Returning to a Natural Cycle of Wildfire

Thousands Speak Out Against Post-Fire Logging In Klamath Region

Wednesday, April 29th, 2015
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Concerned community members attend Forest Service meeting to oppose the Westside proposal.

Concerned community members attend Forest Service meeting to oppose the Westside proposal.

Westside Timber Sale Threatens Salmon and Wildlife

Over 12,000 concerned residents have submitted comments in opposition to a logging plan in Northern California that proposes to decimate protected old-growth reserves and recovering salmon-bearing watersheds.

The Klamath National Forest is proposing a massive plan to clearcut fragile post-fire forests. The Westside Project would authorize the logging of over 30,000 acres of forest that are currently protected by the Forest Plan. The Forest Service has requested permission to fast-track the project and limit public participation.

“It is disheartening that the Forest Service would attempt to bypass opportunities for public collaboration.” Said Morgan Lindsay of the Klamath-Siskiyou Wildlands Center. “Rather than fast-track a heavy-handed logging outcome, the Forest Service should substantively collaborate with stakeholders to identify areas of agreement and priorities for treatment.”

“This region is one of the most biologically significant and ecologically rich areas in the country ” said Kimberly Baker of the Environmental Protection Information Center. “Our watersheds are worth far more than short-term monetary value. We would like to see the Forest Service work with affected river communities to develop a long term fire strategy that is best for wildlife, rivers and the people.”

“People from all walks of life are speaking up to oppose this project,” Said Laurel Sutherlin with the Rainforest Action Network. “Salvage logging should not be used a means to rush timber production at the expense of cultural, wildlife and watershed values.”

As proposed, the Forest Service would clearcut tens of thousands of acres located primarily in backcountry  “Late Successional Reserves” that were established to protect wildlife habitat and accommodate wildfires. The timber sale will harm approximately 70 Northern spotted owl nesting sites and log on steep unstable “Geological Reserves” located in “Key Watersheds” for salmon recovery. The Forest Service plans acknowledge that the project would violate the Klamath National Forest’s own management plan.

At the very least, when the Forest Service does propose pot-fire logging, they must follow the law. This means that creeks should be protected with riparian reserves as required by the Forest Plan, and that yarding on steep granitic soils should be avoided when possible. Unfortunately, some timber planners see fire as an opportunity to throw the rulebook out the window.

Over 12,000 comments from concerned Americans around the country have been submitted to the Klamath National Forest asking the Forest Service to protect, rather than log, the old-growth reserves and fragile watersheds in the Klamath Mountains.

The public comment period on the draft environmental impact statement closed on April 27, 2015.


Westside Fire Recovery Project a Hot Mess

Wednesday, April 29th, 2015
By

Whites_RussiansWith over 30,000 acres of Klamath National Forest proposed to be harvested and sold, the Westside Fire Recovery Project is poised to be one of the largest ever post-fire timber harvests on a National Forest. This so-called “recovery” project places timber company profits over community safety and wildlife by clearcutting complex, habitat-rich forests and replacing them with fire-prone plantations.

The Klamath National Forest is special to a lot of people in this region, and for good reason. Its wild canyons and old, expansive forests support a wide variety of unique animals and plants including the endangered northern spotted owl, Pacific fisher, California wolverine, and Siskiyou Mountains salamander. It also hosts the most productive wild salmon and steelhead fisheries outside of Alaska. Because of its biological diversity and unique evolutionary history, the World Wildlife Fund refers to the Klamath-Siskiyou region as the “Galapagos of North America.” The rugged beauty and ecological importance of the area is recognized through the nation’s highest concentration of designated Wild and Scenic Rivers. Preserving intact forests in this region is also a local solution to climate change; the Klamath contains some of the most biomass-dense forests in North America, which sequester and store carbon long after a fire.

Fires produce some counter-intuitive results in forests. Post-fire areas are biological hotspots, having greater biodiversity than unburned forests, and critters like the infamous northern spotted owl appear to actively prefer burned forests for foraging. Fires also help forests develop old-growth characteristics faster, increasing the complexity and fecundity of the landscape. Despite this, many forest managers continue to operate under outdated and disproven ideas for how to help a forest recover after fire, as exemplified by this project.

While the fires were still smoldering last summer, the Forest Service hatched a plan to capitalize on them. By declaring the area an “emergency,” the Klamath National Forest could fast-track a massive timber sale, bypassing opportunities for public comment or participation. It is clear why the Forest Service wants to limit public scrutiny: the Westside Project is an ecological disaster. Miles of new roads would increase sediment in Coho bearing streams and the Wild & Scenic Scott, Salmon and Klamath Rivers. Logging would impact — by the Service’s own admission—over 90 spotted owl activity centers and remove thousands of acres of habitat.

The Westside Project also increases risky fire behavior. Helicopter logging will leave “jackpots” of fuel, ready to catch and burn in the dry summer months. Replanting will create dense, even-aged plantations prone to being ripped through by high-severity fires. Unmaintained fire suppression lines and fuel breaks will accumulated dense, thick fuels, and act as a vector for future fires.

EPIC and others are open to working collaboratively to draft a project that protects people and biodiversity. We have done so in the past, for example in drafting the post-fire response to the Little Deer salvage timber sale on the Goosenest Ranger District. And it is not too late. Forest Supervisor Grantham has broad power to shape the project to protect rural communities and the environment. She has heard from EPIC and other environmental groups. Now she needs to hear from you. Public comments close on the draft environmental impact statement on April 27. Let Supervisor Grantham that you support light-touch treatments, not clearcuts.

Published 4/7/15 in the Eureka Times-Standard


The Westside Story

Wednesday, April 15th, 2015
By

from_BR_Lookout_1314

Summer 2016 update: The Westside project has been approved. Logging is underway, and we have filed a lawsuit to stop the project. Unfortunately, a decision from the 9th Circuit Court of Appeals is not expected until late this year. Klamath National Forest’s Timber Sale maps and information can be found here.

TAKE ACTION: Say no to a logging tragedy! The heart of Klamath-Siskiyou bioregion could lose 30,000 acres of prime snag forest habitat on the steepest of unstable slopes above vital wild salmon rivers. Late Successional Reserves, meadows, seventy-five watersheds and the Caroline Creek eagles, bumblebees, endemic salamanders, Pacific fisher and seventy threatened Northern spotted owls need your help.  The Westside situation is perilous.

The Westside Story is a detailed look at what could be a logging tragedy for wildlife, wild rivers and wild places.  It is a summary of the findings, inconsistencies and untruths of Alternative 2 in the Klamath National Forest’s Westside Draft Environmental Impact Statement (DEIS).

OVERVIEW

218,600 project acre Three Fire Areas- Beaver, Happy Camp and Whites

11,700 acres larger units, 8,900 treatment acres (3,920 in *Riparian Reserves)

20,500  acres roadside “hazard” removal or 650 miles (9,995 acres in Riparian Reserves)

22,900 acres fuels treatments (10,146 acres in Riparian Reserves)

7,900 acres of prep and plant aka: plantations

75 watersheds impacted

22 miles “temporary” roads (includes reconstructing 9 miles of decommissioned roads)

14 new stream crossings

152 new landings!

75 existing landings! That may require expansion

* Areas along streams, wetlands, ponds, lakes or potentially unstable areas.

Whites Russian Fire

Whites Russian Fire

The Westside project of the Klamath National Forest (KNF) surrounds the east, south and north sides of the Marble Mountain Wilderness. The terrain is extremely rugged with slopes commonly over 65 percent. The wild rivers and extremely biologically rich watersheds burned in a mosaic pattern, during the 2014 wildfire season, with high soil severity on less that 5% of the fire areas. The ecological and monetary costs of fire suppression actions were extreme. With the cost of 195 million dollars- fire fighting constructed nearly 200 miles of bulldozed ridge tops for fire lines, dumped thousands of gallons of fire retardant in sensitive areas, impacted hundreds of miles of roads and caused unknown acres of high severity burns. Several salmon streams and rivers are now choked with sediment. Before the smoke cleared timber planners started in on project planning.

North Fork Salmon River

North Fork Salmon River

The Westside Draft Environmental Impact Statement (DEIS) was released March 13, 2015.  Comments are due April 27th.  The agency is requesting an expedited process with plans to start logging in July 2015!

There are 7,560 acres of logging treatments within Late Successional Reserves and 13,215 acres of activity are in Riparian Reserves spanning seventy-five watersheds. The agency is proposing to extract green live trees as well as clearcut snag forest ecosystems. The largest unit is over 555 acres, three units are over 300 acres, five units are over 200 acres, seventeen units are over 100 acres and the remaining 203 units are less than 100 acres.

The DEIS exacerbates fire severity by clumping high severity with moderate severity. This affects all native plant, fungi and wildlife species. Moderate severity causes moderate soil heating and occurs where litter is consumed and duff is charred or consumed, but the underlying mineral soil is not visibly altered.

WESTSIDE WILDLIFE

The Westside Fire project has far reaching affects to multiple species including, rare birds, endemic salamanders and bumblebees. The KNF fails its responsibility to conserve and recover threatened and imperiled wildlife. The agency considers moderately burned areas as no longer providing habitat for a number of species, although this is not consistent with the best available science and increases impacts to wildlife by putting more forest habitat at risk.

Pacific Fisher

Pacific-Fisher_Bethany-Weeks-300x200

Photo Credit: USFWS

The Westside DEIS looks at 67 sub-watersheds, which are equal to a fisher (Pekania pennanti) home range. Habitat connectivity is rated low to very low in 37 of the sub-watersheds. Project treatments would diminish connectivity in 14 sub-watersheds and would remove connectivity in three others including, Cougar Creek-Elk Creek, Lower West Fork Beaver Creek, and Tom Martin Creek-Klamath River. The loss of several home ranges can result in large effects to the overall population. Habitat lost is difficult to replace and it may take many years before the area develops into habitat again.

While fishers are commonly observed on the lower 2/3 of slopes, snag retention is generally planned for only the lower 1/3 of slopes. Fishers are strongly associated with dense, mature forest, which provide the necessary food, water, shelter for reproduction and survival. Depending on the sex, the fisher’s average home range is 4.7 to 36 square miles.

Bald Eagle

Photo Credit: USFWS

Photo Credit: USFWS

The Caroline Creek eagles nest area, which has been active for decades would be destroyed. The project would remove 180 acres of habitat within 600 feet of the nest, making a high risk of eagles abandoning the nest during the nesting period and a high risk of the eagle pair not finding a nest tree in the future.

Three other nest sites, Donna, Muck-A-Muck, Frying-pan and three winter roost sites exist along the Klamath and Scott Rivers, occur within the project area. The Westside project proposes treatment within 0.5 miles for all four bald eagle nest sites, all four nest sites have been active recently and are likely to continue to be active.

Northern Spotted Owl

There are 94 nest sites, core areas and home ranges, also know as Activity Centers in the project area.  The project would likely adversely affect 70 NSO Activity Centers and may adversely affect another 17. This information was not provided in the DEIS but was included in the Draft Wildlife Biological Assessment.

NSO fem&juv _0397Westside would eliminate 1,758 acres of Critical Habitat for the owl and would remove and downgrade thousands of acres of suitable habitat.

It is important to note that exact numbers are difficult to ascertain given that the DEIS and the Draft Wildlife Biological Assessment (BA) are wrought with inconsistencies.

The US Fish and Wildlife Service recently issued a finding that Northern Spotted Owls deserve further review for up listing, from threatened to endangered under the Endangered Species Act. Recent regional surveys show that populations continue to plummet at 3% per year. Barred owls and habitat loss remain to be the biggest threats.

Northern Goshawk

northern goshawk FWS

Photo Credit: USFWS

Eleven goshawk nests have been occupied at some point in the last twenty years within or near the project area. Only one of the nest sites meets the standards for habitat minimums, which is mostly outside the fire perimeter. Broadcast surveys are currently being conducted although two years of broadcast surveys are the legal requirement.

The project proposes treatment within 0.25 miles of six goshawk nest sites (Kohl, Beaver, China, Elk, Middle, and Hickory). The project would remove habitat around four nests (Beaver, Hickory, Kelsey and West Whites) causing a high level of risk to reproduction.

Bald eagles, Northern spotted owls and goshawks like many long-lived bird species show a great fidelity to nest sites and certain landscape elements, like meadows, northerly slopes and water sources.

Siskiyou Mountains Salamander

Siskiyou Mountain Salamander photo credit: USFWS

Photo Credit: USFWS

The Siskiyou Mountains Salamander (Plethodon stormi) is endemic to 420 square miles of known habitat in northern Siskiyou County, CA and southern Jackson Country, OR. About 25% of its range overlaps the Happy Camp Fire area.

There are 48 known sites within the project area and 19 known sites are within treatment units, where ground disturbance is expected. Most of these sites have experienced high and moderate severity fire so the agency assumes habitat is not suitable and is not completing pre-disturbance surveys.

It is likely that these sites are still occupied, as salamanders have evolved with fire. The agency expects that flagging small areas around known sites and retaining some standing trees will minimize compaction by heavy equipment and state that the level of risk for disturbing known sites is low. However, mitigations are often ignored during logging.  The proposed removal of canopy and shade and possible compaction will likely create conditions that would risk salamander survival. Further, surveys have shown that salamanders use early seral habitat, such as natural recovery areas post-fire.

