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New Action Alert: The Westside Story

Wednesday, April 15th, 2015
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from_BR_Lookout_1314

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.


Arcata Film Screening Pickaxe: the Cascadian Free State Story

Wednesday, April 15th, 2015
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loggingpickaxeEPIC screens Pickaxe: the Cascadian Free State Story 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.


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.


An EPIC Thank You to All Who Helped at the Moonalice Benefit

Tuesday, March 31st, 2015
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Moonalice HandbillOn behalf of the Environmental Protection Information Center, event coordinators Amber Shelton, Mitra Abidi and Natalynne DeLapp would like to extend a heartfelt thank you to everyone who turned out on Friday, March 27th to help make the Moonalice fundraiser a successful event! Hundreds of people gathered to celebrate activists that have put their all into environmental advocacy and restoration work to make our community a better place for the forests, rivers and wildlife that we share this beautiful land with. The event began many years ago as the Pisces Party to support the work of Richard Gienger and his forest protection and watershed restoration efforts that have been at the core of EPIC’s work for decades. This year, in addition to honoring Richard, EPIC also recognized the Eel River Cleanup Project (ERCP), which Mike Miller breathed new life into a few years ago, and with the social networking efforts of Amy Machado, Chris Anderson and Brian St. Clair, the cleanup became a team effort to get trash out of the river and help keep it clean. The proceeds from the event benefited EPIC’s forest advocacy work in general that is done by a number of Epicureans. It is people like this who inspire us to continue the work we do, and who make us grateful to have such a wonderful community that has made 38 years of environmental advocacy work possible.

A special thank you goes out to the artists and local businesses that made contributions to the event. A huge thank you goes out to Moonalice for rocking the house with their psychedelic music and light show and for gifting attendees with beautiful artistic posters, to Dian Patterson for her amazing songs and beautiful voice, to Sue’s Organics for catering a delicious meal and Bergin Sipila Wines for donating quality wine. Thank you to Eureka Natural Foods, Wildberries Marketplace, Signature Coffee, Mad River Brewery, Kathleen Bryson, Redway Liquor and Rays Food Place in Garberville for contributing raffle items, food for the event and for selling tickets.

So many volunteers put their all into promoting the event, creating a welcoming atmosphere and producing a fabulous meal and a stunning show. A huge thank you goes out to Sue Maloney and her kitchen crew Barbara Kennedy, Leo Power, Lois Cordova, Michael McKaskle, Barley, Marcy Olson, Dan Reiss, Chip Tittmann and Wes Demarco for whipping up a delicious organic feast. Thanks to Bobby Shearer for booking Moonalice, Dian Griffith for welcoming people at the front door, Tom Wheeler for doing the dishes, to Lucy Allen for serving dessert and Gisele Albertine and Rob Diperna for helping setup and staffing the Dutch raffle table. Thank you to Bob Special, Caelidh Liddell and the Funk House crew for helping with cleanup. Thanks to Elizabeth Morgan for rocking it all day and night from setup to kitchen to cleanup. Thank you to Rob Fishman, Nat Pennington, Josh Brown, Erin Leonard and Megan Smith for serving up drinks to keep us going all night long.

Thank you to Tanya Lynne for helping with dishes, Cecilia Lanman for bringing scrumptious desserts, and to Rob Seifert, JIM FULTON, Eric, Gage & Johnny for helping with the sound, light and stage effects. A special thank you goes out to KMUD, Redwood Times, the Independent, Lost Coast Communications, KZYX, Jama Chaplin, BR, Lauren Oliver and Karin the publicist for promoting the event.

And many thanks to anyone who contributed but may not have been included in this publication, we appreciate all of your contributions and look forward to the next time we are all brought together for a common cause.  When it came time to recognize those who were important to the EPIC organization, it became apparent that just about everyone who filled the room was deeply involved with EPIC at some capacity.  This is the kind of community that makes a difference.  Thanks to each and every one of you, your participation fuels our forest protection efforts.

Moonalice poster gift to concert attendees

 

 

 


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

Wednesday, March 25th, 2015
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Westside photo 2

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

 

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

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

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

westside photo

North Fork salmon River Salmon Salvage Timber Sale 2013

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

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

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

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

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


Action Alert: Speak Up for Rare Mendocino County Pygmy Forest

Monday, March 23rd, 2015
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Mendocino Cypress Pygmy Forest Photo Credit:  hidesertdi1 (Flikr)

Mendocino Cypress Pygmy Forest Photo Credit: hidesertdi1
(Flikr)

Click here to take action. The supposed inevitable march of progress of modern society over the last 150 years in Northwest California has left a landscape that has largely been logged, converted, scarred, or otherwise fragmented. This dynamic is most acutely understood in the context of the loss of nearly 95 percent of the original old growth redwood forests. However, other forest and vegetation types have experienced similar detrimental impacts and precipitous declines.

