Monday, April 16, 2018

Action Alert: Chetco Bar Fire Salvage Logging Environmental Assessment Released. Comment now!

The Wild and Scenic Chetco River watershed is being targeted by the Rogue River-Siskiyou National Forest for post-fire, clearcut logging. This beautiful watershed deserves better. It is up to us to protect the clean, clear waters of the Chetco River. Please comment on the project now!
The Rogue River-Siskiyou National Forest has released its Environmental Assessment (EA) for the Chetco Bar Fire Salvage Project. The proposal includes 4,090 acres of post-fire logging, most of which will be implemented as vast clearcuts on steep, unstable slopes. Although you may have heard that the project will log only previously logged plantation stands, this claim is far from the truth. Of the 4,090 acres proposed for logging and replanting, 2,222 acres, or 54% of the proposed logging and artificial reforestation, is located within unmanaged stands (i.e forests that have never been logged). These unmanaged stands contain a variety of habitats and structural conditions, but many of them support late successional or old-growth characteristics. Those stands that burned in stand replacing fire events, but supported late successional habitats before the fire, create highly diverse, wildlife rich conditions identified as complex, early successional habitat. Complex, early successional habitat is the most important post-fire habitat in the planning area, however, these habitats are being targeted for logging due to their enormous timber volumes. This means the lion's share of timber production will be coming off the lands with the highest ecological values. 

The EA acknowledges the importance of post-fire ecosystems stating, "stand replacing events such as portions of the Chetco Bar fire often produce early-successional (early seral) forest ecosystems which are diverse in species, process and structure. Post-fire ecosystems often contain biological legacies, including dead standing (snags) trees, and down woody debris. The legacies and post-fire plant communities provide resources that attract and sustain high watershed to landscape-scale species diversity, including early-successional obligates."  Also, according to the EA, areas subjected to post-fire logging and replanting "are expected to lose their diversity in species, process and structure (complexity)." This loss of diversity, process and structure translates to diminished habitat values, degraded water quality, impacted post-fire regeneration, and more uniform, explosive fuel loads in future fires, due to artificial reforestation and simplified structural conditions.
An example of complex, early-seral habitat in the Mineral Hill Fork. Stands like this will be converted from diverse, post-fire habitat into stump fields and highly fire-prone, plantation-like stands.

Many of the areas proposed for logging contain highly diverse plant communities, geologic histories and burn mosaics. Although many of the proposed units consist of intensely burned habitats, stands with as little as 50% mortality have been included in post-fire logging plans, meaning stands that largely survived the fire will be subjected to post-fire logging practices. 

Numerous important habitats have been proposed for post-fire logging, including units within unroaded, unmanaged or undeveloped areas near Packer's Cabin in the Quail Prairie Creek watershed, at the lower end of Quail Prairie Creek, in the vicinity of High Prairie above the Chetco River, in the Eagle Creek and Mineral Hill Fork watersheds, and above the Pistol River on Sunrise Creek. Many wild and beautiful landscapes will be reduced to stump fields and replanted in plantation-like stands if this proposal is approved. 
The forest in this photograph will be logged as a roadside hazard unit and as unit 25 in the Chetco Bar Fire Salvage Project. Located at the head of Quail Prairie Creek, this intact forest legacy should be retained and unit 25 should be canceled immediately to protect the important complex, early-seral habitat provided by fire-affected, old-growth stands.

Perhaps more devastating than the logging itself is the over 13 miles of new road construction proposed to access post-fire logging units. These roads will be built on intact ridgelines, on steep, erosive slopes, and above important fisheries habitat in the Chetco River Watershed. The Forest Service calls these "temporary roads," yet there is nothing temporary about the actual ecological impacts of road construction. Numerous of these roads consist of long segments, rather than small extensions of existing roads. Many roads are also proposed to be built across steep, mountainous slopes, creating large road cuts and permanent impacts to hydrology, soils, water quality, fisheries, noxious weeds spread and wildland habitats. Simply closing or decommissioning the roads does not negate these problems. 

