Northern Spotted Owl

Base Camp Reflections

Thursday, June 15th, 2017
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Over the weekend, EPIC staff and volunteers and ventured out into the remote wildlands of the Klamath Mountains for EPIC Base Camp; a three day “groundtruthing” training that focused on data gathering to help reform grazing and timber sale practices on public lands. Outdated laws allow for private timber companies and ranchers to use public lands for private profit, and the fees collected for these destructive activities do not cover the costs of the impacts, regulation, or oversite associated with the practices.

Because regulatory agencies tasked with protecting our natural resources are under staffed, they do not have the capacity to visit all of the sites in a timber sale or grazing allotment, so they depend on public citizen monitoring to report inconsistencies between what is proposed and what is happening on the ground. In essence, agencies are complaint driven, meaning that they don’t act unless someone files a formal complaint.

Day 1: Grazing Monitoring and Timber Sale Sleuthing

On Saturday, June 10, Felice Pace, Project Coordinator of the Grazing Reform Project took the group on a field tour of the Horse Creek Grazing Allotment, and the Horse Creek post-fire timber sale in the Klamath National Forest. A site visit of the Horse Creek Grazing Allotment revealed illegal felling of a large old-growth tree that had been cut  and likely used for fire wood. Environmental impacts, including damage to water quality, impairment of meadow hydrology and degradation of fish, amphibian and wildlife habitat are a common occurrence in these allotments, which are located on public lands.

Next, the group ventured up into the mountains to monitor the Horse Creek timber sale, which was burned in the 2016 Gap Fire. These burned areas were already regenerating with tree seedlings and new plants sprouting up all over the forest floor. In the units that were visited, the landscape was extremely steep with a slope of 30%-70%. It was clear that logging, tractors, skid trails, and new roads would tear up and compact these steep fragile soils, resulting in erosion and delayed regeneration of the fragile post-fire ecosystem years to come. The low gradient of Horse Creek makes it one of the best coho salmon habitats in the Klamath Basin. Logging and road building above critical coho habitat will result in sediment entering the stream, which degrades salmon habitat and smothers baby salmon. The total amount of logging in the Horse Creek watershed is massive.

Several of the timber sale units were located within Late Successional Reserves. The objective of Late-Successional Reserves is to protect and enhance conditions of late successional forests (think: old-growth), which serve as habitat for old-growth dependent species, including the northern spotted owl. However, most of the largest trees visible from the roadway within these areas were marked for logging, a violation of the law.

The federal timber sale is immediately adjacent to massive private timber operation, compounding the impacts to fish and wildlife. As of June 1st EPIC identified 21 emergency notices in the Gap Fire area totaling 4,863 acres from private land owners (primarily Fruit Growers Supply Company) in addition to the Horse Creek timber sale. Emergency notices are private post-fire logging projects that are exempt from environmental review. On the way to investigate Unit 115.34 of the Horse Creek project, the neighboring parcel, owned by Fruit Growers Supply Company, was being actively logged under an exempt emergency notice. Volunteers noted that the riparian areas within Fruit Growers’ land were being logged. Emergency timber operations can be conducted in riparian areas, including adjacent to streams known to provide critical habitat for threatened and endangered salmon and steelhead species without environmental review by the CAL FIRE or agencies responsible for administering the California or Federal Endangered Species Acts.

Day 2: Timber Monitoring Continues

On Sunday, June 11, EPIC volunteers braved the weather and poor roads to investigate the largest timber sale unit. Volunteers walked a road proposed to be punched in to facilitate logging. Again, life was everywhere in this “dead” forest. Hardwoods were sprouting from stumps, conifer seedlings provided a green carpet, and many trees the Forest Service considers to be dead were alive, with green boughs and branches. After hours of documenting the forest, EPIC volunteers ended the weekend with a cheer and a promise to return.

It is important to note that most projects like these don’t get monitored, and therefore private companies get away with violating environmental laws and standards that are in place to protect common pool public resources, like clean water we rely on for drinking, critical habitat for species such as salmon that feed our local communities, forests that provide us with clean air, and other ecosystems that support the web of life that we all depend on.

THANK YOU! 

Although EPIC has been groundtruthing for years, this is the first EPIC Base Camp. Our inspiration came from Bark, an Oregon based non-profit that has held an annual Base Camp event for years. Bark was kind enough to send expert ground-truther, Michael Krochta, to share techniques, and lead some of the trainings. EPIC would like to thank the 17 volunteers who came out to the boonies in a rain storm to document these projects, and the information they gathered, will be used in our comments to improve the Horse Creek project to minimize impacts to these wild places. EPIC has the best members. THANK YOU!

If you would like to check out our timber sale unit notes click here.

To view the photos we took in the project areas, click here.

Photos by Amber Shelton.