Mendocino Pygmy Cypress Woodlands, otherwise known as “pygmy forests” have been subject to significant conversion, logging, and other varieties of development. These unique and rare forests require a combination of environmental factors—including highly acidic and nutrient-depleted soils with an underlying layer of hardpan rock or dense clay—which stunts the trees’ growth. Some estimates put the total remaining acres of Mendocino pygmy forests at 2,600 acres or less, and the California Department of Fish and Wildlife estimates that approximately 70 percent of what remains is under some sort of non-protective status.

Now, the Mendocino Solid Waste Management Authority is proposing a solid waste transfer station for the City of Fort Bragg on a 17-acre parcel of undeveloped Mendocino Pygmy Cypress Woodland and Northern Bishop Pine Forest—another rare forest type—along state highway 20. The 17-acre parcel is currently owned by the state, and is being managed as part of the Jackson Demonstration State Forest, but the proposal involves a land-swap that would transfer it out of state ownership for the purposes of the proposed development.

The proposed conversion of these forests for a waste transfer facility runs contrary to several land management mandates that are built into the Mendocino County General Plan, and even runs contrary to tenants of the Jackson Demonstration State Forest management plan, which calls for protecting and maintaining the current extent and distribution of pygmy cypress forest types.

The Draft Environmental Impact Report (DEIR) for the project fails to adequately assess potentially significant adverse environmental impacts resulting from the conversion of these rare forest habitats, and fails to present or adequately analyze feasible alternatives to the project that would either avoid or substantially lessen the potentially significant adverse impacts of the conversion.

In a letter dated February 28, 2014, the California Department of Fish and Wildlife indicates that it believes the project will have a significant adverse impact on pygmy forest, stating: “[g]iven this project has the potential to remove acres of high quality habitat in a rare, threatened, and declining vegetation type, CDFW finds it is highly likely this project will result in significant impacts to Mendocino Pygmy Cypress Woodland.”

Click here to take action now. Tell the Mendocino Solid Waste Management Authority that you oppose placement of the solid waste transfer station on lands currently occupied by rare Pygmy Cypress Woodland and Northern Bishop Pine Forest. Tell the Mendocino Solid Waste Management Authority that it must properly evaluate the potentially significant adverse impacts of the proposed waste transfer station location, and that it must develop and consider feasible and meaningful alternatives to the proposed location that would avoid or substantially lessen the potentially significant environmental impacts of the project as proposed.


One Plan to Rule Them All

Monday, March 23rd, 2015
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NWFP LogoOver the next few weeks and months, EPIC is going to focus in depth on the Northwest Forest Plan revisions for the U.S. Forest Service. Each week we will bring you a new topic. To catch up on what EPIC has previously written, click here.

Species like the northern spotted owls don’t respect political boundaries. For that reason, the original Northwest Forest Plan was a regional forest management plan. The Plan amended the forest plans for 26 separate forests, managed by the U.S. Forest Service, the Bureau of Land Management, and the National Park Service, across 24 million acres of the American West. As a single, regional, interagency plan, the Northwest Forest Plan allowed for an ecosystem management approach to account for the needs of multiple listed species across three states through a system of wildlife reserves.

The Plan, by and large, has worked. Recent science has reaffirmed the importance of the Northwest Forest Plan as a global model for ecosystem management and biodiversity conservation, particularly the reserve network. Forest growth as a result of the Plan has turned the forests of the Pacific Northwest from a significant annual source of CO2 to a carbon sink. The reserve system has mitigated the impact of logging and the invasion of the barred owl on the northern spotted owl. Water quality has significantly improved due to the plan’s emphasis on watershed restoration and system of riparian buffers.

Now 20 years into a 100 year restoration plan, the Northwest Forest Plan is at risk. There is pressure to ditch the single, regional format of the Plan and go back to the old days where each federal agency and each forest was managed differently. This plan to go it alone puts at risk all of the gains made, particularly for the imperiled northern spotted owl which depends on the system of interconnected wildlife reserves.

We urge the Obama Administration to keep the Northwest Forest Plan as a consistent, interagency ecosystem management plan to manage all of the federal public forests of the West. The reserves work; going it alone doesn’t.

NOTE: The first CA listening session will in Redding, CA on Wednesday March 25, 2015 from 5:30 PM to 8:30 PM at the Red Lion Hotel. We hope to see you there! If you are planning on attending, please let Tom know by shooting him an email at tom@wildcalifornia.org.


Caltrans District 1: Wake up and smell the 21st Century

Thursday, March 12th, 2015
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It is time for a change. Now is time to rein in Caltrans. Last year, an independent report—the SSTI Assessment and Recommendations, authored by the State Smart Transportation Initiative—was released. Commissioned at the behest of Governor Brown, the report found that Caltrans is stuck in an “era of [i]nter-state building” despite calls (since the 1970’s) for more multimodalism, sustainability and less reliance on auto-mobilty. The study also finds that Caltrans has not developed sufficient communications skills and procedures to either explain its own decisions or to take into account important material from communities and partners; and has not fully adapted to the multi-stakeholder environment in which it finds itself. The pattern of inadequate response to community concerns about social and environmental impacts of highway development, as well as a lack of legal accountability becomes apparent when a series of projects are looked in their entirety.