Siskiyou Mountains salamanders require moisture to breathe through their skin. Due to their need for moist microhabitats, they can live deep underground during the summer months, prefer the shade and while at the surface, they remain under objects during the day and are active at night. Their habitat is mostly comprised of lose rock and soil where salamanders can move through the small pockets of space up to several feet below the forest floor.

Scott Bar Salamander

Salamander Plethodon Photo credit: USFWS

Photo Credit: USFWS

The endemic Scott Bar salamander (Plethodon asupak), discovered in 2001, is currently known to occur in a very small area near the confluence of the Klamath and Scott Rivers. The international Union for Conservation of Nature has assessed it as being a “vulnerable species“. Both the Siskiyou Mountains and the Scott Bar salamander have the smallest ranges of any western salamanders in their genus. The loss or decline of salamanders from forest ecosystems has important consequences up and down the food chain. Salamanders play a key role in forest nutrient flow, regulating the abundance of soil invertebrates that are responsible for the breakdown of plant detritus. Salamanders’ loss from forests is indicative of changes that will likely affect a broad array of species.

The Westside project area contains Scott Bar salamander habitat but fails to survey or analyze any effects to this species.

Pallid Bat Townsend’s Big-eared Bat and Fringed Myotis 

Photo credit: Oregon Dept. of Wildlife

Photo credit: Oregon Dept. of Wildlife

In the project area, there are 58 sites of possible bat habitat containing caves, mines, or the potential to contain either of these structures. The treatments may disturb a maternity site because maternity roosts are active from about April to August, and are most sensitive during the early spring when the offspring are not capable of flight. There are 15 areas with potential hibernacula with moderate risk of disturbance, which could affect a maternity roost. The sites with potential cave or cave-like structures in 13 areas with potential hibernacula have a high risk of disturbance and are likely the most vulnerable to abandonment; this could affect a population. Further, cumulative effects from other projects would result in doubling the number of areas with potential hibernacula that have a high risk of disturbing bats. Surveys have not been completed contrary to the KNF forest plan.

Willow Fly Catcher mapWillow Flycatcher

Willow flycatchers breed in moist, shrubby areas, often with standing or running water and winters in shrubby clearings and early successional growth. Habitat for the species was assumed to be 3rd order streams and wet meadows. The Westside project would result cumulatively in four watersheds shifting from a low to a high level of habitat alteration. The Westside DEIS fails to consider wintering habitat and the effects of grazing on riparian willow habitat.

Western Bumble Bee

Photo Credit: USFWS

Photo Credit: USFWS

Western bumble bee (Bombus occidentalis) populations have declined dramatically in recent years and like other species of bumblebees, is sensitive to habitat disturbance. In the project area, high-quality habitat for bees is likely to occur in the meadows where several species of flowering plants occur. Meadows also offer a high density of plants to provide additional structure and small animal burrows that bees also use for nesting.

The western bumble is likely to occur over much of the Klamath National Forest although it has only been incidentally observed. The actual distribution of the bee on the forest is not known. Although the species is not exclusively associated with meadows, there is a strong relationship with its habitat needs and meadows.

There are five watersheds with possible disturbance occurring at a high level. In addition, there are five watersheds where a moderate level of disturbance may be created. Cumulative effects with other projects would result in another three watersheds going from a low level of disturbance to a moderate level. A high level of disturbance would result in affecting at least one bee colony where reproduction will be compromised. Moderate level of disturbance will result in bees traveling further to find food resources if a colony is present within close proximity to the treatments.

The Westside project would diminish eight and destroy five meadows and possibly five colonies. This is contrary to maintaining and enhancing meadows as directed in the KNF Forest Plan.

Franklin’s Bumble Bee

Franklins bumble beeFranklin’s bumblebee (Bombus franklini) was historically found only in a small area in southern OR and northern CA. The Westside project has habitat and past known locations for the bee, however, no surveys or consideration are given to this imperiled bee species. Franklin’s bumblebee has the most restricted range of any bumblebee in the world. Its entire distribution can be covered by an oval of about 190 miles north to south and 70 miles east to west. Populations were readily found throughout its range throughout the 1990s but have declined precipitously since 1998; subsequent yearly surveys have suggested this bee is in imminent danger of extinction.

Peregrine Falcon

Chainsaw activity and helicopter noise could disturb nesting Peregrine falcons in the Grider Creek watershed within and around a Special Habitat Management Area for Peregrine falcon eyries.

Snag Dependent Species

Salvage treatment units will not provide five snags on every acre but the project will meet the Forest Plan standard of five snags per acre- averaged over 100 acres. This is inconsistent with snag retention guidelines. The project would result in 11,693 acres of snag habitat being degraded and 1,692 acres would be removed.

White-headed Woodpecker Photo Credit: USFWS

Photo Credit: USFWS

Cavity-nesting species are prime beneficiaries of fires, 62 species of birds and mammals use snags, broken-topped, diseased or otherwise “defective” trees for roosting, denning, foraging, or other life functions. The White-headed Woodpecker, Pygmy nuthatch and Flammulated owl all have habitat ranges within the project area.

The Northwest Forest Plan at C-45-46 states, “White-headed Woodpecker, Black-backed Wood Pecker, Pygmy nuthatch and Flammulated Owl- These species will not be sufficiently aided by application of mitigation measures for riparian habitat protection.” It continues, “Specifically, the Scientific Analysis team recommends that no snags over 20 inches DBH be marked for cutting.”  The KNF forest plan requires that the largest snags be retained as they last longer make the best wildlife habitat.

Forests that burn at high severity burn, snag forests, are often incorrectly assumed to be damaged. Ecologically, this is strongly contradicted by the scientific evidence. Peak biodiversity levels of higher plants and vertebrates are found in patches of snag forest habitat—areas where most or all of the trees are killed by fire, consistent with the principle that pyrodiversity enhances biodiversity, especially where mixed-severity fire effects occur. As a result, avian species richness and diversity increases in heavily burned patches occurring within a mix of low and moderate severity effects.

Scientists recommend that forest managers ensure the maintenance of moderate and high severity fire patches to maintain populations of numerous native bird species positively associated with fire. At the landscape level, high severity habitat (unlogged) is among the most underrepresented and rare forest habitat types.

Hardwood Dependent Species

The cumulative effect will be 1,318 acres of hardwood habitat being removed and would not function as habitat in the near future.

Species recognized on the KNF as being associated with hardwoods are the Acorn woodpecker and the Western gray squirrel. The KNF forest plan standards require that pure hardwood stands be managed for wildlife habitat values and to maintain or improve the presence of Oregon white oaks.

Neo-tropical Migratory Birds

The regional decline of migratory birds is a significant issue. Numerous studies have reported local and regional trends in breeding and migratory bird populations throughout North America. These studies suggest geographically widespread population declines that have provoked conservation concern for birds, particularly neotropical. The 2005 report from the Klamath Bird Observatory indicates that several species of songbirds are suffering declining population trends at the regional level.

The DEIS states the project would result in up to 21,650 acres of habitat being affected but fails to consider the actual impacts of proposed treatments on neo-tropical migratory birds.

American Marten

Photo Credit: USFWS

Photo Credit: USFWS

The distribution of marten (Martes Americana) in the project area is not well-know and martens have not been detected at any of the fisher survey stations nor have surveys been done to assess population distribution. Martens are known to occupy higher elevations with true fir forest types so while habitat exists in the project area, the DEIS claims they are not likely to occur in the project area. True fir high elevation stands occur near Tyler Meadows, Eddy gulch ridgeline and within the Grider Creek drainage.

Like fisher, marten are also associated with late-successional conifer forests characterized by an abundance of large dead and downed wood and large, decadent live and dead trees.  The marten’s home range is 1 to 6 square miles.

Wolverine

Wolverine Photo Credit: NPS

Photo Credit: NPS

Wolverines (Gulo Gulo) have not been observed on the Klamath National Forest since the 1980’s. There are sixteen documented detections but no den sites or evidence of reproduction has been found. The wolverine’s home range is 38 to 347 square miles with the closest located study to the project area reporting an average of 130 square miles. Wolverines are typically associated with high elevation >7,200 feet within montane conifer forest consisting of Douglas fir in lower elevation to true fir and lodgepole pine at higher elevation.

Other species in the forest that may be affected but were not considered in the DEIS include; Gray wolf, River otter, beaver, black bear, American mink, ringtail cat, fox, deer, mountain lion, bobcat, coyote, elk and hundreds of other species.

WILD SALMON AND AQUATIC SPECIES

Elk Creek

Elk Creek

The rivers in the Westside project are home to some of the most productive fisheries habitat in the world outside of Alaska. They are vital to salmon survival. There are eleven larger watersheds in the project area and seventy-five sub-watersheds. Coho (Oncorhynchus kisutch) salmon are listed as threatened under the Endangered Species Act. The project area contains over 101 miles of Coho Critical Habitat and the Salmon River is the last stronghold for native spring Chinook salmon.

Relative to aquatic species, the project would cause short-term negative effects to habitat at the site scale (due to temporary road actions and landings) for the following special status aquatic species: resident trout and tailed frog (Management Indicator Species); foothill yellow-legged frog, Cascade frog, and western pond turtle (Forest Service Sensitive). Habitat for Coho Salmon (Threatened), Chinook salmon, steelhead, Pacific lamprey, and Klamath River lamprey (Forest Service Sensitive) may also be negatively affected.

The DEIS is supposed to be in plain language however it waters down any real effects by stating that activities are not directly in the streams and rivers, except water drafting, new landings, temporary road construction and 14 new stream crossings, which are outside of and at least 350 feet above fish critical habitat for Coho salmon. The DEIS relies on unreliable mitigations (Best Management Practices and Project Design Features) and the treatment of 150 out of the 953 legacy sites (at-risk sites or chronic sediment sources mostly associated with roads) as an offset to any effects to aquatic species and calls negative effects discountable. Throughout the aquatics section, the DEIS continually states that treatments are outside Riparian Reserves, however it fails to consider the

13,215 acres of treatment within steep unstable and potentially unstable areas on decomposed granite soils recognized as Riparian Reserves.

This summary is based on the findings in the DEIS, as with wildlife, the Fish Biological Assessment is inconsistent with the DEIS.

Wet Weather Logging in Klamath National Forest October 2014

Wet Weather Logging in Klamath National Forest October 2014

Roads, Landings and Water Drafting

The DEIS states there would be moderate short-term negative effects to aquatic species and sediment production, due to construction/reconstruction of temporary roads, installation and removal of stream crossings, and new landings in Riparian Reserves. The temporary road actions include fourteen stream crossings (4 perennial and 10 intermittent streams): Doggett Creek, Buckhorn-Beaver Creek, Grider Creek, O’Neil Creek, Kuntz Creek, China Creek, Caroline Creek-Klamath River and Whites Gulch. New temporary roads and stream crossings have a high risk for affecting aquatic species because of their impacts on sediment regimes and drainage networks. Re-opening the 46N62 road in Caroline Creek would require the reinstallation of stream crossings and widening the road on an active landslide, which could re-activate.

It is not clear in the DEIS when or how much water would extracted from numerous streams to fill water tank trucks, which can hold over 4,000 gallons per load during the proposed implementation. Given that the project area is over 200,000 acres and that there would be over 650 miles of roads needed for dust abatement, water drafting could have a significant effect on water quantity and temperature during hot summer months.

Cumulative Effects

Whites Gulch

Whites Gulch

Short-term negative effects to aquatic habitat may occur in several stream reaches due to grazing allotments, private timber harvest and Forest Service timber sales, Thom Seider and Eddy LSR, which are expected to contribute sediment delivery to streams. Private land logging would contribute to elevated sediment inputs to the Klamath River, which is admitted in the DEIS but is in violation of the law.

Management Indicator Species (MIS)

River/Stream associated species include steelhead, resident rainbow trout, tailed frog, and cascades frog. There are 802 miles of perennial stream habitat and 1,012 miles of intermittent stream habitat. Resident trout may occur in approximately 338 miles and steelhead in approximately 224 miles. Cascades frogs may occur in about 314 miles and tailed frogs may occur throughout all perennial streams. The western pond turtle is associated with marsh, lakes and ponds. The project area contains about 802 miles of stream habitat and 362 acres of lentic habitat that defines western pond turtle habitat.

The DEIS assumes that high quality riparian and aquatic habitat does not occur in areas of moderate/high fire intensity, and aquatic habitat in streams downstream of these areas is likely also experiencing negative effects such as increases in sedimentation, water temperature and peak flow events. The quality of MIS habitat is expected to be reduced along stream reaches associated with 14 sites where road crossings and landings are constructed. However the DEIS claims, again, that mitigations will reduce or eliminate harm and that the treatment of a fraction of legacy sediment sites will improve habitat.

WATER QUALITY

Water quality in the Klamath River, Scott River, and North Fork Salmon River is listed as impaired and is on the 303(d) Clean Water Act. While the DEIS is supposed to use plain language it skews and blurs actual effects through models and relies on unreliable mitigations and the treatment of a fraction of legacy sediment sites. For instance, models show an increase in risk but it is so slight it does not change the risk ratios. However, any increase in sediment is contrary to the intent of the Clean Water Act, the Basin Plan and the Magnuson-Stevens Fishery Conservation and Management Act.