 

 


Horse Creek Project: Losing Taxpayer Money to Harm Spotted Owls

Tuesday, December 6th, 2016
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Low severity fire in upper Buckhorn Creek. Small snag patches such as this one in upper Buckhorn Creek are being targeted for logging by the KNF. The damage to soils, forest regeneration, and habitat complexity will degrade some of the watershed's only remaining old-growth forest. Photo courtesy of Luke Ruediger www.siskiyoucrest.blogspot.com

Low severity fire in upper Buckhorn Creek. Small snag patches such as this one in upper Buckhorn Creek are being targeted for logging by the KNF. The damage to soils, forest regeneration, and habitat complexity will degrade some of the watershed’s only remaining old-growth forest. Photo courtesy of Luke Ruediger www.siskiyoucrest.blogspot.com.

Take Action Now: Meet the Horse Creek Project, the Klamath’s new boondoggle that will log sensitive areas while losing taxpayer money. (There’s something in it for everyone to hate!)

The Klamath National Forest cannot let a fire go to “waste.” Following the 2016 Gap Fire, the Klamath National Forest is trying to log areas that should be off-limits: Late Successional Reserves, forests set aside from commercial timber harvest so that they can develop into old-growth forests; Riparian Reserves, areas around streams that are supposed to be off-limits to logging to prevent water pollution; and northern spotted owl habitat. The Klamath National Forest argues that logging large diameter snags, (which will stand for decades until new forests grow up around them all the while providing critical wildlife habitat) is good for the forests and for wildlife—paradoxical logic that has been rejected by both science and the courts.

If history is any guide, the Klamath National Forest will lose money in logging owl habitat—what’s known in Forest Service parlance as a “deficit sale.” Burned forests are worth more to owls and fishers than they are to timber mills. To make a profit, timber companies need to purchase trees from the Klamath National Forest for next to nothing. In several timber sales from earlier this year, the Klamath National Forest sold a logging truck’s worth of timber for about $2.50—less than the price of a cup of coffee. The Klamath will lose untold thousands or millions of dollars on this timber sale, money that could go to protecting local communities or improving wildlife habitat.

The Klamath National Forest has also tied important measures such as the removal of roadside hazard trees and the reduction of fuels near private property, to the controversial logging units. By doing so, the Klamath National Forest will not only delay this important work by several months through more complicated environmental review, but may tie up this work for years in court.

EPIC urges the Klamath to focus on the priorities. Protect local communities and drop logging in Late Successional Reserves, Riparian Reserves, and occupied owl habitat.

Take Action Now: Let the Forest Service know you oppose losing taxpayer money to log sensitive areas.


Show Your Support for the Northern Spotted Owl

Monday, March 14th, 2016
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NSO fem&juv _0397Take Action NowThe Northern Spotted Owl (Strix occidentalis caurina), a once-abundant apex nocturnal forest raptor synonymous with the old-growth forests of the Pacific Northwest, has experienced precipitous declines in the 20th and 21st centuries, with the advent of intensive logging of its old-growth forest habitat, and the more-recent incursion of a cunning competitor. The latest long-term range-wide study of spotted owl populations clearly documents that the species continues to decline in the present-day, despite over 20 years of federal ESA protections, and that, alarmingly the rate of decline is increasing.

In August 2012, EPIC filed a petition to list the northern spotted owl as either a “threatened” or “endangered” species under the California Endangered Species Act (CESA), on the basis that federal protections have not been enough to curtail the declines of the northern spotted owl, to bring about recovery of the species.

On February 10, 2016, the California Department of Fish and Wildlife (CDFW) finally released its long-overdue status report detailing the somber state of the spotted owl’s plight in the state of California, a key step in the process to listing the owl under CESA. The CDFW status report outlines the grim status of northern spotted owl populations in the state, and the myriad and ever-increasing threats to the survival and recovery of the species in the wild. The CDFW status report recommends that listing of the northern spotted owl as a “threatened” species under CESA is warranted, citing past and ongoing habitat loss, the increasing and pervasive adverse effects of competitive presence of barred owls, impacts from cannabis agriculture and exposure to rodenticides, impacts from wildfire, fire suppression, and post-fire logging, changing temperature and weather patterns resulting from global and localized climate change, and the inadequacy of existing regulatory mechanisms to protect the owl as reasons for the recommendation.

On April 14, 2016, the California Fish and Game Commission will meet in Santa Rosa to make a final determination on whether the listing of the northern spotted owl under CESA is warranted. The deadline for comments to be received by the Commission on the northern spotted owl listing determination is March 30, 2016. Click here to send a comment to the California Fish and Game Commission or send your own letter to: fgc@fgc.ca.gov.


Westside Project Update

Tuesday, December 8th, 2015
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Westside

Russian Wilderness post 2014 Whites Fire Near north Fork Salmon River.

