Thursday, December 26, 2019

Klamath Forest Alliance, Siskiyou Field Office: A Year in Review

Klamath Forest Alliance works to protect the wildlands of the Klamath-Siskiyou Mountains.
At the Siskiyou Field Office of Klamath Forest Alliance (KFA) 2019 was busy and eventful. We advocated for conservation throughout the Siskiyou Mountains, opposing damaging federal land management projects and worked on policy issues surrounding fire and smoke in the state of Oregon. 

This past year we have worked on projects as diverse as the Siskiyou Mountains themselves — from the fog drenched forests of the Wild Rivers Coast and into the serpentine barrens of the greater Kalmiopsis Wildlands. We also worked in the the chaparral, woodlands and forest habitats of the Applegate Valley; the rocky high country of the Siskiyou Crest; the rugged canyons of the Klamath River; and the transition between the Siskiyou Crest and the Cascade Mountains in the Soda Mountain Wilderness Area and Cascade-Siskiyou National Monument.

We officially submitted substantial comments for five Forest Service projects and four BLM projects, including off-road vehicle developments and timber sales. We participated in two separate requests for comment for public land protections in Oregon. We also filed two administrative objections and one major lawsuit on Forest Service projects on both the Rogue River-Siskiyou National Forest and the Klamath National Forest.  

In 2020 we hope to expand our programs and do even more to protect the Klamath-Siskiyou Mountains and their world-class biodiversity! Please support our work!

  The Applegate Foothills
The Applegate Foothills contain a unique and highly diverse mixture of oak woodland, chaparral and dry conifer forest. They also contain extensive wildland habitats threatened by BLM timber sales, road construction and off-road vehicle use.

KFA has been monitoring multiple projects in the mountains surrounding the Applegate Valley. These projects include the Middle Applegate Timber Sale, the Bear Grub Timber Sale, the Late Mungers Timber Sale and the Upper Applegate Watershed Restoration Project.

   Middle Applegate Timber Sale
A view across the Wellington Wildlands to the Applegate Valley.
In 2018, the Middle Applegate Timber Sale was proposed by the Medford District BLM. The Middle Applegate Timber Sale included a vast planning area sprawling across the Middle Applegate Watershed. At the center of the planning area was the 7,527-acre Wellington Wildlands, a significant unprotected roadless area west of Ruch, Oregon. 

KFA immediately began working with numerous conservation allies to oppose the Middle Applegate Timber Sale and protect Wellington Wildlands. In the fall of 2019, after over a year of consistent campaigning by KFA and others, the BLM officially withdrew the timber sale. Through the efforts of KFA and numerous conservation allies, thousands of acres within the Wellington Wildlands had been spared and the Middle Applegate Timber Sale was canceled!

Bear Grub Timber Sale 

Immediately following the withdrawal of the Middle Applegate Timber Sale, the Medford District BLM announced the new Bear Grub Timber Sale. This timber sale includes the mountains around Ruch, Oregon, the Little Applegate Valley and Sterling Creek. Although the vast majority of the Wellington Wildlands was excluded from the Bear Grub project, a few units have been proposed in the eastern portion of Wellington Wildlands on China Gulch. 

The Bear Grub Timber Sale proposes commercial units along the popular East Applegate Ridge Trail, Jack-Ash Trail and Sterling Mine Ditch Trail. It also includes old-growth units on Bald Mountain in the small, but highly diverse Bald Mountain Roadless Area. Bald Mountain is important for not only its biodiversity, but as a vital link between high and low elevation habitats in the Little Applegate River Watershed.

KFA is working with conservation allies to monitor the proposed timber sale units and has submitted detailed public scoping comments on the Bear Grub Timber Sale. We are committed to working throughout 2020 on the Bear Grub project to encourage the BLM to focus on non-commercial thinning adjacent to homes and communities, rather than environmentally harmful backcountry logging in wildlands.

Late Mungers Timber Sale
Old forest proposed for logging on Mungers Butte.
The Medford District BLM has also proposed a large timber sale in the mountains between Williams, Oregon and Selma, Oregon in the Illinois River Watershed. The project encompasses a large Late Successional Reserve designated to protect habitat for the Northern spotted owl. It is also located in an important connectivity corridor linking the greater Kalmiopsis Wildlands to the Siskiyou Crest. 

The project proposes timber sale units in upper Deer Creek above the community of Selma, in Murphy Creek above Murphy, and in numerous watersheds above the community of Williams in the Applegate Valley. Timber sale units include uncut old-growth forest and diverse, geologically unique serpentine habitats on Mungers Butte.

KFA has been out monitoring the project and in 2020 we will continue leading the opposition to this damaging timber sale.

Upper Applegate Watershed Restoration Project (UAW Project)

KFA has been working on the UAW Project for over four years. We have worked collaboratively with non-profit organizations, Applegate Valley community members, and the Rogue River-Siskiyou National Forest to create a fire, forests, and habitat restoration project focused on prescribed fire for community fire protection, plantation thinning and native plant and pollinator habitat restoration. 

In many ways we are excited to see the Forest Service embrace a more ecological and community-driven approach to project planning, and we support large portions of the project; however, it has been necessary to oppose new off-road vehicle trails proposed by the agencies in the Beaver Creek Watershed, a salmon bearing tributary of the Upper Applegate River. The proposed off-road vehicle trails have no ecologically beneficial results, cannot be described as "restoration," and have been heavily opposed by the Applegate Valley community. 