The DEIS considers different indicators of risk for water quality including: risk to channel morphology, risk of sediment regime alteration, risk of temperature regime alteration and the trend of riparian function for fisheries. The project includes portions of eight watersheds: Beaver Creek; Humbug Creek-Klamath River; Horse Creek-Klamath River; Seiad Creek-Klamath River; Lower Scott River; Thompson Creek-Klamath River; Elk Creek; and North Fork Salmon River (the DEIS Aquatics section includes eleven watersheds) and seventy-five sub-watersheds that intersect portions of the three fire-related areas. Post-fire sediment has already been delivered to project areas streams such as Elk and Grider creeks during winter 2014-2015 storms.

Risk to Channel Morphology

There will be nine watersheds that will continue to have a moderate risk, and two with a high risk to channel morphology. Cumulative effect on risk to channel morphology would result in Jessups Gulch moving from a low to high risk.

Risk of Sediment Regime Alteration

Models show increases for nine watersheds and mass-wasting increase for seventeen watersheds. Site-scale alteration of the sediment regime is anticipated in some cases.

Cumulatively thirteen watersheds had an increase in risk and three for the mass-wasting. The largest increase was in Jessups Gulch.

Risk of Temperature Regime Alteration

Nine watersheds move to high risk, including Robinson Gulch. There are ten watersheds that move to a moderate risk, including Miller Gulch-Klamath River, Upper Grider Creek, Tom Martin Creek, Horse Creek-Klamath River, Headwaters of Elk Creek, Upper Elk Creek, Lower East Fork Elk Creek, Hoop & Devil, Lower South Russian Creek and Big Creek.  Cumulative effects increased the shade loss potential for 19 more watersheds. Big Ferry-Swanson, Quigley’s Cove, Doggett Creek and Dutch Creek had the largest increase in percentage of the watershed with shade loss potential

Trend of Riparian Function

The DEIS claims that eventually the land will heal and the trend will be positive, except for “a slight downward dip in riparian function in watersheds with private land harvest due to the loss of shade in the stream channels.”

While many of the watersheds would have increased high and moderate risk, the DEIS again discounts theses as insignificant and relies on the treatment of a fraction of legacy sites mainly in one watershed, Elk Creek, to offset effects to the activities in the entire project area.  Reforestation is also noted as a positive, however, natural recovery would be more conducive with water quality.

Key Watersheds and the Aquatic Conservation Strategy

Refugia are a cornerstone of most species conservation strategies.  They are designated areas that either provide, or are expected to provide, high quality habitat.  A system of Key Watersheds that serve as refugia is crucial for maintaining and recovering habitat for at-risk stocks of anadromous salmonids and resident fish species.

Northwest Forest Plan (NFP) B-18

Key watersheds in the project area include, Grider Creek in the Siead Creek Klamath River, South and North Fork Salmon River and Elk Creek.  Fires, fire suppression and multiple timber sales have greatly impacted each of these Key watersheds.

Key Watersheds are also defined by the NFP as, a system of large refugia comprising watersheds that are crucial to at-risk fish species and stocks and provide high quality water. They are the highest priority for watershed restoration. Yet, instead of restoring these Key Watersheds- as required in the Northwest Forest Plan Aquatic Conservation Strategy- logging large old trees and snags that are contributing critical elements of forest and riparian structure with ground-based, cable and helicopter yarding, road construction/reconstruction, landings, and skid trails on steep and erodible hillsides will degrade riparian values and watersheds at large.

WILD AND SCENIC RIVERS

The Klamath, Scott and North Fork Salmon River are Wild and Scenic Rivers all known for their outstandingly remarkable fisheries values. Elk Creek, Kelsey Creek and South Russian Creek are eligible for inclusion to the Wild and Scenic River system.

The project proposes:

  • 425 acres of logging units and 379 acres of roadside in the Klamath River corridor
  • 17 acres of units and 491 acres of roadside in the Scott River corridor
  • 83 acres of units and 250 acres of roadside in the North Fork Salmon corridor
  • 599 acres of roadside logging in Elk Creek corridor
  • 41 acres of units and 7 acres of roadside in Grider Creek corridor
  • 1 acre unit and 122 acres of roadside in South Russian Creek corridor

Elk Creek is also recognized for geologic and wildlife values because the Siskiyou Mountains Salamander has been found there.

Grider Creek is recognized for its undisturbed old growth mixed conifer forests and for wildlife because bald eagles and peregrine falcons nest there.

South Russian Creek– fed from the Russian Wilderness is recognized for its magnificent stand of old growth Engleman Spruce and for pristine water quality.

The DEIS states that, “Analysis determined that all action alternatives would protect the outstandingly remarkable values and would be fully compliant with all Wild and Scenic River Act protection requirements and Forest Plan Standards and Guidelines. Select information on resource effects for outstandingly remarkable values is reiterated in this report as taken from the Aquatic Resources, Hydrology, Wildlife, and Scenery reports. For complete details see those reports.” However, these reports and the DEIS fail to meet requirements of the KNF Forest Plan Standards and Guidelines and thereby failing to protect Wild and Scenic River values, such as fisheries, wildlife, recreation, scenery, geology, history, cultural features, or other values including ecology.

WILD PLACES

Late Successional Reserves

Late Successional Reserves (LSRs) are set aside to protect and enhance old growth and mature forest habitat that supports old growth dependent species. Out of 7,560 acres of treatment area within logging units – 6,800 acres are within LSRs.

The DEIS does not mention the quality or characteristics of the Collins Baldy, Eddy Gulch or the Johnny O’Neil LSR. It also fails to disclose perhaps dozens of 100 acre LSRs designated to protect northern spotted owl nests. The condition and purpose of LSRs are important considerations because the existing conditions suggest that they may not be capable of providing long-term, sustainable habitat for imperiled species like Pacific fishers.

Live Trees

DSC02236Tree mortality is a natural process in a forest ecosystem. Diseased, damaged and dead trees are key structural components of late-successional forests. Accordingly, management planning for LSRs must acknowledge the considerable value of retaining dead and dying trees. There are guidelines within the Northwest Forest Plan specifically for post-fire logging within LSRs.  All standing live trees should be retained and management should focus on retaining snags that are likely to persist until late successional conditions have developed and the new stand is again producing large snags. The project as proposed is contrary to the protection of the LSR and threatened species.

The proposal to log live trees raises the controversial issue of mortality models and marking guidelines for designating “dying” trees and it is illegal in LSRs. There is an extensive scientific literature on the delayed mortality of fire-damaged conifers on western forests. Ecosystems affected by the passage of fire are in a stressed condition and are the least able to withstand further disturbance. All trees that have a chance of surviving are needed to play critical roles in natural site regeneration. They should be preserved, even if some will later die. They provide site-adapted seed sources for new trees, shade for seedlings that is critical under the xeric conditions of most western forests, and a host of benefits to wildlife. If a few later succumb, they will provide snag habitat useful to wildlife.

Roadless Areas

Roadless areas are the only remaining larger tracts of intact habitat, which link wilderness and provide crucial wildlife connectivity and corridors. Inventoried Roadless Areas in the project include Grider and Snoozer. Released Roadless Areas include Johnson, Kelsey, Russian and Tom Martin. All roadless areas are increasingly important for maintaining biodiversity, conservation of species with small home ranges and species with special habitat needs.

The KNF proposes only manual treatments of sit prep and plant and fuels treatments within roadless areas, however logging adjacent to the roadless areas would create edge effects and fragmentation just outside of these areas and throughout the existing transportation system by logging from forest roads. Fuels treatments and plantation forestry would impact the undeveloped character of these areas. 

Klamath-Siskiyou Bioregion

The KNF is central to the Klamath-Siskiyou bioregion, which is home to the largest expanse of wild lands on the West Coast. The International Union for the Conservation of Nature recognized it as one of seven areas of global botanical significance in North America. These forests are a stronghold for rare species and wild salmon. The region is third in species richness (for taxa ranging from butterflies and plants to birds and mammals) for all temperate conifer forests across the continent and contains some of the highest biomass-dense forests in North America, sequestering carbon and storing carbon long after a fire.

The Klamath Mountains in the K-S are renowned for their wealth of conifer species and are recognized worldwide as a center of plant biodiversity. In the Russian Wilderness Area eighteen different conifers grow within one mile.

VISUAL QUALITY

This includes units located in the foreground of Highway 96, Klamath Wild and Scenic River, Tyler Meadows Trailhead, Cold Springs Trailhead, Grider Creek, Grider Creek Campground, Grider Creek road, and the Pacific Crest Trail.  The DEIS fails to consider the diminished visual quality from the Marble Mountain and Russian Wilderness Areas.

The project would create large openings with line and texture contrasts with adjacent burned or forested areas. Units and roadside treatments in Retention Visual Quality Objective (VQO) areas would likely not meet the visual quality standards. Recreation settings would also be would be adversely affected.

While an exception is allowed under the KNF Forest Plan Standards and Guideline 11-7 which states “In the case of recovery activities after extreme catastrophic events such as intense wildland fires, time periods to achieve the VQOs may be extended. This would be necessary where previously unnoticed scenery alterations are exposed to view due to loss of vegetative screening, or during timber salvage activities where recovery of forest vegetation is determined to be of greater importance than achievement of VQOs within the time periods established.”

However, clearcut logging is not a recovery activity and the visual quality of natural stands is already meeting visual quality objectives.

SOILS  

According to the KNF forest plan the maintenance of soil productivity, permeability and fertility is a National issue of high intensity. Soil is a critical component to nearly every ecosystem in the world, sustaining life in a variety of ways—from production of biomass to filtering, buffering and transformation of water and nutrients. 

The dominant soils within the analysis area are mostly sandy loams or loams with gravelly to extremely gravelly texture modifiers, indicating high natural infiltration rates, and high rock content in many areas. According to the DEIS, 4,236 acres would not meet desired conditions for soil stability; 900 acres would not be met for surface organic matter, 2,214 acres for soil organic matter and 1,255 acres for soil structure.

Soil Stability

An estimated 4,236 acres of the project area would not meet desired conditions for soil stability because soil cover would be less than 30 percent. Construction of temporary roads, associated with ground based harvest, would have the highest impact to soil stability and sedimentation. Post fire accelerated erosion due to ground based salvage logging could result in a 6 to 1,000 fold increase in sediment production.

Surface Organic Matter

Approximately 900 acres may not meet the desired condition for surface organic matter due to insufficient retention of large woody material. Post-fire woody debris constitutes a valuable natural element as a potential source of nutrients. Charred wood represents a considerable pool of nutrients including Nitrogen and micronutrients Sodium, Manganese, Iron, Zinc, and Copper.

Soil Organic Matter

It is anticipated that 2,214 acres for soil organic matter would not meet desired conditions. Less soil organic matter would decrease soils ability to hold moisture, with implications for soil biota, and plant growth. An adequate level of soil cover is needed to maintain soil stability and prevent accelerated erosion. The most severe displacement is expected to occur during temporary road construction, landings and skid trails. Displacement caused by new skid trails and temporary road construction will be considered a long-term disturbance as no mitigations to replace displaced soil organic matter are planned.

A Non-Native Invasive Plant project design feature would require removal of the top few inches soil on approximately 24 landings. This would result in major decreases to soil organic matter on landings. 

Soil Structure

Soil structure could have substantial negative effects and would not meet desired conditions on approximately 1,255 acres. Soil structure conditions are not met when areas have reduced infiltration and permeability capacity. Reduced infiltration and permeability capacity is expected due to the use of mechanical equipment on landings, skid trails, and temporary roads. Construction of new landings, and temporary roads would reduce infiltration to near zero. Changes in porosity occur both by the reduction of soil pore space by force applied to the soil surface (compaction) and the filling of pores by soil and ash material (soil sealing).

The DEIS claims, “Since this is less than 10% of the project area, Forest Plan standards will be met on the project area as a whole.” However, the KNF Forest Plan standards state that planned activities are to maintain or enhance soil productivity and stability and to maintain soil productivity by retaining organic material on the soil surface and by retaining organic material in the soil profile.

GEOLOGY  

There are about 3,920 acres of proposed salvage units on steep, weathered granitic lands designated as Riparian Reserves, about 960 acres of site prep and plant, 4,395 acres of roadside hazard tree removal and 3,940 acres of fuels treatments on unstable lands, Riparian Reserves.

The watersheds with a high landslide risk that will have a reduced duration of elevated risk are Upper Grider Creek, Cliff Valley, Lower Grider Creek, O’Neil Creek, Walker Creek, and Caroline Creek. The reduction in duration of elevated risk will benefit natural resources and infrastructure in the long-term. Middle Creek, Horse Creek, and Upper Elk Creek have a moderate landslide risk and will have a duration of elevated risk of 30 years in this alternative. Lower Grider and Walker Creek have very high landslide risk due to the potential to impact private land – so the reduction of elevated risk from more than 80 years to 30 years is of great benefit for protecting human safety and private property in these two watersheds. Rancheria Creek, which also has a very high landslide risk, will continue to have a greater than 80-year duration of elevated risk because there is less than 25 percent of the high and moderate vegetation burn severity areas being planted. All other watersheds will have a greater than 80 year duration of elevated risk.

The DEIS states that the project does not change the landslide risk for any watershed. However, there is a change in the risk ratio or the percent of watersheds with high or moderate disturbance for twenty-eight watersheds due to treatments. Then the DEIS claims that there is a reduction in the duration of elevated risk due to planting for nine watersheds compared to no action, but science shows that natural regeneration would take place. 

