Archive for April, 2015

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.


Arcata Film Screening Pickaxe: the Cascadian Free State Story

Wednesday, April 29th, 2015
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elliott-group-photoPickaxe: the Cascadian Free State Story will be screened at the Arcata Theatre Lounge Monday, May 4 from 7-9pm.

Pickaxe is a documentary that follows a group of activists in their direct action efforts to stop post-fire logging of an old growth forest in Warner Creek, Willamette National Forest, blockading the logging road and repelling the State Police. After the film, activist and director, Tim Ream will be Skyped in to answer questions and discuss current efforts to protect old-growth forests in the Klamath National Forest from the Westside Timber Sale – one of the largest timber sales ever proposed in U.S. History.

As a bonus, a new short film about the Westside Post-fire Logging Proposal produced by local film-maker Abianne Prince will also screened. See the trailer below.

$5 suggested donation at the door, no one turned away for lack of funds. 

Pickaxe Description
The film shows confrontations with disgruntled loggers, mass arrests and a 75 day hunger strike. Back at Warner Creek activists build teepees and remain a living blockade on the logging road through the winter and ten feet of snow. Political pressure begins to shift and the White House promises a deal but not before Federal Agents come to bust the camp and destroy the fort. The story resolves with incredible footage of a mass jail break-in and unconditional victory for the forest. This inspiring documentary is two years in the making, and crafted from footage shot by more than two dozen people involved in the struggle to save Warner Creek. Principal photography and direction are by guerilla videographer Tim Lewis, award winner at WorldFest in 1998. Codirector/producer Tim Ream was involved in the action on and off the screen. Running Time: 95 minutes.

Click here to join and share the event on Facebook.

Pickaxe poster


Northwest Forest Plan and Connectivity

Wednesday, April 29th, 2015
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aerial green diamond clearcutYou’ve heard the news about species loss, right? About how we humans are causing a global extinction event, something akin to the comet impact which killed the dinosaurs; that global climate change is only going to exacerbate our impacts to biodiversity; and over half of California’s wildlife is at risk and in need of additional protection? Yeah, that. EPIC is doing something about that.

Habitat connectivity, the arrangement of protected habitats to aid in the likelihood of individual’s movement across the landscape, has been identified as one of the top strategies to preserve biodiversity. That’s why EPIC is fighting to connect areas of high habitat value—wilderness areas, roadless areas, and other pockets of mature forests—on both private and public lands. Our campaign, titled Connecting Wild Places, seeks to achieve permanent protections for habitat corridors. The upcoming revisions to the Northwest Forest Plan offer one of our best opportunities to address habitat connectivity at a landscape level.

The Northwest Forest Plan consists of a series of reserves, areas of habitat generally off-limits to logging, and “the matrix,” forests which are open to commercial logging. There are two major kinds of reserves: Late-Successional Reserves and Riparian Reserves. Late-Successional Reserves were designed with owls in mind. These protected areas were spread across the landscape, like islands of high-value habitat. The theory was, by spreading these pockets out, catastrophic events, such as a massive fire, would have less impact. And while owls prefer not to cross forest breaks, they can and will under the circumstances, so if one reserve was impacted, the owls could fly to another reserve. Riparian Reserves—protected forests alongside streams, rivers, lakes, and marshes—were designed in part to function as wildlife corridors, connecting larger blocks of habitat.

While the current system of reserves has helped to slow species decline, it isn’t perfect. For species like the Pacific fisher, the distances between Late-Successional Reserves are often too great and the Riparian Reserves too small to adequately function. In the anticipated revisions to the Northwest Forest Plan, EPIC will push to re-establish connectivity across the landscape. Specifically, EPIC seeks to establish and protect habitat linkages which utilize elevation gradients and north-facing slopes to act as “climate refugia”—areas that shelters people, plants and wildlife from the worst impacts of global warming. EPIC will also seek to expand the reserve system by protecting all native, unmanaged forests from logging, increasing the functionality of the existing reserve network. Re-establishing connectivity across our public lands won’t be easy, but we are up for the task.


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.