In 2019, we provided detailed public comments on the project and filed an administrative objection asking the agency to cancel all off-road vehicle trails in the UAW Project. In 2020 we will continue standing with the Applegate Valley community and advocating for cancellation of all motorized trails in the UAW Project. We will also work collaboratively to implement the beneficial portions of the project and monitor implementation to ensure the project's habitat restoration goals and objectives are either met or exceeded.  
The Siskiyou Crest
A view north from Bolan Mountain on the Siskiyou Crest, looking down at Bolan Lake.

The Siskiyou Crest is one of the most important connectivity corridors and botanical hotspots in Western North America. It also contains some of the wildest habitat in our region. KFA has been working on two major projects on the Siskiyou Crest, including the Seiad Horse Timber Sale and a comprehensive campaign for off-road vehicle closures in designated Botanical Areas, Inventoried Roadless Areas and other wildlands along the Siskiyou Crest.

Seiad Horse Timber Sale
The 2017 Abney Fire in upper Horse Creek.
Following the 2017 Abney Fire, the Klamath National Forest proposed the Seiad Horse Timber Sale, a large post-fire logging project near Cook and Green Pass and on the southern flanks of the Siskiyou Crest. The timber sale is located between the Kangaroo Inventoried Roadless Area and the Condrey Mountain Inventoried Roadless Area, adjacent to the Cook and Green Pass Botanical Area, the Pacific Crest Trail and within the Johnny O'Neil Late Successional Reserve. 

In 2018, immediately after its proposal KFA was out monitoring proposed timber sale units, writing detailed public comments, and filing administrative appeals. After exhausting all administrative remedies, KFA and other conservation allies filed suit against the Klamath National Forest in 2019. We will be arguing our case in the spring of 2020. Stay tuned!

Off-Road Vehicle Closures
Rehabilitating an illegal off-road route on the Siskiyou Crest.
Since 2015 KFA has been working with the Applegate Neighborhood Network (ANN) to monitor unauthorized off-road vehicle activity and document environmental impacts in the Applegate River Watershed and on the Siskiyou Crest. We have produced numerous off-road vehicle monitoring reports documenting the impact of off-road vehicle use in the region, and we use these reports to advocate for motor vehicle closures in sensitive habitat. In recent years we have focused our energy on protecting the Botanical Areas and Roadless Areas of the Siskiyou Crest from illegal off-road vehicle use. 

We are starting to see results from our hard work, and in 2019, together with the Rogue River-Siskiyou National Forest and other organizations, we helped close down and rehabilitate one extremely damaging off-road vehicle route in the Big Red Mountain Botanical Area. The Klamath National Forest also proposed two significant off-road vehicle closure projects on the Siskiyou Crest in 2019.

In 2020 we will continue our advocacy for the Siskiyou Crest, advocating for motor vehicle closures that will protect our botanical and biological heritage. We will specifically support and encourage the expansion of existing off-road vehicle closure projects on the Klamath National Forest, Rogue River-Siskiyou National Forest and on the Siskiyou Crest.

Cascade-Siskiyou National Monument
Scotch Creek in the Soda Mountain Wilderness Area and Cascade-Siskiyou National Monument.

Klamathon Fire Report
The 2018 Klamathon Fire burned from the Klamath River at Hornbrook, California and into both the Soda Mountain Wilderness Area and the Cascade-Siskiyou National Monument near Pilot Rock. The fire burned through the town of Hornbrook under high winds, burning homes, infrastructure, tragically taking one life and badly burning a firefighter; however, the fire slowed and the weather shifted as it burned into the Soda Mountain Wilderness. 

In response, the Medford District BLM and Oregon Department of Forestry bulldozed over 30 miles across the wilderness area and proceeded to drive throughout the wilderness area for over three months. Although the fire burned in a natural and ecologically beneficial mixed severity fire mosaic in the forests, woodlands and chaparral of the Soda Mountain Wilderness, significant ecological damage was done during suppression of the fire. 

Fire effects from the 2018 Klamathon Fire

Throughout 2019, KFA conducted field monitoring and scoured over BLM FOIA documents, reconstructing fire suppression activities and important fire events. In 2020 KFA will be publishing our Klamathon Fire Report, documenting the ecological impacts of inappropriate fire suppression activities and violations of the 1964 Wilderness Act in the Soda Mountain Wilderness Area. 

The impact of discretionary fire suppression activities has become one of the biggest impacts to our wilderness landscape. Designated Wilderness Areas, Roadless Areas, Botanical Areas and the region's incredible biodiversity are being increasingly impacted each fire season by inappropriate and ecologically damaging suppression activities. KFA is the only conservation organization in the Klamath-Siskiyou Mountains actively working to reform fire suppression policy and encouraging managed wildfire for resource benefit in backcountry areas. 

Kalmiopsis Wildlands
The Illinois River flows through the Kalmiopsis Wilderness Area and into the Rogue River at Agness, Oregon.
In 2019 KFA worked on two major projects in the greater Kalmiopsis Wildlands. These projects included the Shasta-Agness Timber Sale and the Upper Briggs Timber Sale, both on Rogue River-Siskiyou National Forest lands.