Four Caltrans projects on California’s North Coast stand as examples of this “stuck-in-the-past” project planning.

Richardson Grove

richardson_grove_bikes

Richardson Grove State Park. Photo credit: Caltrans

The highway “realignment” through Richardson Grove State Park seriously threatens mammoth ancient redwood trees—a fact confirmed by the 1st District Court of Appeal, which ruled in 2012 that Caltrans failed to adequately analyze the impact of its proposed project on the ancient redwoods. This should have come as no surprise to Caltrans. In 2010, by Caltrans own admission, the agency found the project, as proposed, “may cause significant adverse impacts to old growth trees in this unique natural community.” California State Parks likewise expressed concern in its comments to the Draft Environmental Assessment, “The Draft EA does not provide an assessment of the number of trees that will have their structural root zone compromised. Without such an assessment the State Parks cannot adequately assess the proposed action’s impacts on old-growth redwoods and other mature trees. Caltrans therefore must assume that the proposed action will result in significant adverse effects to old-growth redwoods and that adequate mitigation needs to be developed.” (Emphasis added.)

Caltrans initially informed the public that the purpose of project was to enhance safety and goods movement; however it changed tack during the environmental review process, and ultimately concluded that the Proposed Project is not a safety project and concluded that the economic impacts of the proposed project on Humboldt County businesses and trucking firms would be negligible.

After seven-years and three lawsuits Caltrans has rescinded its approval of the Richardson Grove Project and withdrawn its federal Finding of No Significant Impact. Now the project cannot proceed until additional environmental analysis about the impacts of the project on the environment are completed and approved by the courts.

It didn’t have to be this way. Richardson Grove is world-class state park and the ancient redwood trees it protects deserve the fullest protection under the law—and yet, Caltrans repeatedly failed to follow the law. Instead the agency and Humboldt County advanced a public relations campaign to promote highway expansion saying that the project would be good for business and have “no significant impact,” despite the fact that to date it has not provided the public with any legitimate evidence, criteria for decision making, meaningful explanation why or analysis to substantiate that conclusion. Instead of properly analyzing viable alternatives that better reflect the needs of Californians and the environmental realities of our times, Caltrans has wasted time and money trying to prove its project is benign.

Caltrans estimates that new documentation will be available in fall 2015 and public comment will be re-opened. EPIC is committed to taking all steps to preserve Richardson Grove State Park’s old-growth redwoods and looks forward to reading and analyzing Caltrans’ next iteration of documentation.

Willits Bypass

Winter Willits WetlandThe Willits Bypass is draining 90 acres of precious wetlands for a giant interchange made for a four-lane freeway that will do little to relieve local congestion. Caltrans’ implementation of the Bypass has seen a laundry list of environmental permit and cultural violations including being charged with violating the U.S. Clean Water Act when erosion at the site sent pollution streaming into a protected creek and destroying a known Native American archaeological site that was supposed to be protected by law. The impact is so severe that Caltrans is required to do the largest environmental mitigation in its history to compensate. But Caltrans has had trouble meeting permit and mitigation requirements. In June 2014, Caltrans was so far behind in its environmental requirements the U.S.

Collapse Jan. 22, 2015. Photo Credit: Steve Eberhard Willits News

Collapse Jan. 22, 2015. Photo Credit: Steve Eberhard Willits News

Army Corps of Engineers suspended the permit and shut down most work on the bypass for more than 3-weeks. Then there was the stunning collapse of a 150-foot section of the Bypass viaduct on January 22, 2015, dumping cement and debris right into Haehl Creek! More recently Caltrans requested an additional $64.7 million in funding from the California Transportation Commission for what it calls “unforeseen issues.”

If compelled, Caltrans could implement design changes to the northern interchange such as reducing the footprint from 4-lanes to 2-lanes, which would reduce environmental impacts, damage to cultural sites and save money.

Smith River Highway 199

Smith River Hwy 199

Smith River Hwy 199

A highway development project planned for Highway 199 and 197 in the northwestern-most corner of California poses direct and indirect threats to our redwood parks and the unparalleled salmon habitat of the wild Smith River in Del Norte County. In response to a lawsuit by EPIC, Caltrans has agreed to reassess impacts of the highway-widening project on protected salmon and their habitat along the Wild and Scenic Smith River. A settlement agreement will keep in place a court-ordered halt of construction work until Caltrans completes consultation with the National Marine Fisheries.

Four Bridges Project

Elk Creek Bridge

Elk Creek Bridge

Lastly, Caltrans’ Four Bridges Project is proposing to upgrade four existing bridges along the Avenue of the Giants, a world-famous scenic drive through the ancient redwood groves of Redwood State Park. EPIC found that the agency’s initial release of the project proposal violated the California Environmental Quality Act as it failed to adequately provide the public with access to various environmental studies, which the agency relied on to justify its conclusion that the project would have no significant impact and that further study wasn’t needed.

The North Coast community deserves an honest, transparent, and open discussion about the impacts of highway development on its irreplaceable natural treasures, and about the costs and the benefits of this infrastructure development. This discussion must include recognizing the viability of alternatives that will meet needs for goods movement and transportation, as well as protect the rare and sensitive environments.

