Action Alerts

Action Alert: Defend Public Lands; Defeat Trump’s Environmental Agenda

Thursday, June 29th, 2017
By

TAKE ACTION! On the 4th of July, you can help save our forests by halting bad legislation. A new bad forest bill, the ironically named “Resilient Federal Forests Act” (HR 2936), is quickly heading to a vote. The bill recently escaped the House Natural Resources Committee through a party line vote. Now, Trump’s lawless logging bill will soon come up for a vote before the House.

This is the worst federal forest legislation in EPIC’s lifetime. And scarily, it might pass. Here’s four reasons why we are freaked out:

(1) Up to 30,000 Acres of Lawless Logging

The bill gives a free pass to lawless logging by exempting logging plans up to 30,000 acres—nearly 47 square miles—that are developed through a “collaborative process” from having to comply with the National Environmental Policy Act (NEPA). By comparison, under the existing law only logging projects 70 acres or less are exempted from NEPA. In one fell swoop, Congress could rollback decades of work by EPIC and allies to protect federal forests.

(2) Weakens Endangered Species Act Protections

Under current law, whenever the Forest Service proposes a project that could harm threatened or endangered species, the agency needs to consult the National Marine Fisheries Service and/or the U.S. Fish and Wildlife Service. The proposed legislation would change the law to remove this consultation requirement by allowing the Forest Service to choose whether or not to consult on a project. Further, the bill would exempt other forest management activities entirely from the Endangered Species Act.

(3) Closes the Courthouse Doors

The bill also limits the ability of citizens to challenge bad agency action in court. The bill would prohibit temporary injunctions and preliminary injunctions against “salvage” logging projects, virtually guaranteeing that logging will occur before a court can hear a challenge. The bill prevents plaintiffs from recovering attorneys’ fees if they win. While money is never the object of a lawsuit, the ability to recover fees is critical to enable public interest environmental lawyers to take cases for poor nonprofits like EPIC. Finally, it moves many forest management activities out from our federal courts to a “binding arbitration” program, whereby an agency-appointed arbitrator’s decision would decide the fate of projects.

(4) Shifts Money from Restoration to Logging

In a sneaky move, the proposed legislation would move money earmarked for forest restoration projects to logging. By adding one small phrase—“include the sale of timber or other forest products”—the bill would mandate timber sales as part of at least half of certain stewardship projects.

CLICK HERE TO TAKE ACTION NOW TO STOP BAD FOREST LEGISLATION


Action Alert: Congress Threatens Public Input for BLM Lands

Friday, February 17th, 2017
By

Headwaters Forest Reserve 20 Anniversary Hike

Take Action Now: The Senate is considering S.J. Res 15, a resolution to overturn the Bureau of Land Management’s “Planning 2.0” land-use planning rule, which gives the public a voice in large-scale planning for public lands. If the resolution is passed, public input in the management of our public lands would be drastically limited. the U.S. House of Representatives already voted in favor of the resolution, and the Senate will be voting any day. Senators need to hear that we value our public lands and we should have a say in how these lands are managed.

The BLM manages over 245 million acres of land mostly within Western states, with over 15.2 million acres in California, and 86,000 acres in Humboldt County alone, including the King Range National Conservation Area and the Headwaters Forest Reserve.

Arcata and Redding BLM Field Offices are currently undergoing their Resource Management Plan updates for managing 20-25 years out, and they have combined updates to create a more regional approach for Northwest California planning, which is referred to as the Northwest California Integrated Resource Management Plan.

Hunters, anglers and conservationists support Planning 2.0 because the rule ensures important migration corridors and other intact habitats are identified so these areas can be conserved throughout the planning process.

Click here to send a letter to your Senators asking them to preserve public participation in the planning process for public lands by voting no on S.J. Res 15. Its best if you personalize your letter to reflect your experiences and highlight the places you care about.

OR for those of you in California, please send your comments to the email addresses below, or call:
Senator Feinstein’s office: Kenneth_Rooney@feinstein.senate.gov 202-224-3841
Senator Harris’s office: Nicole_Burak@harris.senate.gov 415-355-9041 and 202-224-3553


Action Alert: Say No to Climate Denier and Yes to Science

Monday, January 30th, 2017
By

Holm_Fay_date2008-04-09_time16.02.45_IMG_8035 copy

Trump Chooses Climate Change Denier to Head Department of Agriculture

Take Action to stop climate change denier from taking cabinet position. On January 19th, Donald Trump selected conservative Republican and climate change denier, Sonny Perdue, to be his Secretary of Agriculture. In 2014, Perdue wrote an opinion article describing climate change as “…a running joke among the public, and liberals have lost all credibility when it comes to climate science because their arguments have become so ridiculous and so obviously disconnected from reality.”

If confirmed, Mr. Perdue would be the head U.S. Department of Agriculture, an agency with a $155 billion budget that is charged with oversight of our national forests and grasslands, which make up 279,000 square miles of public lands. Additionally, he is tasked with matters relating to Wildlife Services, overseeing farm policy, food safety, and the food-stamp program.

The former governor of Georgia who once ran a grain and fertilizer business, has received hundreds of thousands of dollars in federal farm subsidies that help chemical companies and large agriculture conglomerates at the expense of the environment and small farmers. As governor, Perdue championed the expansion of factory farms and pushed against gas taxes and EPA efforts to enforce the Clean Air Act.

Perdue’s nomination must now be vetted by the Senate Committee on Agriculture, Nutrition and Forestry, which will examine Perdue and vote on whether or not to recommend him for confirmation by the Senate.

Click here to take Action now to ask your Senator to ensure that climate change deniers like Perdue are not confirmed leading roles in our government.

 


BLM Seeking Input for Public Land Management in NW CA

Monday, January 9th, 2017
By

Full page photo

The Bureau of Land Management will be holding public scoping meetings to seek comments to help shape the Northwest California Resource Management Plan (NCIMP) and Environmental Impact Statement for public land management over the next 15 to 20 years. The plan process is expected to take up to four years to complete and would govern 400,000 acres of public lands and resources in Del Norte, Siskiyou, Shasta, Humboldt, Mendocino, Trinity, Tehama and Butte counties. Several meetings will be held throughout the region, including one in Eureka on Wednesday, January 11th at the Humboldt Bay Aquatic Center at 911 Waterfront Drive from 5 to 7 p.m. Other meetings will be held in Redding, Weaverville, Garberville, Willits, Chico and Yreka.

The planning area includes lands that are comprised of wilderness trails, hunting areas, off-highway riding areas, mountain bike trails and scenic vistas. Many of these lands provide habitat for fish and wildlife, as well as resource uses including mining, timber production, livestock grazing, and firewood collecting. Click here to find background documents that provide information about the planning area.