Shasta-Agness Timber Sale

The Shasta-Agness Timber Sale has been proposed in and around beautiful Agness, Oregon near the confluence of the rugged Illinois River and the mighty Rogue River. KFA conducted field monitoring and submitted detailed public comments on the Draft Environmental Impact Statement (DEIS) for the Shasta-Agness Timber Sale.

The Forest Service claims the Shasta-Agness Timber Sale is a "restoration" project, yet the actual project proposals demonstrate otherwise. Although cloaked in restoration language, the project proposes aggressive commercial logging, new road construction, reductions in current habitat protections for the Northern spotted owl and its most important prey source, the red tree vole, as well as new off-road vehicle trails.
The Shasta-Agness Timber Sale proposes logging units in Shasta-Costa Creek.

Much of the Shasta-Agness Timber Sale is located in the Fishhook  Late Successional Reserve (LSR). LSRs were set aside to provide habitat for the threatened Northern spotted owl, but are targeted for logging in this project. In the Draft Environmental Impact Statement for the Shasta-Agness Timber Sale, the agency has proposed "plan amendments" that would alter existing management plans for LSR forest, allowing the removal of trees over 20" in diameter and logging in stands over 80 years old. This sort of logging will negatively affect suitable Northern spotted owl habitat in the Shasta-Agness Planning Area and the Fishhook LSR. 

The project also proposes to strip important protections from tens of thousands of acres in the Fishhook LSR by eliminating many current protections for the Northern spotted owl's major prey species, the red tree vole.

In 2020 KFA will continue monitoring this project, advocating for conservation measures, and participating in the planning process for the Shasta-Agness Timber Sale. Our goal is to protect the old forests, large, fire resistant trees, wildlife habitat, water quality, and fisheries in the Shasta-Agness Planning Area.

Upper Briggs Timber Sale
Old-growth forests that burned at low severity in the 2018 Taylor Fire are now targeted for logging in the Upper Briggs Timber Sale.

Briggs Creek is an important tributary and fishery for the Illinois River. The watershed contains extensive coho salmon habitat, old-growth forests, rare plant species, beautiful mountain meadows, rocky canyons, popular recreational trails, campgrounds, and a designated Wildlife Area. Despite the many important biological and recreational values of the Briggs Creek Watershed, the Forest Service has approved a large timber sale in the upper watershed. Although the Upper Briggs Timber Sale is being promoted as a "restoration" project, the unique values of the Briggs Creek Watershed will only be degraded if the project is implemented.

In the spring of 2018, KFA conducted extensive field monitoring in proposed timber sale units and submitted detailed public comments on the project. That summer, the Briggs Creek Watershed burned at roughly 80% low severity in the Taylor Fire. 

Despite the natural landscape-scale restoration that took place during the Taylor Fire, and despite our requests to withdraw the project from consideration, the agency pushed forward. The timber sale proposed to log the recently burned watersheds to "reduce fuels" and "fire risks" by logging forests and trees that survived the 2018 Taylor Fire. 

In 2019, the agency approved the Upper Briggs Timber Sale and KFA immediately filed an administrative objection. Despite our advocacy, the project has moved forward and the first timber sale, called, the Wildhorse Timber Sale will be auctioned soon.

In 2020, KFA will continue advocating for conservation in the Briggs Creek area. We will also monitor and document the impacts of any timber sale activities associated with the Upper Briggs Timber Sale. Monitoring information will be used in future efforts and to demonstrate the impacts of old forest logging in the Siskiyou Mountains.

Regional Projects and Policy
Klamath Forest Alliance works to protect specific habitats in the Klamath-Siskiyou Mountains. We also work to promote conservation policy that will protect the unique values of the Siskiyou Mountains. In 2019, we worked on the following regional projects and policies: Oregon Fire/Forest Policy and the Integrated Vegetation Management for Resilient Lands Programmatic Environmental Assessment. We also commented on nation-wide NEPA revisions proposed by the Forest Service and on the now successful proposal to list the Pacific fisher as an endangered species.

Oregon Fire/Forest Policy
In 2019, the politics of wildfire took center stage. The timber industry, federal land managers, and politicians throughout Oregon and California have been promoting aggressive wildfire suppression and exclusion, and increased logging as a solution to the so-called "fire problem."

Due to political pressure following the 2018 fire season, Governor Kate Brown of Oregon created the Council on Wildfire Response.  KFA provided detailed policy recommendations and scientific analysis in a report to Governor Brown, state legislators and the Council on Wildfire Response regarding wildfire, smoke and forest management. The report titled, Information and Policy Recommendations Pertaining to Forest, Fire & Smoke Management in Southwestern Oregon can be viewed here.

Integrated Vegetation Management for Resilient Lands Programmatic Environmental Assessment
The Integrated Vegetation Management for Resilient Lands Programmatic Environmental Assessment (IVM) has been proposed by the Medford District BLM. Although it sounds benign, the project is heavily geared towards logging Late Successional Reserves, Lands with Wilderness Characteristics, Areas of Critical Environmental Concern and other conservation-based land management allocations. 

The IVM would affect vast swaths of BLM land in SW Oregon.
The project would allow heavy commercial logging and new road construction to occur across over 800,000 acres of land in southwestern Oregon without public comment, public involvement, scientific review or the disclosure of environmental impacts. The current proposal would allow up to 25,000 acres of commercial logging and 90 miles of new road construction to be implemented every ten years, and would "have no sunset date," meaning it could theoretically be implemented for decades, allowing hundreds of miles of new road construction and many tens of thousands of acres to be commercially logged. 