BOTANY

The DEIS assumes that botanical species of concern located in moderate severity burn areas are extirpated! This is not based in science as native plants have evolved with fire and could actually benefit. While microclimates may have changed in some areas, moderate severity fire is extremely variable and may still be providing all necessary elements for growth. Moderate severity fire causes moderate soil heating and occurs where litter is consumed and duff is charred or consumed, but the underlying mineral soil is not visibly altered.

Genter’s fritilary (Fritillaria gentneri) is an endangered lily, which is only known to occur in far northern California and north to Josephine County, OR. Habitat is present in the Beaver Fire area. The DEIS states surveys will be during appropriate times. The flowering season is late March to early April, so surveys should be complete.

Lake Mountain Special Interest Area is special interest area composed of 100 acres and is the northern most known location of Foxtail pine. It is home to at least 6 different conifer species including: western white pine, foxtail pine, Shasta red fir, white fir, mountain hemlock, and Jeffrey pine. Such assemblages of high-elevation conifers are rare throughout California and are restricted to the Klamath-Siskiyou Mountains. While a forest botanist is supposed to be on site, in order to maintain foxtail pine snags within this Special Interest Area it is not guaranteed. The retention of foxtail pine snags is important

because it provides an ecological role in stabilizing soils and providing food and habitat for animals. The Lake Mountain foxtail pine population represents the northernmost stand of this species and includes approximately 250 – 300 trees. One tree, cut after it was killed in the 1987 fires, was estimated to be between 550-600 years old.

The Cold Creek springs area within the Happy Camp area is an important resource for maidenhair fern (Adiantium aleuticum), which is frequently utilized by the Karuk tribe for basket weaving and botanical remedies. The KNF Forest Plan Standard and Guidelines require the maintenance and perpetuation of cultural botanical resources. There are 6 units located in the Cold Creek springs area that may affect the continued viability of this resource. Flagging these areas on the ground are supposed to protect this plant, however the agency and logging contractors have been know to enter flagged areas with heavy equipment.

Suitable habitat and/ or confirmed populations of 3 Sensitive species and 17 Fungi, Lichen and Bryophyte Survey and Manage species are present in the area. The cumulative effects of multiple projects on Sensitive species are expected to cause a short-term declining trend in population viability as individuals are lost.  The DEIS assumes that some activities would benefit populations in the long-term but fails to account actual details of specific places or populations or the benefits of natural regeneration.

Sensitive Vascular Plants

Eriogonum hirtellum is restricted to bald serpentine outcrops and gravelly slope and ridges that typically have no overstory cover and little understory vegetation. Due to the open characteristic of E. hirtellum habitat, equipment may be transported through the area, which could potentially damage some individuals within the populations. In the short-term, these effects would have a declining effect on population viability as individuals are impacted.

Direct effects to Erythronium hendersonii populations would occur to individuals and portions of the habitat where piles are burned but in the long run may benefit if understory vegetation is controlled.

The DEIS states that effects to Thermopsis robusta populations would benefit from using the gravel pullout where this population exists because of disturbance and that vegetation encroachment would cause negative long-term effects on population viability.

Sensitive Fungi, Lichens and Bryophytes

The DEIS claims that there would be no effects to these species because they are not known to occur, but surveys have not been done for these species in the project area.

Conifer planting is supposed to benefit sensitive ectomycorrhizal fungi, however the DEIS does not address the benefits of natural regeneration.

Survey and Manage Plant Species

Eighteen Cypripedium fasciculatum and sixteen Cypripedium montanum populations are present within units. High priority will be given to robust, healthy populations located in areas with intact suitable habitat present following the 2014 fires. The agency is relies on flag and avoid to protect these species.

Survey and Manage Bryophytes 

There are 2 known populations of Ptilidium californicum in roadside hazard units, which must be protected. Flag and avoid is expected to protect the species.

Survey and Manage Fungi 

There is one population of Albatrellus flettii, Otidea leporine,Phaeocollybia

californica and Tremiscus helvelloides and two populations of Phaeocollybia olivacea located throughout activity units. Flag and avoid is expected to protect the species.

Non-native Invasive Species

The project has a high risk potential for the introduction and spread of non-native invasive species, which are likely to persist long term. This is due to the high level of ground disturbing activities and increased vectors. There are 995 acres of known non-native invasive plant populations for 12 different species in the project area.

A non-native invasive plant project design feature would require removal of the top few inches soil on approximately 24 landings, resulting in major decreases to soil organic matter on landings. Cumulatively there are 8 grazing allotments that overlap treatment units and may contribute to the long-distance dispersal of infestations in the project area.

The Forest Service has a duty to reduce and eliminate noxious weeds on our public lands and the DEIS does not fully consider or analyze the long-term affects to our watersheds and native plant species.

CULTURAL RESOURCES

The project has the potential to affect 159 previously recorded historic properties and an unknown number of unrecorded historic properties and cultural resources. The DEIS does not consider numerous culturally significant trees, plants or animals as required for cultural botanical resources nor does it consider or incorporate Traditional Ecological Knowledge. 

RANGE 

The DEIS states that to allow for post-fire recovery of vegetation, livestock grazing areas will be modified within the project area where necessary. For the Middle Tompkins allotment, livestock grazing permits will not be authorized until 2016 or later. Lake Mountain and Dry Lake allotments will be monitored prior to the 2015 grazing season to determine if vegetation has recovered enough to support grazing and grazing won’t hinder tree establishment. If grazing is allowed, animals may be turned out at a later date and/or the season may be shortened in the fall to allow for optimal vegetation recovery and the most beneficial use of livestock grazing. These modifications for post-fire livestock use of rangelands will be variable based to rangeland conditions and climate as observed by rangeland managers.

While we encourage the recovery of our wild places, grazing cattle continues to be one of the most harmful practices on our national forests and certainly on the KNF. There is little confidence the agency will follow through with its commitments. Five years of monitoring and documenting grazing allotments on the KNF has shown the consistent failure to meet water quality and KNF Forest Plan standards.

SOCIAL, ECONOMIC AND COMMUNITY IMPACTS 

Only 32% of the cost for the fuels treatments and the site prep and plant would be captured.  This leaves a small chance that these activities, that the DEIS relies on for reducing fuels and “restoring” forests faster, would actually happen.  The increased fire danger from not treating activity fuels and small fuels around communities is not considered.

The social and economic impacts to public trust resources such as clean water, wildlife, fisheries and carbon storage were not evaluated.

Helicopter logging and ‘salvage’ logging in general would extract the largest trees, leave the small trees creating a deep sea of slash and flammable fuels.  The Salmon Salvage timber sale, implemented last year on the KNF is a testament to that.  Forest managers are scratching their heads trying to figure out how to deal with all the slash. They are even considering dropping fire from a helicopter to engulf the flammable ground fuels left behind from logging on these steep mountain slopes.  Logging in this manner does not create fire safe communities. It puts communities at risk with immeasurable ecological costs. 

CLIMATE CHANGE

The ability of the Region’s forestlands to sequester and store carbon has become a matter of national and international significance.

Region 5 Ecological Restoration Implementation Plan

The DEIS claims that our forests will benefit from fuels reduction designed to favor fire-resistant trees and reduce the risk of loss due to wildfire and will ultimately reduce carbon dioxide emissions from future fires. The DEIS fails to mention the effects of logging or include analysis regarding the carbon emissions involved in logging, yarding, hauling and processing. It does not consider: the rate of CO2 emissions from standing snags compared to snags that are taken off site, the role of down rotting logs on soil carbon levels or future stand development and CO2 capture, the role of forest soils on carbon sequestration, the impacts of increased fire hazard (via slash and plantation establishment) for the first 20 years after harvest on carbon sequestration should there be another stand replacing fire or the influence of the low surface to volume ratio of slash, sawdust and disposable wood products compared to the high surface to volume ratio of large snags and down wood on carbon sequestration.

A recent Executive Order called for several agencies, including the Department of Agriculture to meet and create a plan to adapt their land- and water-related policies to protect watersheds and natural resources in the face of climate change. The DEIS does not consider or address the 2012 National Fish, Wildlife and Plants Climate Adoption Draft Strategy.

Live tees, like the live trees targeted for removal in the Westside project, absorb carbon dioxide for use in photosynthesis, making them one of the most effective natural tools to remove the greenhouse gas from the atmosphere. It is imperative to retain dense stands and canopy on north and east facing slopes in regards to climate change as these areas will provide the highest amount of refugia for plant and animal species.  Further, the DEIS fails to analyze the fact that large old trees can store carbon for decades and even centuries. Preserving intact snag forest ecosystems and forests in this region is also a local solution to climate change.

NATURAL REFORESTATION AND RESTORATION

Recent data shows that the highest biomass and carbon levels are maintained by periodic high-intensity fire, due to the combined biomass of the snags and logs from the previous fire and the vigorous natural tree regeneration spurred by the fire and the nutrient cycling resulting from the fire. Vigorous natural conifer regeneration is the rule, not the exception, in high-intensity fire areas in Northern California.

Undisturbed complex early successional post-fire forests are often the most biologically diverse of all forest conditions and are both more rare and more imperiled than old-growth forests in many regions.

Although tree regeneration after disturbances is important, a narrow view of this issue ignores ecological lessons, especially the role of disturbances in diversifying and rejuvenating landscapes. Disturbances are not catastrophes and post-fire logging is not forest restoration or recovery.

High-severity patches are of greatest importance to the ecological integrity of a large burn area as they provide a unique pulse of biological legacies that sustains the diversity of plants and wildlife. Post-fire landscapes are not in need of “restoration” because fire itself is a restorative agent. Public lands may be the last stronghold for maintaining these unique ecosystems.

CONCLUSIONS

The Westside project would destroy the Caroline Creek eagle nest area and would harm imperiled native wildlife, endemic species, wild salmon, water quality Wild and Scenic Rivers, Visual Quality Objectives, soils, geology, botany, cultural resources and vital biological legacies.  Fuels treatments may never be funded and would endanger river communities.

Most of the impacts are to Late Successional Reserves and to Riparian Reserves, Visual Quality Objective areas and Critical Habitat for the increasingly threatened Northern spotted owl and Coho salmon.  The KNF cannot legally elect to span snag retention guidelines to average over one hundred acres when it is clear that snag retention is meant for a per acre basis nor can it assume that moderate severity burn areas no longer support habitat for native plant and animal species.

The Westside DEIS is contrary to the recovery of threatened species listed under the Endangered Species Act.  The project violates the Clean Water Act, the Magnuson-Stevens Fishery Conservation and Management Act, the Northwest Forest Plan and the Klamath National Forest Land Resource Management Plan and is contrary to the recommendations of multiple watershed analysis and Late Successional Reserve Analysis.

The project also violates the National Environmental Policy Act by failing to take a hard look at cumulative effects, failing to use plain language, failing to consider the difference between moderate and high severity fire, fails to consider visual impacts from the Wild and Scenic North Fork Salmon River, fails to consider geologically unstable areas as Riparian Reserves, fails to honestly consider climate change, fails to consider public trust resources such as clean water, carbon storage, wildlife and recreation as an economical value, fails to adequately consider the ecological costs.

Click Here to Take Action Now: Please tell Patty Grantham, KNF Forest Supervisor, to cancel the Westside Project and to work with river communities on a common sense long-term fire strategy plan that is good for wildlife, wild rivers, wild places and the people.


Sign Petition to Stop Westside – One of the Largest Timber Sales in US History!

Wednesday, March 25th, 2015
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Westside photo 2

Westside unit looking into Grider Creek Roadless Area next to a dozer line.

 

Click here to take action now. The Klamath National Forest is proposing one of the largest timber sales in US history!  Over 30,000 acres of post fire habitat are at risk of elimination.  These steep and rugged watersheds support the most productive wild salmon and steelhead fisheries outside of Alaska, the largest acreage of unprotected low elevation ancient wild forest remaining on the West Coast, a high concentration of Wild and Scenic rivers and are world renowned for their rich biodiversity with many rare and endemic native species.

The recently released Draft Environmental Impact Statement contains multiple action alternatives, however none of them are ecologically sound. The project proposes to log between 100 -200 million board feet from 6,800 acres in larger forest stands, 650 miles of roadside equaling 20,500 acres, another 3,000 acres on ridge tops and outside of private property. The project also proposes to re-open decommissioned roads as well as create 22.6 miles of new roads requiring at least 14 new stream crossings.

Nearly half of the treatment area is within mature forest reserves, which were designated to protect and enhance mature forest ecosystems that serve as habitat for old growth dependant species.  A vast amount of the project is within Critical Habitat for the Northern spotted owl and would remove over 1,000 acres of habitat.  Other rare species such as the marten, fisher and the endemic Siskiyou Mountain salamander are in danger. Visual quality and fisheries on six Wild and Scenic Rivers are threatened, as well Key watersheds deemed vital for salmon survival and Critical Habitat for Coho salmon. The project would negatively affect six different Inventoried Roadless Areas, which are vitally important because they are the last large tracts of un-roaded wild lands outside of wilderness.