Specific areas of interest include Elkhorn Ridge, South Fork Eel River, Yolla Bolly, Middle Eel Ishi and Yuki Wilderness Areas as well as Samoa Dunes Recreation Area, Mike Thompson Wildlife Area, Lost Coast Headlands and Ma-l’el Dunes. We are urging our members to come out and advocate for habitat connectivity on these public lands as well as the protection of wildlife and vital ecosystems that could be affected by the plan.

We encourage our members to provide specific landscape-level comments and rationale including how you would like to see these places managed

Click here to comment and or find a meeting near you.


Help Protect Pristine Smith River Waters

Thursday, September 22nd, 2016
By

SmithR by Casey RobertsTake a moment to help safeguard the Wild and Scenic Smith River. Public comments are being accepted by the Oregon Water Resources Department to protect the Smith River watershed in Curry County, Oregon for instream purposes. The classification would provide protection for fish, wildlife and recreation. Click here to send a letter of support for this very important action.


Action Alert: Help Re-open the Klamath National Forest; Broad Closures Hurt Local Communities!

Tuesday, July 5th, 2016
By

Salvage LoggingAll eyes are on the Klamath National Forest as clear cut logging continues within the Westside Project area. The damaging project subsidizes the destruction of spotted owl and salmon habitat above the Klamath River and could result in the “take” of up to 103 northern spotted owls – two percent of the species entire population. The controversial project drew a record 14,000 comments in opposition and the timber sales that were so unattractive the Forest Service reduced their price to $2.50 per log truck load. To make matters worse, Klamath National Forest has issued an unconstitutional closure order.

We have two ways you can help reopen the Klamath National Forest:

1) Click here to send a message to decision-makers

2) Join a rally Friday 7/8 to expose timber welfare on public lands

KNF is shutting the public out of tens of thousands of acres of national forest under the guise of public safety. This is unacceptable. Closing controversial areas surrounding logging operations is used frequently by the Forest Service, to shield itself from scrutiny and attempt to prevent protests. On principle, closures like this one defy the values that set aside national forest land for use—our national forests were established for the enjoyment and benefit of the people; closing them to benefit timber interests is antithetical to that purpose. Closures have a real impact on the rural, river-dependent communities of the Klamath and all people who enjoy the area.

Land that comprises the Klamath National Forest is within Karuk Ancestral Territory, where cultural practitioners frequently gather medicine and basket weaving materials that thrive in post-fire areas, including within the closure area. Other users of the forest have been shut out of popular trail systems leading to the Marble Mountain Wilderness area, and still others are blocked from traveling the road system and collecting firewood during dry summer months. Klamath National Forest is the backyard for many and this closure impacts the ability to recreate and enjoy our public lands.

The Klamath National Forest claims that the closure is necessary to protect public health. This claim falls apart under any scrutiny. If the closure is necessary to protect public health, then why is the Klamath National Forest closing areas where logging is not set to occur? Why is the order in effect for one full year, even though logging is set to wrap up in the fall? If logging is so dangerous, why only close areas which have drawn public protests? And why issue it now, when logging began in March?

The Klamath National Forest has something to hide. Kimberly Baker of the Environmental Protection Information Center has documented failures by the Klamath National Forest to implement key mitigation measures they promised to implement to U.S. Fish and Wildlife Service. Based on these violations, the Klamath National Forest has been put on notice that it will be sued under the Endangered Species Act.

Click here to ask Klamath National Forest to re-open the closure area.

The rally for public lands will be at Grider Creek Campground to raise awareness of industrial logging activities hidden behind locked gates on public lands. Bring a snack for our noon picnic potluck, and a poster to express your love for our public lands. This is a family-friendly public rally, all are encouraged to come.

 

WestsideRallyPoster1


Stop Road Construction in an Inventoried Roadless Area!

Tuesday, December 8th, 2015
By

Bulldozer_CAT_D6M_XL_8705Take action now: The Shasta Trinity National Forest is proposing to build a road through an inventoried roadless area to allow Sierra Pacific Industries Timber Inc. (SPI) to reach and log 80 acres of a forested private inholding! The cost of the road would be borne by the public, subsidizing the logging performed by SPI. EPIC is opposed to the road project and we need your support.

Road construction would come at an extreme environmental cost. According to a retired Forest Service employee familiar with the area, the road would be built on steep and potentially unstable slopes. Public documents state that trees up to 39 inches in diameter would be removed to bulldoze the new road. Species thought to use the area include mountain lions, fishers, ringtail cats, and martens. Nearby streams may also be affected, including wildlife, such as trout, tailed frogs, and yellow-legged frogs. Roadless areas are the largest tracts of intact wild lands outside of wilderness areas and they provide landscape habitat connectivity for wildlife.

Road construction through public land is unnecessary. The parcel in question is not landlocked; SPI can access the parcel through its own lands, however it does not want to spend the money if the Feds would do it for them. Further, SPI routinely utilizes helicopter logging for other areas where it would be too difficult or costly to put in a logging road.

This road is unwarranted and comes at too great of an ecological cost. Tell Forest Supervisor Myers that you don’t support roads for private logging in roadless areas!


Action Alert: Don’t let Congress Silence You and Clear-cut Millions of Acres of our Forests

Friday, December 4th, 2015
By

Willits Rein in Caltrans Slide

TAKE ACTION NOW:  Tell Congress to pass a clean fire suppression funding bill—No anti-environment riders!

Some in Congress are trying, once again, to take way our voice in decisions that affect our lives. The National Environmental Policy Act is the foundational law that gives every citizen the right to be involved in decisions that affect our environment and to stop illegal activities. But some in Congress are chipping away at that law and those rights. Backroom deals are taking place in Congress right now to allow the US Forest Service to log millions of acres of our public forests with little to no public input.

The US House of Representatives passed a very bad bill this year, HR 2647, ironically called the “Resilient Federal Forest Act.” The bill has nothing to do with making forests more resilient. This is a typical trick of the anti-conservation politicians. Those pushing HR 2647 want to use fires as an excuse to clear-cut millions of acres of our National Forests that have experienced fire and to silence critical voices. Let’s be clear: this legislation will not help with better fire management and prevention—the bill is about massive clear-cuts, and taking away our public voice.

Knowing that their extreme anti-environmental rhetoric is toxic, Big Timber is pushing politicians to sneak their bad bill in as a rider to a bill to fix the fire funding chaos. Tell Congress, “No Bad Logging Riders!” Pass a clean bill or no bill.

At the same time, there is strong bipartisan support in Congress and by citizens to fix the chaotic way we fund firefighting. It is clear that we need to find a more sustainable solution to ballooning fire suppression costs, which often far exceed the amount appropriated to the Forest Service for fire suppression. This in turn forces the Forest Service to pull money from other departments, such as recreation and forest health—a process known as “fire borrowing.”