Earth Day Cleanup and Hoedown – April 25

Monday, April 13th, 2015
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River CleanupCome celebrate your love for the planet by giving back! River cleanups are fun and satisfying, and we need your help to make these special places more beautiful. The third annual Earth Day cleanup and Hoedown will take place on Saturday, April 25. EPIC Volunteers are needed to help clean up the lower Mad River! The cleanup will take place in the morning, and the Hoedown will be in the afternoon from 2-6pm.  Admission to the Hoedown will be free to cleanup volunteers or $5-10 sliding scale.

CLEAN-UP

EPIC will be working with Eco-Flo Rafting Company to organize a rafting cleanup on the lower Mad River. If you are interested in participating in the EPIC clean up, please meet at the Warren Creek Disc Golf Course (between Blue Lake & Arcata) at 9:00 am. Click here to help us spread the word by joining the event and inviting your friends on the Facebook event page.

Eco-Flo Rafting Company will be providing two large rafts to take people down the Mad River to collect trash. We will be meeting at the Pump Station/ disc golf course off Warren Creek Road between Blue Lake and Arcata. Space is limited, so please RSVP with amber@wildcalifornia.org if you would like to be a part of the rafting crew. Up to 10 volunteers can fit into the boats, and others can walk the river banks, in the area in search of trash.  Rafts, paddles, life vests and trash bags will be provided for rafters. Please bring your own snacks, water, gloves, water friendly gear, a warm jacket and layers in case it gets hot. 

Directions: 101 north of Arcata to 299 exit. 1st exit, take right at stop sign (Guintoli Ln.), then left at next stop sign (West End Rd.). Go 2 miles to a left at Warren Creek Rd. Drive slowly, pass under train tressel, then up hill to 1st driveway on the left. Please meet at the parking lot at 8:45am so we can be floating by 9.

HOEDOWN

After the clean-up, volunteers will celebrate by boogying down at the Earth Day Hoedown, which will be in the afternoon from 2-6pm. Admission to the Hoedown will be FREE to cleanup volunteers!

The Hoedown will take place at the Humboldt Coastal Nature Center at 220 Stamps Lane in Manila featuring music by Lyndsey Battle and the Striped Pig String Band with barn dance calling by Nigella Mahal. Beer, wine, non-alcoholic beverages and food from the Tako Faktory will be available. In addition to the music and barn dance, a silent auction, live painting by Matt Beard, and a family games and kids corner will keep everybody entertained.

Earthday Cleanup & Hoedown

 


Fish and Wildlife Service Finds Northern Spotted Owl May Be Endangered

Wednesday, April 8th, 2015
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Owl Self-Defense wings shadowToday, the United States Fish and Wildlife Service issued a positive initial 90-day finding on an EPIC petition to reclassify the iconic northern spotted owl from a “threatened” to an “endangered” species under the Endangered Species Act. The positive 90-day finding on EPIC’s petition to reclassify the northern spotted owl demonstrates that sufficient evidence exists that existing conservation measures have not been enough to protect and recover the owl, and that additional, more stringent and immediate measures are necessary to achieve this goal.

EPIC submitted a reclassification petition for the northern spotted owl to the U.S. Fish and Wildlife Service on August 15, 2012. Today’s decision clearly demonstrates that the owl is in trouble across the species’ range, and that more stringent protections and conservation measures are necessary.

The northern spotted owl is an iconic keystone species which is dependent on large blocks of intact old-growth forests to provide for habitat. The owl was a focal point of the timber wars of the 1980s and early 1990s and was listed as a “threatened” species under the ESA in 1990. The listing of the northern spotted owl under the ESA lead to sweeping changes in land management practices on public lands with the advent of the Northwest Forest Plan during the Clinton era. The Northwest Forest Plan created a large system of reserves for the northern spotted owl and other old-growth associated species known as “Late Successional Reserves.” Although logging of suitable spotted owl habitat has been substantially curtailed on public lands, it has not been completely eliminated. What’s more, conservation of the northern spotted owl on private lands has largely been left up to voluntary measures, such as Habitat Conservation Plans and Safe-Harbor Agreements. Logging of suitable owl habitat continues at a frightening rate on private lands in California and across the species’ range, and even the U.S. Fish and Wildlife Service itself has decried the inadequacy of private lands regulatory mechanisms in California to protect and conserve the species.

