Clean Water

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

Thursday, June 29th, 2017
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TAKE ACTION! On the 4th of July, you can help save our forests by halting bad legislation. A new bad forest bill, the ironically named “Resilient Federal Forests Act” (HR 2936), is quickly heading to a vote. The bill recently escaped the House Natural Resources Committee through a party line vote. Now, Trump’s lawless logging bill will soon come up for a vote before the House.

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

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

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

(2) Weakens Endangered Species Act Protections

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

(3) Closes the Courthouse Doors

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

(4) Shifts Money from Restoration to Logging

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

CLICK HERE TO TAKE ACTION NOW TO STOP BAD FOREST LEGISLATION


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.

 

 


Westside Update: EPIC Back in Court to Fight for Project Remediation

Tuesday, April 11th, 2017
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Photo by Amber Shelton

For more articles about the Westside Timber Sale, click here.

EPIC is back in court to ensure that promised logging remediation will occur. EPIC is seeking to amend our original lawsuit to target some of the unfulfilled promises made by the Forest Service. The amended complaint is here and our motion to amend is here.

Broadly speaking, the Westside Timber Sale consisted of two components: a timber sale and project features to “recover” the forest post-fire and post-logging. The first part, the logging, has occurred. But the second, the recovery actions, may never occur because of the Forest Service’s failures.

Through the Westside Timber Sale, the Forest Service has denuded around 6,000 acres of mostly steep and unstable slopes in the Klamath National Forest. In its wake, the Forest Service has left a mess. Slash and logging debris litter the landscape. Roads are collapsing and washing into the Klamath River. Forest fuel conditions are worse than when the project started. (In short, this is what EPIC predicted would happen. But no one likes an “I told you so.”)

As promised to the public in their environmental impact statement, the Forest Service indicated that it was going to come back in and clean up this mess through fuels reductions projects and treatment of “legacy” sources of sediment pollution. The Forest Service predicated this remediation work on selling timber for exaggerated prices—$240 per thousand board feet of timber. In reality, the Forest Service sold owl critical habitat for as low as $.50 per thousand board feet, as the market for these fire-killed trees dried up. (At that price, a log truck full of trees would cost less than a cup of coffee.)

When the Forest Service realized that the project was no longer economically viable, it should have stopped logging and reevaluated the Project. It didn’t. Now EPIC is asking the court to force the Forest Service to think critically about what it can feasibly do by revisiting its environmental impact statement.


Keep California Great!

Thursday, January 26th, 2017
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img_4386California did not exist at the founding of our country, but we are the future of America.

Look: we are going to experience losses at the federal level. Since our federal environmental laws were passed, they have been chipped away at; now, they be wiped off the books entirely. We can no longer rely on federal environmental law to protect the clean air and water, biodiversity, and ecosystem health that we need and cherish.

Now is time for California to take charge and ensure that our state environmental laws are strong enough to keep California great.

EPIC calls on the Legislature to review and revise California’s foundational environmental laws—the California Endangered Species Act, the California Environmental Quality Act, and the Porter-Cologne Water Quality Control Act, among others—to ensure that we have a safe and healthy California, for all its residents (both humans and critters alike).

California has led the nation before in setting environmental policy. California was among the first to move to protect biodiversity, passing the California Endangered Species Act in 1970, three years before the federal Endangered Species Act. Before the creation of the U.S. Forest Service, California recognized the public importance of our forests and charged the Board of Forestry, first founded in 1885, with the enforcement of forestry laws.

What we do in California has an outsized importance not just in our country, but around the globe. If it were its own country, California would boast the 6th largest economy in the world—ahead of France and just below Great Britain. Our laws can help shape federal environmental policy, even if they only apply within our own state.

EPIC is heartened to hear that Governor Brown has pledged to take up the slack left by the Trump administration and join with other states and countries to fight climate change and the declaration by California Senate President pro Tempore Kevin de León and California Assembly Speaker Anthony Rendon that California will “set an example for other states to follow.


