Friday, July 28, 2017

The Pickett West Timber Sale: Old-Growth Logging Disguised as "Restoration"


Old-growth forest in unit 3-11 is targeted for logging in the Pickett West Timber Sale. The stand is an important remnant habitat providing connectivity in a highly altered watershed. Thompson Creek is heavily fragmented by clearcut logging and simplified plantations stands. Unit 3-11 is located adjacent to widespread plantation management and provides a necessary corridor of old forest habitat. The tree with the pink flag around its trunk supports an active Red Tree Vole nest, an important food source for the Northern spotted owl.
The Pickett West Timber Sale is perhaps the worst old-growth logging project proposed by the BLM in southern Oregon for many years. The project is proposing to log some of the last remnants of old forest surrounding the communities of Selma, Merlin, Galice, Wilderville, Murphy and North Applegate. The Pickett West Timber Sale also proposes significant logging in tributaries of the Wild and Scenic Rogue River between Grants Pass and Graves Creek.


The band of late successional forest at the center of the photograph is units 3-9 and 3-11. The high brushy summit is Kerby Peak.
Despite standing above our homes and communities very few have visited these last intact forests, now targeted by the BLM for logging. They are not the iconic wilderness landscapes of the west, instead they are the backdrop to our communities. They also represent the charm and beauty that is bringing people to our region. They are the last fragments of natural, fire resilient, old forest in our rural communities; they are salmon streams; they are Northern Spotted Owl strongholds; they are the last small corridors of intact forest threading our low-elevation habitats together, and they are islands of habitat in otherwise fragmented landscapes. The fact that they are the last, makes them disproportionately important to our communities, to our fisheries, and to our wildlife.
  
A broad-based coalition of conservation organizations, recreation enthusiasts, businesses, fishing organizations, rural residents and citizens across the region will be joining together to protect these last intact stands and oppose the Pickett West Timber Sale. We will not watch these last stands fall to the whine of the chainsaw, instead we will work to preserve them, respect them, and enjoy them, as they define who we are as Southern Oregonians.

Roughly half the Pickett West Timber Sale is located in old-growth stands between 150 and 240 years old. Unit 3-10 in the Pickett West Timber Sale is 160 years old.

The Pickett West Timber Sale targets old-growth stands throughout southern Oregon for heavy industrial logging. Half the units in the timber sale are located in old-growth stands between 150 and 240 year old. These old, complex forests are highly fire resistant, provide important forest habitat, and are also increasingly rare, especially at low-elevations and adjacent to local communities. These stands protect our viewsheds, our clean water, our wildlife habitat and buffer our communities from the effects of uncharacteristic wildfire, while providing accessible and important recreational opportunities like the Thompson Overlook Trail, Applegate Ridge Trail, and Hellgate Canyon on the Wild and Scenic Rogue River.

Ironically, the BLM claims these highly industrial logging treatments are "restorative" in nature. Somehow, reducing canopy cover to 30%, rendering important Northern Spotted Owl habitat "unsuitable," building new roads, logging large, old-growth trees and drastically increasing fuel loads in the Wildland Urban Interface (WUI) is being promoted as "restoration." In reality, it is a timber grab intended to mislead the public into thinking that old forest logging is necessary to increase forest resilience and restore the natural role of fire.


A "tractor swing road" will be built through this grove of large, old trees in unit 4-1. The trees in this photograph will be logged to provide access for yarding actvities and a tractor swing road will be built through the center of the photograph.

The manipulation of science and the misrepresentation of proposed industrial logging treatments as "restoration" constitutes a new low. The Pickett West project has been designed around — in BLM jargon it is "tiered to" — the Southern Oregon Forest Restoration Collaborative's ill-conceived Rogue Basin Cohesive Forest Restoration Strategy (RBCFRS). The strategy encourages our federal land management agencies to industrially log forests across the Rogue River basin. The strategy proposes to log 2.1 million acres across the Rogue River drainage in the next twenty years, increasing the number of acres logged on federal land to six times the current level.

The RBCFRS identifies an excess of closed-canopy, late-seral forest — a finding that contradicts years of ecological research in the area — and is encouraging the agencies to convert closed-canopy, late-seral, and old-growth forest into open canopied, low density stands. The simplistic idea is that much of southern Oregon was once dominated by open, low density forest with a frequent, low-severity fire regime. By logging old, closed canopy stands, the BLM says it is hoping to create relatively stable and more fire resilient forests; however, the outcome of logging old-growth forest to 30% canopy cover will dramatically degrade habitat values and increase fuel loads. Woody understory species will capitalize on the newly created conditions and colonize canopy gaps, creating dense woody thickets and increasing fire hazards. 


The old-growth forest canopy in unit 3-11. Canopy cover in this stand is currently 91%. The BLM is proposing to remove two-thirds of the overstory, reducing canopy cover to as low as 30%.

With each large, old tree removed, resilience to wildfire is reduced. With the drastic canopy cover reduction proposed in the "restoration thinning" prescriptions, highly flammable, young vegetation will proliferate and replace large, fire resistant trees.

To make matters worse, the mythical "open forests" appear to have been greatly overestimated by those promoting this strategy. Yes, we did historically have open forests in southern Oregon, but we also had a lot of closed-canopy forests as well. Much of our region is affected by a mixed-severity fire regime, a fire regime that creates diverse habitat types, including significant closed-canopy forest habitats, open canopied forest and deciduous woodlands as well as large, fire-mediated brush fields in southern Oregon. The world-renowned biodiversity of the Siskiyou Mountains is partially dependent on this seemingly chaotic mosaic of stand conditions, habitat types and fire histories. 

The baseline conditions and reference ecosystems used to promote these "restoration thinning" treatments have been proven inaccurate by numerous local historic vegetation studies. In reality, those studying historic vegetation, interpreting General Land Office surveys  and conducting tree ring research across the region, have found highly variable conditions, highly variable fire return intervals and a mosaic of habitat types across the landscape. 
(Hickman 2011, Dipaolo 2015, Baker 2011, Muir 2006, Duren 2012, Agee 1993, Willis and Stuart 1994.)