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North Fork salmon River Salmon Salvage Timber Sale 2013

The Westside project considers logging in three distinct fire areas but fails to analyze them separately. The Beaver Fire area is north of the town of Scott Bar near the Oregon border.  Here the public land is intermixed with forests long abused by industrial timber management.  In fact, the entire area has been logged and replanted since 1955.  The Happy Camp Fire area, on the Klamath River contains one of the most important wildlife corridors on the North Coast, the Grider Creek watershed, which is threatened by the proposed project.  The Whites Fire, on the Wild and Scenic North Fork Salmon River, burned within and adjacent to the Russian Wilderness.  The entire watershed has been impacted by two years of fire, fire suppression and multiple timber sales.  The Salmon River watershed is a stronghold for the last remaining viable run of Spring Chinook salmon.

The project would multiply the damage already incurred by last summer’s fires and fire suppression, which cost taxpayers $195 million dollars.  Nearly 200 miles of ridgelines were bulldozed to bare earth leaving behind swaths of clearcuts and huge amounts of slash.  Hundreds of thousands of gallons of fire retardant coated entire ridgelines and the heavy use of roads and fire effects caused severe sedimentation into salmon bearing creeks.

Comments on the recently released Draft Environmental Impact Statement are due April 13th.  Because vital wildlife information has not been released but is referenced in the document, EPIC is asking for an extension on public comment.

Please tell the Klamath National Forest that the ecological costs of the Westside project are too high.  Our forests have higher than monetary value. Our communities, wildlife and watersheds deserve better.

Click here to voice your opposition and share your concerns- Sign the petition and please attend a public meeting hosted by the Klamath National Forest Tuesday April 7 @ 5:30 at Six Rivers Headquarters by the Bayshore Mall.


Massive Timber Sale Proposed for Klamath National Forest – Public Meetings Announced

Tuesday, January 27th, 2015
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Photo by Nat PenningtonA massive 43,883 acre post-fire logging project is being proposed by the Klamath National Forest. Almost half of the project is within areas that are supposed to be set aside to protect and enhance old growth forest ecosystems called, Late Successional Reserves. The Forest Service is planning to streamline this unprecedented timber sale, which would shorten public comment opportunities, and speed up the environmental review process.

The proposal is dubiously named the Westside Fire Recovery Project, but instead of acting as a prescription for recovery; the proposal would devastate old growth forests, watersheds, salmon, sensitive animal and plant species, and proposes to plant 20,000 acres of even aged plantation forests that would increase the potential for high intensity fires in the future.

Recent post-fire “salvage” logging projects that have been carried out by the U.S. Forest Service on Klamath National Forest have not followed mitigation measures and have failed to implement project design features put in place to protect wildlife and fisheries, resulting in negative impacts to fish and wildlife.

We recognize the need for hazard tree removal for roadside safety along primary roads, defensible space around homes and communities, and strategic fuel breaks. However, proposed logging in the Westside proposal targets mature forests that are located on steep slopes with unstable soils in high value watersheds for at-risk salmonid populations. This is a region where salmon populations are already heavily impacted by many other factors including dams, diversions and drought, and millions of dollars have been spent on fisheries restoration projects. These irreplaceable ecosystems should not be traded for short-term economic gains.

Forests need fire. Post-fire landscapes are more biologically diverse than unburned forests are considered to be one of the rarest and most ecologically important forest habitats. Historically, Native Americans would use fire as a means to thin out the understory, open up the forests for fruit and nut producing shrubs, and enhance prairie grasslands and to cultivate basket weaving materials. Decades of fire suppression combined with post-fire logging, and uniform tree planting, has allowed for much of the region become densely overgrown and the forests have become less biologically diverse. After a fire burns through a forest, the large old growth trees usually don’t die, the small overcrowded trees are cleared out, the snags that are left become wildlife habitat, and the downed trees hold the slopes together, enhance soil complexity and eventually become fish habitat when they fall into the waterways. However, when roads are made on the sensitive burned soils and many of the largest marketable trees are logged, large sediment loads are sent into watersheds, and the soils, forests and watersheds have a difficulty recovering.

We need your voice to advocate for real recovery! The Forest Service has scheduled informational meetings to allow for public input on the Westside Project. Please come out and voice your concerns for this unprecedented large and hurried process that targets some of the most productive and best habitat for the last remaining run of wild spring Chinook salmon and other rare plant and wildlife species.

Westside Fire Open House Meeting Schedule:

Yreka– Friday, January 30 from 6:00 to 8:00 p.m. at the Klamath National Forest Headquarters Office

Scott Valley– Saturday, January 31 from 12:00 to 3:00 p.m. at the Fort Jones Community Hall

Klamath River– Tuesday, February 3 from 6:00 to 8:00 p.m. at the Community Center

Happy Camp– Wednesday, February 4 from 6:00 to 8:00 p.m. at the Karuk Senior Nutrition Center

Scott Bar– Thursday, February 5 from 4:30 to 6:30 p.m. at the Community Hall

Sawyers Bar– Friday, February 6 from 3:30 to 5:30 p.m. at the Salmon River Restoration Council

Seiad– Friday, February 6 from 6:00 to 8:00 p.m. at the Seiad Fire Hall

Please come to these meetings and be a voice for the wild!


Advocate for Real Recovery

Wednesday, November 12th, 2014
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Take Action: The Klamath National Forest recently proposed a massive post-fire logging operation throughout some of the most important watersheds on the north coast. The Westside project targets up to 43,338 acres concentrated in Late-Successional Reserves (old forests), Riparian Reserves (streamside forests), in Wild and Scenic River corridors and within Northern spotted owl critical habitat.

This summer, fire burned through 200,000 acres of the Mid Klamath watershed, three-quarters of which were low to very low severity. While the fires burned—a necessary and important forest process in the Klamath Mountains—fire suppression efforts left a long-lasting mark on the landscape. Bulldozers marched through the forest creating wide and often ineffective firebreaks stacked with slash and denuding untold miles of ridgelines.

While the proposed cuts are bad in their own right, they are especially egregious in light of the recent past fires and intense fire suppression activities surrounding the Marble Mountain Wilderness Area. Further, there are past, present and proposed future timber sales throughout the region. The additional logging proposed in the Westside project would diminish crucial wildlife connectivity, like the Grieder Creek corridor that links contiguous habitat to and from the Marble Mountain Wilderness.

The Klamath National Forest is central to the Klamath/Siskiyou bioregion and is a treasure worth protecting. It is a biodiversity hot spot, supporting a wide variety of unique animals and plants including the endangered Northern spotted owl, Pacific fisher, Humboldt marten, and California wolverine. The cool, clean waters of the area protect California’s most robust salmon runs. Preserving intact forests in this region is also a local solution to climate change. The bioregion contains some of the highest biomass-dense forests in North America, sequestering carbon and storing carbon long after a fire.

Fire is a necessary component of healthy forest ecosystems. EPIC is currently engaging with the Klamath National Forest on a programmatic and project-by-project level to ensure sensible fire management. Post-fire logging is devastating for our wildlife, and wild places. The agency should engage with local community partners like the Western Klamath Restoration Partnership to work towards long-term fire strategies. Comments are due by November 14th. We need your help. Please help us advocate for real recovery.

Click here to take action now!

For more information on fire’s role in our forests and the harmful effects of post-fire logging, please visit our website.


Jess Say No—Take Action to Save Forest Canopy and Wildlife Trees

Monday, November 10th, 2014
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Take Action: The Jess timber sale would remove vast amounts of forest canopy, disturb riparian reserves and targets old growth and mature wildlife trees within Critical Habitat for the Northern spotted owl. The project would cut nearly 1,000 acres of north facing slopes within the North Fork Salmon River watershed on the Klamath National Forest, adding to the cumulative effects of 45,000 acres of wildfire, extreme impacts from firefighting and post-fire logging from the 2013 Salmon Complex Fire.

The Wild and Scenic North Fork Salmon River is one of the most important rivers for the last remaining wild-run of spring Chinook salmon and contains habitat vital to rare and threatened species. These north facing native stands offer cool microclimates that contain precious remnants of older trees and are generally less susceptible to severe fire events. Removing 70% of the forest canopy, as proposed would be detrimental to wildlife and would increase fire behavior in the long-term.

The recently released Draft Environmental Impact Statement did not consider the massive impacts from recent two years of fire activity. Nearly the entire road system in North Fork watershed has seen considerable traffic from large trucks and heavy equipment. The prolonged high-use of roads has caused sediment to flow into creeks throughout the watershed. In the Jess project area, approximately twenty miles of ridge top fire lines were bulldozed to bare earth during the 2014 Whites Fire and are now covered in slash. Further, wet weather post-fire logging has occurred roughly 1,000 acres of steep erodible hillsides directly across the river.

The Jess DEIS did not consider the newly proposed Westside post-fire project introduced by the agency last month, which targets up to 43,883 acres of fragile post-fire habitat throughout the Klamath National Forest. Within the Whites Fire footprint, directly across the river, 7,600 acres of Late Successional (mature trees) Reserves, Riparian Reserves and the North Fork Salmon Wild and Scenic River corridor are threatened.

Please urge Klamath National Forest decision makers to protect our wildlife and wild places and to work proactively and collaborate with local communities, partnerships, watershed restoration and fire safe councils to create an alternative that would follow the recommendations in the Salmon River Community Wildfire Protection Plan and would accomplish fuels reduction, forest health and fire resiliency objectives in a way that retains forest values.

Click here to sign a petition now!

Or submit your own comments through the Forest Service Portal November 17th.

Dozer lines in the proposed Jess timber sale project area from the 2014 Whites Fire

Canopy removal with leave tree mark- all trees not marked with orange would be cut

Jess Project forest stands

Wildlife trees


Protect the Wild Salmon River – Stop “Salvage” Logging

Tuesday, June 10th, 2014
By

Photo#1_KellyGulchTake Action! The Wild and Scenic (W&S) North Fork Salmon River is threatened with post-fire “salvage” logging. The Salmon/Scott River Ranger District of the Klamath National Forest (NF) is proposing to streamline logging on over 1,000 acres of steep slopes, including road construction over trails and overgrown roads.  Over 60% of the project area is within Critical Habitat for the threatened Northern Spotted Owl.  The W&S North Fork Salmon River is designated a Key watershed, meaning it is critical for salmon recovery.  The river is also listed under the Clean Water Act as being impaired. This project jeopardizes the wild and rugged nature of the North Fork Salmon River.

The Klamath NF Environmental Analysis of the Salmon Salvage project continues to claim that no new roads are needed, however one of the “existing” roadbeds, nearly a mile long, has not been used for decade. It is grown over, laden with landslides and located on a steep and unstable hillside. Heavy equipment and severe earth moving would be required to make it ready for 18 wheeler logging trucks. Where there are roads, there are landings to accommodate heavy equipment.  Landings are bulldozed flats that are 1/2-acre to up to two-acre openings.

Photo#2

Kelly Gulch A Spur “Existing” Road

Photo#3_LookCloseFlaging

Same “road” look close for flagging, which indicates location of the road

Over 300 acres of the project is within larger forest stands.  One of these areas along the Garden Gulch Trail provides high quality Critical Habitat for the Northern Spotted Owl, and is a popular gateway that leads into the Marble Mountain Wilderness.  EPIC and the conservation community have been defending this beautiful forest stand for a decade, first fighting the Knob Timber Sale, and then recently in opposition to the Little Cronan Timber Sale.  The agency is calling the trail an “existing” road, and now proposes to open the Garden Gulch trail, which is adjacent to a creek, to 18-wheeler logging trucks, bulldozers and other heavy equipment.

Garden Gulch Trail next to the creek and proposed road location

Garden Gulch Trail next to the creek and proposed road location

This particular forest stand, Unit 345, contains hundreds of big older trees, many of which are still very alive and green. It provides a vital link for wildlife connectivity and exemplifies high quality mixed conifer post-fire habitat.  The area burned at moderate to low severity contributing to the ecological quality of this ideal post-fire forest stand.  These trees are providing shade and valuable wildlife habitat, creating a healthy complex forest structure, all part of a natural process. Bulldozers, trucks, roads and landings do not belong on this trail or in this showcase post-fire habitat forest stand.

Southern Boundary next to the Garden Gulch Trail

Southern Boundary next to the Garden Gulch Trail

There are five Northern Spotted Owl (NSO) home ranges within the project vicinity.  Recent science shows that the owls benefit from burned forest stands and that post-fire logging has the potential to increase extinction rates, especially when done within core areas.  The NSO species Recovery Plans calls for “conserving and restoring habitat elements that take a long time to develop (e.g., large trees, medium and large snags, downed wood).

In their rush to implement this ecologically damaging project, the agency has sought an Emergency Situation Determination (ESD) from the regional forester.  If the request for an ESD were to be granted it would mean that trees can be cut down as soon as a decision is issued and a contract is signed, despite any appeal or claims brought in court.  Seeking an ESD circumvents judicial review, eliminating the public’s recourse in challenging poor decisions that threaten our public lands.

Take Action Today to Stop the Salmon River Salvage Project! Let Patricia Grantham, Forest Supervisor of Klamath National Forest know that you oppose post-fire logging that results in habitat destruction and road construction in designated Key watersheds like the North Fork Salmon River. Post-fire landscapes are considered to be one of the most rare, endangered, and ecologically important habitats in the western U.S.  They are rich, vibrant and alive and often provide more biodiversity than green forests.  Read more about the environmental effects of post-fire logging.  Take a walk in Garden Gulch.   See the overgrown unused Kelly Gulch A Spur Road on steep and unstable hillsides proposed for re-construction.  View more photos here.


Connecting Wild Places

Tuesday, April 22nd, 2014
By

Journey LOGO selected finalSign the petition to Protect and Connect Wild Places!