For the past year, we have discussed the proposed “Westside Project” on the Klamath National Forest. The Westside Project is an environmental disaster, proposing huge clearcuts across thousands of post-fire acres of the Klamath National Forest. The project would drastically impact northern spotted owls and would harm other wildlife, such as bald eagles and the Pacific fisher. You can read more about the Westside Project here.

Four major steps need to be made before logging could begin in earnest. First, the Forest Service and U.S. Fish and Wildlife Service need to complete their “consultation,” a process required by the Endangered Species Act, given the high magnitude of threats to the northern spotted owl. Second, the Forest Service and the National Marine Fisheries Service need to complete their consultation, also required by the Endangered Species Act, because of the potential harm to threatened coho. Third, after consultation is completed, we expect the Klamath National Forest to issue a decision on the project. Lastly, after it releases a decision, then the Forest Service can apply to the North Coast Regional Water Quality Control Board for a “waiver of waste discharge requirements”—a permit to pollute, to (overly) simplify. EPIC is engaging with all of these ongoing processes to provide the necessary critical oversight. Given the timeline with these steps, we do not expect the Forest Service to be able to log until early spring.

While most of the major activity will not be able to occur this winter, the Forest Service could complete other logging activities in the vicinity, including some major “hazard tree” removal on the Sawyers road between Whites Gulch and Robinson Flat, a roughly two mile stretch. This stretch of road is within the Wild and Scenic North Fork Salmon River corridor. In about 95 acres, the Forest Service estimates it would remove approximately 1,400 trees greater than 14” diameter at breast height. Smaller trees will be felled and not removed. The Klamath National Forest indicated that this road presents an immediate safety risk for the surrounding communities.

EPIC will continue to bring you updates on the Westside Project as they unfold.

 


Exposed: Post-fire Logging Harms Endangered Owl

Tuesday, November 24th, 2015
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ScottHarding-KlamathNF-SHP_9598

Mixed-severity fire, like that shown, provides functional habitat for northern spotted owls. Photo credit, Scott Harding.

Private landowners, in particular Fruit Growers Supply Company, recently cut thousands of acres of northern spotted owl habitat, likely killing or harming the protected owl in violation of both federal and state law. And they got away with it. Here’s the story of how a timber company likely violated the law and how no one caught it.

Spotted owls utilize post-fire landscapes, including those that burn at high-severity—that is the conclusion of numerous recent scientific papers. High-severity areas, marked by significant numbers of dead or dying trees, provide excellent foraging grounds for spotted owls. The surge of dead wood and new shrub growth forms ideal habitat for wood rats, deer mice, and other spotted owl prey. The standing dead trees, or snags, provide branches for owls to roost while scanning for dinner. And because fires generally burn in a mixed severity pattern, with high-intensity burns close to areas that fire barely touched, there are often nearby trees for the owls to roost. This is informally known as the “bedroom/kitchen” model of habitat usage.

This finding, that spotted owls utilize post-fire forests, is somewhat new. It also runs counter to generalized statements about spotted owl habitat, which has generally been associated with complex mature forests. The Forest Practice Act was certainly written before this was well recognized.

While most logging in California is accomplished through a Timber Harvest Plan (THP), substantial logging can evade the environmental review provided by a THP. Under an “emergency notice,” a timberland owner can clearcut an unlimited number of acres by declaring an “emergency”—a broad loophole, which includes almost all conditions that render a tree “damaged, dead or dying.”

In 2014, the Beaver Fire burned some 32,496 acres, including 13,400 acres of private timberlands in Siskiyou County, much of which is owned by Fruit Growers. Based on the available information, between 2014 and 2015, Fruit Growers filed 32 emergency notices with CALFIRE totaling 8,644 acres. Other nearby landowners similarly filed emergency notices totaling 1,166 acres.

From surveys conducted by the U.S. Forest Service, we know that individual owls were harmed in violation of federal law by Fruit Growers. After the fires but before most logging had begun, a curious male northern spotted owl, identified as KL0283, responded to the hoot of an owl surveyor; he had survived the fire and was living amongst the dead trees. KL0283 was proof that spotted owls utilize post-fire forests.

Sadly, the Forest Service reports later surveys attempting to locate KL0283 after logging failed to yield any positive survey results. The Forest Service notes that logging reduced the owl’s habitat far below minimum acceptable levels, and given the lack of nearby habitat, it was unlikely that he had moved to somewhere better. KL0283 is likely dead, killed by the impacts of logging.

On a facial level, Fruit Growers followed the law—they filed emergency notices telling CALFIRE that they were planning on logging and logged pursuant to those notices. However, upon investigation, it appears that Fruit Growers harmed northern spotted owls in violation of both federal and state law. How was Fruit Growers able to log spotted owl habitat without detection for so long? Turns out, it was pretty easy.

