Nedsbar EA Released! Public Comments Needed.

Nedsbar Timber Sale: Public Comment Guide

Unit 28-10B in the Bald Mountain Roadless Area. Trees up to 42" in diameter are marked for removal. The stand is naturally fire resistant with large well spaced trees, tall canopies, and minimal understory fuels. Logging will remove late seral characteristics while increasing understory fuel loads and fire hazards.

On July 2, 2016, the Medford District BLM released the Nedsbar Forest Management Environmental Assessment (EA). The EA analyzes the predicted environmental impacts of various action alternatives. The primary alternative proposed by the BLM is Alternative 4, which would target some of the most intact, fire resistant forests in our region. The alternative would include 1,500 acres of commercial logging in the Little Applegate and Upper Applegate Valleys.  If implemented, Alternative 4 will increase fire hazards by removing excessive levels of forest canopy and large, fire resistant trees.  

The proposal would log some of the most scenic backcountry in the Applegate Valley along the proposed Jack-Ash Trail and within the viewshed of the popular Sterling Ditch Trail. It would also log forest directly adjacent to our communities in the Little Applegate and Upper Applegate Valleys, impacting the scenic quality of our properties and the view from many of our homes, as well as the region's bourgenoning recreation-based economy, wildlife habitat, wildlands and the beauty of the valley we love.

Fortunately, local residents, the Applegate Neighborhood Network (ANN) and the Community Alternative Working Group joined forces to create a more responsible, sustainable, and fire-wise alternative. Known as Alternative 5 in the Environmental Assessment, the Community Alternative would retain higher levels of canopy cover and large, fire resistant trees, while reducing fuels, prmoting forest health and producing a sustainable amount of timber. 

The BLM has fully analyzed our community-based alternative and acknowledged that it meets the "purpose and need" of this forest management project. Alternative 5 is also consistent with the mandates of the Applegate Adaptive Management Area that was designated to encourage collaboration, innovation and community involvement in public land management planning and implementation. Please consider writing a comment to the BLM. Comments will be accepted until August 1, 2016. Comments can be sent to: blm_or_md_mail@blm.gov 

Below is an analysis of impacts associated with the BLMs Alternative 4, in comparison to the Community Alternative, Alternative 5. 

Fire/Fuels:

Fuel increase associated with commercial thinning.

BLM's Alternative 4: Alternative 4 would increase fire hazards adjacent to our communities by removing excessive levels of canopy cover, removing large fire resistant trees and targeting intact, naturally fire resilient forests. The heavy canopy reductions proposed in Alternative 4 will drastically increase fuel loads and fuel laddering by encouraging a dense shrubby understory beneath the remaining "leave" trees. The reduction of canopy will also extend fire season by allowing stands to dry out much earlier in the fire season. This pattern can be seen across the Applegate Valley in stands that were logged in the last 10-20 years. 

The BLM will also be removing many large, fire resistant trees that are the cornerstone of fire resilience and are most likely to survive the effects of a summer wildfire. These large trees are also particularly important for wildlife and contribute to the scenic qualities of the Applegate Valley. 

Finally, Alternative 4 proposes to significantly reduce canopy cover levels and remove large, fire resistant trees in many of our most intact, fire resilient forests. Many of these stands consist of large, old trees with fire resistant characteristics such as closed canopy conditions that suppress shrubby understory fuels, thick insulating bark, high canopies and sufficient space between live trees. The stands are naturally fire resistant and are the most likely locations on the landscape to sustain low to moderate severity fire effects in a summer wildfire scenerio. The relative abundance of intact fire resistant forest contributes directly to our area's fire resilience. Logging these stands will increase fuels and fire risks, potentially encouraging high severity fire effects.

Nedsbar Community Alternative, Alternative 5:

In treated stands, the Community Alternative, Alternative 5, will retain adequate levels of canopy cover to address forest health concerns, suppress shrubby understory fuels and reduce the likelihood of extending fire season by drying treated stands. Alternative 5 will also retain all large, fire resistant stands in our remote and unroaded wildlands. Alternative 5 is also the only alternative to propose the use of prescribed fire to more effectively reduce understory fuels and restore low intensity fire to long unburned areas. The Community Alternative will reduce fuels, maintain fire resistant stands, protect large, fire resilient trees and begin to restore fire to ecosystems in need. 

Unroaded Areas:

Alternative 4 proposes new road construction through these beautiful oak woodlands in the Trillium Mountain Roadless Area. The road would be built to access the uncut forest in units 26-20 and 27-20 on the northern slopes. The road would be built on the ridge in the center of the photograph.