You can stop these bad riders. The action has moved to the back rooms of the US Senate now and your Senators can help stop this.

Click here to take action now!

Or contact your Representatives in Congress directly:

Senator Diane Feinstein

Northern California (San Francisco) Office: (415) 393-0707

Washington, D.C. Office: (202) 224-3841

Email: https://www.feinstein.senate.gov/public/index.cfm/e-mail-me

 

Senator Barbara Boxer

California District Office (Oakland): (510) 286-8537

Washington, D.C. Office: (202) 224-3553

Email: https://www.boxer.senate.gov/contact/shareyourviews.html

Twitter: @SenatorBoxer

 

Congressman Huffman (California 2nd District )

District Office (Eureka): (707) 407-3585

Washington, D.C. Office: (202) 225-5161

Email: https://huffman.house.gov/contact/email-me

Twitter: @RepHuffman

 

Congressman LaMalfa (California 1st District)

District Office (Redding): (530) 223-5898

Washington, D.C. Office: (202) 225-3076

Email: https://lamalfa.house.gov/contact/email-me

Twitter: @RepLaMalfa


BLM Seeks Input on Management of Headwaters Forest Reserve

Friday, August 21st, 2015
By

Headwaters Forest Thinning By Rob DiPernaThe Bureau of Land Management is seeking public input on plans to amend the management plan for the Headwaters Forest Reserve, located just south of Eureka, California.

The 7,742-acre Headwaters Forest Reserve was established in 1999 by the landmark Headwaters Forest Agreement, and in 2004, the BLM adopted a contemporary management plan for the reserve. The 2004 plan articulates nine management objectives for the reserve, foremost among these being preservation of old-growth dependent species and habitats, and the restoration of old-growth and aquatic ecosystems.

While the Headwaters Forest Reserve was originally created for the purpose of protecting old-growth forests and old-growth dependent species and their habitats, only a percentage of the reserve actually contains old-growth forests, with the majority of the reserve containing previously-harvested stands in varying states of regeneration and recovery.

The primary means of returning previously-managed forests towards old-growth characteristics over time in the Headwaters Forest Reserve has been the use of prescribed thinning. Currently, the BLM employs a method known as “lop-and-scatter,” where forest stands are thinned by cutting small-diameter trees in young, dense regenerating forest stands, and the resulting material is scattered on the forest floor. No trees are removed from the forest.

The purpose of these thinning treatments is to move previously-harvested stands towards an old-growth-like state over time, consistent with the reserve’s management goals. Previously-harvested stands in the reserve represent a wide range of forest conditions which are in varying states of regeneration and recovery. Regenerating forests often grow back much thicker and denser than the original forest stand condition. As a result, regenerating previously-harvested forests often contain too many trees, too tightly packed together. This results in forest stands which are highly homogenized and simplified, leading to unhealthy conditions for wildlife, and the forest itself.

The BLM is now seeking to revise its 2004 management plan to allow for greater flexibility in the methods available for restoration of previously-harvested forest stands in the reserve. Possible approaches could include re-entry of previously thinned stands or even the implementation of prescribed burning in previously-managed stands to thin trees and manage fuel loads.

The BLM will hold a public meeting to take input on potential revisions to the 2004 management plan on Tuesday, September 1st, from 6-7:30 p.m. at the BLM offices in Arcata, located at 1695 Heindon Road in Arcata. EPIC encourages interested members of the public to attend.


Don’t Trash our State Park Lands—Protect Mendocino County Forests

Monday, August 10th, 2015
By

Mendocino_Pygmy_Forest_in_Van_Damme_State_Park_2Wikipedia commonsTake Action: Would you trade rare state park forestland for a defunct waste transfer station? Neither would we. Yet, that’s what the County of Mendocino and the City of Fort Bragg are poised to do.

In a complicated three-way land swap proposal, 12.6 acres of rare Russian Gulch State Parks forestland would be transferred to Jackson Demonstration State Forest, which would then transfer 17 acres of its property to the city and county for development of the Mendocino Central Coast Waste Transfer Station. State Parks would then have the option of acquiring 60 acres of county and city property, formerly the site of the Caspar Landfill and waste transfer station.

How is this possible? The framework of this land swap was created by legislation brought forward by then-Assemblymen Wesley Chesbro. The proposed Central Coast Waste Transfer Station is currently undergoing environmental review. Numerous groups, citizens, and even public agencies have submitted comments expressing concerns about the proposed land swap and the adverse environmental consequences of the project, citing inadequate treatment of potential environmental impacts and inadequate consideration of other feasible alternatives.

So, what’s at stake? The 12.6 acres of Russian Gulch State Parks property currently proposed as part of the swap contain rare and important forest habitats, including Mendocino Pygmy Cypress Woodlands, Northern Bishop Pine forests, and also serve as important habitat for threatened and endangered species such as the marbled murrelet. These lands would be transferred to Jackson Demonstration State Forest, which is dedicated to experimental logging of its forestlands for sustainable wood production. Meanwhile, state parks would get in return lands that were once a landfill and waste transfer station.

Fortunately, there is still time to stop this ill-conceived plan. On August 17, 2015, the city and county will hold a hearing on whether or not to certify the Final Environmental Impact Report (FEIR) for the project. The FEIR, like the draft before it, is fatally flawed and should not be the basis for allowing the project to go forward.

Click here to take action now to tell the City of Fort Bragg and the Mendocino County Board of Supervisors that you value rare forests!


Take Action: Klamath River Runs Brown!

Tuesday, July 21st, 2015
By
Klamath River Near Mouth 7.13.15 by Mark Harris

Near the mouth of the Klamath River. July 13, 2015. Photo Courtesy of Mark Harris

Take Action Now to stop Westside: A few short but intense rain storms hit the 2014 fire areas on the Klamath National Forest causing massive sediment events that turned the mighty Klamath and Salmon River systems muddy and brown. On July 5th, 7th and 12th rainstorms brought over an inch of rain in less than an hour causing road damage, intense debris torrents with slurries of mud, rock, water and trees to sliding for miles, filling in pools and creeks that serve as some of the best salmon spawning habitat. These watersheds are located within the same steep and unstable hillsides that are targeted for logging in the Westside project.

Salmon

Juvenile and adult salmon struggle to survive in oxygen-depleted lethal water temperatures with high rates of disease and algae. The storm events greatly increased turbidity and lowered oxygen levels in the water for nearly two weeks. Massive amounts of sediment dumped into some of the most important spawning habitat and cool water refuges. There appears to be considerable reduction in size, volume, and depth of pools. It is uncertain how salmon and other aquatic life will survive this onslaught of impacts, especially with the hottest summer temperatures soon to come and the proposed clearcutting and logging activities.