Numerous recent historic vegetation studies have found a much broader distribution of closed-canopy forest types than open forest habitats (Hickman 2011, Dipaolo 2015, Baker 2011, Muir 2006, Duren 2012) in Southwestern Oregon. Often, but not always open conditions have been predicated by particular soil types and accentuated by the disturbance history. This is especially true as you transition across the area, from the more arid interior valleys to the more moist habitats in the Western Siskiyou Mountains around the lower Applegate River, Rogue River, and Illinois River watersheds, all within the planning area.


Old-growth, closed-canopied stands like this one in unit 3-11 of the Pickett West Timber Sale are prioritized for treatment and targeted with "restoration thinning" in the Pickett West Timber Sale The prescription calls for 30% canopy cover, converting this stand to an "open" canopy condition.
The RBCFRS is encouraging the BLM to target largely intact, old forest habitats, and the widespread logging of old forest in the proposed Pickett West Timber Sale is a direct result. The strategy requires the removal of large, old-growth trees to meet strict and scientifically unjustified canopy cover targets in an attempt to recreate open forest in habitats it likely never existed.

The strategy also prioritizes the "treatment" of late-seral and old-growth stands over young stands with what they call a "priority multiplier." The "priority multiplier" weighs old forest habitats twice as heavily as younger, more altered stands. The strategy designed by the Southern Oregon Forest Restoration Collaborative and the local Nature Conservancy has provided a greenwash for the BLM, who claims an ecological benefit from industrial, old forest logging, while ignoring the impact of road development, large tree removal, soil disturbance from yarding activities, invasive species introduction, forest fragmentation, impacts to the understory plant community, and increasing fuel loads.

The RBCFRS also promotes heavy industrial logging within nearly all federal land allocations, including Inventoried Roadless Areas, Late Successional Reserves, Botanical Areas, Research Natural Areas, and other important conservation-based land management designations. The implementation of the Rogue Basin Cohesive Forest Restoration Strategy is pushing the BLM towards logging older, more intact forest stands and in sensitive habitats.


Unit 3-11 at the headwaters of Thompson Creek contains naturally fire resistant, late-seral habitat. The stand is not in need of "restoration." The current stand condition only contributes to complex, late-seral habitat conditions, fire resilience and connectivity.

Recently, I have been hiking units all around the Thompson Creek watershed in Selma, Oregon. The BLM is proposing to log nearly every accessible old-growth stand in the watershed, and many of the Pickett West project's worst units are located directly above the rural community of Selma, Oregon. 

Below is a photo essay depicting stand conditions in units I hiked last weekend. These units are proposed for "restoration thinning," and in many cases over half the overstory canopy will be removed. The proposed logging will permanently impact ecological values and nearby rural communities. The vast majority of the Pickett West Timber Sale would produce unacceptable impacts and the entire sale should be canceled.

Unit 3-9 
Canopy conditions in the old forest portion of unit 3-9. This is currently an open canopy and opening it up even further will impact the health of the forest.

Unit 3-9 is located at the headwaters of Thompson Creek. Half the unit consists of unlogged, mid-seral forest. The stand is in the process of self-thinning and is developing habitat complexity through blowdown and other forms of mortality. The western portion of the stand is complex, old forest with stands between 24" and 56" in diameter. A small portion of the stand has been logged, but many old trees were retained and the canopy has recovered in the preceding years. The BLM has documented the stand to be 160 years old, but many of the stand's largest trees are likely much older. 
 
The mid-seral portion of unit 3-9 is healthy and developing complex structure.

The BLM claims the stand is dispersal habitat for the Northern Spotted Owl. This designation is clearly an error as all the higher quality habitat characteristics of Nesting, Roosting and Foraging habitat are present. The stand is located within a Critical Habitat Unit for the Northern Spotted Owl and was designated as Late Successional Reserve forest in BLM's 2016 Resource Management Plan (RMP). 

The unit should be canceled to protect the stand's late-seral conditions and habitat connectivity in the Thompson Creek watershed. 

Unit 3-10
 
The unlogged portion of unit 3-10 contains higher levels of shading and, thus, less understory fuel.

Unit 3-10 has been previously logged, but contains many large, old trees between 18" and 60" in diameter. The stand was previously selectively logged, creating a dense, shrubby fuel load in the understory. The BLM has documented the stand to be 160 years old and it does, in fact, contain many old-growth habitat characteristics. Thinning this stand will only compound the current fuel loading by opening the canopy and disturbing soils, triggering an aggressive understory response and an increase in fuel loading.


The previous logging in unit 3-9 resulted in heavy understory fuel. 
The BLM claims the stand is dispersal habitat for the Northern Spotted Owl. This designation is clearly an error as all the higher quality habitat characteristics of Nesting, Roosting and Foraging habitat are present. The stand is located within a Critical Habitat Unit for the Northern Spotted Owl and within forest designated as Late Successional Reserve in the 2016 RMP. 

The unit should be canceled to maintain late-seral habitat conditions and the canopy allowed to close, suppressing understory fuels that have exploded in growth in response to previous commercial thinning treatments. 


Unit 3-11
 
Incredible old forest in the northeastern portion of unit 3-11. The unit is among the worst in the entire Pickett West Timber Sale.

Unit 3-11 is among the worst timber sale units I have hiked in the Pickett West Timber Sale. The unit is a classic, low-elevation, Western Siskiyou old-growth forest. The forest contains complex structural conditions, a multi-tiered canopy, large, old trees, high quality snags, large downed wood and other late-seral characteristics. The BLM has documented the stand to be 160 years old, but many of the stand's large trees are likely much older. 