The northern spotted owl is also faced with several new threats that were not contemplated or foreseeable at the time of the original listing. In particular, the severe threat now being posed by the invasive barred owl (Strix varina) has complicated and confounded northern spotted owl conservation and recovery efforts. While the true impacts of barred owls on northern spotted owls is still being studied and is not fully-understood, it has become clear that aggressive measures may be necessary to curtail the negative effects of barred owls on spotted owl populations.

Indeed, the latest study on northern spotted owl populations shows significant declines in several northern spotted owl vital statistics across most demographic areas studied, including the Green Diamond study area here in Humboldt County. Another population study, due out in June, is predicted to have even more dire results, showing alarming declines across the population.

“The positive initial 90-day finding on our petition to reclassify the northern spotted owl from a threatened to an endangered species demonstrates that the U.S. Fish and Wildlife Service can no longer deny the extreme threats now facing the species,” said Rob DiPerna, California Forest and Wildlife Advocate at EPIC. “It is now clear that more stringent, more aggressive, and more immediate actions are necessary to ensure that the northern spotted owl survives, recovers, and thrives in the wild.”

Other conservation groups have supported EPIC’s efforts to see the spotted owl listed as endangered, including Conservation Congress. “While it is important the Fish and Wildlife Service is acknowledging the dire population declines in northern spotted owls warrants a review for endangered status, it remains incomprehensible that the agency continues to sign off on logging of owl habitat under the unscientific ruse of saving habitat from fire while also authorizing ‘take’ of reproductively successful pairs,” said Denise Boggs, Executive Director of Conservation Congress. “The Service must insist on protecting all remaining suitable owl habitat and no ‘take’ should be authorized for a species with declining populations throughout its range,” she said.

The positive initial 90-day finding by the Service will now set into motion a 12-month period in which it will conduct a full status review for the spotted owl in order to determine if reclassification is warranted. The Service expects to complete this 12-month review in 2017. EPIC will continue to engage at each stage of the listing process and will continue to advocate for the reclassification of the northern spotted owl, and for implementation of more stringent, more aggressive, and more immediate actions in order to save this iconic and imperiled species from extinction.

Click here to view EPIC’s official press release for the NSO Uplisting.


A Call to Action: Help Stop Westside Post-Fire Logging Proposal- Attend Eureka Meeting April 7

Monday, April 6th, 2015
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Logging deck on the Salmon Salvage Oct. 2014

Logging deck on the Salmon Salvage Oct. 2014

Take Action: The Klamath National Forest’s proposed Westside project is one of the largest timber sales in U.S.F.S. history. The massive logging project is proposed within one of the most biologically intact watersheds in the west. Environmental advocates, forest defenders and regional stakeholders will be rallying at the Klamath National Forest’s open house meeting for the Westside post-fire logging project on Tuesday, April 7th 5:30 p.m. – 8:00 p.m. The meeting will be held at the Six Rivers National Forest Headquarters, 1330 Bayshore Way, Eureka, CA 95501. A few hours before the meeting in Eureka, EPIC will host a pre-meeting poster making session 3:30-5pm at the EPIC office located at 145 G Street, Suite A in Arcata, where snacks, poster-making supplies and talking points will be provided.

Westside is a massive project with over 30,000 acres of post fire habitat 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 logging proposal includes:

* 22.6 miles of new roads w/ 14 new stream crossings, and will open decommissioned roads
* critical habitat for Northern Spotted Owl & Coho Salmon
* negatively impacts 6 different Inventoried Roadless Areas
* over 6,000 acres of clearcuts in sensitive post-fire habitat

Please come to the open house and speak up to protect these irreplaceable wild places and the wildlife that depend on them.


Fish & Wildlife Service Doesn’t Care About the Humboldt Marten

Monday, April 6th, 2015
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Humboldt MartenThe Fish and Wildlife Service issued their 12-month finding on the Humboldt marten listing petition submitted by the Environmental Protection Information Center and the Center for Biological Diversity. While the Service acknowledged that the populations of coastal martens are extremely small and isolated, the Service did not find the marten to be threatened or endangered. This conclusion is dubious and runs counter to the best available science.

The Humboldt Marten (martes caurina humboldtensis) is a stealthy, cat-sized forest carnivore in the weasel family (related to minks and otters). The Humboldt marten is so rare that it was thought extinct until rediscovered in 1996.