Grazing Reform Project Works Toward Responsible Grazing Practices

Wednesday, January 18th, 2017
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bigmdws_cattle-trail-in-wetlands-2EPIC is excited to announce the launch of the new website for our Project to Reform Public Land Grazing in Northern California, located at www.grazingreform.org. On the site you can access lots of information about the impacts of public land grazing, including 28 photo-illustrated reports which span the seven years during which Project volunteers have monitored and documented the manner in which livestock grazing, all by cattle, is being (mis)managed within 15 separate grazing allotments in wilderness areas and on other national forest lands within the Klamath, Rogue-Siskiyou and Shasta National Forests. If you like the work we are doing, please consider making a donation to the Project.  All donations will keep our intrepid grazing monitor, Felice Pace, out in the field documenting problems. We are also looking for volunteers to help perform grazing monitoring, in particular grazing allotments in the Mad River Watershed of the Six Rivers National Forest.

On the website you can access, read and download reports which document the poor manner in which public land grazing is managed and the resulting degradation of water quality, riparian areas and wetlands. On the site you can also access research on grazing impacts, best management practices for managing grazing, specialist reports, like the report of hydrologist Jonathan Rhodes on the Big Meadows Grazing Allotment in the Marble Mountain Wilderness, and several videos Felice and other Project volunteers have made in the field to highlight the negative impacts of grazing on riparian areas, wetlands, water quality and meadows.

Click here to donate to the grazing monitoring project

Click here to volunteer

A little background: 

The Project to Reform Public Land Grazing started over seven years ago in support of water quality testing by the Quartz Valley Indian Reservation (QVIR) in streams like Shakleford Creek and East Boulder Creek in the Scott River Basin. Using an environmental justice grant from the EPA, QVIR began testing water quality in streams issuing from grazing allotments within the Marble Mountain and Trinity Alps Wilderness Areas. QVIR testing documented violation of water quality standards for fecal coliform bacteria and excessive nutrients; both are associated with water pollution from poorly managed grazing.

Inspired by this QVIR effort, our project coordinator, Felice, decided to go onto the grazing allotments themselves to document the bad grazing management that resulted in the water pollution QVIR found and to use that information to advocate for improved grazing management. Over the past seven years, we’ve logged 1,210 hours monitoring grazing on-the-ground in our national forests—that’s over 150 person days of volunteer grazing monitoring!

While it is certainly impossible to eliminate all the negative impacts of grazing on water quality, riparian areas and wetlands, negative impacts within Northern California’s wet meadow headwaters could be substantially reduced if Forest Service managers would require that grazing permit holders implement modern grazing management methods, including regular herding to rotate grazing among the various pastures on an allotment. Presently, however, permit holders place their cattle on the public lands in the spring or summer and don’t return until mid to late October when the snow flies and cattle must be taken to the home ranch. Some grazing permit holders have become so lax that they do not even collect their cattle in the fall. Instead they allow their livestock to wander home on their own while continuing to graze on national forest land.

Allowing cattle to remain unmanaged on public land for months on end always leads to degraded water quality, trashed riparian areas and trampled wetlands. This is just one of the many instances of lax Forest Service grazing management which the project hopes to change. Trampled springs like the one in the photo below are a common sight on Northern California’s public land grazing allotments and a clear indicator of inadequate Forest Service grazing management.

Donate Now!

Sign up as a volunteer!


Three Victories for the Crown and Coast of California!

Tuesday, January 17th, 2017
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Lost Coast Headlands. Photo courtesy of Mark Harris

The Cascade-Siskiyou National Monument is expanded to 100,000 acres! Before leaving office, President Obama added 48,000 acres to the monument, which lies mostly in southwestern Oregon and now includes 5,000 acres in Northern California. The expansion will provide vital habitat connectivity and added landscape scale protection. The convergence of three geologically distinct mountain ranges, the Cascade, Klamath, and Siskiyous, has created a truly unique landscape, home to many rare and endemic plants and animals. It is the first monument set aside solely for the preservation of biodiversity.