Rally in Sacramento

Rally in Sacramento

Yet, Caltrans has refused to be forthright with residents about the direct impacts of its highway development projects, much less been willing to engage the public in a productive manner when concerns are raised. In the absence of credible leadership by Caltrans, EPIC has challenged the legality of these projects with the immediate intent of protecting rare and sensitive environments, and with the long-term goal of leveraging successful court action into political momentum that will lead to a serious reform of the agency and change in culture. A major restructuring of the Caltrans is under way as a result of the SSTI Report; the question remains whether the recommendations of the independent review combined with the reality check of the court orders will be sufficient impetus to bring Caltrans out of the past.

Last Chance Grade

Last Chance Grade AerialCaltrans may have an opportunity to get it right with Last Chance Grade—a stretch of U.S. Highway 101 about ten miles south of Crescent City which sits precariously high above the Pacific Ocean and experiences frequent landslides due to the geological instability of the area Caltrans is in the beginning stages of planning for the Last Chance Grade Project along Highway 101. The agency is considering possible alternatives and reroutes in an attempt to find a long-term solution for the Last Chance Grade. U.S. Congressman Huffman’s office is working to develop a stakeholder group for facilitated discussions regarding potential projects to address Last Chance Grade. This group would work to identify one or two alternatives for a project that would ensure that U.S. Highway 101 is protected from a serious failure of the roadway and environmental harms are reduced. The group’s discussions would parallel and inform the current public process Caltrans has embarked on.

There is no question that Caltrans needs significant reform to bring it into step with best practices in the transportation field, with the state of California’s policy expectations and the true needs of North Coast residents. While the lawsuits are effective for enforcing the law, they do not permanently stop projects, and reform is what will lead to sustainable transportation solutions for rural communities. This reform is not only the demand of citizen organizations like EPIC; it is the recommendation of one of the nation’s leading authorities on sustainable transportation. The time has arrived to rein in Caltrans.


EPIC Digs in on Northwest Forest Plan Revisions

Wednesday, March 11th, 2015
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Holm_Fay_date2008-04-09_time16.02.45_IMG_8035 copyAncient forests of Douglas fir, hemlock, western red cedar—and in our lucky corner of California, the majestic redwoods—once stood proudly on the landscape. These forests, nurtured by the warm, wet climate, supported an amazing diversity of life; from salmon to northern spotted owls, Pacific fishers to grizzley bears, many species evolved to depend on these verdant lands.

And then came European settlors and everything changed. Decades of logging largely stripped these ancient forests from the landscape. By the late 1980’s there wasn’t a whole lot left and what still remained was going fast. The critters that evolved to depend on these big, old trees were on the brink of extinction—most notably the poster child of old growth forests, the northern spotted owl. In 1990, the spotted owl was listed under the federal Endangered Species Act. Locally, 1990 was the start of “Redwood Summer,” a movement of environmental activism devoted to protecting the last remaining stands of old growth redwoods.

The listing had near immediate effect; logging on national forests containing owls was enjoined in 1991. But the issue was far from resolved. Indeed, it was only heating up. A back-and-forth fight ensued between pro-timber interest on one side and pro-forest forces on the other.

In 1993, the Clinton Administration intervened, beginning a series of hearings and reports. By 1994, a plan was developed: The Northwest Forest Plan, a set of federal policies and guidelines amended 26 land use plans, spanning 24 million acres of Forest Service, Bureau of Land Management, and National Park Service-managed lands in Northern California, Washington and Oregon. The plan, designed to protect the northern spotted owl by setting aside large swaths of land, “Late-Successional Reserves,” while still providing for some limited timber extraction in so-called “Matrix” lands.

In has been 20 years since the Northwest Forest Plan was adopted. Revisions to the land use plans which constitute the Plan are either underway or are about to begin. The BLM has begun to create new management plans for the forests they manage. The Forest Service is just beginning listening sessions for their forest plan revisions.

Over the coming weeks and months, EPIC is going to talk about the revisions to the Northwest Forest Plan. We will keep you abreast in ongoing discussions, provide critical evaluations of the success (and failures) of the original Plan, and will preview important revisions and principles EPIC will champion in forest plan revisions. So stay tuned. And thanks for your support.

NOTE: The first CA listening session will in Redding, CA on Wednesday March 25, 2015 from 5:30 PM to 8:30 PM at the Red Lion Hotel. We hope to see you there! If you are planning on attending, please let Tom know by shooting him an email at tom@wildcalifornia.org.


Marbled Murrelets Protected Again

Wednesday, March 11th, 2015
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MAMU_AlaskaFWSThe DC Circuit Court of Appeals rejected yet another attempt by the timber industry to remove federal endangered species protections from the marbled murrelet. The appeal was the timber industry’s fifth attempt—and fifth loss—in the past decade to eliminate protections for the old growth forests that marbled murrelets call home, despite undisputed scientific evidence that has shown murrelets are continuing to disappear from the coasts of Washington, Oregon and California.