KFA will be working hard in 2020 to keep the public in our public lands. We will fight to maintain the accountability, transparency, scientific rigor and levels of public involvement currently required in public land management planning and we will continue opposing the IVM!

Connectivity Conservation

The protection of the Siskiyou Crest Connectivity Corridor is a major objective of our work. Klamath Forest Alliance works to protect wildlands, biological values, wildlife and biodiversity throughout the region on both public and private lands. We recently worked to protect 240 acres of privately owned old-growth forest in the Condrey Mountain Roadless Area and have continued working in the Elliott Creek Watershed to promote the strategic acquisition of private industrial forestland containing old-growth forest habitat and/or located within the Siskiyou Crest Connectivity Corridor. 

Our goal is not to just protect the best remaining wildlands on the Siskiyou Crest, but also to restore connectivity and rewild damaged habitats. We are working toward protecting the world-class biodiversity and regionally important connectivity of the Siskiyou Crest with a comprehensive conservation approach.

Wild and Scenic River Nominations
The proposed Wild and Scenic Middle Fork Applegate River.

In 2019 Senator Ron Wyden (D-OR) and Senator Jeff Merkley (D-OR) requested Wild & Scenic River nominations in Oregon. Klamath Forest Alliance has been working with Applegate Neighborhood Network (ANN) to identify and propose Wild and Scenic River designations in the Applegate River Watershed. We are currently working to promote four major proposals for the Upper Applegate River, Little Applegate River, Slate Creek and the Pipe Fork of Williams Creek. 

We will continue promoting these proposals in 2020 and will keep looking for opportunities to promote more permanent protections for wildlands throughout the Siskiyou Mountains of southern Oregon and northern California. 

Klamath Forest Alliance is dedicated to the wildlands and wildlife of the Klamath-Siskiyou Mountains. Support grassroots environmental conservation work in the Siskiyou Mountains with a year-end donation!

The Siskiyou Crest as seen from Big Red Mountain.


Monday, November 11, 2019

BLM Proposes to Eliminate Public Comment Periods in New Logging and Road Building Proposal

A view down Powell Creek in the Late Mungers Project. The Late Mungers Project is "tiered" to the analysis in the IVM Project and would be the first timber sale approved if the IVM Project is authorized.
As part of their continuing assault on the National Environmental Policy Act (NEPA), the Medford District BLM has proposed the Integrated Vegetation Management for Resilient Lands Project (IVM). Although it sounds benign, in many cases, terms like "Integrated Vegetation Management" are a euphemism for commercial logging and serve only to mask the impacts and objectives of timber management with misleading language.

Under the IVM Project the BLM has proposed to allow up to 4,000 acres of commercial logging and 10 miles of new road construction per year without public comment, public involvement or environmental review. This would include up to 25,000 acres of logging and 90 miles of new road construction in a ten year period. According to the BLM, these authorizations would have "no sunset date," meaning that overtime they could be used to build hundreds of miles of new roads and log many tens of thousands of acres.
Old-forest proposed for logging in the Late Mungers Project near Morgan's Buckhorn.

Yet, this project is even more insidious in that it focuses its commercial logging "treatments" in conservation-based land use allocations like Late Successional Reserves (LSR), Areas of Critical Environmental Concern (ACEC), Lands with Wilderness Characteristics (LWC) and other areas outside the BLM's Timber Harvest Land Base.

The IVM Project proposes to approve commercial logging, prescribed fire and/or fuel reduction on virtually any location throughout the Medford District BLM. Yet, the location of future timber sales, the intensity of logging and the specific logging prescriptions would remain undetermined and would be at the sole discretion of BLM staff. 
The Burton-Ninemile Lands with Wilderness Characteristics (LWC) located in the Upper Applegate Watershed would be open to commercial logging with no NEPA analysis if the IVM Project is approved.

The IVM Project threatens to take away our right as citizens to influence and participate in public land management. If approved, it would provide the BLM with very broad discretion to authorize timber sales with little to no public involvement or accountability. Nearly all checks and balances currently embedded within the NEPA process would become optional, opening the way for a flood of controversial logging projects throughout southwestern Oregon.

The IVM Project includes an over 800,000-acre planning area encompassing all BLM lands in southwestern Oregon except the Cascade-Siskiyou National Monument and existing Wilderness Areas. Logging treatments could take place along portions of the Rogue River, in numerous roadless areas in the Applegate Watershed, and portions of the Illinois River Valley.

Fire adapted forest targeted for logging in the Late Mungers Project.
Despite having no official approval for the IVM Project, the Medford District BLM has already begun planning commercial timber projects "tiered" to the IVM Project and dependent on its ultimate approval. In the mountains outside Williams, Oregon the BLM has already identified its first large timber sale, called the Late Mungers Project.

The Late Mungers Project is focused on a large block of Late Successional Reserve forest located on the ridgeline dividing the Williams Valley from the Illinois Valley near Selma, Oregon. The project proposes commercial logging units on Murphy Creek, Powell Creek, Mungers Creek, and the South Fork of Deer Creek. 