BLM's Alternative 4:

The BLM is proposing to commercially log nearly 1,500 acres in the Nedsbar Forest Management Project. Of this total, 72% or 1,086 acres are proposed in citizen identified roadless areas including the Buncom, Bald Mountain, Boaz Mountain and Trillium Mountain Roadless Areas. These are the last intact ecosystems in the foothills of the Applegate Valley and were recently proposed by Senator Wyden as a large Back-Country Primitive Area. In response to the proposed protection of these areas, the BLM proceeded to target them for logging before they could be protected. Many of the stands proposed for logging are late-seral or old growth stands that provide exceptional wildlife habitat.  

The BLM is also proposing to build 3.2 miles of new road to access commercial logging units. BLM's Alternative 4 will build 2 miles of new road across the western face of Trillium Mountain and in the riparian reserve of Lick Gulch in the Trillium Mountain Roadless Area. This new road would sever the roadless area and badly damage the areas habitat connectivity, scenic qualities, hydrology, wildlife habitat, riparian habitat and native plant communities, while increasing the potential for unauthorized OHV use. 

Currently these unroaded areas provide important wildlife habitat, harbor intact plant communities, sustain old-growth forest habitats, and offer solitude and non-motorized recreationa opportunities to local residents and visitors. These important values will be degraded by the proposed logging in Alternative 4. 

Nedsbar Community Alternative, Alternative 5:

No new roads will be constructed under Alternative 5. The Community Alternative will protect unroaded habitats and the important values they provide. Proposed logging treatments will include roughly 200 acres within unroaded areas, but these treatments will retain all large trees and adequate canopy cover. These units will be located at the edge of unroaded areas with a few hundred feet of existing BLM roads. Their primary purpose is the creation of roadside fuel brakes intended to aid in the containment of wildfire or future prescribed fires. The effect will be an increase in forest health and fire resilience, yet the intact nature of these stands will not be compromised. 


The Community Alternative proposes to eliminate 19 units on over 800 acres in unroaded area that are proposed for logging in BLM's Alternative 4. 

Recreation:

The view from the Sterling Mine Ditch Trail across the Little Applegate River Canyon to units 26-20 and 27-20 proposed for logging in the BLM's Alternative 4. One mile of new road would be built in the Trillium Mountain Roadless Area to facilitate logging these uncut forests.

BLM's Alternative 4: 
The BLM has proposed logging 57 acres of intact old-growth forest on the proposed route of the Jack-Ash Trail. The Jack-Ash Trail is proposed to extend from Jacksonville to Ashland, Oregon and is poised to become a recreational hotspot for residents of southwestern Oregon and visitors to the region. The proposed logging units are located within one of the trails wildest sections in the Bald Mountain Roadless Area. Trees up to 42" in diameter have been marked for removal.


BLM's Alternative 4 proposes to log numerous units directly across from the Sterling Mine Ditch Trail. These units are predominantly located in the Trillium Mountain Roadless Area, an area that currently appears completely undisturbed. The majority of these units would be logged to 40% canopy cover, which would make the logging units very prominent and disruptive to the trail's viewshed. At least 25 units would be highly visible from the Sterling Mine Ditch Trail. 

Nedsbar Community Alternative, Alternative 5:

The Community Alternative would protect the viewshed of the Sterling Mine Ditch Trail. Only 4 units would be visible from the Sterling MIne Ditch Trail, but these units would reduce canopy cover far less drastically that proposed in the BLM treatments, making the units less visible and more naturally appearing. 

The Community Alternative proposes no logging in the Bald Mountain Roadless Area, eliminating the impact of old-growth logging on the Jack-Ash Trail. 

In a era of diminishing opportunities to hike in areas unmarred by logging, road building and other industrial impacts, it is vital to retain the natural characteristics of the Applegate landscape for the economic importance of our growing recreational economy. 

Northern Spotted Owl Habitat

BLM's Alternative 4:

Alternative 4 would impact Northern Spotted Owl (NSO) habitat and complex, late seral forest habitat by "removing" or "downgrading" NSO habitat. Removing habitat means that habitat conditions following logging operations have been degraded to the extent that NSO will no longer use the area for nesting, roosting and foraging (NRF) or dispersal. Downgrading habitat means that the quality of habitat following logging operations will be less useful to the owl than it was prior to logging treatments. 

For example, habitat currently, identified as suitable for nesting, roosting and foraging would be "downgraded" to dispersal, meaning that the habitat conditions would no longer support nesting, roosting, or foraging habitat and will only function for NSO that are "dispersing" or migrating through the area. Dispersal habitat can be downgraded to "capable" habitat, meaning it is currently not useful to the NSO, but the soils and climatic conditions could support the complex forest that in turn supports the NSO. 