On appearance alone, the marbled murrelet doesn’t appear to be very remarkable. The murrelet is a small seabird mottled with streaks of brown, grey and white—the timber industry dismissively compares the murrelet to a pigeon. But looks can be deceiving—the marbled murrelet is quite extraordinary. Murrelets make their home in old growth forests and travels daily up to 50 miles from the coast to return home. (Let’s see a pigeon do that!) Each year, breeding murrelets return to the same home forest. The murrelet does not build a nest; females lay a single egg in mossy deposits high in old growth trees.

Marbled murrelets are near the brink of extinction in California. Only a few nesting areas remain in the whole state. But EPIC has their back. Since the marbled murrelet was listed under the Endangered Species Act in 1992, EPIC has zealously defended the murrelet and its remaining habitat. In 1995, EPIC’s instrumental victory in Marbled Murrelet v. Babbitt was instrumental in the creation of Headwaters Forest, one of the last intact tracts of murrelet habitat. The DC Circuit Court of Appeals decision is yet another victory benefitting the murrelet and the big, old trees on which it depends.

Despite five consecutive losses, we are sure that the timber industry will continue to try to delist the murrelet by any means possible. That’s where we come in: EPIC will continue to stand guard against industry attacks on the murrelet and the ancient forests it calls home.

This work is made possible by people who value big, old forests and want to see that the wildlife that inhabit these forests receive the best possible protections. Make a donation now and help EPIC continue to fund groundbreaking litigation to protect marbled murrelets and old-growth forests.


Update on Caltrans’ Last Chance Grade Project

Thursday, February 19th, 2015
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Drilling Last Chance Grade

Caltrans recently held a series of public workshops seeking input from the public as the agency considers possible alternatives and reroutes in an attempt to find a long-term solution for the Last Chance Grade — a stretch of U.S. Highway 101 about ten miles south of Crescent City, which sits precariously high above the Pacific Ocean and experiences frequent landslides due to the geological instability of the area.

lcg_preliminary-alternativesThe road-building agency is currently examining a number of preliminary alternatives that would reroute Highway 101 to the east through Del Norte Coast Redwoods State Park and private timberland. The reroutes would impact old-growth, mature and young redwood forests, coastal spruce forests and Mill Creek, which provides the best spawning habitat for the federally endangered Coho salmon  in the Smith River basin. The price tag for these projects run between $200 million to over $1 billion.

There is little question among the staff at EPIC that the project has a legitimate need: to maintain motorist safety and to connectivity of the major highway between Oregon and California; but we believe that all viable options for avoiding impacts to our natural resources must be thoroughly studied, and these studies must be made available to the public, before the project proceeds.

Specifically, studies regarding the feasibility of using the existing right of way for the project – through more permanent stabilization efforts than are currently taking place, use of a viaduct, or other measures – must be conducted and made available to the public. Despite what Caltrans officials said at the public meetings, EPIC does not consider this to be a “no action” alternative. Instead, we would like to see the feasibility of taking action within or near the existing roadway first. If a study concludes that this is infeasible, Caltrans should select an alternative that avoids impacts to old-growth redwoods to the greatest extent possible. For impacts that are truly unavoidable, Caltrans should implement mitigation that enhances old growth redwood and salmon habitat values. EPIC supports keeping the project as a 2-lane, 55mph road.

As this project unfolds, EPIC will continue to advocate for full public transparency and protection of old-growth redwood forest and salmon habitat values.

Click here to be redirected to Caltrans’ website for technical documents.


EPIC in Review

Tuesday, February 17th, 2015
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salmon-river-spring-M-Aaron CowanEPIC in Review, a summary of original comments submitted and letters signed to support conservation across the state and nation.

EPIC submitted substantive comments on the Draft Working Group Charters for the California Timber Regulation and Forest Restoration Program. The California Natural Resources Agency (CRNA) and the California Environmental Protection Agency (CAL EPA) are implementing the provisions and intent of Assembly Bill 1492. EPIC has reviewed the draft working group charters for Ecological Performance, Data and Monitoring and Administrative Performance Measures. The draft charters lack fundamental foundation definitions, goals, and objectives; and EPIC does not believe it to be a true public process designed to deliver necessary change. If ecological standards and performance measures are intended to secure vibrant forests, healthy rivers, and abundant, self-sustaining wildlife populations, then measurable objectives must be defined and monitored. They must be science-based, and done out-in-the-open in a collaborative process using the input of stakeholders from outside of the usual agency and industry suspects. EPIC supports the concept of a comprehensive review and analysis of the existing forest practice regulatory system.

Six Rivers & Klamath National Forest road maintenance plans: EPIC submitted scoping comments on the Six Rivers Road Maintenance Project. The project proposes to maintain and treat portions of up to 2,682 miles of National Forest Transportation System roads on Six Rivers National Forest and Klamath National Forest. We urge the agency to scale down the project either in size, timing or by other means to allow a sufficient analysis to the impacts.