How much more evidence do we need until entrusted representatives and forest, wildlife and water managers work together to change the direction of this crisis we are in? How many decades do we need to learn the same lessons? We can and we must act now to protect and connect wild places!

Conserving and connecting habitat is the number one goal of the National Fish, Animal and Plants Climate Adaption Strategy, “Sustaining a diversity of healthy populations over time requires conserving a sufficient variety and amount of habitat and building a well-connected network of conservation areas to allow the movement of species in response to climate change.” Establishing wildlife corridors and linkages that are providing vital habitat connectivity is key to species survival and should be a priority.

With 25 National Park units, 18 national forests, more than 15 million acres of Bureau of Land Management lands and 270 state parks and beaches California offers an amazing opportunity to establish an interconnected intact landscape, especially in the Pacific Northwest. Roadless areas, rivers and ridges linking wilderness and core habitat areas, not only provide for wildlife but are also a key to clean water and air in this rapidly changing climate.

Our forest ecosystems of are astoundingly beautiful and globally significant.  They serve as massive carbon banks and are refuge for increasingly rare plants and animals.  California is the wildlife state with unparalleled biological diversity. We have more species and endemic species than any other state in the nation. Alarmingly, according to the CA Dept. of Fish and Wildlife’s 2011 Special Animals List, the majority of our wildlife needs help: 88% of amphibians, 87% of native fish, two out of three mammals, and nearly half of all birds and reptiles are “at risk.” This decline of wildlife is indicative of the failing health of our ecosystems, of which we depend.

Logging, grazing, agriculture and multiple other stressors continuously threaten our watersheds and come with devastating ecological costs. It is time for change. California will soon be welcoming wolves and they need room to roam. We need wild places. Tell your entrusted leaders to Protect and Connect Wild Places now!

Our goal is to reach 10,000 signatures by June 1st and >50,000 signatures by the 50th Anniversary on the Wilderness Act on September 3rd. Please sign the petition and share with your friends and family.

The petition will go to:

  • President Obama
  • Secretary of the Interior- Sally Jewell
  • Secretary of Agriculture
  • Chief of the Forest Service- Tom Tidwell
  • Chief of Bureau of Land Management
  • US Fish and Wildlife
  • California US Forest Service Supervisors
  • CA Department of Fish and Wildlife
  • CA Fish and Games Commissioners
  • All of the CA House of Representatives and Senate
  • Governor Brown
  • Others TBD

Links for additional resources:


Take Action! Protest Destructive Post-Fire Logging on the Salmon River

Tuesday, December 3rd, 2013
By
Photo#1_KellyGulch

Kelly Gulch Hillside- within the Salmon Fire Project

Take Action! The Wild and Scenic (W&S) North Fork Salmon River is threatened with post-fire “salvage” logging. The Salmon/Scott River Ranger District of the Klamath National Forest (NF) is proposing to streamline activities within Inventoried Roadless Areas and riparian reserves, including extensive new road construction over trails and overgrown roads.  Over 60% of the 1,872 acre project area is within Critical Habitat for the threatened Northern Spotted Owl.  The W&S North Fork Salmon River is designated a Key watershed, meaning it is critical for salmon recovery.  The river is also listed under the Clean Water Act as being impaired. This project jeopardizes the wild nature of the North Fork Salmon River and the well-being of the wildlife and communities that depend on it.

Photo#2

“Existing Road”

The Klamath NF deceptively claims that no new temporary roads are needed, however some of the “existing” roadbeds have not been used for decades, have completely grown over and are covered in trees, rocks and landslides. One of these very old unused roads, which is nearly a mile long, is located on a steep and extremely unstable hillside. A great deal of heavy equipment and severe earth moving would be required to make it ready for logging trucks and equipment. Further, when there is a road there is often a need for a landing at the end of the road to accommodate large trucks and heavy equipment.  Landings are bulldozed flats that are 1/2-acre to up to two-acre openings.

Photo#3_LookCloseFlaging

Same “road” look closely for the flagging which indicates location of the road.

Over 300 acres of the project is within larger forest stands.  One of these areas along the Garden Gulch Trail provides high quality Critical Habitat for the Northern Spotted Owl, and is a popular gateway that leads into the Marble Mountain Wilderness.  EPIC and the conservation community have been defending this beautiful forest stand for a decade, first fighting the Meteor Timber Sale, and then recently in opposition to the Little Cronan Timber Sale.  Again, the agency is calling the trail an “existing” road, and now proposes to open the trail, which is adjacent to a creek, to bulldozers, logging trucks and heavy equipment.

Garden Gulch Trail next to the creek and proposed road location

Garden Gulch Trail next to the creek and proposed road location.

This particular forest stand exemplifies high quality mixed conifer habitat and contains hundreds of big older trees, many of which are still very alive and green.  Only very small patches of the forest burned at high severity, which actually contributes to the ecological qualities of this ideal post-fire forest stand.  These trees are providing shade and contributing to a healthy complex forest structure, and they will be providing future nutrients to the soil.  It is all part of a natural process. Bulldozers, trucks, roads and landings do not belong on this trail or in this showcase forest stand.

Southern Boundary next to the Garden Gulch Trail

Southern Boundary next to the Garden Gulch Trail

There are four Northern Spotted Owl (NSO) nest sites (core areas) within the project vicinity.  Recent science shows that the owls benefit from burned forest stands and that post-fire logging has the potential to increase extinction rates, especially when done within core areas.  The NSO species Recovery Plans calls for “conserving and restoring habitat elements that take a long time to develop (e.g., large trees, medium and large snags, downed wood).

In their rush to implement this ecologically damaging project, the agency has sought an Emergency Situation Determination (ESD) from the regional forester.  If the request for an ESD were to be granted it would mean that trees can be cut down as soon as a decision is issued and a contract is signed, despite any appeal or claims brought in court.  Seeking an ESD circumvents judicial review, eliminating the public’s recourse in challenging a poor decision that threatens our public lands, making public participation a mere charade. This project not only threatens the ecological viability of forests on the edge of the Marble Mountain Wilderness, the Klamath National Forest is attempting to undermine democracy.

Take Action Today to Stop the Salmon River Salvage Project! Let the Regional Forester and the Forest Supervisor know that you oppose post-fire logging that results in habitat destruction and road construction in designated Key watersheds like the North Fork Salmon River.

Post-fire landscapes are considered to be one of the most rare, endangered, and ecologically important habitats in the western U.S.  They are rich, vibrant and alive and often provide more biodiversity than green forests.  Read more about the environmental effects of post-fire logging.  Take a walk in Garden Gulch.   See the overgrown unused Kelly Gulch A Spur Road on steep and unstable hillsides proposed for re-construction.  View more photos here.

 


Aerial Tour of Summer 2013 Fires

Tuesday, October 15th, 2013
By

Aerial Tour of Summer 2013 Fires

In September, as Public Land Advocate for EPIC, I was provided the opportunity to do an aerial tour of this summer’s wildfires.  As with most fires in Northern California, a majority of the fire areas burned at low and moderate severity.  Over 50 miles of bulldozer lines were constructed and estimated costs for suppression efforts reached up to one million dollars per day.  EPIC advocates for appropriate land management in order to restore fire on the landscape and to protect communities rather than continuing the expensive chaotic military style of fire suppression.

There are always lessons to learn after an active fire season.  This year, local river communities and tribes worked closely with fire and Forest Service personnel, unlike years past.  These small changes over time may one day find us well-prepared and ready to welcome fire.  (All photos courtesy of Kimberly Baker, unless otherwise noted.)

Salmon River Complex

SalmonRiver

Salmon River Panoramic: Butler Fire on left, Forks Fire on right – photo courtesy of Thomas Dunklin

Butler

The human caused Butler Fire on the main stem Salmon River reached over 22,000 acres and burned for nearly two months.  The estimated cost for suppression was $36,000,000.  Approximately 27 miles of bulldozer lines and approximately 10 miles of hand fire lines were constructed.

1-ButlerHomesA

Surrounding Butler Flat – Photo courtesy of Thomas Dunklin

 

Overview of mosaic burn patterns

Overview of mosaic burn patterns

 

Fire line near Orleans Mt. summit - Photo courtesy of Kimberly Baker

Fire line near Orleans Mt. summit

 

5-dozerButler

Fire line Somes Mt. summit

 

6-hotelling

Extensive 5 mile bulldozer line on Hotelling Ridge

 

Forks (North Fork)

The human caused North Fork Salmon River Fire reached nearly 15,000 acres.  It burned for the month of August with suppression costs of $23,000,000.  Over 8 miles of hand fire lines were constructed as well as over 5 miles of bulldozer lines. Overall, a vast majority, 10,658 acres of the fire burned at low severity, 3,250 at moderate and 802 acres burned at high severity.

1-NorthFork_ThomasDunklin

Complete overview North Fork Fire – Photo courtesy of Thomas Dunklin

 

Downstream Forks Fire - Photo courtesy of Kimberly Baker

Downstream Forks Fire

 

Fire line burnout - Photo Courtesy of Kimberly Baker

Fire line burnout

 

 Dance Fire

The Dance Fire in the town of Orleans reached 650 acres and burned for nearly a week.  Tragically a home belonging to a Karuk elder was completely lost.

1-Dance

Dance Fire

 

Corral

The naturally ignited Corral Fire outside the Hoopa Valley and Willow Creek burned entirely within the Trinity Alps Wilderness.  The fire reached over 12,000 acres and burned for nearly two months. Approximately 21 miles of bulldozer line was constructed and approximately 18 miles of hand fire line was constructed.

Trinity Alps Wilderness

Corral Fire in Trinity Alps Wilderness

 

Corral fire with Megram Fire of 1999 in background

Corral Fire with Megram Fire of 1999 in background

 

3-Mosiac_Corral

Mosaic burn patterns

 

Mosaic burn patterns

Mosaic burn patterns

 

Corral Fire lines

Corral Fire lines

 

Bulldozed fire line

Bulldozed fire line

The Dance, Butler and Salmon Fires were all intentionally set. There is a $20 000 reward for information leading to the arrest and conviction of the person or persons responsible for starting the Salmon River Complex and Butler Fires. Anyone with information is asked to contact the Arson Tip Line at 1-800-842-4408.


Wildlands Civics as an Expression of the EPIC Mission

Sunday, October 13th, 2013
By
Caribou Fire Salvage Sale: these four foot snags were saved by EPIC.

Caribou Fire Salvage Sale: these four foot snags were saved by EPIC.

A recurring theme in all of the work that EPIC develops, to advance protections for the web of life in Northwest California, is the concept of environmental democracy. Whether it be advocating for an increased inclusion of stewardship land ethics in natural resource based economic sectors in our bioregion, challenging state agencies to do adequate review of the major infrastructure projects that are proposed in sensitive landscapes, or leveraging the online activism of our supporters to secure conservation oriented management regimes on our public lands, EPIC strives to be a conduit for meaningful public participation by our community on the issues that can have an impact on our rural lives. Environmental democracy is one way to describe the involvement of the citizenry in these crucial processes around natural resource exploitation on the North Coast—our team at EPIC also refers to our authentic grassroots activism as an expression of “Wildlands Civics.”

The idea of Wildlands Civics is captured in the mission statement of EPIC. Ancient forests, watersheds, endangered species; these elements of the biosphere are all included in our mission. EPIC has a far-reaching objective to protect natural and human communities on the North Coast of California. To understand how the concept of Wildlands Civics influences the development of EPIC advocacy strategies it can help to look further at the mission of EPIC: EPIC uses an integrated, science-based approach, combining public education, citizen advocacy, and strategic litigation.

Breaking these elements down further illuminates how the active participation of EPIC and our base of supporters in a multitude of public decision-making processes is in its purest form a practice of civics with the overarching intent of protecting the wildlands that provide habitat for wildlife and essential environmental services for human kind—hence, Wildlands Civics.

Public Education

Any effort to mobilize and galvanize the public to engage on a particular issue requires a concentrated effort at Public Education. As an example, the Public Lands Program at EPIC has a long-term conservation advocacy vision of Returning a Natural Cycle of Fire to Our Landscapes. Clearly, the best contemporary science shows that fire plays an essential role in the maintenance of a healthy forested landscape, yet there are major impediments to achieving a reestablishment of natural patterns of wild fire disturbance regimes across Northwest California. As our organization engaged with land managers and stakeholders on this issue we knew immediately that informing California residents about the benefits of wildfire would take some degree of Public Education to ensure that our goals regarding fire would be understood, and to get people involved in a proactive manner with the issue. The evolution in the policy discourse around wildfire is resulting in an increased understanding by the public that fire is as natural, though less frequent, than rain in our diverse North Coast forests. This is an encouraging sigh that our public education efforts at EPIC are contributing in a positive way to a broad movement of diverse stakeholders that aspires to change the way our society perceives our relationship to the land and the natural processes that provide for ecological resilience and the maintenance of biodiversity.