The Chetco Bar Fire Salvage Project is one of the largest, most damaging federal land management projects proposed in our region for many years. The project has no restorative value or benefit to the surrounding ecosystem; in fact, the EA documents that significant scientific research has concluded, "in general, little research supports the idea that salvage logging has beneficial ecological effects on terrestrial and aquatic resources." The Chetco Bar Fire Salvage Project fails to serve the public interest, and instead, is responsive only to the needs of the timber industry that will profit from clearcutting vast swaths of public land. 

Our public lands will be sacrificed to the highest bidder if this project is approved, but it will be low value "salvage" timber in a market already flooded by the estimated 9,455 acres harvested from private timber lands in the Chetco Bar fire perimeter. This basically ensures that federal timber will be sold at bottom-of-the-barrel prices, creating a net loss to the public taxpayer. In essence, the entire project is corporate welfare, and after footing the bill, the public will be stuck with the long-lasting ecological consequences. 
Unit 121, on the slopes above Quail Prairie Creek, is proposed for tractor logging. The unit contains many large old, fire-killed snags and highly diverse post-fire habitat. The unit, along with many proposed on north-facing slopes above Quail Prairie Creek, should be canceled to protect habitat values, fisheries and water quality. 

The Chetco River is worth far more as a diverse, intact ecosystem, than as just another coastal tree farm. The decisions we make today will impact this beautiful, productive watershed for generations to come. Which do you prefer? Diverse post-fire landscapes or the real catastrophic disturbance taking place in the Chetco River watershed: post-fire industrial logging?

Which do you prefer? Post-fire clearcuts....
...or spectacularly wild river canyons and naturally diverse, regenerating forest?

Please send your public comment as an email message, plain text (.txt), rich text (.rtf), or word (.doc) formats to:  

Talking Points for Public Comment
  • Cancel all post-fire logging units in complex, early successional habitat throughout the planning area. 
  • Cancel all units in undeveloped areas identified in the planning area. 
  • Cancel all units in Post-Fire Foraging habitat for the Northern spotted owl. 
  • Cancel all new road construction to protect aquatic habitats and water quality in the Chetco River watershed. 
  • Cancel all artificial reforestation units. Natural tree regeneration provides adequate reforestation, creates a more healthy habitat mosaic, harbors higher levels of biodiversity, and provides more patchy, fire resilient, early-seral habitats than artificial reforestation. 
  • Cancel all units in Quail Prairie Creek, Mineral Hill Fork, Eagle Creek, around Packer's Cabin and Long Ridge, above the Chetco River, near High Prairie above Road 1376, and above Mislatnah Creek.
  • Conduct activities that provide for public safety, maintain undeveloped habitats, encourage complex, early successional forests, biodiversity, and create more fire resilient habitats adjacent to the community of Brookings. Backcountry logging and artificial reforestation provides absolutely no benefit to communities at risk in the Brookings area.  
  • Cancel all units that will impact the viewshed for recreational users along the Chetco River and its tributaries. Recreation on the Chetco River helps sustain the economy of southern Oregon's coastal communities. Logging public land will diminish the recreational experience along the Wild and Scenic Chetco River and its tributaries. 

Friday, April 13, 2018

Klamath National Forest Proposes Post-Fire, Clearcut Logging on the Siskiyou Crest near Cook and Green Pass!

Upper Horse Creek, the Condrey Mountain Inventoried Roadless Area, Johnny O'Neil Late Successional Reserve, and the Abney Fire viewed from the Siskiyou Crest. The burned forest at the center of this photograph is proposed for clearcut logging by the Klamath National Forest.

The 2017 Abney Fire burned for over two months in both the Applegate River and Klamath River watersheds. The fire burned nearly 40,000 acres on both sides of the Siskiyou Crest, including some of the wildest country in the Siskiyou Mountains. The Abney Fire burned in a characteristic, mixed-severity fire mosaic, creating diversity and habitat heterogeneity on the landscape scale.