Much of the stand is dominated by large, old Douglas fir among a diverse mixture of live oak, tanoak, madrone, dogwood, bigleaf maple and a few scattered sugar pine. Along the small draws that drain the unit, the understory is often lush and abundant with vanilla leaf, red huckleberry, tangles of vine maple, and populations of Hartweg's wild ginger. 

The BLM claims the stand is dispersal habitat for the Northern Spotted Owl. This designation is clearly an error as all the habitat characteristics of high quality (RA-32) habitat are present. The stand is also located within a Critical Habitat Unit for the Northern Spotted Owl and was designated as Late Successional Reserve in the 2016 RMP.  
The BLM claims unit 3-11 is dispersal habitat for the Northern Spotted Owl in the Pickett West Environmental Assessment. In reality, unit 3-11 is complex, old-growth forest providing high quality Nesting, Roosting and Foraging habitat.
Much of the stand is old-growth forest with trees between 24" and 65" in diameter. Three large trees in the unit are documented to contain active Red Tree Vole nest sites. These sites should be protected by 10-acre, no-cut buffers. These buffers will exclude the vast majority of the unit from treatment and the unit should be canceled. 

The unit is surrounded by plantation stands and along with unit 3-9 provides very important connectivity habitat for late-seral species from the ridgeline above to the upper portions of Thompson Creek. 

The unit should be canceled to protect old-growth habitat values, maintain connectivity in the Thompson Creek watershed, sustain habitat complexity and to retain naturally occurring fire resistance. 

Unit 4-1
Groupings of large, old trees are scattered across unit 4-1.

Unit 4-1 is located on a forested knob in Upper Thompson Creek. The BLM has documented the stand to be 140 years old, but many large trees are likely much older. Two clear cohorts (stand ages) colonize the stand and create distinct diameter classes. A portion of the stand contains relatively even-aged Douglas fir trees between 18" and 30" in diameter. Groupings and groves of large, old-growth trees between 40" and 52" in diameter grow scattered across the unit. I found one of these large, old trees has been documented to support an active Red Tree Vole nest and would require a 10-acre no-cut buffer. 

Two separate sections of tractor swing road are proposed to be developed at the upper portion of the unit, fragmenting habitat, damaging soils and encouraging an expansion of unauthorized OHV use. A single track trail currently exists in the location of one tractor swing road. This trail should be designated for non-motorized use and maintained as part of the non-motorized trail system.

Unit 4-1 and the tractor swing roads proposed to access the unit should be canceled to protect a relatively large block of undisturbed, complex, mid- to late-seral forest. The unit does not currently need "treatment" to maintain healthy habitat conditions. 


Unit 4-1 is located on the ridgeline in the foreground of this photograph. A new tractor swing road would be built across the ridge accessing the uncut forest on the ridgeline's eastern face.

Please contact your local BLM officials and ask them to cancel the Pickett West Timber Sale and protect all old forest over 150 years old in the Pickett West Planning Area. 


Contact the BLM:
Field Manager, Allen Bollschweiler 
abollsch@blm.gov

District Manager, Elizabeth Burghard
eburghar@blm.gov

Monday, July 17, 2017

Pickett West Timber Sale: Logging the Last Old-Growth in Haven Creek

Unit 35-11 is beautiful and intact old-growth forest providing high quality habitat for the Northern Spotted Owl. The unit should be canceled.
Extending from the Wild and Scenic Rogue River to the Applegate Valley and over the ridge to the Deer Creek watershed in Selma, the Pickett West Timber Sale is a massive, old-growth logging project proposed by the Grants Pass BLM. Nearly half the project is proposed in stands over 150 years old and new logging prescriptions ironically called"restoration thinning" would drop canopy cover in many stands to as low as 30%. Over half the overstory canopy would be removed, leaving a few scattered trees in place of what was once a forest. 

The new "restoration thinning" prescriptions are designed to convert closed-canopy, old-growth or late-seral forest into "late-seral, open forest." The result is heavy industrial logging and extensive damage to the habitat of the Northern Spotted Owl, Pacific fisher, Red Tree Vole, Coho salmon and many other iconic, old-growth dependent species of the Klamath-Siskiyou Mountains. 

Other units would be logged with "density management" prescriptions to 40% or 60% canopy cover, and 14 miles of new road would be built into previously inaccessible and often unlogged forest.
Unit 35-11 consists of intact, structurally complex old-growth forest. The Pickett West Timber Sale is targeting the last old-growth habitats in the Deer Creek watershed for commercial logging. The sale will severely impact many unique low-elevation, old-growth forests. Over half the units proposed for logging support old-growth characteristics and are vital for the survival of the Northern Spotted Owl, Pacific fisher and Red Tree Vole. 

I spent the last two weekends hiking Pickett West Timber Sale units in the mountains above Selma, Oregon. What I found was both disturbing and beautiful. 

The vast majority of the units I have surveyed — 12 of 14 to be exact — have been old-growth forest. Many of the units are remnant stands bordering both private land and federal land clearcut logging units. Others are part of large contiguous blocks of intact forest. The BLM is coming after the last low hanging fruit, proposing to log nearly all the relatively accessible late-seral forest in the upper Thompson Creek watershed. 

The Pickett West Timber Sale should be canceled in its entirety. The project is the worst federal land logging project in Southwestern Oregon for many years. The BLM should cancel the sale and adopt a more responsible, collaborative approach throughout the planning area.

 I recently hiked two units in upper Haven Creek, a tributary of Thompson Creek in the Deer Creek Watershed. 

Unit 35-9
 
Old-growth groupings of sugar pine and Douglas fir dominate two-thirds of unit 35-9.

Unit 35-9 is located at the headwaters of Haven Creek. The stand is 51 acres of old-growth and second-growth forest on a steep, southwest facing slope. The southwestern portion of the stand has been logged and is now dominated by mid-seral pole stands. Roughly two-thirds of the remaining unit is uncut, old-growth forest. The Pickett West Environmental Assessment claims the stand is 150 years old, but many of the stand's largest trees are much older. 