Grazing leases in the King’s Range: EPIC joined with Western Watersheds and submitted comments on the proposed renewal of Grazing Leases in the King’s Range National Conservation Area.  The HJ Ridge grazing lease includes 1,160 acres of public land with approximately 1,000 acres in wilderness. The Spanish Flat grazing lease includes 9,100 acres of public land, all entirely within wilderness. EPIC believes that livestock grazing is degrading wilderness character, impacting cultural and ecological resources, and recreational experience. With ongoing drought and climate change issues, and lack of water for livestock, the Bureau of Land Management should be working with the public to close these allotments to further commercial livestock use. We urge the BLM to complete a full Environmental Impact Statement before renewing these leases.

EPIC Submitted comments in support of the US Fish and Wildlife Service’s proposed rule to list the West Coast Distinct Population Segment of the Pacific Fisher as a “threatened” species under the federal Endangered Species Act. The letter encourages the Service to designate Critical Habitat for the Fisher at the time of listing.

Vote NO on H.R. 161, the Natural Gas Pipelines Permitting Reform Act: EPIC co-signed a letter urging representatives to oppose HR 161, a bill that would spread pipelines into parks, forests, and private property, across the country thereby fragmenting forests and causing loss of critical habitat. HR 161 seeks to rubber-stamp Federal Energy Regulatory Committee permits, superseding states’ authority to provide their own protection under the Clean Water Act and the National Environmental Protection Act.

EPIC signed a coalition letter opposing H.R. 399, the “Secure our Borders First Act of 2015.” Under the guise of enhancing border security, H.R. 399 would further militarize areas already glutted with walls and roads; undermine environmental laws, and allow more damage to the fragile border environment. Sections 3 and 13 would only harm wildlife, and communities on the border while doing nothing to increase border security.

EPIC signed on in support of Booker’s Amendment #155 to the Keystone XL Pipeline bill, S.1. This amendment ensures agencies disclose any significant new circumstances or information on the environmental, public health, social, and other impacts resulting from the project and that the Keystone XL Pipeline is subject to the same requirements as all other major pipelines.

EPIC signed on to letter challenging unmitigated Navy Testing and Training in the Pacific Northwest: The Navy shows a continued failure to protect whales, dolphins and other marine life from behavioral disruptions such as the separation of mothers and calves, and injury such as permanent hearing loss. They must develop alternatives and mitigation measures in a wholesale revision of the DEIS.

EPIC signed on to a Letter to Secretaries of Agriculture and Interior re: the Aquatic Conservation Strategy (ACS) of the Northwest Forest Plan: The ACS is largely responsible for higher quality aquatic habitats, enhanced water quality, sustenance of imperiled salmon and associated recreational and commercial fisheries, restoration of sediment and hydrologic regimes, increased floodwater retention, and countless other ecological and economic benefits that flow from healthy watersheds. Emerging science on climate change, stream conditions, nutrient retention and other issues justify more, not less, protection, yet despite its success, the ACS is under attack. The Forest Service and Bureau of Land Management, the land management agencies charged with its administration, are being pressured by Congress to dismantle or significantly weaken the ACS.


Moonalice at the Mateel Community Center, March 27

Sunday, February 1st, 2015
By

Moonalice_Psychedelic_Bob-Minkin

The event, formerly known as the Pisces Party, benefits EPIC’s efforts to restore the forests and watersheds of the North Coast of California. The Pisces Party is a celebration to welcome the coming spring and honor local activists who are working to create a healthy, sustainable forested landscape for flourishing nature and wildlife, and to safeguard earth’s valuable living resources in a changing climate for current and future generations.

In addition to celebrating long-time Pisces activists such as North Coast restoration advocate Richard Geinger as well as Sharon Duggan, Sue Malony, Greta Montagne, Bear Behr, Sam Johnson, Shawnee Alexandri, et al., EPIC will honor the Eel River Clean-up Project for their efforts to clean up trash and abandoned home encampments along the Eel river in Southern Humboldt County. The Eel River Clean-up Project is a collective of committed individuals who have shown remarkable dedication and garnered enormous success over the past several months.

Come early for drinks and a delicious dinner of mouth watering creations from Sue’s Organics!

Click here to buy tickets.

Moonalice is a band of hippie musicians from California with no label, no manager, no problems, and lots of fans. They’re made up of seasoned players exploring new musical territory with a passion. Bringing their heady brew of roots, rock, rhythm-and-blues, peppered with spirited doses of improvisation and surprise to the North Coast to benefit forest protection and restoration in Northwest California.

  • Doors open at 6pm for dinner and music by Diane Patterson
  • Moonalice performs at 8pm
  • Tickets: $20 for concert, dinner an additional charge TBD

Moonalice is known for integrating multi-sensory experience of lights, visuals, music, art, dance and sound highlighted by extended improvisations in the tradition of the Grateful Dead into every show. A new psychedelic poster is created for each concert and gifted to guests to memorialize the show.