After the smoke cleared, the Klamath National Forest (KNF) did what they do following almost every fire season—they proposed to clearcut vast swaths of fire-affected forest in sensitive land management allocations. This year's damaging proposal is located high on the slopes of the Siskiyou Crest and adjacent to Cook and Green Pass, one of the most diverse plant communities in all of California.

The KNF recently released an Environmental Assessment and initiated a public comment period for the Seiad Horse Project. The project is a massive post-fire, clearcut logging proposal on the southern flank of Siskiyou Crest, in the Klamath River watershed. Located in between the Condrey Mountain Inventoried Roadless Area, Kangaroo Inventoried Roadless Area, the Red Buttes Wilderness Area, and the Cook and Green Pass Botanical Area, on a steep ridgeline near Copper Butte, the region is wild, remote, spectacularly diverse and particularly important for habitat connectivity.
Inventoried Roadless Areas are depicted in green. Surrounding the Red Buttes Wilderness Area is the Kangaroo Inventoried Roadless Area, to the east is the Condrey Mountain Inventoried Roadless Area. The areas depicted with green stripes are uninventoried roadless areas identified by conservation organizations. The area outlined in red shows the Seiad Horse Project area. The Cook and Green Pass Botanical Area is located at the northwest corner of the project area. Logging in this particular location will have significant impacts to connectivity, botanical values, back country recreation and intact native habitats.

The entire project is also located within the Johnny O'Neil Late Successional Reserve (LSR), an area set aside to protect late successional forest habitat and connectivity for the Northern spotted owl, as well as other old forest associates such as the Pacific fisher. The Johnny O'Neil LSR was designated specifically to protect and maintain connectivity between the Klamath River Watershed and the headwaters of the Applegate River, allowing dispersal between southern Oregon and northern California.

The Johnny O'Neil LSR contains large stands of uncut, old-growth forest, especially on the northern slopes of the Siskiyou Crest above the Applegate River and on the Rogue River Siskiyou National Forest (RR-SNF). Much of this relatively intact, unmanaged forest burned at low severity in the Abney Fire, clearing back understory fuels, recycling nutrients and maintaining complex canopy conditions.

The KNF portion of the Abney Fire, on the other hand, contained large swaths of plantation forest interspersed with stringers of intact, old-growth forest. The KNF portions of the Abney Fire burned at much higher severity. Previous logging operations had converted large swaths of fire-adapted ancient forest into simplified plantation stands. These plantation stands contained heavy fuel loads and dense, even-aged vegetation with very little fire resistance. The Abney Fire burned through most of these former plantations at high severity, creating relatively large swaths of stand-replacing fire and thrusting the fire into the canopy of the remaining old-growth stands. These old-growth stands are now proposed for clearcut, post-fire logging.
This map shows the density of plantation stands on the southern face of Copper Butte before the Abney Fire. Each plantation is outlined in green along with the year it was clearcut and replanted into plantation structure. It is no coincidence that this particularly large, interconnected plantation area burned at high severity. The KNF is currently proposing to clearcut many of these stands again in the Seiad Horse Project, and replant with conifers, despite the correlation between plantation stands and high-severity fire effects in the Abney Fire.

This maps shows fire severity on the southern face of Copper Butte in the Abney Fire. Red depicts high-severity fire effects, while yellow depicts moderate-severity fire effects, and green depicts low-severity fire effects. Using the upside down L-shaped piece of private land in the center for reference, notice the correlation between high-severity fire effects on this map and plantation stands in the map above.

Ironically, many of these plantation stands were developed by the KNF following post-fire logging in the late 1980s and early 1990s. At the time, the stated goal was to reduce future fire severity and accelerate forest establishment. Unfortunately, these goals were not met, and just a few years later the Seiad Creek Watershed Analysis identified these very stands as some of the worst fire hazards in the Seiad Creek area. It is no coincidence that these plantation stands also constitute the largest concentration of stand-replacing, high-severity fire in the entire Abney Fire. 