The methodology used by the BLM to identify stand age grossly underestimates the age of uneven-aged, mixed conifer stands like those found in the Klamath-Siskiyou Mountains and Pickett West timber sale units. The methodology the BLM uses to estimate stand age excludes the oldest, most dominant overstory trees. They estimate the age of the younger, less dominant cohort; therefore, a stand identified as 150 years old may actually be dominated by trees between 200 and 300 years old. This is likely the case in both units 35-9 and 35-11. 

Despite the harsh, south-facing exposure, the unit is populated by groves of large, old trees.  Many of the old-growth groupings include large sugar pine and Douglas fir. Sugar pine from 30" to 65" in diameter and Douglas fir from 20" to 66" in diameter create complex, multi-layered canopies. Towering old-growth conifers rise above beautiful hardwood stands, including tanoak, live oak, madrone and chinquapin. 

Except for the logged-over portion of the unit, dense, pole-sized stands and young cohorts of fir are largely absent. Fuel loads are minimal due to high levels of canopy cover and the dominance of large, fire resistant trees. The late-seral portions of the stand are naturally fire resilient and highly complex.
Unit 35-9 maintains healthy, highly complex, late-seral stand conditions with exceptional fire resilience

The stand provides important nesting, roosting and foraging (NRF) habitat within a Critical Habitat Unit for the Northern Spotted Owl. The stand is also within a 0.5-mile "owl core" designated to protect the nesting habitat of the Northern Spotted Owl. The unit represents potential RA-32 habitat and should be removed from the harvest land base. 

Instead, the BLM is proposing a density management prescription with 40% canopy retention. They are proposing to remove over half the overstory canopy in this unit, reducing canopy cover from 96% to 40%. This drastic reduction will require the removal of many large, old trees.

The area is also very important for the Northern Spotted Owl's  main food source, the Red Tree Vole (RTV). The stand supports six documented RTV nesting sites. Reducing canopy cover will damage habitat values for the RTV by removing potential nest trees, disrupting RTV nest tree recruitment, and destroying the complex, interwoven canopy structure this species requires. The impact will be a reduction in habitat quality, quantity and connectivity.
Old-growth trees like this one in unit 35-9 provide important habitat for the Northern Spotted Owl and Red Tree Vole. The old-growth portions of unit 35-9 should be designated as RA-32 habitat for the Northern Spotted Owl and removed from the harvest land base. 

The BLM has also proposed two new sections of road to access unit 35-9. The BLM is calling these "temporary roads," but the impacts will be permanent, including compaction, soil displacement, soil erosion, impacts to water quality, increased access by unauthorized OHV use, the removal of large trees, and the destruction of understory plant communities. The roads required to access unit 35-9 traverse steep slopes and will, in places, need a full bench cut, creating a long-lasting environmental footprint.

Unit 35-9 should be canceled to protect late-seral habitat for the Northern Spotted Owl and RTV.

Unit 35-11
 
Unit 35-11 is beautiful, complex, old-growth forest that provides important connectivity habitat for late-seral species across environmental gradients in the Haven Creek watershed.

Unit 35-11 is among the worst in the entire Pickett West Timber Sale. The unit is located in the middle fork of Haven Creek in section 35. Unit 35-11 is 59 acres of old-growth forest surrounded by relatively recent clearcut logging and plantation stands, to the north and to the south. The BLM claims the stand is 190 years old, but many trees are likely much older. A significant portion of the unit is undeniably old-growth forest. The old forest along Haven Creek is refugia habitat, providing important connectivity habitat for late-seral species. The area connects the still relatively intact slopes of Kerby Peak to the low-elevation forests surrounding Thompson Creek. 

The stand is NRF habitat for the Northern Spotted Owl and is located within the home range of two owls and a Critical Habitat Unit.

The current canopy condition includes 92% canopy cover with significant levels of structural complexity. Stand conditions vary depending on aspect, but in general the stand contains all the characteristics of old-growth habitat, including large, old trees, large snags, large downed wood, high levels of canopy cover and a multi-layered canopy structure. The unit represents potential RA-32 habitat and should be removed from the potential harvest land base. 
Unit 35-11 is potential RA-32 habitat for the Northern Spotted Owl and supports many large diameter trees with complex branch structure, creating ideal Red Tree Vole nesting habitat. 

The stand provides important habitat for not only the Northern Spotted Owl, but also the Pacific fisher who often uses low-elevation, old-growth habitat along streams for dispersal, foraging and denning. The unit also likely supports a viable population of Red Tree Vole (RTV). Numerous "wolfy" trees with potential RTV nesting habitat can be found throughout the unit, especially on north-facing slopes. Trees between 45" and 62" diameter dominate the stand, creating ideal conditions for a variety of late-seral species including the RTV, Northern Spotted Owl and Pacific fisher.

At the top of the unit, on a small bench above a spectacular bedrock waterfall, lies an entire stand of potential RTV nest trees, many over 50" in diameter. 


A bedrock cascade on Haven Creek at the center of unit 35-11. The Pickett West Timber Sale has proposed to reduce no-cut buffers along riparian reserves. The impact will be disastrous to streams like Haven Creek.
Vollmer's lily (Lilium pardalinum ssp. vollmeri)
The stream is cold and clear as it runs through a heavily shaded canyon. Haven Creek pours down a series of spectacular bedrock cascades
3'-15' tall. The stream pours down cascades, through giant  river-washed boulders and large downed wood. Thick moss beds line the bedrock channel and Vollmer's lily (Lilium pardalinum ssp. vollmeri) blossoms along the stream with saxifrage, goats beard and elk clover. 

The southern slopes are dominated by old-growth Douglas fir, a few old sugar pine and a well developed secondary canopy of live oak, tanoak and madrone. Large portions of the stand support a broken canopy of live oak, pierced by large, old fir between 30" and 56" in diameter. The understory is sparse and rocky with minimal understory fuel. 
The south-facing slopes above Haven Creek support spacious stands of massive, old Douglas fir with a secondary canopy of live oak, tanoak and madrone. The stand supports complex, old-growth stand conditions and exceptional fire resilience.