An area proposed for commercial logging on Mungers Butte.
Very little information is available about the Late Mungers Project, but we were able to obtain a draft unit map showing proposed commercial logging and fuel reduction units. According to these maps, the commercial logging component appears quite extensive. It also appears that some of the last remaining corridors of intact forest habitat on the Applegate-Illinois River divide are targeted for commercial logging.

The BLM is accepting public comments on the IVM Project until November 18, 2019. Please consider the talking points below when drafting a public comment.

IVM Talking Points:  
  • Activities such as commercial logging, road construction and large scale fuel reduction have the potential to create significant environmental impacts and effects. These activities should therefore require site-specific NEPA analysis, including the disclosure of impacts, scientific review, public involvement, environmental analysis and public comment.
  • All Programmatic NEPA analysis should be implemented through development of a full Environmental Impact Statement (EIS). The currently proposed Environmental Assessment (EA) lacks the detail and rigor required to consider environmental effects across such a broad, complex landscape. 
  • The agency must analyze and disclose the impact of all logging and road building activities. This should include direct, indirect and cumulative impacts. 
  • Concerns regarding increased sedimentation and water quality impacts, impacts to late successional habitat, Northern spotted owl habitat, increased fire risks, increased fuel loading, standing drying, and accelerated canopy loss associated with commercial logging should be addressed in NEPA analysis. 
  • BLM monitoring data demonstrating the actual, on-the-ground effects of previous commercial timber sales should be analyzed throughout the 800,000-acre IVM planning area. The actual outcome of these timber sales should be compared to previous effects analysis to monitor for compliance and consistency. 
  • Planning on the Late Mungers Project is pre-decisional and additional planning efforts should be discontinued. The Late Mungers Project has the potential to create significant adverse effects and is located in a large block of LSR forest. This project should require site specific NEPA analysis and a full public comment period. 
Submit your comments:

By Mail or Delievery: 

Medford District BLM
3040 Biddle Road
Medford, Oregon 97504 

For more information on the project, click here. 

Also please attend the upcoming BLM open house to discuss the project at the Jackson County Expo, Mace Watchable Wildlife Building 4:30-7:00 PM Thursday, November 14, 2019. 

The green polygons represent commercial logging treatments currently proposed in the Late Mungers Project, blue depicts fuel reduction, while the narrow brown lines following major ridges are proposed as 300' wide fuel breaks which could include commercial and non-commercial treatments.

Tuesday, July 30, 2019

Dismantling NEPA Part 2: Local BLM Efforts to Undermine the Public Input Process

A BLM field trip into a portion of the Nedsbar Timber Sale as part of NEPA planning in 2014. If the Integrated Vegetation Management for Resilient Lands Environmental Assessment is approved, community meetings, field trips and public comment periods would be a thing of the past. 
On a national level the Trump Administration is pushing hard to eliminate or drastically reduce public involvement in federal land management planning, but it is not just a national issue. Local land managers in southwestern Oregon are also working to find ways to cut the public out of the process. This includes our local BLM, who is proposing an extremely large Programmatic Environmental Assessment of Integrated Vegetation Management for Resilient Lands (IVM-RL EA). 

Although the name intentionally sounds rather benign, the goal of this project is to increase timber production without conducting environmental review or soliciting public input. "Integrated Vegetation Management" is often actually commercial logging and "resilient lands," refers to the entire landscape. When translated from industry/agency jargon, Integrated Vegetation Management for Resilient Lands, means, "log the entire landscape."

The Programmatic EA would allow 15,000 acres of commercial logging and 25 miles of new road construction annually on the Roseburg and Medford District BLM. The majority of the project, including 14,000 acres of commercial logging and 20 miles of new road construction, would be proposed annually on the Medford District BLM, including both the Grants Pass and Ashland Resource Areas.

A fire-adapted forest proposed for logging in the Nedsbar Timber Sale and canceled due to public input during the NEPA process.

Under the proposals of the Programmatic EA, the Medford District BLM would no longer be required to conduct site specific environmental analysis and would no longer ask for public input or solicit public comments on up to 14,000 acres of commercial logging each year. Instead, they will notify the public only after approving a timber sale. Project approval would be followed by a mere 15-day Objection period, and barring an objection or lawsuit, commercial logging projects could then proceed to the federal timber auction.

Although the proposal would allow logging in nearly any land management designation, it appears to be specifically designed to implement logging prescriptions in Late Successional Reserve (LSR) forest. LSR forest was set aside to protect the habitat of the Northern spotted owl, to encourage the maintenance and development of late successional forest habitats, and to provide connectivity between old forests. LSR forests are the foundation of Northern spotted owl recovery and are necessary for the Northern spotted owl's continued persistence. 

The IVM-RL EA would allow land managers to downgrade or remove Northern spotted owl habitat within LSR forest by logging large, old trees, removing important habitat elements and significant levels of canopy cover, all with no environmental review or public comment. 

In fact, currently the Grants Pass Resource Area is considering the Late Munger Project in LSR forest. The project is located in the Williams Creek watershed between Mungers and Powell Creeks. Despite having no authorization to do so, the agency is already planning the Late Munger Project under the expectation that the project will be "tiered" to the Programmatic EA and approved without environmental review or public comment.

Given that no EA has been published, no analysis has been conducted and no official decision has been recorded for the Programmatic EA, the Late Munger Project should be canceled. Either the outcomes of the Programmatic EA are predetermined or the development of the Late Munger Project is pre-decisional; either way, the development of the Late Munger Project under the currently unauthorized provisions of the Programmatic EA is unacceptable.