These extremely secretive animals are known for their slinky walking motion and ability to prey on porcupines by biting them on the face. Typically about two feet long, with large, triangular ears and a long tail, they eat small mammals, berries and birds, and are preyed on by larger mammals and raptors.

Due to extensive clearcut logging and short rotation forestry on low-lying coastal forests on private lands which have replaced the diverse native forests of Northern California and Southern Oregon with oversimplified tree plantations, the marten has been eliminated from 95 percent of its historic range.

In order to save this unique carnivore from oblivion, EPIC petitioned the Fish and Wildlife Service to list the Humboldt marten under the Endangered Species Act. Today’s decision is a blow to marten conservation in Northern California.

“I am shocked and disappointed,” said Tom Wheeler, Program and Legal Coordinator at EPIC. “The Fish and Wildlife Service admits that the California marten population only totals around 40 individuals. The Service has no idea how many coastal martens are left in Oregon, but all experts agree that the population there isn’t thriving. Our martens are holding on by a thread but the Service has its head in the sand.”

Rob DiPerna, California Forest and Wildlife Advocate at EPIC concurred, “The Service’s decision was not based on the best available science. The decision discounts the numerous, serious threats to the marten while trumpeting voluntary conservation measures as a fix to the marten’s problems. Under the Service’s rationale, the marten won’t recover and may go extinct in the near future.”

Despite the setback, EPIC will continue to work on necessary and immediate protections for the Humboldt marten. While the Fish and Wildlife may not care about the marten, EPIC does.


EPIC Invites You to Hike the Headwaters Forest Reserve April 18

Monday, April 6th, 2015
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DCIM100MEDIAEPIC invites you to join us for an educational hike in the Headwaters Forest Reserve on Saturday April 18, 2015. This guided educational hike will be led by Rob DiPerna, EPIC’s California Forest and Wildlife Advocate. We will discuss the history of the struggle to protect Headwaters Forest, the mechanisms that created the Headwaters Forest Reserve, and the contemporary challenges to land management in the Elk River watershed. The hike will originate from the Headwaters Forest Reserve South Fork Elk River trailhead, at the end of Elk River road, just south of Eureka, CA at 10 a.m. on Saturday April 18th.  This hike will cover six miles, and will take approximately 2-3 hours to complete. The hike along the South Fork Elk River trail for these six miles will be easy to moderate difficulty. Please come prepared with water, food, and appropriate hiking attire. For more information, please contact EPIC at: 707-822-7711. Hope to see you there!


The Endangered Species Acts—Tools of the Trade for Protecting Species Diversity and Forest Health

Monday, April 6th, 2015
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Pacific-Fisher_Bethany-Weeks-300x200A brief primer on the federal Endangered Species Act and the California Endangered Species Act

In the time of the Anthropocene, human activities have triggered what has become known as the “sixth great extinction period.” As far back as the 1970s, citizens and lawmakers alike saw this massive crisis unfolding and began to take steps towards reversing the downward spiral of species in California and across the United States.

In California, 1970 was a landmark year for historic environmental legislation, with the enactment of the California Environmental Quality Act (CEQA), and the original version of the California Endangered Species Act (CESA). Yes, believe it or not, CESA actually came before the current version of the Endangered Species Act. The modern version of CESA came into being in 1984, and was substantially amended into its current form in 1997.

In 1973, Congress enacted the modern version of the Endangered Species Act (ESA). In enacting the ESA, Congress found that “various species of fish, wildlife, and plants in the United States have been rendered extinct as a consequence of economic growth and development untampered by adequate concern and conservation.” The law was clear in its ambition; as the United States Supreme Court found, the “plain intent” of Congress in enacting the ESA “was to halt and reverse the trend toward species extinction, whatever the cost.” Similarly, in enacting CESA, the California state legislature found that untampered economic growth and development had driven certain species to extinction, and threatened to push other species toward extinction. As such, in enacting CESA, the California legislature declared that it is the policy of the state to “conserve, protect, restore, and enhance” threatened and endangered species in the state.

Both the ESA and CESA are founded on the basic underpinning of preventing “take” of threatened or endangered species listed pursuant to the Acts. “Take,” however, is defined differently in the ESA and CESA. The fundamental difference in the “take” definitions is that the ESA includes the terms “harm” and “harass” as prohibited actions, whereas CESA does not. The prohibitions of both acts apply to any “person” who may engage in a prohibited activity.

