martin, Russian, Snoozer, Kelsey, or Johnson Roadless Areas.
·      No salvage logging on sensitive soils, active landslides, earth flows and other erosive soil types.
·      No salvage units on decomposed granite.
·      No salvage and 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.
·      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,                     Kuntz Creek, Tom Martin Creek
                        Whites Fire: E. Fork Whites Gulch, Sixmile Creek, South Russian Creek,                           Tanners Peak area
·      No salvage in endemic or rare conifer stands and adjacent available habitat. This would include foxtail pine (Pinus balfouriana), Baker’s cypress (Cupressus bakeri), and Brewer spruce (Picea breweriana) to allow for natural regeneration.

Project design features
·      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 risk 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.  

Minimum prescription guidelines for salvage units
·      Emphasize the retention of biological legacies such as large live trees, large snags, coarse woody debris, and intact thickets of unburned vegetation. These features should be retained in falling and yarding operations. (Lindenmeyer & Franklin 2008 p.29-34 & 143-146)
·      Retain adequate large downed wood for slope stability and regeneration.
·      Retain adequate snags for downed wood recruitment and cavity nesting habitat. This may include significantly higher levels of snag retention than in other logging applications — up to 25 snags per acre — due to attrition and collapse of damaged trees. The impact of salvage logging can often accelerate windthrow and attrition in snag fields.
·      Snags with broken or forked tops, complex branching, cat faces, fire damage that will encourage hollows and cavity creation, large diameter trunks, and/or rot resistant species should be retained.
·      Retain the largest live trees and snags in all salvage units. Consider the retention of snags in aggregates with scattered large snags in between the aggregates. Consider retaining groupings of snags around existing live trees.
·      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.

Please send public comments
Westside Fire Recovery Project
 Wendy Coats/Klamath National Forest
wcoats@fs.fed.us