First, it is unclear whether Fruit Growers knew it was violating the law. In each emergency notice, it wrote, “Due to the severity and intensity of stand replacing fire, [the] area can no longer be considered Suitable NSO Habitat.” As explained above, this is a common misunderstanding. By regarding all burned forest as non-habitat, it provided Fruit Growers an easy way to avoid having to evaluate and state the potential impacts to spotted owls.

Second, CALFIRE dropped the ball. It is CALFIRE’s job to evaluate emergency notices and reject any notice which may cause more than a minimal environmental impact. CALFIRE obviously failed at this.

Third, it is unclear whether anyone else was paying attention. It does not appear that the California Department of Fish and Wildlife reviews emergency notices—the Department only recently was able to hire sufficient staff to even review ordinary THPs, let alone emergency notices. The U.S. Fish and Wildlife Service, the agency charged under federal law with the protection of the owl, does not review California timber harvest implementation. EPIC, I freely admit, failed to put the pieces together until too late.

But never again. EPIC is on a mission, spurred by the likely death of KL0283, to reform post-fire logging on private land in California. For more on the environmental impacts of post-fire logging, please visit wildcalifornia.org.


Agency Delays May Cook Owl’s Chance at Protection

Tuesday, November 24th, 2015
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spottedowlhelper_1It is thanksgiving time here in Northwest California, a traditional time for giving, for caring, and for sharing. For the wild creatures that call our forests home, such as the northern spotted owl, it is a time for preparing to endure the long, wet winter. However, as we know, things are much different in the halls of Sacramento government and politics, where the rule of the day seems to be “if you aren’t at the table, you are on the menu.”

Such seems to typify the plight of the northern spotted owl in California, a species in precipitous decline with no voice to defend itself against the march of human progress and its disregard for the natural world. For 37 years, EPIC has served as a voice for the voiceless, willing to take the fight to protect our forests and the life that depends upon them to the halls of Sacramento, to the courtrooms, and beyond.

In accordance with our mission to give a voice to the forest, EPIC filed a petition with the California Fish and Game Commission to list the northern spotted owl under the California Endangered Species Act, in September 2012. In California, as with elsewhere in the species’ range, the northern spotted owl is in great peril of extinction as a consequence of human activities that have modified the forests it once knew and widely inhabited. Today, industrial logging practices continue to destroy and degrade habitat for the northern spotted owl on both public and private forestlands, despite over 25 years of federal protections afforded by the federal Endangered Species Act.

CESA protections for the northern spotted owl are warranted and necessary if the species is to continue to persist in the wild. However, after more than three years of advocacy for the owl to be listed under CESA, the listing process has stalled, primarily due to the willful refusal of the California Department of Fish and Wildlife to complete a review of the scientific and commercial information to assist the Fish and Game Commission in making a final decision on whether or not the listing is warranted under the law.

CESA calls upon the Department to complete a so-called “status review and report” within one year after a species is designated as a “candidate” for listing to help guide the Commission’s decision-making during the listing process. The status review and report was first due by the Department in December, 2014. The Department missed this deadline. The Commission, at the request of the Department, extended the deadline by six months, to June, 2015. The Department likewise missed this deadline; however, this time the Commission did not authorize additional extensions. EPIC considered suing the Department at this juncture but were dissuaded by the Department’s claims that it was hard at work and a final was forthcoming. This week, EPIC learned that the Department will now also fail to submit its report to the Commission at its upcoming December 2015 meeting, despite assurances that it would do so. Consequently, it appears that the Commission will once again kick the can down the road on deciding whether or not to protect the northern spotted owl.

Behind these seemingly inexplicable delays being perpetrated by the Department, and by extension, the Fish and Game Commission, is the ugly specter of big-money Sacramento politics and timber industry influence to extend the “business as usual” model indefinitely.

Scarcely a month after the Fish and Game Commission adopted findings to ratify its decision that the northern spotted owl may be either “threatened” or “endangered” under California law and afforded it the protections of a “candidate” species, the Department of Fish and Wildlife sent a letter to the Director of the California Department of Forestry and Fire Protection, the agency responsible for approving private lands logging projects, to assure it that no changes in the existing review process or resultant protective measures would be necessary or required to conserve the northern spotted owl during the candidacy period. What’s more, we know that the Department of Fish and Wildlife has held several meetings and workshops with timber industry groups to discuss the northern spotted owl. None of these meetings were publically noticed or publically accessible. Department of Fish and Wildlife Director, Charlton H. Bonham, openly questioned the necessity of the spotted owl listing petition during the course of a formal Commission hearing on the merits of the petition, further betraying a bias on the part of the agency.