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Trinidad Head. Photo courtesy of Mark Harris

The California Coastal National Monument now includes six new sites totaling over 6,230 acres. Three of them are in Humboldt County, Trinidad Head, Waluplh-Lighthouse Ranch and 440 acres of Lost Coast Headlands south of Eureka and the Eel River. The other areas include the 5,785-acre Cotoni-Coast Dairies parcel on the slopes of the Santa Cruz Mountains, Piedras Blancas lighthouse in San Luis Obispo County; and offshore rocks and small islands off the Orange County coast. The monument designation ensures the protection of all islets, reefs and rock outcroppings along the entire 1,100-mile long coastline of California within 12 nautical miles.

A recent Public Land Order has secured a 20-year Mineral Withdrawal just north of the state border in the Klamath Mountains. Covering 100,000 acres of land managed by the Rogue River-Siskiyou National Forest and Bureau of Land Management the order will protect some of the region’s most pristine rivers from large-scale strip mining and new mineral development, although it does not prohibit ongoing or future mining operations on valid pre-existing mining claims. The defining characteristic of the proposal is the Wild and Scenic North Fork of the Smith River, which originates in the Kalmiopsis Wilderness and runs through the South Kalmiopsis Roadless Area.

The crown of California, also known as the Siskiyou Crest, is an extremely ecologically important east to west biological corridor that straddles our neighboring state of Oregon. With the newly designated National Monument to the east and added protections for roadless lands to the west, the crown jewel of the state just got wilder! Together in combination with the addition of the culturally significant areas along the coast to monumental status is a real win for the people, plants and wildlife of our wild places.


State Initiates Pilot Watershed Study of Timber Harvest Plan Process

Monday, January 9th, 2017
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The State of California has initiated the first of three planning watershed-scale pilot studies to evaluate the adequacy utility, and methods of representation and assessment of information that informs the modern-day Timber Harvest Plan review process. The Campbell Creek Planning Watershed Pilot Project is a subsidiary to the larger Timber Regulation and Forest Restoration Program that was created in the wake of 2012’s Assembly Bill 1492, that calls for ensuring efficiency, accountability, and transparency in the THP process, and the eventual development of “Ecological Standards and Performance Measures,” to ensure the overall effectiveness of the THP administration program.

The concept behind the Planning Watershed Pilot Project study is to evaluate pre-existing information in Timber Harvest Plans over history in a specific planning watershed and to then “truth” the value, utility, clarity, and representation of the information against the physical on-the-ground conditions in the watershed via field examination. The study will evaluate the ability of the information as represented to accurately depict field conditions, identify and design mitigation measures, and to identify restoration opportunities and prioritization of restoration activities and funds. The Planning Watershed Pilot Project study is the brain-child of long-time EPIC associate, Richard Gienger.

The Planning Watershed Pilot Project study for Campbell Creek, a tributary to the Ten Mile River in Central Coastal Mendocino County, is being conducted by the Planning Watershed Pilot Project Working Group. The Working Group is comprised of an agency leadership team, a team of agency technical staff, and an appointed group of non-governmental stakeholders, including land owners, Registered Professional Foresters, scientists, fisheries restorationists, environmental non-profits including EPIC, and a tribal liaison from the Pomo tribe. The concept of having “multi-disciplinary” team and approach to evaluation is critical to the premise of the pilot project concept.

Another, though understated objective of the Planning Watershed Pilot Project study, is to evaluate the ability of existing information in the THP process to inform and guide methods of assessment and develop necessary mitigations to address cumulative environmental impacts of past and contemporary timber harvesting activities on private lands in the State.

The Pilot Project Working Group held its first meeting in Fort Bragg in December 2016. The location allows for easy access to field site visits in the Campbell Creek watershed on its timberlands. Timberlands in Campbell Creek are presently primarily under the ownership of Lyme Timber. Lyme is a Timber Investment Management Organization (TIMO), and is the successor to Campbell Global, itself a TIMO. Campbell Global acquired the property from Georgia-Pacific Corporation. The Ten Mile River in Central Coastal Mendocino County is one of the last vestiges of remaining native wild-run coho salmon in the Central California Coast, and is thus a critical watershed for study and assessment of restoration opportunities.

