Within the Eel River Late Successional Reserve (LSR) on the Mad River Ranger District of Six Rivers National Forest, the Rattail Vegetation Management (“logging and road building”) Project proposes to:
Commercially cut 630 acres of forest;
Construct 3.4 miles of new “temporary” roads and 21 new landings and;
Use 1.4 miles of non-system existing roads and 30 landings.
Forest treatments are proposed on 1,500 acres (or 2.3 square miles). To put that in perspective, the U.S. Forest Service intends to construct and utilize 5 miles of roads in a 2.3-square-mile area with over 50 landings!
Cutting in Late Successional Reserves (LSRs) may only legally occur if it is crucial to maintain or improve habitat for species dependent on closed canopy mature forests. In this case, the agency is proposing to cut 6 million board feet from 630 acres of forest, remove half of the trees, and reduce forest canopy down to as low as 40% in an already heavily fragmented watershed. That equals roughly loading 1,200 18-wheeler logging trucks (with 5,000 board feet per truck).
In Critical Habitat for northern spotted owls, the Rattail project would impact one of the few long-term active nest sites on the Mad River Ranger District. There are two nest cores in the project area with overlapping home ranges. The agency is planning to log 105 acres and construct 0.6 miles of roads, some within the nest cores, in already suitable nesting and roosting habitat, yet claims no habitat would be removed or downgraded. It admits that roads and features that bisect habitat have the greatest impact on fragmentation and loss of habitat connectivity, but deemphasizes this fact — claiming canopy loss is minimal, the impact is limited to small areas, and roads would resemble small openings.
For decades, studies in a variety of terrestrial and aquatic ecosystems have demonstrated that many of the most pervasive threats to biological diversity — habitat destruction and fragmentation, edge effects, impacts to hydrology and aquatic habitats, exotic species invasions, pollution, and poaching — are aggravated by roads and landings. This amount of canopy removal with its concentrated impacts appears to be an aggressive timber grab cloaked as “fire resiliency” and community protection.
Please urge the Mad River Ranger District to consider a less harmful alternative by submitting comments to the U.S. Forest Service by September 11th on the project webpage at: https://cara.fs2c.usda.gov/Public//CommentInput?Project=65240.
Feel free to use the talking points below, and please personalize your comments. If you live, work or recreate in the project area, please highlight that in your comments, and how the project would impact your use of the land and resources.
SUBJECT: Rattail Project
TALKING POINTS (please personalize!):
I urge you to consider a reasonable alternative that would reduce road and landing construction in the Eel River LSR, primarily, the longest proposed “temporary” road on the southeast corner. This could easily be done by decreasing commercial logging acres or incorporating helicopter logging.
Change nest core units 11, 17, 21, 22, 68 and 69 to <10" DBH Fuel Treatment.
Increase canopy cover to at least 60% in nesting roosting habitat.
Drop road and landing construction in nest cores.
Road and landing construction, even “temporary”, causes significant long-lasting harm to soil, wildlife and forest ecology and productivity. Please abide by the recommendations in the Eel River Late Successional Reserve and Van Duzen Watershed Assessment and reduce road mileage in this heavily fragmented watershed.
Logging and road building in critical habitat would allow further invasion of barred owls and is contrary to the intent of the Endangered Species Act, Six Rivers Land Management Plan and NSO Recovery Plan.
There should be absolutely no cutting of old-growth conifer, hardwood trees or mature trees with old-growth characteristics, the intensely concentrated road and landing construction would inevitably cut these important fire resilient trees.
A reasonable alternative would increase canopy cover to at least 60%, which would keep flammable vegetation from quickly growing in, maintain cooler climates, diminish the need for future maintenance and better meet wildlife recovery needs.
Please consider a reasonable alternative by diminishing the project footprint to maintain more canopy, and change the 105 acres of commercial logging, road building and landing construction in NSO home ranges, nesting and roosting habitat, critical habitat and in the Eel River LSR to fuels treatments. This would still meet the purpose and need, creating a more resilient landscape while protecting highly threatened wildlife.
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