As a consequence of the long and unnecessary delay by the Department in producing a status report to guide the Commission’s decision-making, EPIC has been compelled to take more aggressive actions in hopes of expediting the listing process for the critically-imperiled northern spotted owl. On November 24, 2015, EPIC submitted a letter to the Fish and Game Commission detailing the long and sordid history of delay tactics perpetrated by both the Department and the Commission itself, and requested that the Commission simply proceed with a hearing on the merits of our petition in the absence of the Department’s report. EPIC is considering legal alternatives should this administrative appeal fall short.

And so, as you hunker down to partake in the wonderful feast and bounty of the land this thanksgiving, please remember those that are not at the table, but rather sadly, on the menu.

 


Thousands Speak Out Against Post-Fire Logging In Klamath Region

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

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

Westside Timber Sale Threatens Salmon and Wildlife

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

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

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

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

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

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

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

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

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


Northwest Forest Plan and Connectivity

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

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

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

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


Westside Fire Recovery Project a Hot Mess

Wednesday, April 29th, 2015
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Whites_RussiansWith over 30,000 acres of Klamath National Forest proposed to be harvested and sold, the Westside Fire Recovery Project is poised to be one of the largest ever post-fire timber harvests on a National Forest. This so-called “recovery” project places timber company profits over community safety and wildlife by clearcutting complex, habitat-rich forests and replacing them with fire-prone plantations.

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

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

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

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

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

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


The Westside Story

Wednesday, April 15th, 2015
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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.


Fish and Wildlife Service Finds Northern Spotted Owl May Be Endangered

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

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

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

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

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

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

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

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

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


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

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

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

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

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

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

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

EPIC’s efforts to defend biodiversity

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

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

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

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

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

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

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


One Plan to Rule Them All

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

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

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

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

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

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


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

Wednesday, January 28th, 2015
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Pacific FisherAfter 15 years of delays and subsequent litigation, the U.S. Fish and Wildlife Service is proposing to list the West Coast population of the Pacific fisher, a small, weasel-like forest carnivore, as a “threatened” species under the federal Endangered Species Act. In 2000, EPIC and 16 other conservation groups petitioned the U.S. Fish and Wildlife Service (Service) to list the West Coast population of the Pacific fisher under the Endangered Species Act (ESA). Now, the end is almost in sight; our goal is almost achieved.

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

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

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

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

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

Action:

Tell the U.S. Fish and Wildlife Service:

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

Send Comments to Federal eRulemaking Portal:

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


Save Richardson Grove: Think Globally, Act Locally

Sunday, January 25th, 2015
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Madrone Hugging Ancient RedwoodIf everyone cared for their own wild back yard, the world would be a better place. Northwest California is known for having some of the wildest lands, including the Lost Coast and the tallest trees on the planet, which have been preserved behind the redwood curtain since time immemorial. With less than three percent of the planet’s old growth redwood trees remaining, it is imperative that every ancient tree is protected, especially if they are entrusted into a park system, which has vowed to protect them in perpetuity.

Since 2007, EPIC has been working to protect some of the most well-known giant redwoods in the world from the California Department of Transportation’s destructive highway-widening project. A grass roots coalition of community members, business owners, economists, conservation and Native American groups have opposed the Richardson Grove Operational Improvement Project, which proposed tree removal and destruction of the root systems of ancient redwood trees in Richardson Grove State Park – trees that are supposed to be protected by the state park system.

Richardson Grove is the first cluster of old-growth redwoods people see as they head up the coast on Highway 101, it is essentially the “redwood curtain” that has allowed Humboldt County to retain its rural character. The redwoods in Richardson Grove also serve as critical habitat for Marbled Murrelets, Northern Spotted Owls and streams going through the Grove are critical habitat for endangered Coho Salmon. Maintaining the integrity of these trees is incredibly important not only to the ecosystem, but to the community, since these trees are the pinch point that do not allow for larger trucks serving corporate chains that are characteristic of sprawling urban areas, and which many people feel would change the essential character of Humboldt County.

For eight years EPIC and allies have organized community support, provided comments, and filed substantive lawsuits that convinced a federal judge to grant an injunction halting the Richardson Grove project citing that the agency had been “arbitrary and capricious” in its use of what the court called “faulty data.” This past December Caltrans revoked its approval of the project. If the agency decides to pursue the project, a complete and comprehensive environmental review and approval process will have to start over. This is a victory, we can all breathe a sigh of relief and rest assured that the trees in Richardson Grove State Park will not be harmed for now.

An important lesson has been learned because of this case, that Caltrans consistently breaks the rules, violating environmental laws and risking important public trust resources. For this reason, EPIC will continue to engage with Caltrans and hold them accountable to the environmental standards that have been put in place to protect our natural treasures.