Citizen Advocacy

EPIC was formed in 1977, and technology has changed a great deal since the founding of the organization. This change in technology has spurned an increase in the ability of public interest advocacy organizations like EPIC to provide a means to gain standing in a public process, and to provide comments to address shortcomings and inadequacies in project design and environmental review. A substantial amount of EPIC’s practice of Wildlands Civics is built around proven methodologies of forest watch and agency monitoring, in which systematic attention is paid to the process by which projects are announced and how documentation concerning economic activities is presented to the public. Wildlands Civics is in this way predicated on the tactics of an environmental watchdog group, and the mobilization of a concerned constituency of local, state, and national residents who stand behind our organization’s policy positions provides EPIC the leverage to be an effective guardian of your wild backyard. Another important aspect of Citizen Advocacy is that some of the most severe threats to landscape integrity in our bioregion, such as egregious cannabis agriculture operations, are still outside of the purview of regulating agencies. By getting the public involved on complex and unorthodox issues we can create a vocabulary that describes the standards of sustainability that our landscapes require of us, and through Citizen Advocacy EPIC can participate in the community drive to find workable solutions to complex challenges.

Strategic Litigation

Even as global alarm bells are ringing with an increasing urgency, many environmentally harmful projects and economically unsustainable natural resource exploitation schemes are approved by government agencies across our region. In some instances, well thought out and strategic litigation is necessary to protect public trust resources and the rights of the citizenry to have influence over how our tax dollars are spent. A citizens organization only has the right to litigate after having established standing through early participation in a decision making process. Public interest litigation is an action of last recourse, when the concerns of the public have been disregarded after a long process, and is enshrined in our laws as a justified exercise of our democratic rights. EPIC has a well-earned reputation for cutting edge and strategic litigation that can shape the content of public policy for decades to come. Our organizations successful actions before the courts in order to protect our communities and rare environments is an authentic expression of EPIC’s effective mission and expertise in Wildlands Civics.


Take Action: Bulldozers in the Trinity Alps Wilderness

Tuesday, August 20th, 2013
By

CoralComplex

Take Action Now. The Corral Fire was started by lightning on August 10 in the Trinity Alps Wilderness and has reached over 4,000 acres.   The fire is currently less than a mile away from the Hoopa Reservation. The Six Rivers National Forest Supervisor in conjunction with the Hoopa Tribe have been granted permission from the Regional Forest Service Office to use bulldozers and heavy equipment within the wilderness to clear ridgetops and trails to create “fuelbreaks” or “firelines” in hopes of stopping the fire before it reaches the reservation.

Ridgetop fuelbreaks are often unsuccessful at stopping fires depending on weather and topography.  According to the Inciweb website there are currently seven bulldozers working around the fire area.  Up to 5 miles may be cleared, using a variety of treatments in different areas.  For instance, some of the firelines are on old decommissioned roads that are currently on the trail system.  Other firelines are just outside of the wilderness boundary on the Six Rivers National Forest.

While protecting life and homes is always a priority, there has got to be a better way.  Dozerlines in the wilderness will scar the landscape for decades, increasing habitat fragmentation, damaging soils and seriously spoiling wilderness characteristics.  Fire ignited by lightening in our forest ecosystems is as natural as life itself and post-fire landscapes are among the most rare and biologically rich landscapes existing.

Please click here to urge Regional Forester Moore to apply Minimum Impact Suppression Tactics (MIST) or call him at 707-562-9000.  Let him know you will be watching closely at what is happening in the Trinity Alps and that you greatly value landscapes affected by fire.  Voice your support for allowing fire to play its role, especially in the wilderness which is supposed to be safeguarded and untrammeled by mankind.

corral8_18

 


EPIC Collaborates to Improve Wildfire Management

Wednesday, June 12th, 2013
By
Moonlight_Fire2007

Moonlight Fire 2007

The Environmental Protection Information Center (EPIC) monitors activities on more than 5 million acres of federally owned public land in Northwest California. We caught up with Kimberly Baker, EPIC’s Public Land Advocate, between one of her many trips to our National Forests to check on projects, as well as attend meetings to continue ongoing conversations with the Forest Service, diverse stakeholders, and conservation partners about the management of our public lands. The issue of wildfire is without question one of the “hottest topics” that Kimberly is engaged on, and we recently asked her a few questions about how EPIC is taking a proactive stance as a stakeholder with a strong local constituency that is invested in the promotion of long term ecosystem health on our region’s national forests.

Kimberly, you have been traveling lately to represent EPIC in new stakeholder processes concerning wildfire management on National Forests in Northern California. Describe the different endeavors that you are taking part in.

EPIC has been invited to be on the design team of FireScape Mendocino. It is a collaborative approach that will look at natural resource management in order to develop resilient, fire-adapted communities and ecosystems across the landscape. The Upslope Working Group on the Klamath and Six Rivers National Forests is doing the same. Both groups are being facilitated by the Fire Learning Network, an organization that has been successful in developing these grand collaborative visions all over the country.

The Shasta-Trinity National Forest will be convening an interactive meeting to discuss “Continuous Improvement in Wildfire Management.”  This will not be facilitated by the FLN, nor is this a long-term planning process — but it is a continuation of similar meetings that have been held annually over the last three years.

Who are the other stakeholders in these processes, and how do participants actually engage with each other?

There is a long list of stakeholders including Native Tribes, local FireSafe councils, US Forest Service staff, US Fish and Wildlife Service, and the local counties, which are represented by various Resource Conservation District representatives. As well, there are representatives from the timber industry and other conservation groups, on the Mendocino the Blue Ribbon Coalition, as well as various agencies and local community members.

The FLN facilitated groups have well established ground rules. We are here to find common ground, albeit not to avoid discussion of dissenting view points respectfully. Humor is often used in place of anger or disagreement.

What is at stake in these sorts of engagements? You have been involved with similar processes in the past, what makes this round of stakeholder talks different from what you have experienced previously?

The future of our forests is at stake here. We are talking essentially about how to treat and manage thousands of acres of Northwest California forestlands, all of which are ecosystems that to one degree or another have evolved naturally to need fire for maintaining resiliency and health. What makes this different is that the plans coming out of this process will entail only those actions that people can agree upon.

How much disagreement exists in this broad stakeholder group about the importance of wildfire in maintaining forest ecosystem health in Northwest California?

As far as letting fire maintain landscapes in the long run, I do not believe there is much disagreement. However, how we get there is another question. There is no doubt that creating a more fire resilient landscape is going to require a lot of time, work, planning, and money. The idea is to start where there is agreement, which is yet to be determined.

EPIC has a reputation for challenging bad projects, but you also do a lot of monitoring of the implementation of projects. Are there concerns that you have identified in project implementation that will be addressed in these stakeholder conversations?

The EPIC stance upfront is that timber sales are not the way to establish fire safe communities, or to steward for fire resilient forests. Effective treatments must retain canopy and large fire resistant trees. Thinning previous clearcuts and small diameter trees could attain potential commercial gain; EPIC believes that treating plantations is one key area to focus on.

What can folks expect to see happen this summer around wildfire, and how can we be attentive both to the needs of rural residents as well as a forest ecosystem in which fire may be less frequent, but is clearly as natural as rain?

The fact is preparing a defensible space around homes and communities is the best way to protect life and property.

Unfortunately, as far as fire goes this summer, we can expect to see the same military style of fire suppression as seen from recent years, such as bulldozing miles of ridge tops, cutting snag habitat, and high severity back burning, followed by subsequent post-fire logging proposals like this years Mill and Stafford Fire projects, which are clearly destructive and unsustainable. These are the reasons EPIC is dedicated to finding a better way.

 

 


Act Now to Stop Destructive Post-Fire “Salvage” Logging on the Mendocino National Forest

Thursday, March 14th, 2013
By
Dozerline backburn on the Southern end of Mill fire.  Credit Reuben/Feather River Hotshots

Dozerline backburn on the Southern end of Mill fire. Credit Reuben/Feather River Hotshots

Mill Fire Project

Update 3/14/13

The Mendocino National Forest has released an Environmental Analysis for post-fire logging on 985 acres in the Mill fire area, outside of the town of Stonyford.  Public comment is due by March 25thPlease Act Now to stand up for forests, wildlife and watersheds.

Although a vast majority of the forest marked as timber sale units actually burned at moderate and low severity, with many live trees remaining within these stands, the agency claims the stands are in a “deforested condition” and are not functioning “normally.”  This claim is used to justify removing most of the trees in the units, including live green trees, totaling nearly 1000 acres of ecologically unnecessary post-fire salvage logging.

The Emergency Situation Determination (ESD) that the Mendocino planners are seeking streamlines environmental review, reduces public recourse, and would allow logging to begin immediately after a Decision by the Forest Supervisor despite an appeal or pending lawsuit. Now is the time for the public to speak up and voice their opposition to this undemocratic decision making process.

It is clear that timber volume is driving this project running over ecology and the best available science.  One statement made in the ESD letter after land managers met with timber industry representatives:  “It was concluded that the sale would need to contain enough volume to cover move in move out costs of logging operations as well as high haul cost from this remote area of the forest.”

The project is within the Blue Slides Late Successional Reserve (LSR). The reserves are set aside to preserve old growth forest and species like the Northern Spotted Owl that depend on big old trees for survival. Damaged and dead trees (snags) are important structural components of late-successional forests and are key habitat for numerous species. They provide forage, cavities for nesting and protection, perch sites, and den sites. Large snags are considered to be one of the distinctive features of an old-growth forest.

Fire and tree mortality are natural elements in a forest ecosystem.  Logging of large snags does not contribute to recovery of forest habitat; in fact, the only activity more antithetical to the recovery process would be removal of surviving green trees from burned sites, which the Mendocino timber planners are proposing to do in this project. Much of the area is already naturally regenerating.  Logging with ground based equipment such as tractors and bulldozers on fragile soils will inhibit and kill natural growth.

Post-fire landscapes and snag forests are alive and vibrant. They are more biologically diverse than unburned forest, and provide for an array of plant and animal species. Post-fire landscapes are considered to be one of the most rare, endangered, and ecologically important forest habitat types in western U.S. forests, and the stand-transforming fires that create this habitat are not damaging the forest ecosystem. Rather, they are advancing ecological restoration.

Act now to protect your public lands!  Please ask Mendocino National Forest to cancel destructive post-fire logging within the Blue Slides LSR.

Update 1/8/13

The Mendocino National Forest is proposing to streamline more than 250 acres of post-fire logging.  The 30,000 acre Mill Fire burned outside the town of Stoneyford and within the Blue Slides Late Successional Reserve (LSR).  The reserves are set aside to preserve old growth forest and the species that depend on big old trees for survival.

A majority of these forest stands had a moderate severity burn with many green trees unaffected.  In fact, less than 10% of the fire area burned at high severity.  Much of the area is already naturally regenerating.

Mendocino National Forest planners are seeking to undermine and ignore meaningful environmental analysis, and declare an “emergency” that would allow logging to begin immediately after a decision by the Forest Supervisor despite an appeal or pending lawsuit.

Please ask Mendocino National Forest Supervisor and timber planners to cancel destructive post fire logging within the Blue Slides LSR.

 

North Pass Fire Project

Update 3/14/13: You made a difference!

A step in the right direction.

The North Pass post-fire logging project was recently rescinded due to serious watershed concerns.  The canceled 900-acre project area was proposed within the Wild and Scenic Middle Fork Eel River, a key watershed that is critical for salmon recovery.  This watershed is also listed as being “impaired” under the Clean Water Act.

Due to the destructive effects of logging activities on fragile post-fire soils, in combination with the documented negative effects from the fire suppression activities such as “backburns” or “burnouts,” along with the excessive firelines created by bulldozers, the proposed salvage-logging project was predicted to increase sediment and disturb soils to an unacceptable level.  In short, it would have choked streams and harmed Steelhead trout and Salmon.

Mendocino land managers also received a flood of concerns from EPIC’s last Action Alert.  Thanks to all of you who took action! Your taking action makes a difference in protecting your public lands!

While it is not clear that land managers will totally abandon the idea of logging the fire area, they have indicated that future plans may be significantly reduced to focus on roadside cutting.

Your actions make a difference—take action on the Mill Fire salvage-logging project today! 


Update  3/7/13: Thanks to your participation, this proposal has been withdrawn.

The Mendocino National Forest is proposing two post-fire logging sales.  One is the Mill Fire project detailed above and the other is the North Pass Fire “Salvage” logging timber sale.

According to the September 25, 2012 Burned Area Report for the North Pass Fire lasted for 24 days and burned 31,050 acres on the Mendocino National Forest of which 21,693 acres were low severity, 8502 acres were moderate and only 855 acres burned at high severity (<3% of the fire area).  The Forest Service’s fire supression tactics created 46 miles of fireline and 79.35 miles of National Forest roads utilized during fire suppression efforts.

The proposed project would tractor and cable log within snag forest habitat on approximately 300 acres of Northern Spotted Owl Critical Habitat within Matrix and Riparian Reserve allocations and would subsequently damage natural regeneration and establish highly flammable plantations.  The project is within the Wild and Scenic Middle Fork Eel River Tier 1 Key Watershed.  The project proposes- to construct .5 miles of new “temporary” road, 3 miles of road maintenance and log hauling.

Please  let the Mendocino NF know that you value post-fire habitat, and ask them to stop ill-conceived plans to clearcut our forests.


Help Stop More Post-Fire Salvage Logging Proposed on the Mendocino National Forest

Wednesday, January 30th, 2013
By

UPDATE 3/7/13: Thanks to your participation, this proposal has been withdrawn.  For more information visit our Returning to a Natural Cycle of Wildfire page.