The proposed IVM-RL EA would also build many miles of new roads, create new log landings, drag large logs across mountainsides with tractors, clear vast skyline yarding corridors and increase fire risks, not only in the Late Munger Project, but throughout southwestern Oregon.

The BLM calls thinning like this in the O'Lickety Timber Sale restoration or fuel reduction. It is, in fact, commercial timber production that degrades ecological values and tends to increase fire risks as woody vegetation fills in the canopy gaps created by commercial logging operations.

Although the agency claims to be conducting "habitat restoration and resilience treatments," the Programmatic EA would allow the agency to log virtually anywhere in the Medford or Roseburg District BLM landbase. This could include Late Successional Reserve forests, Riparian Reserves, Lands with Wilderness Characteristics, Areas of Critical Environmental Concern, the Cascade-Siskiyou National Monument and other conservation-based land management allocations. The level of harvest proposed in the Programmatic EA could range from "regeneration" logging, (a form of clearcut logging) to heavy commercial thinning. 

Unfortunately, the concept of restoration is being used as an excuse for the BLM to log virtually anywhere and by any means they deem necessary. Restoration is used as a euphemism to disguise the impact of commercial logging and provide a thick layer of greenwash over BLM timber sales. 

Despite their overly optimistic claims, BLM logging projects are far from restorative and generally include an increase in fire risk, an increase in overstory tree mortality, the spread of noxious weeds, increased soil erosion and stream sedimentation, significant impacts to biodiversity and a loss of late successional habitat used by the Pacific fisher, the Northern spotted owl, the Siskiyou Mountain salamander, and many other important wildlife species. 

What the BLM is proposing is not focused on restoring habitats, it is an attempt to increase timber production and reduce the public's ability to provide feedback or influence the process. 

Intact, old-growth forest was targeted for logging in the Pickett West Timber Sale. Large portions of the project were canceled due unacceptable impacts to the red tree vole, late successional habitat and due to public input provided during the NEPA process. NEPA tends to make land management projects more socially and environmentally acceptable and creates transparency that is important when managing public lands.

Comment now on this project and support the public's right to provide input and influence public land projects. Let the BLM know that all commercial timber projects and road construction projects should undergo a full National Environmental Policy Act (NEPA) process with rigorous environmental review and a full public comment process. 

To read the Scoping Notice and comment on this project, follow this link and hit "Comment on Document":

Sunday, July 28, 2019

Dismantling NEPA Part 1: A National Push for NEPA Rule Changes

Community members and the Forest Service conducting a public field tour during a NEPA process in the Applegate. If proposed NEPA rule changes are approved, public involvement could be a thing of the past.

This summer the Forest Service proposed dramatic nationwide changes to the National Environmental Policy Act (NEPA) process. These revisions to NEPA would allow widespread logging, mining and road building throughout Forest Service lands.

To achieve these goals the agency has proposed sweeping changes that would drastically limit public input and eliminate environmental review for the vast majority of Forest Service projects. These changes would essentially shut the public out of public land management planning.

The National Environmental Policy Act (NEPA) is the foundation of public involvement on our public lands. It is also intended to facilitate a thorough environmental analysis for federal land management projects. The public process required under NEPA has consistently made public land management projects significantly better for natural resources, wildlife, watersheds and local communities. NEPA brings a sense of democracy and accountability into the public land management planning process.

NEPA's bedrock principals include government transparency, accountability, public involvement, and science-based decision making. It is used to analyze the impacts of specific land management projects, disclose those impacts to the public and allows the agency to make more informed decisions. The public's ability to provide comment and demand a seat at the table is dependent on the integrity of the NEPA process.
The Elimination of Public Scoping
The Forest Service's proposed NEPA revisions would eliminate the requirement to conduct public scoping on most federal land management projects. Public scoping is used to inform the public of land management proposals and solicit an initial public comment period. This comment period is used to create proposed action alternatives, document public concerns and identify exceptional values at risk. 

Scoping promotes transparency, accountability and scientific credibility. It also allows land managers to meaningfully address public concerns in an EA or EIS. The proposed NEPA revisions would largely eliminate Scoping requirements for most land management projects conducted on Forest Service lands.

Categorical Exclusions

The agency has also proposed the adoption of seven new Categorical Exclusions (CE) and the expansion of two existing Categorical Exclusions. CE's are used to expedite the planning process by virtually eliminating public involvement and environmental review. 

CE's supposedly identify projects "that do not individually or cumulatively have a significant effect on the human environment and therefore, do not require preparation of an Environmental Assessment (EA) or Environmental Impact Statement (EIS)." Historically, CE's were meant to facilitate the maintenance of existing infrastructure or to authorize very small projects, with minimal environmental effects.

Large Forest Service logging projects, including up to 4,200 acres of commercial logging, could be approved without public input or environmental review under the newly proposed Categorical Exclusions.

The proposed NEPA revisions would allow land managers to  approve large, complex, and potentially damaging projects as CE's. It would also allow land managers to approve numerous associated projects under CE's, creating significant cumulative effects, without analyzing, documenting or disclosing those effects publicly in an Environmental Assessment or Environmental Impact Statment.