A related proposal that should be watched closely is Caltrans’ “Last Chance Grade” project, located along Highway 101 ten miles south of Crescent City where the roadbed is sliding into the Pacific Ocean. Caltrans is in the beginning planning phases of this project and is looking at potential alternative routes to the east, away from the sliding cliffs, which includes multiple alternatives that would go through the middle of Redwood State and National Parks. EPIC is committed to finding the least environmentally destructive project alternative that meets the needs of the community, while holding Caltrans accountable to environmental laws.

The loss of large tracts of intact wild lands may be the single biggest threat to our way of life. Climate disruption will only compound the threats that future generations face. In order to secure a sustainable future, it is clear that protecting and restoring Northwest California’s forest ecosystems will provide necessary habitat, clean air and water, carbon sequestration, and improve quality of life for people and native wildlife for generations to come.

In order to hone EPIC’s effectiveness in protecting wild forestlands within our bioregion, we have restructured the organization, added two new attorneys to our staff, and developed a new strategic plan to focus on three primary campaigns:

•Achieving permanent connectivity of working and wild forestlands, a campaign called “Connecting Wild Places;”

•Ensuring best management of public forestlands; and

•Ensuring best management of private industrial forests with an emphasis on the Elk, Mattole and Freshwater watersheds.

With your help, we can protect wild places and ensure that public and private lands are managed responsibly to maintain healthy intact ecosystems. We have our work cut out for us, but we are dedicated and determined to leave our children with a legacy we can all be proud of.

 


Spotted Owl Told to Wait (Again)

Wednesday, January 14th, 2015
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Owl-Self-Defense-wings-shadow-296x300The Northern Spotted Owl is an iconic corner-stone species that has called the forests of northwest California home since time immemorial. Despite over 20 years of enhanced protections afforded by the listing of the owl under the federal Endangered Species Act, the best available science continues to show alarming and precipitous declines in NSO vital statistics across the species’ range.

EPIC’s Northern Spotted Owl Self-defense Campaign has sought to achieve enhanced protections for the owl in California and beyond. Given the myriad and immediacy of threats to the species, EPIC believes that urgent actions are needed to prevent the extinction of the NSO.

In 2012, EPIC filed a petition with the U.S. Fish and Wildlife Service to ‘up-list’ or ‘reclassify’ the NSO from a “threatened” to an “endangered” species under the federal ESA. Despite statutory obligations to produce an initial 90-day finding on our petition, the U.S. Fish and Wildlife Service has failed to fulfill its responsibilities under the ESA. In 2014, EPIC reached a ‘handshake’ agreement with the U.S. Fish and Wildlife Service. The Service had committed to publishing its initial 90-day finding on our petition by December 12, 2014. However, the Service failed to meet this specified deadline, now indicating that it does not intend to publish the 90-day finding until March 31, 2015.

Meanwhile, EPIC also submitted a listing petition for the NSO under the California Endangered Species Act (CESA) in 2012. After a great deal of delay, the California Fish and Game Commission considered the petition in August 2013. The Commission found that the proposed listing action ‘may be warranted,’ thus initiating a one-year ‘candidacy’ period for the NSO under CESA, during which time the species would be treated as if it were listed. The NSO is thus currently protected under California state law.

CESA requires the California Department of Fish and Wildlife to ‘promptly’ commence a full status review of the NSO in California, and to produce a status report for submission to the Fish and Game Commission to inform the Commission’s final decision on the listing proposal. The Department of Fish and Wildlife’s status review and report were to be completed by December 2014. However, the Department has sought, and successfully received a six-month extension for the submission of its status report for the NSO. The new release date for the Department’s status report is now June 26, 2015.

The failure of the wildlife agencies to address our listing petitions and the increasing threats to the NSO in a timely manner bodes poorly for the prospects for survival of the owl in California and elsewhere in the species’ range. Despite the fact that existing conservation measures for the owl have clearly failed, both the state and federal governments have shunned their responsibilities to ensure the conservation, survival, and recovery of the NSO in the wild. Instead, business as usual prevails in both our public and privately-held forestlands.
Preventing the extinction of the NSO is key to maintaining forest ecosystem health, maintaining species’ biodiversity in the forest, and for protecting and connecting our wild places and managed landscapes. EPIC will continue to use the tools available to advocate for the conservation and recovery of the Northern Spotted Owl.


Advocate for Real Recovery

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

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

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

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

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

Click here to take action now!

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


EPIC Advocates for Northern Spotted Owl Using Best Available Science

Tuesday, August 5th, 2014
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NSOEPIC relies upon an integrated science-based approach to environmental advocacy. Consistent with our mission statement, we apply the best available science at the legislative, regulatory, and policy levels of government and industry. In our ongoing efforts to protect, enhance, restore, and conserve the Northern Spotted Owl, EPIC uses the best available science to inform our advocacy and decision-makers.