Click Here to Take Action Now! kp0829_Cut3The Mendocino National Forest (NF) is proposing another post-fire “salvage” timber sale, covering 300 acres in the Wild and Scenic Middle Fork Eel River, a key watershed that is critical for salmon recovery.  Several units of the project are proposed right against the border of recently designated wilderness.

The 31,050 acre North Pass Fire burned 21,693 acres at low severity, and only 855 acres at high severity, making up less than 3% of the total fire area.  The North Pass Fire burned as fire is supposed to do; it was a totally natural event. Nevertheless, there were 46 miles of fireline constructed during suppression efforts, most often done with bulldozers, a highly impactful means of responding to a disturbance cycle that is as natural as rain in Northern California forests.

The proposed project would log snag forest stands within Northern Spotted Owl Critical Habitat, while damaging natural regeneration and recovery.  Subsequent replanting would establish highly flammable plantations. 

Your voice makes a difference!  Let the Mendocino NF know that you value post-fire habitat, and ask them to stop ill-conceived plans to clearcut our forests.

Good News on the Klamath NF!

Public Input Works.  By taking action late last year with EPIC to oppose salvage logging proposed after last summer’s Goff Fire in the Klamath NF near the Oregon border, you have saved wild forests from unnecessary and damaging post-fire logging. The Klamath National Forest has cancelled plans to heavily log the Kangaroo Roadless Area! The Forest Service changed course because-

1) Helicopter logging was not economically viable;

2) Klamath NF Fire staff said that post-fire logging would not improve firefighter or community safety; and

3) the Forest Service had heard from enough people that value the Kangaroo Roadless Area to realized there was nothing collaborative about a “salvage” proposal.

Now, land mangers will be concentrating on fuels reduction 500 feet around private properties and roadside hazard tree logging. Because a formal proposal is not yet finalized, EPIC will continue to follow the Klamath National Forest post-fire projects related to the Goff fire closely.

Your participation makes a difference! Take action today to oppose the North Pass post-fire logging proposal on the Mendocino National Forest! Your voice helps restore a natural cycle of wildfire to the landscape!

To learn more about post-fire “salvage” logging click here.


Action Alert: Protect Mendocino National Forest from Destructive Post-Fire Logging

Wednesday, December 5th, 2012
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Smoke from burnout. July 10, 2012. Credit: Steve Clark, USFS, NorCal Team II

Take Action Now!  The U.S. Forest Service is proposing to conduct damaging “salvage logging” on  the Mendocino National Forest in an area affected by the 2012 Mill Fire.  This logging is planned to take place within the Blue Slides Late Successional Reserve (LSR) and designated Spotted Owl critical habitat.  Under the Northwest Forest Plan, the LSRs are supposed to be managed to promote old growth forest characteristics and the species that depend on big old trees for survival.  Damaged and dead trees (snags) are important structural components of late-successional forests and are key habitat for numerous species, especially Spotted Owls and Pacific Fisher.  Indeed, snags and downed wood have been found by leading researchers to be critical for numerous species and the integrity of old-growth forests.  They provide forage, cavities for nesting and protection, perch sites, and den sites. Large snags are considered to be one of the distinctive features of an old-growth forest.

Fire and tree mortality are natural elements in a forest ecosystem.  Logging of large snags does not contribute to recovery of forest habitat, but instead is one of the most damaging forms of logging that can take place.  In addition to removing legacy snags and old-growth components, the U.S. Forest Service is also proposing to arrest the natural recovery process by removing numerous living trees that have survived the fire.  Much of the area is already naturally regenerating.  Logging with ground based equipment such as tractors and bulldozers on fragile soils will destroy natural re-growth and exacerbate erosion and sediment deliver to waterways.

Post-fire landscapes and snag forests are alive and vibrant. They are more biologically diverse than unburned forest and provide for an array of plant and animal species. Post-fire landscapes are considered to be one of the most rare, endangered, and ecologically important forest habitat in western U.S. forests, and the stand-transforming fires that create this habitat are not damaging the forest ecosystem.  Rather, they are advancing ecological restoration and are part of the natural cycle.

Click here to learn more about the ecological consequences of salvage logging.

The Emergency Situation Determination that the U.S. Forest Service officials are seeking will have the effect of short-circuiting responsible environmental analysis and would allow logging to begin immediately after a Decision by the Forest Supervisor despite an appeal or pending lawsuit. Science indicates that post-fire logging may result in significant impacts to soils, wildlife, late successional characteristics and hydrology, which necessitate the completion of an Environmental Impact Statement.

Please ask Mendocino National Forest Supervisor and timber planners to cancel destructive post fire logging within the Blue Slides LSR and the Mill Fire area.  Tell them to leave the area alone and allow for natural recovery to occur.

Click here to view the U.S. Forest Service announcement and project documents.


Help Stop “Salvage” Logging in the Kangaroo Roadless Area

Sunday, November 25th, 2012
By

UPDATE: January 30, 2013

Public Input Works. By taking action late last year with EPIC to oppose salvage logging proposed after last summer’s Goff Fire in the Klamath NF near the Oregon border, you have saved wild forests from unnecessary and damaging post-fire logging. The Klamath National Forest has cancelled plans to heavily log the Kangaroo Roadless Area! The Forest Service changed course because-

Goff Fire

 

1) Helicopter logging was not economically viable;

 

2) Klamath NF Fire staff said that post-fire logging would not improve firefighter or community safety; and

3) the Forest Service had heard from enough people that value the Kangaroo Roadless Area to realize there was nothing collaborative about a “salvage” proposal.

Now, land/ mangers will be concentrating on fuels reduction 500 feet around private properties and roadside hazard tree logging. Because a formal proposal is not yet finalized, EPIC will continue to follow the Klamath National Forest post-fire projects related to the Goff fire closely.

November 25, 2012

Click here to take Action! The Kangaroo Roadless Area outside the Red Buttes Wilderness is in danger.  This backcountry forest is one of the largest intact wild lands in California.  It provides critical connectivity for wildlife and is a virtual hotspot for biodiversity and endemic species.  It hosts waterfalls, high mountain meadows, lush old-growth forests, endless wildflowers and amazing vistas from the Pacific Crest Trail.

This summer the 22,000 acre Goff Fire burned exquisitely with a vast majority of the flames burning low to the ground cleaning the forest floor in its path. Now that the smoke has cleared, the Klamath National Forest is considering helicopter logging the biggest old-growth snags (burned trees) in the name of “forest health”.

Please Act Now and tell the Klamath National Forest to forgo logging in backcountry roadless areas and that you value rare and biologically rich post-fire habitats.

 


Clearcutting Triggers Hotter Fires and Reduces Water Supplies

Tuesday, August 14th, 2012
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State Regulators Ignore the Best Available Science

The dry season is upon us and the likelihood of forest fires will grow while our creeks and rivers drop ever lower.  The potential for forest fires coupled with the paucity of water presents serious concerns to natural and human communities alike.  Recent events across the country and within California have us wondering: What are the impacts of the industrial forestry model of clearcutting and dense, mono-culture tree plantations on fire behavior and water availability?

The best available science shows that young, dense tree plantations are prone to higher severity fire than comparable natural forests with older trees and greater ecological complexity.  A recent study out of the U.S. Forest Service’s Pacific Southwest Research Station (Miller et al 2012) clearly shows that tree plantations are prone to high severity, stand replacing fires.  These findings are consistent with other research implicating tree plantations as tinder boxes.  This contrasts sharply with low and moderate severity fire behavior generally displayed within natural forests on public lands with older trees and complex structure.

Similarly, intensive industrial forestry is simply not compatible with the conservation of water resources.  Many municipalities that source their water supply from forested watersheds have protected them from damaging logging practices.  Portland, Oregon and New York City are two examples where a century of foresight to protect forested watersheds yields a reliable supply of clean water.  In California, numerous watersheds throughout the Sierra Nevada, Cascades, Trinity Alps and Klamath Mountains provide water to millions of people, agriculture and diverse ecosystems.  While some of the watersheds are protected in national forests, millions of acres are in private hands and much of that is extensively clearcut.  Natural forests with older trees provide reliable, clean water supplies because they shade the ground and contain complex aquatic habitat and pools.  In contrast, industrial forestry landscapes are often devoid of any vegetation or contain simplified plantations that do not provide the same benefits for water supplies.

Additionally, recent research has uncovered a critical variable that is often overlooked.  Stubblefield et al (2012) compared overall water usage by young, dense Douglas-fir tree plantations versus older, natural forests in the Mattole River watershed.  The study concludes that tree plantations use more water than older forests, adding an additional indictment of the industrial forestry model.

Meanwhile, California’s regulations for private industrial forestlands continually fail to account for these threats.  California’s Forest Practice Rules allow intensive clearcutting across entire watersheds.  The specter of past, ongoing, and foreseeable cumulative impacts resulting from a century and a half of logging continues to threaten endangered fish and wildlife species.  The best available science implicates the lack of adequate state-level regulations to prevent significant adverse cumulative impacts to our forests and water resources.

In the midst of this ongoing crisis, California’s regulators are completely disconnected from realities on the ground.  Even worse, current proposals do nothing to address the ongoing threats posed by industrial forestry.  Governor Brown has proposed private timber-related items that are nothing more than industry giveaways.  The Governor wants to institute a cap on liability stemming from damages caused by forest fires in response to the federal prosecution of Sierra Pacific Industries for the Moonlight fire. Such meddling in long established law would undermine the ability of the public to recover costs and restore landscapes damaged by the negligence of private logging operations.  Most baffling, the Governor also proposes a new consumer tax on lumber that would be used to fund regulatory agencies’ review of private timber harvest plans.  The proposed tax would give the timber industry the ability to freely pass the cost of public trust analysis onto the consumer.  This approach provides no incentive to engage in sustainable, selection forestry, but instead allows business as usual for those large industrial landowners that clearcut forests across California.  Instead, a progressive fee-based program should be created that promotes good practices.  Damaging logging plans that include clearcutting require more intensive review by state agencies, and therefore should be more expensive to permit.  Genuine stewardship of California’s forests and water resources by landowners should be rewarded with reduced fees for selection forestry.  Holding the timber industry accountable for the damage they have wrought on our natural landscapes and human communities is imperative for charting a new path forward to restore California’s forests.


Caribou Fire Project

Tuesday, May 24th, 2011
By

Caribou Fire
The Caribou Fire area on the Wild and Scenic South Fork Salmon River on the Klamath National Forest was logged the past few summers.  EPIC was able to get some of the best snag habitat saved for wildlife.  The Forest Service’s environmental analysis (EA) was replete with “Project Design Features” and “Best Management Practices” that were put in place to protect fisheries, hydrology, soils and wildlife.  However, after on-the-ground monitoring we discovered multiple inconsistencies between the EA and what is actually happening on the ground.

Countless mitigations were ignored.  The Forest Service severely failed to meet their promises, surveys for threatened and sensitive species were not completed, most all of the largest snags and large logs that were to remain standing or within the logged areas were removed, all of the hardwood snags were removed and sold as firewood, despite the requirement for it to remain on the landscape, riparian areas were logged and much of the work took place during rainy weather.

We were extremely disappointed to discover the broad swath of disparity separating the Caribou Project description from the reality of what actually has occurred in this Key watershed that, is critical for Salmon recovery.  Further, this project cost over $1.6 million dollars to plan, the contractor paid a less than $50,000 and did not make a profit, leaving taxpayers holding the bill for the destruction of their national forest.

To add insult to injury the Klamath National Forest is not being held accountable.  There is no recourse that can come to them aside from your public outcry.

Caribou Pre-Salvage

Caribou Pre-Salvage

Snags in Riparian Reserve.
Caribou Pre-Salvage

Caribou Pre-Salvage

Post-fire recovery in the Caribou.
Caribou Pre-Salvage

Caribou Pre-Salvage

Large snag marked for cut in the Caribou Salvage sale.
Caribou Pre-Salvage

Caribou Pre-Salvage

Two large snags marked to be cut alongside a recovering creek.
Caribou Pre-Salvage

Caribou Pre-Salvage

Native plants and insects return to burnt landscapes following fire.
Caribou Pre-Salvage

Caribou Pre-Salvage

Native birds such as this woodpecker take advantage of the post-fire landscape.
Caribou Pre-Salvage

Caribou Pre-Salvage

Seasonal ponds form in depressions caused by bears wallowing (rolling around) in the soil.
Caribou Pre-Salvage

Caribou Pre-Salvage

Caribou post-fire, pre-salvage logging implementation: Unit 8 and large snags
Caribou Pre-Salvage

Caribou Pre-Salvage

Caribou post-fire, pre-salvage logging implementation: Unit 8 and large snags
Caribou Pre-Salvage

Caribou Pre-Salvage

These four foot snags were saved by EPIC.
Caribou Post-Salvage

Caribou Post-Salvage

Post Salvage Logging: the hillsides along Caribou have been ravaged.
Caribou Post-Salvage

Caribou Post-Salvage

Unit 10 of the Caribou Salvage Sale. The hillside is left barren and desolate.
Caribou Post-Salvage

Caribou Post-Salvage

Post-Salavage Logging of Caribou's Unit 8.
Caribou Post-Salvage

Caribou Post-Salvage

Logging equipment leaking oil and fuel into the ground.
Caribou Post-Salvage

Caribou Post-Salvage

The non-merchantable timber is culled, rejected, and left to waste on the log landing.
Caribou Post-Salvage

Caribou Post-Salvage

Unit 10: the hillside is left barren and desolate.