Although the Forest Service claims they need these changes "to increase the pace and scale of work accomplished on the ground," and address supposed wildfire concerns, these Categorical Exclusions would include many provisions that have no restorative benefits and do not directly address fire, fuels or community fire safety. These provisions include, but are not limited to:

  • The ability to authorize broadly defined "restoration and/or resilience activities" without public input or environmental review. This would include up to 4,200 acres (or 6.6 square miles) of commercial logging and 7,300 acres of manual thinning in a single CE. 
  • The ability to authorize the construction of up to 5 miles of new road and the reconstruction of 10 miles of existing roads in a single CE, with no public input or environmental review. 
  • The ability to convert currently illegal and environmentally damaging off-road vehicle routes into official Forest Service trails or roads without public input or environmental review. 
  • The ability to authorize damaging land management projects in Inventoried Roadless Areas with no public input or environmental review. 

The proposed rule changes would allow the agency to implement large and potentially damaging projects without site specific environmental review or meaningful public input. In fact, under the proposed rule changes, the public would only be notified of a project after it has been approved.

Determinations of NEPA Adequacy

The proposed NEPA revisions would also encourage the use of another internal review process, known as a Determination of NEPA Adequacy (DNA). A DNA allows Forest Service land managers to use their "experience" with past projects to authorize a project of similar nature without public comment or environmental review, again cutting the public out of the process and avoiding site specific environmental review. 

Condition-Based Management

Proposed NEPA revisions also propose the use of "condition-based management," which allows land managers to implement projects across broad landscapes based on a particular environmental condition, rather than on site specific needs. Environmental conditions such as high fuel loads, dense forests, bark beetle outbreaks, post-fire landscapes, and a broad range of other perceived and highly subjective conditions, would trigger specific management actions including logging, road building, and fuel reduction. 

Land managers would approve a range of generalized activities to address environmental conditions existing on the landscape. These activities would then be implemented across the landscape without public input or environmental review.


If these rule changes are approved it is estimated that roughly 75% of the projects currently requiring a more thorough EA or EIS would be implemented utilizing the newly proposed CE's. It is also estimated that an astounding 98% of federal land management projects would not include any level of public input before they are approved. 

    The proposed NEPA revisions will eliminate or limit important  requirements intended to protect public resources and encourage public involvement. If these provisions are approved, NEPA will be functionally dead, community-based collaboration will be a thing of the past, and science-based management will disappear from our federal lands.

    According to the official Forest Service website, the agency motto is, "Caring for the land and serving the people." The proposed NEPA rule changes will neither care for the land or serve the people. Instead they will serve the industries and ignore the people.
    Although local communities will be affected by federal land management planning decisions and often actively participate in the planning process, proposed NEPA rule changes will almost completely exclude the public from the process.

    Please Comment

    Please use the public process, while it is still available, and send in a comment opposing these unreasonable rule changes. The NEPA process should be used to front-load projects with public input, collaboration, and science. When implemented effectively NEPA can be used to find common ground, create better projects and implement non-controversial land management activities. The proposed NEPA revisions will do the opposite.

    Comments can be submitted until August 12, 2019. Please stand up for the NEPA process. The future of our National Forest lands depend on your contribution. Speak up for the science-based management, environmental review and rigorous public involvement process that NEPA currently requires. These are our public lands, please use your voice to protect them.

    To comment please follow this link and click on "Comment Now"

    Public meetings to discuss land management proposals and solicit feedback from community members are part of the NEPA public process and would be eliminated under new proposals by the BLM and Forest Service.

    Monday, June 17, 2019

    The Upper Briggs Restoration Project: The Wrong Treatments, in the Wrong Place, at the Wrong Time!

    A view across the Briggs Creek watershed in the spring of 2019 following the 2018 Taylor/Klondike Fire.
    Recently the Rogue River-Siskiyou National Forest approved over 4,000 acres of commercial logging in the Upper Briggs Restoration Project. The Upper Briggs Restoration Project is located in the Briggs Creek watershed west of Grants Pass, Oregon on the Wild Rivers Ranger District. The project is yet another damaging federal timber sale disingenuously cloaked in restoration language. 

    Briggs Creek is a major tributary of the Illinois River with significant anadromous fisheries and a botanical hotspot with high recreational values including hiking trails, mountain biking trails, Botanical Areas, Designated Wildlife Areas and popular campgrounds. 

    The area also burned in the 2018 Taylor/Klondike Fire and according to the Decision Notice for the Upper Briggs Project, "the fire effects were generally very low intensity mostly burning ground fuels with occasional torching of individual trees." Despite these restorative mixed severity fire effects, the Rogue River-Siskiyou National Forest has approved commercial logging within fire resilient stands throughout the upper Briggs Creek Watershed. 
    Unit 21 in the Briggs Creek Timber Sale is located along the popular Secret Way Trail and contains important fire-adapted late successional habitat. The unit burned at low severity in the Taylor/Klondike Fire and supports a particularly large population of the rare Clustered lady slipper orchid (Cyprepidium fasculatum). It is also proposed for commercial logging in the Upper Briggs Project.

    Klamath Forest Alliance has filed an Administrative Objection and will continue working to fight for the Briggs Creek watershed, its spectacular forests, rare plant species, and wild habitats. 

    Below is an article being published on June 19, 2019 in the Illinois Valley News by the Siskiyou Mountain Conservation Director for the Klamath Forest Alliance and the author of the Siskiyou Crest Blog, Luke Ruediger. 