Coho salmon are listed as threatened under the Endangered Species Act. There are 101 miles of coho Critical Habitat in the project area. This includes the rivers affected by recent storms, Klamath and North Fork Salmon Rivers and many of the cool water tributaries vital for fish survival, including: Grider, Beaver, Elk, South Russian Creeks and Whites Gulch.

Roads

Road systems were blocked and sliding mud, trees, rock and debris clogged dozens of culverts and ditches. Thousands of cubic yards of sediment came down hills and hundreds have already been cleared from roads with heavy machinery, but much more debris continues to be suspended on the hillsides waiting for the next rain event.

Click here for before and after photos of road work in the Walker Creek drainage. At least 24 different road locations on roads 46N64, 46N65, and 46N67 were blocked by mud, rock, and debris flows, and numerous culvert inlets are still buried under mud and rocks.

Roads are the leading contributor of sediment into our creeks and rivers. There are over 950 “legacy” sites, which are chronic sources of sediment in the Westside project area. The Klamath National Forest is proposing to treat only 150 legacy sites in one watershed, leaving over 800 sites untreated.

The Forest Service proposes to open miles of decommissioned and self-decommissioned roads. These roads also contain legacy sites. For instance, road 16N41 up Little Elk Creek is approximately 2 miles long and completely grown over, which would require intense forest clearing and reconstruction just upstream of coho Critical Habitat. Further, there are over 280 miles of level 2 roads, passable by high clearance vehicles only, which would require reconstruction in order to accommodate for the proposed use by heavy machinery and large trucks. These are few of many road issues that were not adequately considered, addressed or disclosed.

The Past the Future and Westside

As temperatures and extinction rates soar globally and climate change brings more extreme weather, like summer rainstorms – our water, wildlife, salmon and wild places need extra protection. Low to no snow pack and higher temperatures means increasingly low and warm summer flows in our rivers. Extreme wind, rain and fire leave behind fragile ecosystems susceptible to severe damage from industrial activities on the landscape.

The Klamath Mountains are some of the steepest and most erodible hillsides on the west coast. For decades we have witnessed and documented major impacts to our watersheds during large storm events. The decomposed granitic soils in the Westside fire areas will slide downhill and into our rivers. The entire watersheds of Grider and Walker are unstable, which is where the highest concentration of Westside units are proposed!

Click here now to tell Patty Grantham to stay off geologically unstable slopes, disclose the extreme amount of roadwork proposed, to learn from the past and allow for the natural recovery of our fragile and fire dependent watersheds.

Rivers and Creeks up Close 

A few short and intense summer storms brought massive debris flows choking the Klamath and Salmon Rivers and many of its tributaries with thick sediment and mud. The Klamath Mountains are some of the steepest and most erodible lands on the west coast. The rivers listed below support a suffering salmon population- all are proposed for clearcut logging by the Klamath National Forest in the Westside project and all are listed as impaired under the Clean Water Act, mostly from temperature and sediment. Many of them are supposed to be federally protected designated or eligible for designation as Wild and Scenic Rivers.

Klamath River

The Wild and Scenic Klamath River (Karuk: Ishkêesh,‪ Klamath: Koke,‪ Yurok: Hehlkeek ‘We-Roy,‪ Hupa: k’ina’-tahxw-hun’) flows 263 miles southwest from Oregon and northern California, cutting through the Cascade Range to empty into the Pacific Ocean. It is listed as impaired under the Clean Water Act for Nutrients, Organic Enrichment/Low Dissolved Oxygen, Temperature and Microcystin.

It was once the third most productive salmon-bearing river system in the country. Today, thanks to habitat blocking dams, logging, mining, grazing, agriculture, poor water quality and too little water left in the river, the once abundant Klamath salmon runs have now been reduced to less than 10% of their historic size. Anadromous species present in the Klamath River basin below Iron Gate Dam include Chinook, coho, pink, and chum salmon, steelhead and coastal cutthroat trout, eulachon, white and green sturgeon, and Pacific lamprey. Some species, such as coho salmon, are now in such low numbers in the Klamath River that they are listed under the Federal Endangered Species Act (ESA).

North Fork Salmon River

Deeply incised canyons, rugged terrain and highly erodible soils characterize the Salmon River watershed, comprised of two forks, the North Fork and the South Fork to form the mainstem. The free flowing river is one of the largest most pristine watersheds in the Klamath River system, although it is listed under the Clean Water Act as a 303(d) impaired water body for high temperatures. The Wild and Scenic Salmon River provides over 175 miles of anadromous fish habitat and retains the only viable population of spring Chinook salmon and retains the last completely wild salmon and steelhead runs in the in the Klamath watershed. The Salmon River offers some of the best habitat on the west coast for salmon, steelhead, green sturgeon, rainbow trout, Pacific lamprey, and other fish. It is home to one of the most sought after world-class whitewater rafting trips in the country. It combines lush coastal scenery with emerald green waters, steep granite gorges and numerous waterfalls.

The North Fork Salmon River, containing highly erodible granitic soils is steep to very steep. The globally significant carbon dense forests provide important wildlife habitat connectivity, particularly the released roadless areas within the Westside project area. With the combination of unique geology, climate and biology the North Fork Salmon River watershed supports populations of deer, elk, black bear, mountain lion and is home to many rare species, including Pacific fishers and pine martens. The North Fork Watershed Analysis notes that, “the watershed has habitat critical to wildlife and fish species that are listed or petitioned for listing through the Endangered Species Act. Some of these habitat features may be at risk and need protection or enhancement. Older, late successional forest stands and anadromous fish habitat are considered some of the most important features within the watershed.”

This watershed has a total of 1,035 miles of roads, and over 73 stream crossings. These roads—along with timber harvesting in this area—have increased landslide potential, and have therefore increased the potential for negative impacts on the streams. Logging in this area has also led to a decrease in shade along the entire North Fork of the Salmon River. As a result, the Salmon River is now listed under the 303(d) Clean Water Act for temperature. This increase in water temperature has resulted in fish kills of Chinook salmon and steelhead during drought conditions, such as in the years 1994 and 2014.

South Russian Creek and Music

South Russian Creek, fed from the Russian Wilderness, is eligible for designation as a Wild and Scenic River and is recognized for its magnificent stand of old growth Engleman Spruce and for pristine water quality. Music Creek is a tributary to South Russian Creek that leads to the Russian Wilderness and the Pacific Crest Trail. Both of these watersheds are comprised of highly erodible decomposed granitic soils and have seen huge landslides and road impacts from past storms. In August, 1996 a thunderstorm triggered a debris torrent that scoured 2.6 miles of stream in Music Creek. The resulting plume of sediment impacted the North Fork and Mainstem of the Salmon River for several weeks.

Whites Gulch

Whites Gulch is a tributary to the North Fork Salmon. It is critical cold water refugia and spawning habitat for juvenile and adult Coho salmon, spring and fall Chinook salmon and steelhead trout. Whites Gulch watershed contains Critical Habitat for Coho salmon and the Northern spotted owl. This watershed is also home to one of the four Northern goshawks nest areas that would have a high risk of abandonment because of the Westside clearcutting units.