The north-facing slopes are lush and productive with groves of massive, old fir between 30" and 65" in diameter. These north-facing slopes support coastal vegetation with large, old-growth fir. Tanoak, live oak, madrone, and Pacific dogwood create a secondary canopy. Evergreen huckleberry, red huckleberry, Cascade Oregon grape, vine maple, azalea, hazel and oceanspray grow in tangled thickets on the forest floor. 

These north-slope forests are particularly complex with large diameter snags, large downed wood and diverse overstory distribution. The oldest trees grow in isolation or in groupings of old-growth trees scattered throughout the stand. Although canopy cover levels are high, the patchy distribution allows enough sunlight to reach the forest floor to encourage large summer berry crops and diverse understory vegetation. 
Lush, coastal-influenced old-growth grows on the north-facing slopes in unit 35-11.

Fuel loading and fire hazards in this stand are extremely minimal. In general, massive old trees with high canopies and thick, insulating bark dominate the stand and create fire resistant stand conditions. The current canopy condition is suppressing understory growth in many locations, limiting fuel loads, maintaining high levels of fuel moisture late into the fire season and shielding the stand from intense sunlight and winds. The combined effect is to naturally moderate fuel loading and fire hazards.

The BLM has proposed a density management prescription, reducing canopy cover by over half from 92% to as low as 40%. Meeting the canopy cover and basal area targets for this stand will require the removal of many large, old-growth trees. The drastic removal of canopy cover will significantly increase understory fuel loading, desiccate the stand, reduce habitat complexity and downgrade Northern Spotted Owl habitat to dispersal. 
 
Old-growth canopy conditions on the north-facing slopes in unit 35-11. The BLM is proposing to remove over half the existing overstory canopy, reducing canopy cover from 92% to 40% after logging operations are completed. Does this stand need "restoration?"

Unit 35-11 should be canceled to protect connectivity of old-growth habitat, maintain Northern Spotted Owl habitat, protect late-seral habitat and sustain fire resilience. 

Submit comments to: 

Grant Pass Inter-agency Office/Don Ferguson

2164 NE Spalding Ave. 

Grants Pass, Oregon 97526

-or-
    blm_or_pwest@blm.gov
Comments are due July 17th


Friday, July 14, 2017

Pickett West Timber Sale: Logging Off The Last Large Blocks of Old-Growth Forest in the Deer Creek Watershed.

Old-growth forest proposed for logging in unit 26-3.
The Pickett West Timber Sale is a massive timber management project proposed by the Grants Pass BLM. The project spans across much of interior southwestern Oregon, from Galice and Graves Creek on the Rogue River, to the lower Applegate Valley, and south to the Deer Creek drainage in Selma, Oregon. 

The BLM is proposing to log thousands of acres of old forest in the mountains surrounding the community of Selma, Oregon. The project proposes to convert closed-canopy, old-growth forest into open-canopied, late-seral habitat by reducing canopy cover to as little as 30%. In many places this will require the removal of the majority of dominant overstory trees and the elimination of Northern Spotted Owl habitat. 

The BLM has proposed four units in section 26 at the headwaters of Camp Creek and an unnamed drainage to the south, a tributary of Haven Creek. The area supports hundreds of acres of contiguous, intact, old-growth habitat in sections 22, 23, 26, and 27. The area contains the large blocks of late-seral habitat necessary for the survival of the Northern Spotted Owl and other late-seral species. All units currently provide Nesting, Roosting and Foraging (NRF) habitat for the Northern Spotted Owl and the vast majority of the surrounding area is NRF habitat as well. 
 
Complex, old-growth forest in unit 26-2 contains high quality habitat for the Northern Spotted Owl, red tree vole, Pacific fisher and other late-seral dependent species.

A portion of the area has been identified as Critical Habitat and the entire area is designated Critical Habitat Units (CHU). The area is also Late Successional Reserve in BLM's 2016 Resource Management Plan (RMP). Units 26-1, 26-2 and 26-4 lie within the 0.5-mile owl cores. Numerous of the units likely contain RA-32 habitat, the highest level of NSO habitat available on the landscape and should be removed from the harvest land base.  

The area is currently functional, diverse, highly resistant to natural disturbance, such as insect infestations and wildfire, and represents one of the most intact habitats in the Deer Creek Watershed. 
Naturally open, late-seral forest in unit 26-2 contains all the key elements of fire resistant habitat. The stand is dominated by large, old trees with thick insulating bark, high canopies, closed-canopy stand conditions that suppress understory fuel, diverse, patchy tree distribution, and fire resilient species.

In 2005, the BLM approved the development of the Thompson Overlook Trail, a six-mile, non-motorized trail providing access to the large block of old forest, rock outcrops and natural openings in sections 22, 23, 26, and 27. The trail was approved due to the highly scenic and unique natural features of the surrounding region, including what BLM now identifies as units 26-1, 26-2, 26-3 and 26-4.  

Ancient forest like that found in unit 26-2 is a unique biological and recreational resource. The Thompson Overlook Trail could be one of the region's best low-elevation, old-growth trails, it should not be logged in the Pickett West Timber Sale.
The Thompson Overlook Trail, although approved, has not been developed due to a lack of funding, volunteers and support from BLM staff. Although not yet developed, the trail was approved because of the exceptional value it would provide to local residents and visitors alike. No specific analysis of the Thompson Overlook Trail or the recreational opportunities in the area was documented in the Pickett West EA. Logging units 26-1, 26-2, 26-3 and 26-4 will significantly degrade the recreational experience on the proposed Thompson Overlook Trail.  

The BLM has proposed a nearly half-mile long "temporary tractor swing" road across the currently unroaded ridgeline, providing access to the units for old-growth logging. The impact to soils from the extensive use of this tractor swing road would be significant. Tractor swing roads utilize only one tree suspension and require many more passes than a skid trail. The impact to soils is often far more significant than skid trails and includes dragging old-growth logs across the road bed, over and over again. Impacts will be concentrated and compounded across the entire half-mile long corridor.

