The Squishy Bug Timber Sale: "Salvage" Logging, Bark Beetles and Invalid Assumptions for NEPA Analysis

A large "group selection cut" in the Squishy Bug Timber Sale on the west face of Woodrat Mountain above Ruch, Oregon. The BLM removed many large, living trees in this unit, creating small clearcuts in forest that survived the 2016 bark beetle outbreak.

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The Squishy Bug Timber Sale: "Salvage" Logging, Bark Beetles and Invalid Assumptions for NEPA Analysis

In the spring of 2016, a relatively large-scale outbreak of flat headed fir borer beetles spread throughout the more arid portions of the Applegate Valley. The usually chronic, but low levels of bark beetle mortality generally present in the Applegate were temporarily replaced by an increased and eruptive level of bark beetle mortality. This relatively short-lived outbreak was triggered by the drought conditions of 2013-2014 that allowed flat headed fir borer populations to expand quite rapidly. Although this was a large-scale outbreak for the region, it was selective, killing Douglas fir trees in patches in marginal habitats and in previously logged areas.

The Klamath Forest Alliance, Applegate Neighborhood Network and the Siskiyou Crest Blog work together to examine BLM timber management in the Applegate Valley. Our recent monitoring and research has shown a connection between BLM thinning operations and concentrated bark beetle mortality. In November 2017, we provided a detailed monitoring report to the local BLM and the U.S. Fish and Wildlife Service (USFWS), Bark Beetles, Timber & the BLM in the Applegate Valley: An Overview of Bark Beetle Science and Land Management on the Medford District BLM

In our report we documented how many forests subjected to commercial thinning in the Applegate Valley since 1990 have sustained high levels of bark beetle mortality. This is significant for many reasons, the most obvious of which, is that since 1990 nearly every timber sale proposed by the BLM in the Applegate watershed was predicted to have beneficial or restorative effects. BLM analysis and USFWS consultation is heavily dependent on the predicted "forest health" benefits of commercial thinning. The assertion is that by removing trees, reducing canopy cover levels, and reducing competition between trees, both individual tree and stand level vigor will improve. According to BLM analysis, the projected increase in vigor will translate directly to an increase in resistance to bark beetle mortality.

This stand like, many others in the Squishy Bug Timber Sale, was commercially thinned in the 1990s and then logged again roughly 20 years later. The BLM claimed in earlier environmental analysis that commercial thinning would accelerate the development of late successional characteristics and canopy conditions would recover in between 10 and 30 years. This previous analysis has proven invalid and inaccurate. In the 20 years since the initial "forest health" thinning, the canopy conditions have unraveled due to significant mortality and "salvage" logging in the Squishy Bug Timber Sale.

   
The agencies also claim that in the long term, habitat values for late successional (i.e old-growth dependent) species like the Northern spotted owl (NSO) and Pacific fisher will be improved through commercial logging. BLM analysis claims that by reducing competition and increasing both vigor and growth, the development of late successional characteristics will be accelerated, creating high quality habitat for the Northern spotted owl. 

Unfortunately, although many large, landscape-scale commercial thinning projects have been implemented in the area since 1990, they have often failed to create the intended or predicted results. The heavy commercial thinning treatments implemented by BLM have instead made many forest stands more susceptible to drought stress and less resistant to bark beetle mortality. They have also progressively degraded late successional habitat conditions through commercial thinning operations and their unintended consequences.

A group selection cut in the Squishy Bug Timber Sale on Grub Gulch, a tributary of Sterling Creek. The vast majority of the trees removed in this unit were live, green trees that survived the 2016 bark beetle outbreak in the Applegate Valley.

Recently, the BLM approved the Squishy Bug Timber Sale in the Sterling Creek watershed and on the western face of Woodrat Mountain above Ruch, Oregon. The timber sale was approved with a Categorical Exclusion (CX), meaning it was approved without the normal public comment process and without a thorough Environmental Analysis (EA) or review. 

In the CX approval document the BLM describes the timber sale as a "salvage" and hazard tree logging project that will remove only dead and dying trees. The agency utilized Forest Service guidelines for hazard tree removal along roads, landings and work sites (Filip 2016). The Forest Service document identifies guidelines for evaluating public safety hazards associated with dead standing or damaged trees. The document provides guidance for hazardous tree removal; however, it does not consider or provide guidance for green tree removal or logging in areas far from roads or infrastructure.

In fact, the guidelines recommend against removing live trees under a CX stating, "In some cases, line officers have decided to remove live trees that have a very low-probability of survival post-fire (e.g. trees with >90% crown scorch or consumption) within striking distance of roads that would most likely become dangers in the future. This usually requires a different level of NEPA than a road maintenance Categorical Exclusion." (Filip P. 45)

Many live trees have been logged in the Squishy Bug Timber Sale.