The outer ridges were used extensively for fire suppression operations during the 2014 fires and the road system, with its many sediment sources, also saw a large amount of traffic from heavy trucks.

In October 2008, the Salmon River Restoration Council, in cooperation with the California Department of Fish and Game and NOAA Open Rivers Initiative, removed two dams from the upstream reaches of Whites Gulch. Both of the dams were remnants of the historic mining activity that had occurred within the watershed. The removal of the dams and the subsequent removal of the culvert barrier on Whites Gulch Road, restored access to 3.5 miles of refugia, rearing and spawning habitat in Whites Gulch.

 

Grider Creek/ No Name Creek (Grider Tributary)

Upper Grider Creek watershed contains one of the most important roadless areas, which provides a vital north to south wildlife corridor that connects the Marble Mountain Wilderness with the Siskiyou Crest and Red Buttes Wilderness. The entire watershed contains the largest expanse of geologically unstable areas of the Kla math National Forest and is where the highest concentration of clearcut units in the Westside project are proposed.

Grider Creek is a key watershed, meaning that it contains crucial for salmon survival. It provides spawning, rearing, and holding habitat for Steelhead, Coho, and Chinook salmon. In fact, the mouth of Grider Creek used to provide one of the largest and most important cold water refuge areas on the Klamath River. Unfortunately, the storm of 1997 raised water temperatures in this area and degraded its function as a cold refuge.

It is eligible for designation as a Wild and Scenic River recognized for its undisturbed old growth mixed conifer forests, high water quality and for wildlife because bald eagles and peregrine falcons nest there. These eagles would have a high risk of abandoning their nest areas because the Westside project would decimate the area.

While Grider Creek still has large areas with minimal human activity, it is clear that managed areas of the creek are being degraded. Areas that previously provided the connectivity necessary for the wellbeing of many sensitive species in the area have turned into patchy forests unusable by many animals. If human activity increases throughout this pristine area, habitats will quickly diminish and already threatened species will suffer.

 

Walker Creek

Walker Creek provides high quality water to the Middle Klamath River and acts as a thermal refuge for anadromous salmonids during warm months. Additionally, Walker Creek provides spawning, rearing, and holding habitat for fall and spring-run Chinook salmon, winter and summer-run steelhead and threatened Coho salmon.

The Walker Creek area contains many large, active earthflow landslides and with Grider, contains the largest expanse of geologically unstable areas of the Klamath National Forest and is where the highest concentration of clearcut units in the Westside project are proposed. This along with strong seasonal storms makes this creek particularly susceptible to large amounts of sedimentation. Past management of this area has not been successful in combating this unique feature, and has made stream sedimentation worse. These high levels of sedimentation can have devastating effects on sensitive aquatic species, and therefore must be properly controlled in order for the creek and the surrounding habitat to thrive.

Elk Creek 

The Elk Creek watershed is 60,780 acres of steep slopes and large dispersed benches. It is the municipal water supply for the town of Happy Camp. This watershed provides 51.6 miles of habitat for Steelhead, Coho, and Chinook salmon, Pacific lamprey, Klamath small-scale sucker, and other native fish species. In fact, Elk Creek provides one of highest quality spawning and rearing habitats for Coho salmon in the Middle Klamath River. Its low water temperature also makes Elk Creek an important thermal refuge for many aquatic species during warm periods.

In addition to aquatic species, this watershed is home to many threatened, endangered, and sensitive species listed under the Endangered Species Act. These species include Northern spotted owls, marbled murrelets, bald eagles, and peregrine falcons. Other sensitive species include goshawks, willow flycatchers, fishers, western pond turtles, great grey owls, and martens.

Elk Creek is eligible for designation as a Wild and Scenic River and is recognized for its fisheres, geologic and wildlife values because the Siskiyou Mountains Salamander has been found there.

Logging and road building activities throughout the watershed have disturbed habitat crucial to the survival of both aquatic and terrestrial species. For example, 9,833 acres of Elk Creek watershed have experienced harvest activity over the last 40 years, 7,445 of which were clear cuts or other types of regeneration harvest. This, along with other activities has caused the creek to exceed the Mass Wasting threshold of concern, which indicates an increased risk for hillslope sediment production. It has also led this important thermal refuge to range from “properly functioning” to “at risk” for proper stream temperatures. Once a cool water safe haven for aquatic species, increased water temperatures throughout this creek may lead to increased wildlife mortality. And while storm events and landslides are natural disturbances throughout this watershed, road building, timber harvesting, and other human activities have made it so storm events have much higher impacts on downstream aquatic resources than they naturally would.

The current goals for the Elk Creek watershed include maintaining and restoring the following: spatial and temporal connectivity, physical integrity of the aquatic system, water quality necessary to support healthy ecosystems, and sediment regimes in which aquatic systems evolved. In order to meet these goals and protect important wildlife throughout Elk Creek, it is critical that human activity is kept to a minimum.

Beaver Creek

Beaver Creek after storm. July 15, 2015. Photo courtesy of Bruce Harlow

Beaver Creek after storm. July 15, 2015. Photo courtesy of Bruce Harlow

The Beaver Creek watershed is checkerboarded with forests used as industrial timberlands. Extreme logging has taken place since the 2014 fires. Logging operations were still active up to the time of these recent storms. The Klamath National Forest has had the sense to cancel commercial logging in the watershed in the Westside project.

Beaver Creek is an important tributary to the Klamath River. This watershed makes up approximately 70,000 acres of steep sloped habitat dominated by mixed conifer and true fir forests. Beaver Creek is home to several sensitive species such as Northern spotted owls (threatened under the Endangered Species Act (ESA)), northern goshawks, martens, fishers, willow flycatchers, Siskiyou mountain salamanders, and great grey owls. Additionally, Steelhead, Coho, and Chinook salmon are dependent on Beaver Creek habitat for spawning, rearing, and holding for adult and juvenile fish. Due to its ecological importance, this watershed includes designated Special Interest Areas, and Late-Seral Reserve land allocation areas. These areas provide important habitat for sensitive species, and help protect the integrity of this rich watershed.

Over the years the quality of the Beaver Creek has been greatly degraded. Roads, mainly created to access timber harvest areas, are the current largest impact on the drainage. Approximately 440 miles of roads and an unknown amount of skid trails now occur within the drainage. These roads, as well as timber harvesting, has negatively impacted the watershed and degraded high quality habitat in many ways. Accelerated erosion associated with roads and logging leads to extremely high levels of stream sedimentation, which in turn results in loss of aquatic habitat for many species. In fact, Beaver Creek is on the 303(d) Clean Water Act list as impaired for sediment, and it has been reported that the likelihood of aquatic habitat being damaged due to debris is likely, and may influence the surrounding habitat for as long as ten years.