Unit 26-1

The complex, old growth forest in unit 26-1 at the headwaters of Camp Creek lies within a 0.5-mile owl core designated to protect the habitat of the Northern spotted owl.

Unit 26-1 is located at the headwaters of Camp Creek among a large, contiguous stand of ancient forest. The unit is located on a very steep northwest-facing slope. The unit provides Nesting, Roosting and Foraging (NRF) habitat for the Northern Spotted Owl and is located within a 0.5-acre owl core designated to protect known nesting habitat from habitat destruction. 

Much of the stand consists of old-growth Douglas fir with an understory of low statured live oak. The stand supports a multi-layered canopy structure with significant complexity of habitat, including large diameter snags, large woody debris and closed-canopy conditions. The unit contains trees between 20" and 36" in diameter. Although the BLM estimates the stand to be 120 years old, the dominant, overstory trees over 30" in diameter are likely much older.

Alternative 2 proposes a "density management" prescription. The proposed logging would downgrade the current NRF habitat to dispersal habitat by removing large, old trees and excessive levels of overstory canopy. Current canopy cover is 92%, the density management prescription would drop canopy cover to 40%, removing the majority of dominant, overstory trees. 

Unit 26-2 
Industrial old-growth logging or restoration? The towering ancient canopy of unit 26-2 will be reduced from 94% canopy cover to as low as 40%. Imagine over half this ancient canopy removed.

Unit 26-2 is also located at the headwaters of Camp Creek on steep west- and northwest-facing slopes. The 14-acre unit provides important NRF habitat for the Northern Spotted Owl. Like unit 26-1, it is located within a 0.5-mile owl core and should be protected from industrial logging activities. 

Numerous large, "wolfy" trees between 42" and 70" in diameter dominate the central portion of the stand, providing excellent late-seral habitat conditions and potential Red Tree Vole nesting habitat. The Red Tree Vole nests in large, old Douglas fir trees, often with complex branch structure. Many trees in this stand support these characteristics. The Red Tree Vole is an important food source for the Northern Spotted Owl and, according to the Northwest Forest Plan, its nest trees should be protected from logging with a 10-acre no-cut buffer. The complex forest habitat found in unit 26-2 meets the criteria for what the government calls "RA-32" habitat, the highest quality Northern spotted owl habitat. All RA-32 habitat is required under the Recovery Plan for the Northern Spotted Owl to be protected from commercial logging, which will only degrade the important habitat features of these exceptional old stands.

Hartweg's wild ginger
The BLM claims the stand is 120 years old, but many of the large, old trees are likely much older. Dominated by large, old Douglas fir with a low statured understory of live oak, the stand supports relatively moist conditions, including a vibrant understory of Cascade Oregon grape, sword fern, vanilla leaf and the relatively uncommon Hartweg's wild ginger (Asarum hartwegii). 

The current 94% canopy cover is suppressing understory fuels and enhancing fire resistance. The limited understory fuels, tall crown-base height, patchy canopy structure and abundance of large, fire resistant trees combine to create a very fire resilient forest. 

Alternative 2 proposes a "density management" prescription, reducing canopy cover to 40%. The removal of large, fire resistant trees and heavy canopy reduction will increase solar radiation, exposure to drying winds, stand drying and trigger an extreme understory response. The currently low-statured and patchy understory of live oak will expand, filling in canopy gaps and, along with young conifer reproduction, will drastically increase fuel loads, fire risks, and fuel ladders leading into the crown of large, old trees.  

Unit 26-3
Unit 26-3 contains beautiful stands of intact old-growth forest.

South of Camp Creek runs an unnamed tributary of Thompson Creek, which later flows into Deer Creek, a large tributary of the Illinois River. At the headwaters of this unnamed stream is a large block of old-growth forest, contiguous with the ancient forests colonizing upper Camp Creek, the area is a vital connectivity corridor leading from the high forested slopes into the valley of Thompson Creek. Unit 26-3 is an old-growth stand within this vital corridor of late-seral habitat.

The stand is relatively moist, with a lush understory of sword fern, Cascade Oregon grape, vanilla leaf and Hartweg's wild ginger. Large Douglas fir and sugar pine (24"-44" diameter) dominate the overstory canopy layer.  Large diameter snags rise above the slopes, while large, downed logs stabalize the soils. The stand contains all the characteristics of old-growth mixed conifer forest. According to the BLM the stand is 180 years old. 

The stand supports NRF habitat within two overlapping Northern spotted owl home ranges. It also supports a documented Red Tree Vole nest tree, which if buffered as required, would eliminate the entire unit from commercial harvest.

The BLM has proposed a "restoration thinning"prescription in this unit, reducing canopy cover to 30%. To meet canopy cover and basal area targets the BLM will be removing the vast majority of large, fire resistant, overstory trees. The level of canopy cover reduction proposed for retention in unit 26-3 will replace complex, old forest with young, highly flammable regrowth. The increase of fuel loads and fire risks will be severe. Logging large, old, fire resistant trees will also render the habitat "unsuitable" for the Northern Spotted Owl and significantly degrade the habitat surrounding the stand's documented Red Tree Vole nest. 

Unit 26-4
A beautiful, old-growth grouping in unit 26-4. The blue marked trees were proposed for removal in the 2005 South Deer Timber Sale, but the sale was never cut. BLM is now back to log these stands and will likely be removing portions of these old-growth groupings in "restoration thinning." Many dominant trees will be removed to achieve a 30% canopy cover.
Unit 26-4 is located on a south-facing slope above Haven Creek. The unit is part of a large contiguous block of old-growth forest extending across the headwaters of Camp Creek and the unnamed stream to the south and into the upper reaches of Haven Creek. 