As part of our efforts to see the spotted owl listed as either a “threatened” or “endangered” species under the California Endangered Species Act (CESA), EPIC has commissioned a wildlife researcher  to conduct an independent status review and prepare an independent status report to be submitted to the California Fish and Game Commission. This report is based upon the best available science regarding the status and population trends and threats for the spotted owl, and will consider possible management recommendations designed to protect, enhance, conserve, and restore the spotted owl in California.

EPIC has pursued this independent review and report to allow for critical evaluation of the available evidence, including scientific, and timber industry-based information. The report will be subject to rigorous outside independent peer-review from a broad array of stakeholders, including independent scientists, researchers, and even timber industry biologists.

This report will be defensible and credible.

The independent review and report will be juxtaposed against the status review and report produced by the California Department of Fish and Wildlife. The Department is charged by CESA with conducting a status review and preparing a status report that will include a recommendation to the Fish and Game Commission as to whether or not it believes the listing “is warranted.” EPIC has chosen to commission an independent review due to the highly political nature of the inner workings of the Department, which has been evidenced in its recent recommendations against species’ listings, most notably the Gray Wolf. In the case of the Gray Wolf, the Department erroneously based its decision on a lack of ‘certainty’ in the science surrounding the wolf, thus dismissing the numerous threats to the species and the enormous opportunities for wolf restoration and conservation in California. Such rationale on the part of the Department leaves many questions as to its ability to review and consider the best available science and to make recommendations regarding species’ listings that are not politically-charged and influenced.

EPIC’s independent status review for the spotted owl is a key cog in our efforts to see the species listed under CESA. The benefits of CESA listing are many. Such benefits include requiring all state boards and agencies to work to protect, enhance, conserve, and restore the spotted owl in California. The practical effects of CESA listing would include the reintroduction of independent agency biologists into private lands timber harvest project review, and to impart upon the state a mandate to consider appropriate management activities to protect, enhance, restore, and conserve the spotted owl, including potential management activities aimed at addressing some of the major threats to the species in California, including the aggressive and invasive barred owl.

The State of California has a responsibility under CESA to protect, enhance, conserve, and restore “threatened” and “endangered” species in California. The best available science, which clearly demonstrates the threats to the species and identifies opportunities for conservation and enhancement supports the proposition that listing “is warranted” under CESA.


EPIC in Review

Tuesday, August 5th, 2014
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Hole in Headwaters Hike ReducedAs the summer heats up, so have some of EPIC’s ongoing projects. This past week, EPIC along with other environmental organizations, wrote letters opposing H.R 1363 and H.R. 4742, two bills that seek to circumvent the National Environmental Policy Act process and threaten fisheries. Additionally, H.R. bills 5021 and 2363 attempt to open loopholes in the environmental review process and public involvement that undermine our checks and balances. The EPIC team is hard at work trying to ensure that the appropriate avenues continue to exist so that we can fight for the wild. The importance of protecting a legal framework cannot be understated when saving our ecosystems, and our natural resources. The input, concern, and passion from the community help drive the campaigns we fight for. For more on the projects we’ve been up to lately, check out the links below.

EPIC Bay Delta Conservation Plan Comments 

Comments have been submitted fighting for the abandonment of the Bay Delta Conservation Project. An antiquated, disingenuous, and grossly expensive project that’s based on over-allocated water rights and serves only to benefit large industrial agriculture. The 67 billion dollar, Bay Delta Conservation Project, a grand misnomer, severely threatens the habitat of a number of threatened and endangered species from the salmon runs of Northern California to the Delta Smelt in San Francisco Bay.

Letter to Evans & Chesbro Regarding Groundwater Regulations

Letter to California Senator Noreen Evans and Assemblymember Wesley Chesbro requesting assurance that the Scott River will be removed from the list of basins exempted from groundwater planning and regulations.

Community Letter Opposing H.R. 1363

EPIC and other environmental organizations, have sent a letter opposing section two of H.R. 1363 for blatantly violating the processes in the National Environmental Policy Act (NEPA) that fully disclose the impacts of an action.

Oppose HR 4742 Community Letter

In this letter, we urged a no vote on H.R. 4742. The bill strives to weaken the Magnuson-Stevens Act and halt the rebounding of many fisheries that have benefited from recent conservation efforts.

Oppose the Anti-National Wildlife Refuge Rider

The potential for expansion of the National Wildlife Refuge system is coming under fire in the form of a 2015 appropriations bill. The rider would require congressional approval for new refuges when congress already controls the financial backbone. This shift goes against the spirit of the original bill and could open the door up to refuges being used in political horse-trading.