Roads and timber harvest also decrease connectivity and makes it more difficult for wildlife to easily move across the landscape. Connectivity is extremely fragmented but important for many species in this area, such as the spotted owl. There are 20 known spotted owl activity centers distributed throughout the Beaver Creek watershed. Without sufficient connectivity throughout the landscape, these owls and other late-seral dependent species are at an increased risk of endangerment.

The forests and rivers need your voice: Click here now to tell Patty Grantham to reconsider post-fire logging sensitive watersheds in the Westside proposal!


Action Alert to Protect the Wild & Scenic Smith River from Strip Mining

Wednesday, July 15th, 2015
By

Smith River by Amber Shelton SM

Take Action Now: Mining companies want to develop large-sale industrial nickel strip mines in the headwaters of the Smith, Illinois and Pistol Rivers. Last year, a mining permit was denied by Oregon Department of Water Resources, but a Canadian based nickel mining company has appealed the decision. Unfortunately, the outdated mining law of 1872 prioritizes mining over all other land uses, and it is possible that the mining industry could have their way with these world class rivers if additional measures are not taken to protect them.

We need your help to ask the Obama administration for maximum temporary protection by withdrawing these rivers from mining while Congress considers the Southwest Oregon Watershed and Salmon Protection Act, which has been proposed by Senators Wyden and Merkley and Representative DeFazio of Oregon, and Representative Huffman of California.

Nickle strip mines would negatively impact some of the highest quality rivers left in the United States, and the native fish and wildlife that depend on them. These pristine watersheds deserve protections from mining operations, haul roads, cesspools, and nickel processing facilities.

Help us keep our wild and scenic rivers pristine. The Interior Department is taking comments on the proposed mineral withdrawal now. Please click here to send a letter of support to protect our clear, emerald waters from industrial mining operations.

 


Action Alert to Ban Bobcat Trapping in California

Wednesday, July 8th, 2015
By

bobcat-kitten flikrTake Action Now: Bobcats are still being trapped throughout California, and their pelts are sold in the international fur trade market. Recent spikes in demand from countries like Russia and China have increased prices for bobcat pelts, resulting in a boom in bobcat trapping throughout the State of California.

On October 11 2013, the Governor approved the Bobcat Protection Act of 2013 (AB1213), which directs the California Fish and Game Commission to increase bobcat protections, and now the Commission is considering two options for bobcat trapping restrictions: Option 1 proposes a partial closure of the state to bobcat trapping by establishing closure boundaries around protected areas; and Option 2, which EPIC supports, would implement a complete ban on commercial trapping of bobcats throughout California.

The Commission is slated to make a decision to adopt regulations at their August 5th hearing, which will be held at 8am at the River Lodge at 1800 Riverwalk Drive in Fortuna California.  EPIC will join bobcat advocates from around the state to rally for the protection of bobcats at 7:30am before the hearing.

Two days before the hearing, on Monday, August 3rd from 6-8pm, EPIC and our allies will host a teach-in and poster making session in the Arts & Crafts Room at the Arcata Community Center. 

The trapping industry  has openly opposed the state wide ban, and will likely send a spokesperson to speak at the August 5th hearing in favor of bobcat trapping. This is why it is important for bobcat allies to make a presence and show the Fish and Game Commission that the overwhelming majority of people are in favor of a statewide ban.  The law on the books allows bobcat trapping season to take place between November 24 and January 31, and anyone possessing an easy-to-obtain trappers’ license can trap as many bobcats as desired until a statewide total of 14,400 bobcats are killed for the season. The nearly unrestricted statewide cap is based on out of date population estimates from the 1970’s of 72,000 individuals. This baseline number is deeply troublesome. Over thirty years ago, in 1982, a court found that the science behind the 1970’s population estimate was too flawed to qualify as the basis for a bobcat management program. Yet, no additional surveys have been conducted since.

Bobcats are shy creatures that do not threaten public safety, and while no one knows what the current bobcat populations are, there is anecdotal evidence that trapping has greatly diminished localized bobcat populations, throwing ecosystems off kilter. In fact, the state legislature recognized that bobcats are important apex predators that play a significant role in maintaining a healthy ecosystem, reducing rodent populations and preying on populations of many animals that are considered “nuisance” animals such as raccoons, opossums and skunks. Bobcat trapping hurts more than bobcats; it hurts our forests and fragile ecosystems.

In addition to protecting bobcats for ecological reasons, there is a moral obligation to end the cruel and inhumane methods of killing bobcats. Because their pelts are worth more without bullet holes or other marks, trappers often strangle, stomp or bludgeon them to death. California should lead the nation and outlaw this cruel and harmful practice.
Click here to take action now!

P.S. The last time we attended a Fish and Game Commission hearing in Fortuna, we helped sway the Commission to protect gray wolves in California and with your help, we can do this again for the bobcats.

 


State Wildlife Action Plan Update & Alert

Monday, June 22nd, 2015
By

Photo Credit: USFWS

Take Action: Advocate for a strong conservation legacy of California’s imperiled wildlife by asking the California Department of Fish and Wildlife (CDFW) to prioritize the protection of species in the North Coast Klamath Province and Pacific Northwest conifer forests.

CDFW is updating the State Wildlife Action Plan (SWAP). The public review and comment period on the draft is open until July 2, 2015. California is the wildlife state, harboring more species and endemic plants and animals than any other state in the nation and it is the most populous, which makes this plan no small task.

The SWAP is a “comprehensive plan for conserving the state’s fish and wildlife and their vital, natural habitats for future generations.” Rather than concentrate on single species, the CDFW targets conservation through defined provinces and different natural habitat types. It includes the consideration of climate change and revises the list for the Species of Greatest Conservation Need and also reiterates the need to promote partnerships with federal, state and local agencies, tribes and non-governmental organizations. The Draft plan outlines goals, key ecological attributes, objectives, pressures and threats, strategies, companion plans, adaptive management and monitoring.

There are over 1,000 species of invertebrates, amphibians, reptiles, fish, birds, mammals and plants that are considered as Species of Greatest Conservation Need! The list includes 414 fish and wildlife species. National forests account for 15.8 million acres (48%) and other public lands account for 4.2 million acres (13%) of the golden state.

The North Coast and Klamath Province encompasses 14 million acres and the vegetation consists of predominantly conifer and mixed conifer forests.  Logging is one of the pressures outlined in the Draft plan. Forestry is the most widespread land use consisting of 1.9 million acres of privately owned timberlands mostly in the coastal portion and 4.8 million acres of national forests and public land managed by the US Forest Service and the Bureau of Land Management. Other pressures in our province include agriculture, dams and water management/use, housing and urban areas, invasive plants/animals, fire and fire suppression, livestock, farming and ranching and climate change.