According to the BLM, the stand is 180 years old and provides NRF habitat for the Northern Spotted Owl. Located on a southern exposure, the stand contains a significant population of large, well space ponderosa pine, sugar pine and Douglas fir between 20" and 36" in diameter. A secondary canopy of madrone and younger, pole-sized Doug fir can also be found scattered throughout the stand. 


The BLM has proposed a "restoration thinning" prescription for this stand. The prescription calls for reducing canopy cover to as low as 30%. The impact on this south-facing slope will be to severely dry the stand and extend fire season due to increased exposure to sunlight and drying winds. The result will be to compound drought stress in the summer months and increase susceptibility to insect infestations and high-severity fire effects.  


Conclusions
The large, contiguous area of old-growth habitat at the headwaters of Camp Creek, the unnamed stream to the south, and upper Haven Creek should be retained for habitat connectivity, the protection of late-seral habitats, and to maintain resilient stand conditions. No commercial logging and new route construction should be approved. The habitat is important for late-seral species and the entire area is identified as a Late Successional Reserve in the 2016 Resource Management Plan for Southwestern Oregon. The logging proposed in the Pickett West project is inconsistent with the values and management directives of a Late Successional Reserve forest. 

The logging will also impact a Critical Habitat Unit for the Northern Spotted Owl by downgrading or altogether eliminating important Northern Spotted Owl habitat. The proposed logging will also impact fuel loading and increase fire hazards by reducing canopy cover and removing large, fire resistant trees. 
Large contiguous blocks of old-growth forest should be retained on the landscape for late-seral species like the spotted owl. Rather than fragment and eliminate or downgrade Northern spotted owl habitat in the name of "restoration," the BLM should cancel all units in section 26 and manage the area for conservation and recreation.

Logging these stands will significantly degrade the scenic and natural environment traversed by the proposed Thompson Overlook Trail. The trail was proposed by local residents and approved by the BLM to provide a high quality recreational experience in the unique, low-elevation forests of the area. The trail was heavily supported by residents of Selma, Oregon and will significantly contribute to their quality of life and local economy. It should not be degraded before it can be built. 

Units 26-1, 26-2, 26-3 and 26-4, along with the tractor swing road proposed to access them, should be canceled. The harm caused to the environment, to the local community and recreation economy far outweight any benefit the timber would provide. Logging some of the last large blocks of low-elevation ancient forest in the mountains above Selma is short-sighted and irresponsible. 


Please consider commenting on the Pickett West Project and ask the BLM to cancel units 26-1, 26-2, 26-3 and 26-4. The deadline for the public comment period ends on July 17, act now!


Submit comments to: 

Grant Pass Inter-agency Office/Don Ferguson

2164 NE Spalding Ave. 

Grants Pass, Oregon 97526

-or-
    blm_or_pwest@blm.gov


Camp Creek, Camp Forest and the Pickett West Timber Sale


Unit 27-12 is a beautiful and increasingly rare low-elevation, old-growth habitat. The unit has been used for decades as an educational laboratory for students of late-seral and old-growth forest habitats. BLM is proposing to log many large trees and reduce canopy cover to as low as 30% in this magnificent old forest. The unit should be canceled to protect the stand's old-growth character and naturally fire resilient forest.
Orville Camp grew up in the Illinois Valley. His family homesteaded the Deer Creek Valley outside Selma, Oregon, starting in 1909. They made a living in the logging and farming industry. A tributary of Thompson Creek, known as Camp Creek, was named for Orville's family. Orville moved away in the 1954 after being drafted into the Korean War. He returned in the fall of 1967 to purchase a portion of his family's homestead on Camp Creek. The 180-acre parcel was ruthlessly clearcut before he acquired the land.

Inspired by the research of Charles Darwin and the science of evolution, he began to manage the land he calls, "Camp Forest," according to the principals of "Natural Selection Ecostry," a light-touch form of forest stewardship that removes only dead and dying trees that are not necessary for ecosystem function. 

In the preceding 50 years Camp Forest has healed and a diverse forest has developed from the young replanted stands Orville originally acquired. Although the careful stewardship of the Camp family has helped, Orville admits that much of the recovery has been due to the old-growth and late-seral forest habitats on adjacent BLM land, providing a repository of biodiversity.
Camp Forest, owned and managed by Orville and Mary Camp, is the large swath of forest at the center of this photograph (the green flat before the valley openings). The forest has grown from a clear-cut over 50 years ago into the maturing forest it is today. In the distance is Eight Dollar Mountain and the Kalmiopsis Wilderness.

Orville remembers the days of old-growth logging in the Deer Creek Watershed. His family worked in the logging industry, cutting the extensive old-growth forests that surrounded the community of Selma. Today he and his wife, Mary, are advocates for the forests that surround them. They are working hard to protect the old forests that remain. After all these years they don't want to witness more old forest fall to the saw; if Pickett West is logged they may, unfortunately, get a front row seat.

Orville and Mary Camp at the Camp Forest property.
This last weekend Orville looked at me, visibly distressed at the thought of Pickett West being logged all around him, and said, "I am more concerned than I have ever been because these are the last remnants of old-growth. Once they are gone they cannot be recovered and they will never return."

As I left to survey the units surrounding their home Mary wished me luck and sincerely thanked me for my efforts; however, the fact that these forests still stand is largely due to Mary's efforts and the gratitude is mutual.

As I hiked through beautiful, threatened, old-growth forest, I thought of the Camps, their little refuge in the trees and the horror that will fill their hearts if they have to hear these giant trees fall.

Below are a few of the Pickett West units near the Camp Forest property:

Unit 27-12
Old-growth forest habitat proposed for heavy industrial logging to 30% canopy cover in unit 27-12.

Unit 27-12 is a beautiful stand of old-growth forest, located directly adjacent to the Camp Forest property. The area has been used for many years as an educational laboratory for students of ecology and Natural Selection Ecostry. Thousands of individuals from around the world have come to this stand to study its late-seral habitat conditions.