Band members: Barry Sless (Phil Lesh & Friends, David Nelson Band), Pete Sears (Jefferson Starship, Rod Stewart), Roger McNamee (Flying Other Brothers), and John Molo (Bruce Hornsby, Phil Lesh & Friends). Plus manager/road scholar/medicine man Big Steve Parish, the man who was Jerry Garcia’s guitar tech for 25 years introduces every show. For posters, music and videos of all shows visit Moonalice.com

diane.maui_Doors open at 6pm for drinks and a delicious dinner prepared by Sue’s Organics. Opening set by folkadelic, singer-songwriter, Diane Patterson. Diane sounds like a cross between “Joni Mitchell, Ani DiFranco, and a young Pete Seeger.” She is a modern day folk goddess singing the world awake with strong voice, rocking guitar, sweet ukulele, and revolutionary lyrics. Her sincere spirit and wild heart joyfully plant seeds of love and light in every listener.

Tickets for sale at Redway Liquor, Blue Moon Gift Shop, Wildberries, the EPIC office (145 G Street Suite A, Arcata, Ca), or online at Brownpapertickets.com. For more information wildcalifornia.org or call 707-822-7711.


Action Alert: Tell Caltrans to study impacts before advancing the Four Bridges Project

Wednesday, January 28th, 2015
By
Avenue of the Giants

Avenue of the Giants

The California Department of Transportation (Caltrans) is proposing to upgrade four existing  bridges along the Avenue of the Giants, a world-famous scenic drive along old Highway 101, through the ancient redwood groves of Redwood State Park.

Take Action: Tell Caltrans that it needs to adequately study impacts, and adequately inform the public, before they move forward with the project.

Elk Creek Bridge

Elk Creek Bridge

Caltrans released an Initial Study with Proposed Mitigated Negative Declaration for the “Avenue of the Giants – Four Bridges Project” over the holidays, comments are due on Monday, February 2.  (A “Mitigated Negative Declaration” is a CEQA document that essentially says that environmental impacts will be mitigated below significant levels, and therefore that further study of the project impacts is unnecessary.) As proposed, this project would involve upgrades to bridge and guard railings and repaving of the existing roadway on each side of four bridges on Avenue of the Giants/Route 254, and all of this work would occur within and around ancient redwoods and important salmon habitat. Yet, despite the precious resources potentially threatened by this project, Caltrans is pushing the project through without adequately analyzing or disclosing to the public the impacts of the project.

 Tell Caltrans:
* Impacts to redwoods need to be fully analyzed, and all conclusions need to be fully explained to the public, before work begins in and around their roots.
* Adequate, and fully explained, measures to avoid spills or other stream disturbances need to be developed before Caltrans begins working over streams with important fish habitat.
* Caltrans needs to recirculate the Initial Study with Proposed Mitigated Negative Declaration with all underlying studies and documents in order to be transparent with the public about the project and its potential impacts to public resources, and in order to comply with CEQA which requires that the public be provided this information for comment.

Impacts to Trees
Caltrans maintains that the project area contains 46 coastal redwood trees. While the Initial Study and Proposed Mitigated Negative Declaration notes that “[i]t is difficult to develop a mitigation strategy that adequately offsets a project’s impacts to old growth redwood trees, due to their size and age,” it nevertheless concludes that the study will have “less than significant” impacts on these trees. The impacts on each tree in the area were rated on a 0-6 scale corresponding with the magnitude of impacts of the projects on the tree: eleven trees were rated “0” (no effect); fourteen were rated “1” (effect of root zone disturbance is extremely minor with no decline in foliage density or tree health); and twenty-two were rated “2” (effect of root zone disturbance is very slight with no decline in foliage density or tree health). Exactly how this rating system was developed, or how the trees were rated, however, was not disclosed. For trees rated “2,” for instance, the Initial Study indicates that there may be project activities closer than 10 feet from the base of these trees. Caltrans needs to explain why it believes that this work occurring so close to the trees would cause only “very slight”  root zone disturbance.

Various avoidance, minimization, and mitigation measures are proposed to reduce impacts to redwoods. Many, however, contain inadequate descriptions regarding how they will be carried out. For example, one such measure is “no roots greater than two inches in diameter will be cut,” however the Initial Study does not describe how work crews will achieve this.

In short, Caltrans has not demonstrated that it takes seriously the great responsibility of working near our precious ancient redwoods, and that it deserves our trust when they say that the project will leave these trees unharmed.

Impacts on Fish
The bridges at issue span Ohman Creek, Elk Creek, Bridge Creek and Bear Creek, all four of which provide habitat for Chinook and Coho salmon, among other aquatic creatures. As with its analysis of impacts on redwoods, Caltrans concludes that the impacts of the project on fish will be “less than significant,” but it provides little evidence to support this conclusion.

Furthermore, the document acknowledges that unexpected impacts to fish can occur from “unintended spills, increased sedimentation, and alteration of pH.”

Collapse Jan. 22, 2015. Photo Credit: Steve Eberhard Willits News

Collapse Jan. 22, 2015. Photo Credit: Steve Eberhard Willits News

As we have unfortunately learned from the recent collapse of the overpass at Willits Bypass, which spilled wet concrete into a nearby stream, raising the pH of the stream to a level that can kill fish immediately, unintended events can have huge impacts. But the “avoidance, minimization, and/or mitigation measures” provided in the Initial Study for the Four Bridges Project for potential impacts to anadromous fish are vague and inadequate. Before starting work above and around these streams, Caltrans should provide additional assurances that spills and other disturbances of the creeks in the project area will be prevented, and it should develop and circulate for public review a site-specific emergency response plan for spills or other disturbances of the streams.