The Planning Watershed Pilot Project study concept has been subject of other legislative efforts in the past that subsequently failed, but is now built into the rubric of the larger Timber Regulation and Forest Restoration Program, with the hope that the study will contribute valuable information to the larger program, and aid in the development of Ecological Standards and Performance Measures. Ecological Standards and Performance Measures can be thought of as “Thresholds of Significance,” in the CEQA parlance, a set of objectives and measureable criteria to aid in the identification and avoidance of adverse cumulative environmental impacts from timber harvest and related activities on private lands in the State.

EPIC’s participation in the Planning Watershed Pilot Project Working Group is a circling back to the landmark 1986 court decision, EPIC v. Johnson, in which EPIC sued CAL FIRE for approving the logging of old-growth in the Sally Bell Grove in what is now the Sinkyone Wilderness State Park, without evaluating the cumulative impacts of successive harvests and the subsequent cumulative loss of old-growth forests.

While EPIC prevailed in forcing private forestry to be subject to evaluation of cumulative impacts via the creation of the modern-day cumulative impacts assessment process in the Forest Practice Rules, the requirements are weak at best, and in the present-day have resulted in little more than cut-and-paste boiler-plate conclusionary statements that are passed off as an “evaluation,” to support a finding of no cumulative impacts. In the 30 years since EPIC v. Johnson, CAL FIRE has never denied a Timber Harvest Plan on the basis of a finding of adverse cumulative impacts, despite the wide-spread loss of old-growth, continued declines in populations of threatened and endangered fish and wildlife, the listing of almost every major North Coast stream as water quality impaired, and now the advent of global climate change.

Long-time EPIC associate, Richard Gienger, has been advocating for a truly multi-disciplinary evaluation of the THP process and the information upon which is predicated for decades, and his vision and prints are all over the concept and structure of the Planning Watershed Pilot Project study and the Planning Watershed Pilot Project Working Group. The Pilot Project study is a foundational element to building an understanding and developing an information-based critique of the current process, identifying opportunities for much-needed reform.

40 years, and still going strong, EPIC is working as hard as ever to protect our forests, fish, air, water and wildlife against the damaging impacts of industrial-scale timber harvest on private forestlands in the State. Far from being finished, EPIC will hang tough and stay strong and vigilant in working for the place we love and call home.


Bag Ban on the Ballot

Wednesday, October 5th, 2016
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Green: Ban; Orange: Tax & Purple: Partial tax or ban (municipal or regional levels)

Green=Ban      Orange= Tax     Purple= Partial tax or ban at municipal or regional levels.  (Photo: Wikimedia)

Help California become the first state in the nation to ban the use of single-use plastic bags. Vote Yes on Proposition 67.

Single-use plastic bags, the flimsy variety provided gratis by grocery stores, are one of the most plaguing and persistent types of litter in our natural environment. Not only are plastic bags an eyesore, they are harmful to wildlife. In the ocean, plastic bags resemble jellyfish and hungry sea life, like turtles, eat the bags. Plastic bags are responsible for many deaths, as the animals can starve to death because their stomachs are clogged with garbage. One easy and commonsense solution is to ban this garbage and to help incentive people to bring reusable shopping bags.

California has always led the nation when it comes to sustainability—banning the use of single-use plastic bags is no exception. In 2007, San Francisco became the first jurisdiction to ban the bag. Other jurisdictions, like Mendocino County and the City of Arcata, followed suit. In 2014, Governor Brown signed SB 270, the first statewide ban on single-use plastic bags in the nation. The bag ban would not take effect. The plastic industry and an army of signature gathers quickly gathered enough signatures to put the measure on the ballot.

Now it is up to us. By voting yes on Proposition 67, you will uphold the bag ban passed by the California legislature in 2014.

Bag bans work. In San Jose, the city monitored litter before and after a bag ban went in effect. The results were stunning: litter had been reduced 59 percent on city streets, 89 percent in storm drains, and 60 percent in creeks.

Proposition 67 is endorsed by many other conservation organizations, including Humboldt Baykeeper and the California Coastkeeper Alliance, the Environmental Protection Information Center (EPIC), Sierra Club California, and many others.

