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.

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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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