CEQA violations
CEQA requires that all documents referenced in a proposed mitigated negative declaration be made available to the public. (See Cal. Pub. Res. Code § 21092; CEQA Guidelines  § 15072). In this Mitigated Negative Declaration, however, many conclusions rely entirely on referenced documents and surveys, which were not made publicly available, in clear violation of CEQA.

While ultimately it may be that Caltrans believes it has put adequate measures in place to reduce environmental impacts of this project to acceptable levels, it needs to prove this to the public by publicly releasing all underlying documents so that the public – as a participant in the process for informed decision-making – can review and comment on all the information.

This must be done before Caltrans can act to decide this project.

Click here to be directed to Caltrans’ website for technical studies.


Take Action—Tell the Fish and Wildlife Service to Protect the Pacific Fisher

Wednesday, January 28th, 2015
By

Pacific FisherAfter 15 years of delays and subsequent litigation, the U.S. Fish and Wildlife Service is proposing to list the West Coast population of the Pacific fisher, a small, weasel-like forest carnivore, as a “threatened” species under the federal Endangered Species Act. In 2000, EPIC and 16 other conservation groups petitioned the U.S. Fish and Wildlife Service (Service) to list the West Coast population of the Pacific fisher under the Endangered Species Act (ESA). Now, the end is almost in sight; our goal is almost achieved.

The Pacific fisher faces many threats to its survival and conservation. From logging to roads, stand-replacing wildfires and overly-aggressive fuel reduction programs, and the explosion in illegal marijuana growing and the associated use of anticoagulant rodenticides, the small, isolated populations of West Coast fishers have long needed the protections afforded by the ESA. However, EPIC is concerned with certain proposals put forward by the Service and big-timber interests.

First, EPIC is concerned about the designation of critical habitat for the fisher and the development of a subsequent fisher recovery plan. The ESA normally requires the Service to designate critical habitat for a listed species concurrently with a listing determination. The Service has indicated it will not do so for the fisher. Instead, the designation of critical habitat will be pushed out into the future. In developing future critical habitat, it is essential that the Service pay close attention to the conservation needs of the fisher and not rely on the conservation strategy for the northern spotted owl to adequately protect the fisher.

Like the northern spotted owl, the fisher primarily relies on old, mature forests and complex forest structures, like snags and mistletoe brooms, for denning, feeding, and dispersal behaviors. Because of these similarities, there is pressure to rely on the conservation strategy developed for the northern spotted owl—most notably, relying on northern spotted owl critical habitat and the system of late-successional reserves on our public lands for the conservation of the fisher. However, reliance on the extant conservation strategy for the northern spotted owl will not likely be sufficient to protect and conserve the fisher across the species’ range. While the owl and the fisher do use some similar habitats, the best available research shows us that the habitat for these two species does not entirely overlap, and that conservation of the fisher will rely on a more comprehensive strategy.

Second, EPIC is concerned with attempts to redefine which populations should be afforded protection under the Endangered Species Act. The U.S. Fish and Wildlife Service is considering several listing configurations for the west coast population of the fisher. When only a portion of a larger species is proposed for listing, the ESA provides for the ability to list what is known as a Distinct Population Segment (DPS). At present, the U.S. Fish and Wildlife Service is considering whether or not to include the entire West Coast population of the fisher into one DPS, or if it will break out the Sierra, Northern California, and Washington and Oregon populations into smaller listable units. EPIC supports the designation of the entire West Coast population of the fisher as a single DPS. Listing of the entire West Coast population of the fisher under the ESA will increase the likelihood that the small, isolated populations of the fisher can persist, and perhaps even reconnect. In addition, listing of the West Coast population of the fisher will serve to improve landscape management, which in turn, will aid in our goals of protecting and connecting our wild and forested landscapes.

Lastly, EPIC is concerned that the Service may attempt to weaken the normal protections afforded to a threatened species to lessen the sting of the ESA on industries which degrade fisher habitat. In addition to the failure to promptly designate critical habitat for the fisher, the U.S. Fish and Wildlife Service has indicated that it is considering the promulgation of a “4(d) rule” which would allow the Service to weaken the default ESA protections for the fisher in favor of promoting so-called “fisher-friendly forestry.” EPIC opposes any such rule which serves only to weaken ESA protections afforded to the fisher.

Action:

Tell the U.S. Fish and Wildlife Service:

  • Listing of the West Coast population of the fisher is a warranted action.
  • List the entire West Coast fisher populations as a single Distinct Population Segment.
  • You oppose any rule that would weaken Endangered Species Act protections for the fisher in favor of “fisher-friendly forestry.”

Send Comments to Federal eRulemaking Portal:

http://www.regulations.gov/#!submitComment;D=FWS-R8-ES-2014-0041-0148