Unfortunately, the BLM did not follow these recommendations, instead they misused their CX authority and the hazard tree removal guidelines in order to log many green, living trees with little to no sign of bark beetle activity. Many of these trees were far from roads and infrastructure. These green trees posed absolutely no elevated safety risk and should not have been logged without public input or a thorough environmental analysis. 

Bark beetle mortality in both chronic, low level conditions and in eruptive outbreaks has been shown to be highly selective. Bark beetle outbreaks can result in strong natural selection, promoting trees with favorable genetic traits for bark beetle resistance. 

These same trees — those that survived the bark beetle outbreak of 2016 and contain favorable genetic traits — are now being logged by the BLM in the Squishy Bug Timber Sale. The removal of potentially bark beetle resistant trees and the intensity of logging taking place will reduce resistance to future bark beetle outbreaks by removing genetically adapted trees and impacting microclimate conditions that support bark beetle resistance.

The actual results of the Squishy Bug Timber Sale are very similar to a green tree timber sale, yet the rigor of analysis and the public involvement process was not. By suggesting that only dead and dying roadside hazard trees would be removed, the agency evaded the more detailed analysis required for green tree logging.  

Many of the Squishy Bug units extend far from roads and include the removal of many large, green, healthy, genetically adapted trees that pose no public safety risk. In numerous units it is estimated that up to 80% of the trees removed were green, living trees. These units often included "group selection" logging where trees were removed in patches, perhaps one to two acres wide that function like small clearcuts. The units are punctuated by these little clearcuts that look like denuded stumpfields. The remaining portion of these stands were heavily thinned, leaving perhaps 15%-25% canopy cover in some units and only scattered overstory trees. 

A unit in the Squishy Bug Timber Sale on the western face of Woodrat Mountain. Despite being analyzed as a "salvage" logging timber sale that would remove only dead and dying trees, many green, living trees were logged. Notice the thick layer of green foliage on the forest floor. This demonstrates the number of living trees logged in the Squishy Bug Timber Sale.

It is highly likely that the residual trees left after logging in the Squishy Bug Timber Sale will begin to lose vigor and the stands will further decline, losing canopy and overstory trees to bark beetles, wind-throw, drought stress, and disease. Some trees intended for retention have been badly damaged in yarding operations, including both conifers and hardwoods such as oaks. Logs were also dragged through the units, creating significant soil disturbance that will likely increase soil erosion rates and noxious weed spread. 

It is important to note that the Squishy Bug Timber Sale is being implemented entirely within previously logged units. It is also important to note that these units were nearly all logged utilizing the BLM's so-called "forest health" thinning prescriptions. The intended outcome was a forest of increased vigor, increased resistance to bark beetle outbreaks, and stands where old-growth or late successional characteristics have been accentuated by commercial thinning operations. Instead, these stands have unraveled and become the center of the 2016 bark beetle outbreak in the Applegate Valley. Contrary to the projections that logging will accelerate late successional characteristics, many of the stands have reverted to early-seral habitat conditions — the exact opposite of what was predicted.

A unit in the Sterling Sweeper Timber Sale in Deming Gulch, a tributary to Sterling Creek and the Little Applegate River, after it was logged in 2014. The Sterling Sweeper Timber Sale environmental analysis incorrectly projected that logging would increase "forest health" and resistance to bark beetle infestations. The unit was logged in 2014 and was followed by a significant bark beetle outbreak. This photo was taken in 2016, two years after the initial logging. Notice how many of the leave trees died after logging occurred.

This lower photograph depicts the same area after the Squishy Bug Timber Sale in March 2018. Although the stand was predicted to respond positively to the previous Sterling Sweeper Timber Sale, canopy cover conditions deteriorated due to bark beetle mortality and "salvage" logging. The trees that died after Sterling Sweeper were then logged in the Squishy Bug Timber Sale, leaving a small clearcut where a forest once stood.

Applegate Neighborhood Network and Klamath Forest Alliance have released a new report on the Squishy Bug Timber Sale. The report provides further evidence of invalid Endangered Species Consultation and inaccurate or incomplete environmental analysis. The projected benefits of commercial logging are simply not materializing. BLM and USFWS have so far refused to accept the reality of this situation; instead, they continue with the same mantra, that commercial thinning has only beneficial outcomes, hoping that if they repeat the mantra enough times it will become true. Unfortunately, the results are written across our landscape and the implications are clear: BLM logging practices in the Applegate Valley are having detrimental impacts. These impacts include significant overcutting, increased drought stress, increased bark beetle mortality, increased fuel loading, and a progressive loss of late successional habitat characteristics. 

Please read our full report, The Squishy Bug Timber Sale: Salvage Logging, Bark Beetles and Invalid Assumptions for NEPA Analysis

The Squishy Bug Timber Sale created small clearcuts, removing living and dead standing trees.