    The Upper Briggs Project: The Wrong Treatments, in the Wrong Place, at the Wrong Time
    Low severity fire reduced fuel, thinned understory growth and increased fire resistance in this beautiful old-growth stand below the Secret Way Trail. Despite these beneficial effects, this forest is identified in the Upper Briggs Project as commercial logging unit 23. 

    Briggs Creek is a major tributary of the Illinois River, a hotspot for recreation and a beautifully diverse watershed with important late successional forests, roadless areas and rare plant populations. Most who have visited the area know Briggs Valley, Sam Brown Campground, Big Pine Campground, Horse Meadows and the vast Briggs Creek Trail system. The area has long been a destination for local residents to enjoy for its solitude and beauty. 

    In recent years, the Rogue River-Siskiyou National Forest has been working on the Upper Briggs Restoration Project, a timber sale on Briggs Creek; cloaked in restoration and fuel reduction language. The premise of the project is that without logging and fuel reduction treatments, rare plant populations would diminish, the Briggs Creek watershed would burn at uncharacteristic levels of fire severity and habitat conditions would suffer from fire exclusion. 

    Ironically, the area has burned four times in the last 10 years, creating a diverse and productive mosaic of mixed severity fire. These fires were restorative in nature and have reduced fuel loading throughout the vast watershed. For example, the Briggs Creek watershed burned at 82% low severity this past summer in the Taylor/Klondike Fire, achieving the stated objectives of the Upper Briggs Project. The 2018 fires reduced understory fuels, maintained Northern spotted owl habitats, and restored the process of fire to fire-dependent ecosystems. In fact, the fire achieved these objectives to such a high degree and across such a broad landscape, that restoration and fuel reduction is no longer needed in the Briggs Creek watershed. 
    Western sophora (Sophora leachiana) is endemic to the Rogue and Illinois River watersheds, is highly adapted to fire, and is more abundant in Briggs and adjacent Taylor Creek than anywhere else in the world. The Forest Service proposed numerous timber sale units to open canopies and restore fire, to fire dependent populations of Western sophora. The 2018 Taylor/Klondike Fire restored fire as a process and has invigorated populations throughout the fire area. These invigorated populations will be impacted by timber harvest in the Upper Briggs Restoration Project.

    Recent fire footprints like the 2018 Taylor/Klondike Fire contain extremely fire resistant conditions, more effective at reducing fire severity and limiting fire spread than any manual logging or fuel reduction treatment. For the next few years, this watershed will be largely fireproof, resisting ignition and limiting fire spread until vegetation burned in the Taylor/Klondike Fire regenerates and builds enough fuel to once again support wildland fire spread. 

    Unfortunately, the project specifically calls for logging stands that burned at low to moderate severity and removing trees that survived the 2018 fires. It is uniquely ironic and hypocritical to see forests recently burned at low severity, logged in the name of "fuel reduction" and "restoration." The Rogue River-Siskiyou National Forest is now using low severity fire as an unprecedented excuse  for logging the post-fire environment. Yet, forests recently burned at low severity are not a priority for treatment and by removing living trees from sensitive fire effected sites, fuel loading and fire risks will increase, as logging slash is deposited throughout the currently fuel-limited landscape. 
    Low severity fire burned through the old forests in unit 63 of the Upper Briggs Project, maintaining important late successional habitats. The 2018 Taylor Fire created beneficial, characteristic fire effects and "restored" fire adapted stand conditions. The logging proposed in unit 63 will degrade rather than restore healthy, fire adapted stands conditions.

    Stands logged in the Upper Briggs Project will also experience stand desiccation and increased fire risks associated with increasing wind speeds, ambient air temperatures, and plummeting fuel moisture contents throughout our fire season. Understory fuels will also increase in direct proportionality to canopy removal. In fact, the loss of overstory canopy will trigger an extensive "understory response" with young trees, shubbery, and increased herbaceous growth filling in the canopy gaps. The result will be an increase in fire/fuel risks and a significant loss of fire resilience. 

    The Upper Briggs Project is far from homes and human communities and provides little to no fire protection for the residents of southern Oregon. Implementation of the Upper Briggs Project is an unjustified waste of limited fuel reduction funding and will reduce, rather than increase fire safety in the Briggs Creek watershed. 

    The exceptional fire resilience of this post-fire landscape will only be impacted by proposed project activities. The project will also impact the natural vegetative recovery, increase sedimentation in streams and erosion on sensitive fire effected soils, spread noxious weeds, impact Special Wildlife Management Areas and degrade Northern spotted owl habitat. 
    Horse Meadows Wildlife Area following the 2018 Taylor/Klondike Fire. The Rogue River- Siskiyou National Forest has approved virtually clearcutting the forest at the margin of Horse Creek Meadows to "restore" the meadow to what is supposedly its former extent.

    There is simply no ecological or fire/fuel related benefit to implementation of commercial logging and fuel reduction treatments in the Briggs Creek watershed, at this time. Furthermore, the conditions created by those logging and fuel reduction treatments will not restore characteristic  habitat conditions. The Upper Briggs Project is an example of the wrong treatments, at the wrong place, and at the wrong time. The project should be canceled and attention placed on reducing fuel around homes and communities where it is most needed, not in the backcountry, where it will impact habitat values and provide little to no fire protection for communities at risk.