Strategies and objectives, in the Draft plan, to conserve wildlife in Pacific Northwest Conifer Forests are: data collection and analysis, outreach and education, management of invasive species, advocating for wildlife-friendly fire management, management planning to ensure the conservation of redwood habitat, improving fire management plans and influencing management of federal lands with partnerships.

While much consideration has gone into the SWAP Draft Update there is a need to prioritize and strengthen working relationships between CDFW and the US Forest Service. Because of increasing pressures and dwindling populations of threatened and endangered species there is also a need to prioritize the conservation of old-growth and mature forest habitat throughout the state, primarily within the Pacific Northwest.

Please take action to ensure a strong conservation legacy for California’s people and wildlife!

Click here for more information or to read a copy of the SWAP Draft Update


State of the Mattole

Thursday, May 21st, 2015
By
Fieldtrip to Mattole THP's with HRC

Fieldtrip to Mattole THP’s with HRC

Nestled in a remote valley that drains to California’s famous Lost Coast, the Mattole River watershed spans from its headwaters near Whitethorn down to the sea where it terminates at Petrolia. The Mattole watershed is a peculiar Humboldt County coastal watershed in that its forests are largely composed of a mix of fir and hardwoods, rather than being dominated by the giant and majestic redwoods found elsewhere in the region.

Pre-European settlement, the forests of the Mattole appear to have been left unmanaged, while grass lands were burned to maintain oak acorn harvests, and to manage conifer encroachment.

Post-European forest management activities and old-growth logging in the Mattole began in earnest after World War II. By 1988, approximately ninety percent of the original old-growth forest had been logged.

In the North Branch of the North Fork of the Mattole, much of the remaining old growth (approximately 48 percent), is still in privately-held industrial timberland ownership. The majority of this property is held by Humboldt Redwood Company, the successor to the Pacific Lumber Company.

While forest conservation activism in Humboldt County in the 1980’s and 1990’s was focused on the redwood region, the old-growth forests of the Mattole on private lands remained largely at risk. With the advent of the Headwaters Forest Agreement in 1999, the Mattole Valley old-growth on the Pacific Lumber Company lands became fair game for logging. The old-growth in the North Branch of the North Fork of the Mattole was considered to be a so-called “sacrifice zone.”

Beginning in 1999, the Pacific Lumber Company aggressively targeted the old-growth conifer forests of the Mattole for clearcut logging. Citizen’s lawsuits and direct actions in the forest were able to slow, but not fully prevent the logging of the old-growth in the Mattole by the Pacific Lumber Company.

After Pacific Lumber went bankrupt in 2008, all PL land and assets were transferred to Mendocino Redwood Company, and in 2012, the newly named Humboldt Redwood Company began to prepare and file logging plans in forest stands thought to be old-growth, or at the very least so-called “primary forests” i.e. areas that have never been managed for timber production. Once again, citizen’s mobilization and direct action ensued. In response to this, Humboldt Redwood Company has voluntarily ceased timber operations in these sensitive forest stands, and is now working with EPIC and other members of the community to determine the most appropriate conservation and management measures within these old-growth and primary forest stands.

While Humboldt Redwood Company touts commitment to protecting old-growth trees and old-growth stands, appropriate management activities in the primary forest stands are still a subject of debate. EPIC will continue to monitor Humboldt Redwood Company’s logging activities in the Mattole, and work to ensure best conservation and management practices are in place to protect the unique Mattole watershed.


The Westside Story

Wednesday, April 15th, 2015
By

from_BR_Lookout_1314

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

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

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

OVERVIEW

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

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

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

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

7,900 acres of prep and plant aka: plantations

75 watersheds impacted

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

14 new stream crossings

152 new landings!

75 existing landings! That may require expansion

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

Whites Russian Fire

Whites Russian Fire

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

North Fork Salmon River

North Fork Salmon River

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

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

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

WESTSIDE WILDLIFE

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

Pacific Fisher

Pacific-Fisher_Bethany-Weeks-300x200

Photo Credit: USFWS

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

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

Bald Eagle

Photo Credit: USFWS

Photo Credit: USFWS

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

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

Northern Spotted Owl

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

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

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

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

Northern Goshawk

northern goshawk FWS

Photo Credit: USFWS

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

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

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

Siskiyou Mountains Salamander

Siskiyou Mountain Salamander photo credit: USFWS

Photo Credit: USFWS

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

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

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

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

Scott Bar Salamander

Salamander Plethodon Photo credit: USFWS

Photo Credit: USFWS

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

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

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

Photo credit: Oregon Dept. of Wildlife

Photo credit: Oregon Dept. of Wildlife

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

Willow Fly Catcher mapWillow Flycatcher

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

Western Bumble Bee

Photo Credit: USFWS

Photo Credit: USFWS

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

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

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

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

Franklin’s Bumble Bee

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

Peregrine Falcon

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

Snag Dependent Species

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

White-headed Woodpecker Photo Credit: USFWS

Photo Credit: USFWS

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

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

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

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

Hardwood Dependent Species

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

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

Neo-tropical Migratory Birds

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

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

American Marten

Photo Credit: USFWS

Photo Credit: USFWS

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

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

Wolverine

Wolverine Photo Credit: NPS

Photo Credit: NPS

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

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

WILD SALMON AND AQUATIC SPECIES

Elk Creek

Elk Creek

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

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

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

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

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

Wet Weather Logging in Klamath National Forest October 2014

Wet Weather Logging in Klamath National Forest October 2014

Roads, Landings and Water Drafting

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

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

Cumulative Effects

Whites Gulch

Whites Gulch

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

Management Indicator Species (MIS)

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

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

WATER QUALITY

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

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

Risk to Channel Morphology

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

Risk of Sediment Regime Alteration

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

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

Risk of Temperature Regime Alteration

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

Trend of Riparian Function

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

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

Key Watersheds and the Aquatic Conservation Strategy

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

Northwest Forest Plan (NFP) B-18

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

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

WILD AND SCENIC RIVERS

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

The project proposes:

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

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

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

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

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

WILD PLACES

Late Successional Reserves

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

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

Live Trees

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

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

Roadless Areas

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

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

Klamath-Siskiyou Bioregion

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

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

VISUAL QUALITY

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

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

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

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

SOILS  

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

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

Soil Stability

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

Surface Organic Matter

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

Soil Organic Matter

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

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

Soil Structure

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

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

GEOLOGY  

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

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

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

BOTANY

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

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

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

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

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

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

Sensitive Vascular Plants

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

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

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

Sensitive Fungi, Lichens and Bryophytes

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

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

Survey and Manage Plant Species

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

Survey and Manage Bryophytes 

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

Survey and Manage Fungi 

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

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

Non-native Invasive Species

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

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

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

CULTURAL RESOURCES

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

RANGE 

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

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

SOCIAL, ECONOMIC AND COMMUNITY IMPACTS 

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

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

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

CLIMATE CHANGE

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

Region 5 Ecological Restoration Implementation Plan

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

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

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

NATURAL REFORESTATION AND RESTORATION

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

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

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

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

CONCLUSIONS

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

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

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

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

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


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

Wednesday, March 25th, 2015
By
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.