BLM's Alternative 4 proposes to remove 109 acres of NRF habitat and 217 acres of dispersal habitat. The proposal includes 269 acres of NRF downgrades to dispersal habitat. In total, 595 acres, or 40% of the commercial logging acres are proposed to have negative impacts on the Northern Spotted Owl. 

Nedsbar Community Alternative, Alternative 5:

Alternative 5 would protect and promote high quality NSO habitat by deferring many of the most complex, old forest habitats from logging treatments. Habitat conditions would be maintained in harvested units by retaining canopy cover levels at between 50% and 60% for the majority of uniti, as well as retaining all large, old trees. This is an important component of the Community Alternative because it is important for the NSO that its habitat is protected within treated areas. 

Although the Community Alternative Working Group developed the alternative with guidelines to protect NSO habitat, the BLM analysis of the Community Alternative, Alternative 5, has shown a supposed downgrade of 26 acres of NRF habitat. We have requested information regarding where these supposed downgrades will occur in the Community Alternative, but we have not yet recieved a response from BLM.

BLM's Environmental Analysis shows that NRF downgrades and removals are nearly 15 time more prevalent in BLM's Alternative 4 than in the Community Alternative, Alternative 5. 

New Road Construction:

BLM's Alternative 4: 

Alternative 4 proposes 3.24 miles of new permanent road construction and 1.28 miles of temporary road construction. According to BLM nearly 1/4 mile of new road would be built in the bottom of Lick Gulch, potentially creating significant levels of sedimentation. Road reconstruction would take place on 4.45 miles of road. Alternative 4 would also build 12 new helicopter landing sites. 

Nedsbar Community Alternative, Alternative 5:

The Community Alternative proposes no new road construction, temporary or permanent. Road reconstruction would take place on 0.31 miles of existing road and no new helicopter landings would be built. 

The BLM already has an enormous backlog of deferred road maintenance because of budget constraints and the sheer size of the current road system. It is fiscally irresponsible to build new roads with public money when there is no funding for long term maintenance. Roads are a major source of sediment in our streams. The chronic sedminentation created by logging roads have long lasting and detrimental impacts to anadromous fish populations. The financial and ecological impacts of road building are just too high. 

Large Tree Retention:
 

A large, old tree over 40" in diameter marked for removal in unit 35-32 located at the headwaters of Grouse Creek. Unit 35-32 is proposed for logging to 40% canopy cover in the BLM's Alternative 4.

BLM's Alternative 4:

The BLM has refused to impose a diameter limit on Alternative 4. Community monitoring has documented trees up to 42" in diameter marked for removal. According to the BLM timber tally, 501 trees over 20" in diameter are proposed for removal. This number excludes 24 units that were "leave" tree marked, making quantifiable numbers more difficult to produce. This is extremely significant because numerous units with large, old trees marked for removal are currently not included in this estimate. In many units basal area and canopy cover targets necessitate the removal of large trees over 21" in diameter. 

Update: Although you will not find the information in the EA, after publicizing our findings, the BLM has published an Errata Sheet admitting that the numbers presented in the Nedsbar Forest Management Project EA were inaccurate. The have increased the number of trees over 20" in diameter marked for removal in Alternative 4 to 1,826, over three times the original estimate in the EA. 

Unfortunately, this new estimate is also suspect. The number is based on estimates that do not include any of the Group Selection units and does not actually quantify many other units due to the way they were marked. This means that the remaining 81% of the units are not quantified. The BLM is claiming that only 501 large trees or 27% of their current estimate are marked for removal in these final 62 units. We are working to verify these numbers because many of these 62 remaining units contain significant numbers of large trees marked for removal. 


Nedsbar Community Alternative, Alternative 5:

The Community Alternative identifies a 20" diameter limit across the entire project area. No trees over 20" in diameter would be removed under the prescriptions outlined in Alternative 5.   

Public Comments can be sent to: blm_or_md_mail@blm.gov   
 Subject: (Attention: Kathy Minor-Ashland Resource Area-Nedsbar) 

Applegate Valley OHV Monitoring Project: Progress made at China Gulch

The closure posted on China Gulch restricts OHV use in the area to reduce disturbance to wildlife, reduce risk of forest fire, and minimize soil erosion.