KNF crews also lit irresponsible backburns during the Abney Fire that compounded the severity of fire effects in upper Seiad and Horse Creeks. Crews added fire and intensity with their backburning operations, and as the fire approached the Siskiyou Crest and merged with intentionally lit backburns, it built momentum. Fire susceptible plantations stands, south-facing slopes, montane chaparral, active fire weather and overly aggressive fire suppression activities combined to create a fast moving fire with significant stand-replacing fire effects. Much of the area burned in a mosaic of stand-replacing fire, punctuated by patches of living, green trees.

A mosaic of live and dead trees in Upper Horse Creek. This forest is proposed for clearcut logging in unit 37 of the Seiad Horse Project.
In response to the Abney Fire, Rogue River-Siskiyou National Forest staff have proposed only hazard tree removal along existing Forest Service roads. The agency is working to protect public safety, preserve the beneficial mosaic of the Abney Fire, and maintain the important biological values of the Siskiyou Crest and Johnny O'Neil LSR.

Meanwhile, the KNF has proposed to clearcut and replant over 2,000 contiguous acres on the southern face of Copper Butte, turning the Siskiyou Crest into a sacrifice zone. The project proposes to clearcut unmanaged forests, fire-affected, old-growth habitats and uninventoried roadless areas. The massive clearcuts would extend from the Seaid and Horse Creek canyons to within a quarter mile of the Siskiyou Crest, severing habitat connectivity between wildlands, major watersheds, and east to west across the Siskiyou Crest Connectivity Corridor.  
A view from the Siskiyou Crest and the Pacific Crest Trail into the Abney Fire and the Seiad Horse Project. The fire-affected forest at the headwaters of Horse Creek is proposed for clearcut logging and plantation development. The impacts to ecological, recreational and scenic values will be severe if the Seiad Horse Project is implemented.

Complex, early-seral plant communities are beginning to develop throughout the KNF portions of the Abney Fire. The snag forests targeted by the KNF for clearcut logging will maintain habitat complexity and aid in the recovery of late successional forest habitats, if left to recover naturally. Unlogged snag forests will contribute large downed wood, standing snags, shade, and microclimates for a diversity of forest species to reestablish themselves in the years following the Abney Fire. 

These complex, early-seral snag forests are also an important and highly diverse successional stage that contributes significantly to the development of complex forest habitats. The standing snags will provide important wildlife habitat for many decades. They will then fall to the forest floor, building soil, holding moisture, reducing erosion and providing important wildlife habitat for hundreds of more years. They will be the only biological input of large wood and large snag habitat on these sites until large, old trees are again established. 
Large, high quality wildlife snags such as this one will be logged in the Seiad Horse Project, converting complex, fire-affected, old-growth habitat into biologically sterile tree plantations. The important ecological values of the post-fire environment will be destroyed by post-fire logging. This photograph depicts current stand conditions in unit 9 of the Seiad Horse Project.

In essence, these snag forests provide continuity and biological legacies for the long transformation ahead. As the forest transitions from complex, early-seral habitat into mature or old-growth forest, these fire-killed trees will act as, perhaps, the most important structural feature on the landscape. Snags are the foundation of forest regeneration and must be maintained.

Despite the inherently beneficial qualities of natural fire recovery and the underlying land management allocation (LSR forest), the Klamath National Forest is proposing to clearcut this biologically diverse and highly productive habitat, disturb the complex, natural regeneration of this forest, recreate the same fire susceptible plantation stands that just burned at high severity, and rob future forests of important biological legacies by removing vast tracts of snag habitat. The KNF also proposes to log living, green trees that survived the fire and are predicted by Forest Service timber managers to die within 3 to 5 years. The cumulative impact will be a loss in biological legacies, forest complexity and regenerative capacity, while increasing future fire severity.