Oppose Toomey Amendment

The Toomey Amendment to H.R. 5021 seeks to avoid any environmental review or consideration for reconstruction efforts in areas after a disaster. Currently, there are already proven avenues for post disaster construction that are more environmentally friendly, transparent, and flexible.

Opposition letter S 2363 Sportsmens Act 2014 – 7.8

This letter also opposes the Senate Bill 2363 and represents the option of a large coalition of 105 groups from around the country. The so-called “Bi-partisan Sportsmen’s Act” seeks to roll back various environmental laws including the National Environmental Policy Act (NEPA), the Wilderness Act, and the National Forest Management Act. In addition, the bill removes the Environmental Protection Agency’s ability to control toxic substances in ammunition or fishing equipment.

Sage Grouse Rider Letter

Representative Moran of Virginia is seeking to prevent a delay in protection for declining Sage Grouse populations. Next year’s appropriations bill, in its current form, includes a rider that would postpone U.S. Fish and Wildlife’s inclusion of Sage-Grouse in a final Endangered Species Act listing.

TRI_Slider_comments

EPIC has submitted comments regarding the “Slider” Timber Harvest Plan (THP) that underlines the inadequacies in CAL FIRE’s assessment of significant impacts. Additionally  CAL FIRE fails to disclose the correct information pertaining to the pre and post harvest stock levels required for demonstration of Maximum Sustained Production (MSP).

Native American Notification Comments EPIC

Comments have been submitted regarding rules for the notice of harvesting in Native American archeological sites. EPIC is calling for rules to be amended so that seven business days or ten total days of notice are given before timber harvesting commences.

Passenger Pigeon Proclamation Request Letter from 137 Organizations and Institutions

In conjunction with 136 organizations, EPIC is urging President Obama to issue a proclamation recognizing the centennial of Martha, the last Carrier Pigeons’, death. The overall goal is to raise awareness of the cost of our environmental actions and to remind Americans of their civil duty to be good stewards of wildlife and nature.

OSV Rule – Comment Letter

Along with a number of organizations, EPIC submitted comments to the National Forest Service regarding proposed rules for over-snow vehicles (OSV). Regulating OSVs on Forest Service land itself isn’t called into question but rather, the scale, types of impacts and violations of a number of executive orders resulting in unenforceable policies.

Thanks to EPIC Interns Nathan Fisch and Taylor Morrison for developing content for this page.

 

 

 


EPIC in Review

Friday, June 13th, 2014
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Over the past few weeks, EPIC has worked to protect wolves in California, stood up to big timber companies, advocated for the Wild and Scenic rivers and endangered species, protected Northern Spotted Owls, opposed the Bay Delta Conservation Plan, requested amendments to groundwater legislation, and worked to protect water quality on timber lands. The documents below are a sample of our efforts to protect the wildlife, forests and watersheds of the North Coast. Several of these documents are the product of larger groups that we work with to develop coalition letters, and other documents are original works produced by EPIC staff. We hope that sharing these works with our readers will bring an awareness of some of the issues that we are addressing to protect the environment that we are rooted in.

EPIC Comments Regarding “Scorpion King” and “Boomer.” These two THPs are proposed by Sierra Pacific Industries and would result in take of Northern Spotted Owls as a result of the cumulative effects of multiple harvest entries over a short time.

Environmental Water Caucus Comment Letter on the 40,000 page Bay Delta Conservation Plan and EIR/EIS. This 259 page comment letter was developed by a coalition of water and conservation advocacy groups including EPIC. The letter outlines environmental impacts to endangered species populations, rivers, the San Joaquin Delta and to the state’s overall water supply.

EPIC Motion for Stay filed with the State Water Resources Control Board. The motion requests a stay of the effect of the North Coast Regional Water Quality Control Board’s approval of a property-wide forest operations Waste Discharge Requirement permit (WDR) order for Green Diamond property back in 2012. The motion for stay is in response to the State Board’s failure to address a petition to review the Regional Board’s approval of the order that EPIC filed in 2012.

HR 4272 Opposition Letter. The Forest Access in Rural Communities Act would modify motor vehicle use on public lands, which would tie the hands of Forest Service managers across the country who work to protect public safety, recreational experiences, and endangers protections for drinking water resources, wildlife and forest resources.

Northern California Prescribed Fire Council letter of support for AB2465. The bill would officially recognize the benefits of prescribed fire in California’s fire-adapted landscapes and facilitate new levels of professionalism for private lands burners throughout the state.

Letters to Senator Pavley and Assemblyman Anthony Rendon requesting amendments to ground water legislation to address the impact that groundwater extraction can have on California’s streams.

Letter of opposition for four House of Representatives bills that would damage the Endangered Species Act. These bills “would undermine the essential protections of the Endangered Species Act by obstructing the development and use of scientific research, squandering agency resources and chilling citizen enforcement.”