The Applegate Valley OHV Monitoring Project is a grassroots public lands monitoring project focused on documenting the impact of OHV use in the Siskiyou Mountains. We are a project of the Applegate Neighborhood Network (ANN), Klamath Forest Alliance and the Siskiyou Crest Blog. Last summer we published a detailed Monitoring Report documenting OHV impacts throughout the Applegate River watershed. We monitored both Forest Service and BLM lands, documenting unauthorized, user-created routes that were impacting riparian areas, botanical resources, wildlife, roadless areas, monarch butterfly habitat and other important resource values. 

One of the most egregious OHV issues in the Applegate Valley was documented to have been expanding out from the proposed, but still unapproved, John's Peak OHV Emphasis Area. The area lies between the towns of Ruch and Jacksonville, Oregon on the edge of the Wellington Butte Roadless Area. OHV impacts are particularly acute in this area and unauthorized OHV routes are nearly always being developed into new habitats and sensitive areas. 

The China Gulch area northwest of Ruch, Oregon has been extremely hard hit with unauthorized, user-created trails crisscrossing the watershed, carving up meadows with compacted OHV routes, creating erosive hillclimbs, and utilizing seasonal streams as OHV trails. OHV closures and gates are regularly breached to access already heavily degraded OHV routes. 

A Google Earth image of China Gulch Meadows. The user-created OHV routes that are negatively impacting the meadows are very obvious in this image.

The China Gulch area is also partially included in the inventoried Wellington Butte Lands with Wilderness Characteristics (LWC). The western half of the watershed is mostly wild and undisturbed, although OHV enthusiasts are beginning to enter the roadless portions of the watershed with unofficial OHV trails. The Applegate Trails Association and others have proposed that the eastern portion of China Gulch be closed to OHV use and included as a 1,300-acre addition to the Wellington Butte LWC. The proposed Applegate Ridge Trail (ART) will traverse the upper reaches of China Gulch through both the proposed 1,300-acre addition and the currently inventoried LWC.

Looking south into Ruch, Oregon from the Oregon Belle Loop Road, a proposed portion of the Applegate Ridge Trail. The oak woodlands, grasslands, and chaparral fields of eastern China Gulch should be included as an addition to the Wellington Butte LWC.

The eastern half of the watershed has been badly damaged by OHV use and the broad grassy meadows at the headwaters of China Gulch have been torn to pieces by unauthorized OHV routes. Our OHV Monitoring Reports placed significant emphasis on the area around China Gulch, and after a year of advocacy, stubborn persistence, and pressure placed on BLM land managers, the agency has finally acted. 

In late May the BLM implemented a project to reinforce the gated portion of China Gulch Road, close down hillclimbs, protect the China Gulch meadow system from further OHV abuse, and close the long-gated, but heavily utilized Oregon Belle Loop Road. This primitive old mining track is proposed as a portion of the non-motorized Applegate Ridge Trail. It has long been closed to motorized use with a large yellow gate, but OHV enthusiasts have created access routes for motorbikes, quads and full sized trucks around the existing closure. These routes were decommissioned and made impassable with debris. Closure of the Oregon Belle Loop Road is another step towards respectful public use, responsible public access and the protection of public resources. Yet, the BLM still has work to do as more routes leading into the China Gulch basin are in need of closure. 

Boulders now line the margin of China Gulch Meadow and China Gulch Road in an attempt to eliminate impacts associated with OHV use.

Recently the BLM placed boulders around the gate on China Gulch Road to reinforce the motor vehicle closure, and they dug "tank traps" and created impassable berms on erosive hillclimbs, as well as lining over 700' of China Gulch Meadow with boulders to restrict vehicle access. Although this is a commendable effort by BLM, motorbike tracks have already entered the area and continued monitoring will be necessary to enforce this important closure.
 
The Applegate Valley OHV Monitoring Project will be active again this summer, monitoring routes, documenting impacts and advocating for OHV closure in damaged or inappropriate areas. We will be working to institute regular citizen monitoring in the China Gulch area. If you are in the area, please consider sending me an update and some photographs at: siskiyoucrest@gmail.com

Please consider helping us by monitoring OHV routes, snapping photographs and sending us your findings. Document OHV impacts and illegal activities wherever you see them. We will compile all information possible for inclusion in the 2016 OHV Monitoring Report. Let us know what you see in your backyard!

Support our efforts with volunteer monitoring or a tax deductible donation. Donations can be sent to KS Wild (our fiscal sponsor) with a note that the donation is supporting ANN or the Applegate Valley OHV Monitoring Project. 