The KNF is proposing to log large, old trees and snags in previously unmanaged stands, converting them into biologically sterile fiber plantations. This reckless proposal would severe the connectivity of the Siskiyou Crest and the Johnny O'Neil LSR, despite management directives requiring the agency to maintain these important public land values. Unfortunately, the only value the Klamath National Forest currently sees in this post-fire landscape is the value of commercial logging for private industrial profit. 
The Klamath National Forest has failed to recognize the ecological or biological values of fire-affected forests; instead, the agency regularly uses wildfire as an excuse to degrade public resources and lose vast sums of public money for the sole benefit of private timber industry profits. The photograph depicts current stand conditions in unit 36 of the Seiad Horse Project.

As they do most every spring, the KNF is proposing to offer public timber from LSR forest to private timber industry interests at extremely low prices and at a massive loss to taxpayers. On the KNF, wildfire is regularly used as an excuse to implement clearcut logging in old-growth forest reserves for the sole benefit of the private, industrial timber industry. 

The Siskiyou Crest deserves better and the KNF must be stopped! Enough damage has been done to this unique watershed by irresponsible fire suppression activities and previous post-fire logging. Please write a public comment on the Seiad Horse Project. We need you to speak up and help defend the Siskiyou Crest. Form letters are often ignored. Individually submitted comments have the most impact.

Send comments to the Klamath National Forest before the deadline on May 7, 2018. Comments can be submitted at this link.

Talking Points: 
  • Cancel all post-fire logging units and focus the Seiad Horse Project on community fire protection rather than back country logging.
  • Implement prescribed fire treatments to reduce fuel loading and protect nearby communities from wildland fire.
  • Cancel all post-fire tree planting, including site prep and plant units, to avoid unnatural fuel loads, stand conditions, and regeneration. 
  • Cancel roadside hazard logging on road 47N80 in the Kangaroo Inventoried Roadless Area. Road 47N80, the road to Bee Camp, should be closed and the Kangaroo Roadless Area allowed to regenerate naturally after the Abney Fire.
  • Protect the connectivity, biodiversity and other biological values of the Siskiyou Crest by canceling all units within two miles of the ridgeline. 
  • Cancel all post-fire logging units in the East Fork of Seaid Creek.
  • Protect the scenic and recreational qualities of the Pacific Crest Trail (PCT) by canceling all post-fire logging units within a mile of the PCT.
  • Protect the viewshed of the PCT by canceling all post-fire logging units visible from the PCT between Cook and Green Pass and Slaughterhouse Flat.
  • Build no new logging roads, either "temporary" or "permanent" roads, in the planning area.
  • Focus "fire recovery" actions on mitigating impacts associated with discretionary fire suppression activities, such as fireline rehabilitation, the removal of activity slash along firelines, and the permanent closure of firelines to discourage OHV use.  
  • Cancel all proposed activity in the Cook and Green Pass Botanical Area. This area is special and deserves the highest level of protection. The KNF's own website, provides the following description of the Cook and Green Pass Botanical Area :
    Cook and Green Pass Botanical Area is 700 acres located within the Siskiyou Crest Zone (T47N, R11W, Secs 8,9,10) and contains a mosaic of plant communities and is considered to be the dividing line between the eastern and western Siskiyous. This area has a phenomenal concentration of native plant species, one of the richest areas in California, with possibly as many as 300 species present. The area also contains a large stand of Siskiyou Cypress (Cupressus bakeri ssp. matthewsii). Rare or sensitive plants present include Pedicularis howellii, Siskiyou lewisia (Lewisia cotyledon), Antennaria racemosa, and Lilium wigginsii. Botanists and plant enthusiasts from around the country have considered the Cook and Green Pass area signifcant for years.                                                                                                                                                                               
    Protect Cook and Green Pass and the surrounding wildlands from destructive post-fire logging. Stop the Seiad Horse Project! 

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