The forest in unit 27-12 contains all the characteristics of old-growth forest, including large, old trees up to 5' in diameter, large snags, downed wood, a complex multi-tiered canopy, high levels of canopy closure, undisturbed biological legacies and sufficient levels of decadence. The Northern Spotted Owl has been seen in the stand on many occasions and their primary prey species, the Red Tree Vole, is also known to nest in a 5' diameter Douglas fir tree.

Dominated by large Douglas fir, tanoak and madrone, with scattered old-growth sugar pine, the stand is naturally quite fire resistant. The understory is also relatively open with minimal ladder fuels. 

In 2005, the BLM approved the construction of the Thompson Overlook Trail, a non-motorized trail leading from Thompson Creek Road to the headwaters of Camp Creek. Due to a lack of funding, volunteers and agency support, the trail has not yet been constructed. A portion of the trail would traverse unit 27-12.

The BLM has proposed a "restoration thinning" prescription for unit 27-12. This prescription will maintain only 30% canopy cover and remove many large, old trees. 

Unit 21-12
Old-growth forest habitat in unit 21-12.

Unit 21-12 is located on a southwest facing slope above the Camp Forest property. The stand supports old-growth characteristics and a wide variety of stand conditions. 

The western portion of the unit consists of predominately 20"-30" sugar pine and Douglas fir with an understory of tanoak, madrone and manzanita. Clear groupings of large, old trees create a filtered, patchy canopy structure. Fire resilience is high due to the dominance of large trees with high canopies and thick insulating bark. The western portion of the stand is dispersal habitat for the Northern Spotted Owl.

The eastern portion of the stand is slightly more moist due to a faint draw and a more southeastern exposure. This portion of the stand is closed-canopy forest with large Douglas fir and sugar pine trees between 20" and 46" in diameter. The stand supports complex forest habitat identified by the BLM as Nesting, Roosting and Foraging habitat for the Northern Spotted Owl. 

The BLM has proposed a "restoration thinning" prescription in this stand. The prescription would remove the majority of the overstory trees, reducing the canopy cover to as low as 30%.

Unit 21-10
Lush, old forest in unit 21-10
Unit 21-10 is a unique, productive, and increasingly rare habitat. The stand supports low-elevation, old-growth forest on a gentle terrace. The gentle terrace covers about 18 acres, all of which is proposed for logging. 

According to the Pickett West EA, the stand is 140 years old, but many of the stand's largest trees are likely significantly older. The stand has a closed canopy with an abundance of large, old trees between 20" and 40" in diameter. Douglas fir and tanoak dominate the area in complex, fire resistant stands. 

The BLM has identified the stand as Nesting, Roosting and Foraging habitat for the Northern Spotted Owl and is proposing to downgrade owl habitat to dispersal. This means that the stand currently provides all the habitat needs for the Northern Spotted Owl, yet after logging has occurred it will only be useful for dispersal and will no longer support nesting, roosting or foraging habitat. 
  
Unit 21-11
Late-seral forest in unit 21-11
Unit 21-11 is located on very steep terrain and supports high quality Nesting, Roosting and Foraging habitat for the Northern Spotted Owl. The stand contains significant late-seral forest habitat, especially on the north-facing slopes. Large Douglas fir dominate these lush north-facing forests, with groupings of large trees scattered across the slope, creating a diverse, filtered canopy and complex forest structure. 

BLM is proposing to log this stand using a "density management" prescription. This prescription will retain 40% canopy cover, while removing many large, fire resistant trees. 

Unit 22-5
Coastal influenced old-growth habitat in unit 22-5.
Unit 22-5 is located on a steep north-facing slope. The forest is lush and coastal with a dense understory of evergreen huckleberry and a secondary canopy of  tanoak. The eastern portion of the stand is uncut, old-growth forest supporting massive old trees with complex branch structure, large diameter limbs and a patchy canopy distribution. According to the BLM, the stand represents dispersal habitat for the Northern Spotted Owl. This determination was made in error, as the stand is clearly high quality Nesting, Roosting and Foraging habitat. 

The BLM has proposed a "restoration thinning" prescription in this stand, removing canopy cover to as low as 30%. 

Logging these last fragments of old, complex forest will have dire consequences for the forests and wildlife of upper Thompson Creek. Forests currently providing refugia for old-growth dependent species like the Northern Spotted Owl, red tree vole, Pacific fisher and flying squirrel will be degraded. Nesting, Roosting and Foraging habitat for the Northern Spotted Owl will be downgraded to dispersal in density management units and eliminated entirely in "restoration thinning" units.

As canopies are opened, stands will also experience desiccation from increased exposure to sunlight and wind. Fire season will come early to these stands and fire hazards will increase as large, fire resistant trees are removed and fuel loads drastically increase. Opening canopy conditions to as low as 30% or 40% will trigger an extreme "shrub response" in the understory, creating a dramatic increase in fuel loads, reducing fire resilience and threatening the safety of nearby communities. 
Open, resilient old-growth forest in unit 27-13 adjacent to the Camp Forest property.

Nearly half the units proposed for logging in the Pickett West Timber Sale are located in stands over 150 years old. The Pickett West Timber Sale is not "forest restoration." This timber sale is an old-school timber grab, targeting the last remnants of old forest in the watersheds it proposes to log. Pickett West will threaten communities across southwestern Oregon by increasing fire hazards and reducing forest resilience. Our watersheds will suffer, habitat will be destroyed, our last old-growth stands will be fragmented and the beauty of our region sacrificed for timber production. 

The Pickett West Timber Sale should be canceled in its entirety and a new, more scientifically valid, socially acceptable and restorative approach pursued. 

Please consider commenting on this project before July 17, 2017. 

Submit comments to: 

Grant Pass Inter-agency Office/Don Ferguson

2164 NE Spalding Ave. 

Grants Pass, Oregon 97526

-or-
                                      blm_or_pwest@blm.gov