Send donations to:
Online Donation 
    -or-
KS Wild 
PO Box 102
Ashland, Oregon 97520 

Summer Solstice on the Siskiyou Crest

The view west from the summit of Observation Peak

Recently my wife and I took a backpacking trip across the eastern Siskiyou Crest for summer solstice and a spectacular full moon. This was the first full moon to land on summer solstice since 1948, and it was perhaps the only time in my lifetime that I will experience the longest summer day and a big, round, full moon.

From the summit of Observation Peak, in a windswept clearing of paintbrush, buckwheat and low, creeping sage, we watched the sun sink to the west, into the rugged blue ridges of the Siskiyou Mountains, casting long shadows into the deep canyons below. Simultaneously, the low and massive full moon rose to the east over the broad ridges of the southern Cascade Mountains, reflecting moonlight on the snow-capped summit of Mt. Shasta — white glaciers were bathed in the light of the full moon and the final fleeting streaks of summer solstice sunlight.

The rare and endemic Jaynes Canyon Buckwheat (Eriogonum diclinum) blooming on Big Ridge in the Condrey Mountain Roadless Area.

From our vantage point on Observation Peak we could see the connection between land and sea, sun and moon, the ancient, eroded Siskiyou and the youthful volcanic features of the Cascade Mountains. The connectivity the Siskiyou provides can be seen as the ridges unfolded before us, connecting the major ranges of the Pacific Northwest. The connectivity can also be seen in the vegetation as little sagebrush and balsamroot mingle with mountain hemlock, huckleberry, and Shasta red fir. Plants from all the cardinal directions converge on these slopes, creating a biological tapestry of exceptional diversity. Endemic species such as splithair paintbrush, Henderson's horkelia and other rarities were blooming at our feet, yet they can be found nowhere outside this unusual mountain range.

Each summit on the eastern Siskiyou Crest has it own geologic history and bedrock, with its own corresponding plant communities and distinctive character. No mountain range on the west coast supports such a rich, undisturbed flora. These mountains have long harbored disjunct plant populations, remnants of former climatic regimes isolated within the varied habitats of the Siskiyou and its transitional nature. 

Looking north from the PCT to Wagner Butte and the McDonald Peak Roadless Area.

We hiked for over 50 miles from Mt. Ashland to lower Elliott Creek across the Siskiyou Crest. The high country was vibrant with fresh melting snow and the first round of summer flowers blooming on the ridges and in high mountain meadows. Although spring has turned to summer in the lower Siskiyou foothills, where the gulches are running low, flowers are setting seed, and grasses have turned golden on sun baked slopes, the high mountains along the Siskiyou Crest have just begun their summer display. They have shed their white, winter shawl, which fills the creeks and springs with cold, flowing water and nourishes the flora for the benefit of birds, pollinators and other wildlife dependent on the Siskiyou's diverse plant communities.

The Pacific Crest Trail traverses the eastern Siskiyou Crest through forests, meadows, glades, rock outcrops and open ridgelines. The trail connects botanical areas and roadless wildlands just as the Siskiyou Crest connects the Cascades Mountains to the Coast Range. In the 50 miles from Cook and Green Pass to Mt. Ashland, the trail enters six roadless areas, five botanical areas and the Condrey Mountain Blue Schist Geologic Area. The conservation values of the Siskiyou Crest are simply not matched with adequate protection or appropriate management. In fact, many of these values are currently threatened by inappropriate off-road vehicle use, public land grazing, industrial logging, mining, proposed ski resort expansion and other forms of misuse.

From the Big Red Mountain Roadless Area looking west across the Siskiyou Crest.

In the era of climate change and industrialization, the connectivity the Siskiyou Moutains provide will allow genetic and biologic diversity to flow freely across the landscape. This flow of diversity will likely be vital to natural climate adaptation and dispersal. The key to protecting diversity in the era of climate change may be in protecting the connectivity of our last wild landscapes and undisturbed habitats. The Siskiyou Mountains are a monumental landscape and should be preserved in perpetuity. A large protected area should be designated on the border of California and Oregon, extending from the Cascade-Siskiyou National Monument to Redwood National Park. The connectivity these mountains provide is priceless, the diversity unparalleled, and the wildness still tangible. If we protect the Siskiyou Crest these important values will remain, if we do not, they may be lost forever. 

Take a trip along the Siskiyou Crest on the PCT and get to know the region more intimately. You'll be glad you did! I recommend the route from Mt. Ashland to Cook and Green Pass, or if you have a little more time, all the way down to Seiad Valley and the Klamath River via Devils Ridge. 

Looking down Silver Fork Glade and the Observation Peak Roadless Area to Dutchman's Peak.

Looking west from the PCT near Alex Hole, across the Condrey Mountain Roadless Area.