Dear Santa: Save our Beautiful Wild Rivers from Strip Mining

Friday, December 12th, 2014
By

Santa and river image for alertTake Action: All we want for Christmas is a mineral withdrawal

This Christmas, please join us in asking Santa for something extra special: a mineral withdrawal in southwest Oregon that benefits California too!

Here’s what’s at stake:

  • the purest of waters and wildest of rivers;
  • a stronghold of native salmon, steelhead, and cutthroat trout; and
  • a treasure trove of botanical diversity with one of the highest concentrations of rare plants in North America.

Mining companies want to develop nickel strip mines in pristine, wild lands in southwest Oregon, including the headwaters of California’s famed Smith River. Senators Wyden and Merkley and Congressman DeFazio have long supported withdrawing the fragile watersheds of Rough and Ready and Baldface creeks (headwaters of the Wild and Scenic Illinois and North Fork Smith rivers) from mining, and we’ve urged them to add Hunter Creek’s headwaters—equally fragile—to their roster. Congressman Huffman has joined them to protect the Wild and Scenic Smith River.

There’s not much time. Immediate introduction of legislation to withdraw the area from mining is needed. This will protect these priceless federal public lands by closing them to mining unless there’s a valid existing right.

It’s our best way to protect the crystal clear, salmon-studded waters of the wild rivers coast from damaging pollution.

Take Action: Urge the Oregon and California delegation to introduce legislation to protect this wild and wonderful area from mining!

 

 

EPIC is a member of the Kalmiopsis Rivers group, we would like to thank them for providing the content of this action alert.

EPIC Arts Arcata and Membership Mixer December 12

Sunday, December 7th, 2014
By

EPIC Membership SlideCelebrate Arts Alive at the EPIC office on Friday, December 12th from 6-9pm! Meet our Board and Staff and hear about our exciting new programs for 2015. Local artist and film-maker, Thomas Dunklin will feature his photography that focuses on local fisheries. At 7pm we will be presenting a slideshow outlining recent accomplishments, and new projects we will undertake in the coming year. 

We will offer art, wine, snacks and a raffle prize, so come visit our workspace, listen to some music, check out local photography and connect with the Northern Humboldt forest protection community at 145 G Street, Suite A in Arcata!

Click here to invite your friends on Facebook!


EPIC in Review

Monday, November 24th, 2014
By
20140201_154619

Redwood Tree Sit

As usual, EPIC is busy upholding environmental laws both at home, and across the nation. Over the past few months our staff has advocated for the protection of old growth in the Klamath National Forest, opposed the Federal Drought Bill and bad forestry bills, requested endangered species protections for monarch butterflies, requested action to protect families from harmful pesticides and submitted petitions on behalf of tens of thousands of people to protect wildlife and wild places. This list of documents is a sample of the many ways we engage with agencies and elected officials to make this world a better place, one issue at a time. Thank you to all of our members who take the time to make individual comments on these issues and for getting engaged with environmental protection on a deeper level. We are in regular contact with officials and it is clear that the agencies are listening and our comments are making a difference in the management of our natural resources.

Westside Scoping Comments – EPIC submitted substantive scoping comments to the Klamath National Forest on November 14, 2014.  The post-fire project proposes logging over 40,000 acres, of which 20,000 acres are within Late Successional Reserves.  Logging is also proposed in Wild and Scenic River Corridors, within watersheds critical for salmon recovery and within vital wildlife corridors.

Jess Petition – EPIC submitted 1,143 petition signatures to oppose logging old growth trees and vast forest canopy removal proposed on the North Fork Salmon River within the Klamath National Forest.  Thank you for taking action.

Sage Grouse Rider Letter – Supporting an amendment to strike the Sage-Grouse Endangerment Rider from the 2015 appropriations bill, which would delay federal protection for sage-grouse, and threaten efforts to protect their habitat.

Letter Opposing Senator Feinstein & Representative McCarthy’s “Federal Drought Bill” –  The bill directly undermines key statutory protections for fish, wildlife and groundwater protection, including water transfers from wildlife refuges and critical fish habitat of North Coast rivers.

Omnibus Letter – Encouraging committee on appropriations to pass a spending bill for the remainder of fiscal year 2015 that is free of policy riders that put polluting interests ahead of our air, water, lands, wildlife, public health and climate.

Nongame Fur Bearing Hunting Contest Comments EPIC submitted a petition containing 15,787 signatures to the California Fish and Game Commission in support of its proposed rulemaking to end inducements for hunting contests for nongame fur-bearing mammals.

Monarch Support Letter – Requesting support for that legal petition and protecting the monarch butterfly as a threatened species under the Endangered Species Act.

Letter to Governor Brown – Requesting that he take significant steps to protect California families from pesticides that have devastating consequences for children and their families.

Coalition Letter Opposing Bad Forestry Bills – The National Forest Jobs and Management Act of 2014 and the Restoring Healthy Forests for Healthy Communities Act pose a serious threat to environmental stewardship, public involvement, wildlife conservation and the rule of law in our National Forests.

Non-profit Letter to Water Board – Supporting the restoration of freshwater flows from the San Joaquin River and its tributaries to the estuary.

Letter to Chief of the U.S. Forest Service –  Supporting the Forest Service’s Community Forest and Open Space Conservation Program.

Organization Comments on “Effective Use of Programmatic NEPA Reviews” – Urging the Council to add clarification and direction in the final guidance making it clear that large-scale programmatic reviews without additional site-specific reviews are insufficient in the vast majority of cases.

Coalition Letter to Central Valley Regional Water Quality Control Board Regarding Land Retirement Benefits to Grasslands Bypass Project – Encouraging the retirement of 9,200 acres of irrigated land in the San Joaquin Delta, which would result in an estimated reduction of 14,000 acre feet of drainage, 92,000 tons of salt, 8,100 pounds of selenium and 282,000 pounds of boron discharges to aquifers and groundwater. This land retirement project would save water, prevent selenium contamination and reduce further impacts to endangered species.

Comment Letter to Forest Service Regarding  Proposed Rule Governing Use by Over-Snow Vehicles -Rrequesting that the final regulation protect resources, promote safety and minimize conflicts between other uses.

Passenger Pigeon Proclamation Request Letter – Requesting a presidential proclamation commemorating the centenary of the extinction of the passenger pigeon and reminding Americans of the need to be continued good stewards of wildlife and nature.