Both the ESA and CESA contain fundamental mandates for agencies responsible for implementation of the Acts to “conserve” species listed as threatened or endangered. In both Acts, the term “conserve” essentially means that agencies and governments must utilize any means necessary to protect and recover threatened or endangered species to the point where listing is no longer necessary.

EPIC’s efforts to defend biodiversity

Over the years, EPIC has successfully utilized the tools of the ESA to protect threatened and endangered species from damaging human activities, primarily logging of suitable habitat for old-growth dependent species. In EPIC’s first federal Endangered Species Act case, Marbled Murrelet v. Pacific Lumber Co. (1993), a federal court determined that Pacific Lumber’s plans to log 237 acres of contiguous old-growth forest in Owl Creek under would violate the ESA by harassing and harming the threatened marbled murrelet. This landmark decision was one of the first successful ESA cases brought against the timber industry. It halted Pacific Lumber’s march to log the old-growth in Owl Creek, and was a major impetus for the creation of the Headwaters Forest Agreement.

Today, EPIC continues to utilize the tools of both the ESA and CESA to protect and conserve species and their habitats. EPIC is currently a part of several listing petitions, both under the ESA and under CESA, to protect the Pacific fisher, the northern spotted owl, and the Humboldt marten. EPIC employs the tools of the ESA and CESA not only to prevent species’ extinctions, but also in order to achieve more long-lasting landscape-level changes in land management practices. These landscape level changes will help provide climate refugia and resilience, carbon sequestration, essential wildlife habitats and corridors between such habitats, and will serve to improve the overall health of our forests and other wild landscapes. By petitioning to list specific target species, EPIC seeks to not only conserve not only those individual species, but also other species that depend upon similar habitats, and also to protect, enhance, and restore our forested and wild landscapes.

Pacific fisher: In 2000, EPIC joined a number of conservation groups from across the Pacific Northwest to petition the U.S. Fish and Wildlife Service to list the Pacific fisher as an “endangered” species under the ESA. After over a decade of delays and subsequent litigation, the Service is now proposing to list the fisher as a “threatened” species. A final listing decision is anticipated for this fall.

Northern spotted owl: EPIC filed a listing petition with the California Fish and Game Commission in 2012 asking it to list the northern spotted owl as either a “threatened” or “endangered” species. In August 2013, the Fish and Game Commission determined that the petition provided sufficient information to lead it to the conclusion that the petitioned-action “may be warranted” and directed the California Department of Fish and Wildlife to promptly commence the conduct of a status review for the spotted owl in California. At this time, EPIC anticipates that the Department of Fish and Wildlife will produce its status report and submit it to the Fish and Game Commission in late June, 2015.

EPIC has also fought to strengthen the protections afforded to the owl under the federal ESA. In 2012, EPIC submitted a “reclassification” petition to the U.S. Fish and Wildlife Service, asking that it “uplist” the iconic northern spotted owl from a “threatened” to an “endangered” species. By uplisting the owl, EPIC aims to achieve greater protections through mitigation measures for federal, state, and private projects which may impact the species. Once again, a great deal of delay has ensued in the Service’s processing of EPIC’s petition. It is anticipated that the U.S. Fish and Wildlife Service will publish its initial 90-day finding on this petition in early April, 2015.

Humboldt marten: EPIC and the Center for Biological Diversity jointly submitted a petition to the U.S. Fish and Wildlife Service to list the elusive and highly-imperiled Humboldt marten as an “endangered” species in 2010. Again, lengthy delays ensued, and subsequent litigation has forced the Service to adhere to a stringent timeline for processing the marten listing petition. Unfortunately for the imperiled martin, on April 6th, the U.S. Fish and Wildlife Service announced a negative finding on the marten listing petition, meaning that the Service will not list the Humboldt marten as endangered. EPIC is now exploring additional options to get the marten the protection it needs.

Unfortunately, ESA and CESA are only effective when the agencies do their jobs, and decision-makers base their findings in sound science. All too often, decision-making bodies are made up of people who have political ties with the industries they are tasked with regulating, which ends up working out like the story of the fox guarding the hen house. EPIC will continue to advocate for the protection of wildlife and wild lands and will remain engaged with agencies and legislators to ensure that these species are given a fair chance at gaining protections that they depend on for their survival.