Big plastic is spending big bucks to defeat Proposition 67, outspending supporters nearly 3-1. Under the deceptive moniker, the “Progressive Bag Alliance,” the plastic industry is not opposed to deception and lies, including that banning bags is bad for the environment. Don’t buy it  and Remember to BYOB: Bring Your Own Bag!

Watch and share the video below and vote Yes on Proposition 67!


Help Protect Pristine Smith River Waters

Thursday, September 22nd, 2016
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SmithR by Casey RobertsTake a moment to help safeguard the Wild and Scenic Smith River. Public comments are being accepted by the Oregon Water Resources Department to protect the Smith River watershed in Curry County, Oregon for instream purposes. The classification would provide protection for fish, wildlife and recreation. Click here to send a letter of support for this very important action.


New: Videos showing local National Forest Grazing damage available online!

Wednesday, September 21st, 2016
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By Felice Pace, Coordinator for the Project to Reform Public Land Grazing in Northern California

This fall for the seventh straight year volunteers with the Project to Reform Public Land Grazing are on the ground in Northern California’s national forests documenting the manner in which public land grazing is being managed or, as is usually the case, mis-managed. What is different this year is that we have video documentation available online. Check out the public land grazing videos on my You Tube channel: https://www.youtube.com/user/Unofelice .

Here is our most recent grazing video, from the Carter Meadows Allotment:

Once again volunteer monitors are finding that water quality has been degraded, riparian areas and other wetlands are damaged and wildlife values are sacrificed all to the benefit of private livestock operations. EPIC sponsors the Project and EPIC donors fund my work using the Project’s documentation to push for grazing management reform.

The Projects first intern and EPIC volunteer Victor Ruether examines a cattle-trampled spring in the Trinity Alps Wilderness. Victor is now an environmental lawyer in Oregon.

The Project’s first intern and EPIC volunteer Victor Ruether examines a cattle-trampled spring in the Trinity Alps Wilderness. Victor is now an environmental lawyer in Oregon.

Even when it is well managed, livestock grazing, like all human activities, entails some environmental impact. But proper application of modern grazing management practices and systems, including regular herding, spring and riparian protection, and rest-rotation grazing, can limit those impacts in order to comply with the Clean Water Act and other applicable laws, plans and regulations.

Unfortunately, Forest Service and BLM managers do not require modern grazing management; instead they condone the long-discredited practice known in range management circles as passive, season-long grazing. When using this grazing non-system, livestock owners move their animals, which are typically cattle but may be sheep, horses, goats or even llamas, to meadows and headwater basins on national forest or BLM-managed public lands at the beginning of the grazing season. The owners don’t herd or move their livestock again until the snow flies and it is time to take the animals back to the home ranch or to a feed lot; most owners don’t even visit the grazing allotments on which their animals are grazing for the entire three to six month grazing season.

Left unherded for months on end, livestock in general and cattle in particular find locations they prefer and remain there until all available forage and desirable browse has been consumed. That invariably leads to degradation of water quality, riparian areas, meadows, wetlands and wildlife habitat.

Rural westerners have a colorful term for this type of management; they call it Christopher Columbus Grazing because ranchers release their cattle onto the public lands in spring or summer and don’t discover them again until snow drives the livestock to lower elevation, which is typically sometime in the fall.

Christopher Columbus style grazing results in degraded riparian areas. This is Alex Hole, an Applegate River headwater basin located just north of the Siskiyou Ridge on the California portion of the Rogue-Siskiyou National Forest.

Christopher Columbus style grazing results in degraded riparian areas. This is Alex Hole, an Applegate River headwater basin located just north of the Siskiyou Ridge on the California portion of the Rogue-Siskiyou National Forest.

Passive Season-Long Grazing often results in cattle grazing for long periods in the headwater basins of forest streams, including many within designated wilderness as well as within key salmon watersheds. When headwater springs, seeps, wet meadows and streambanks are trampled every year for 3 or more months the result is hydromodification: streams become broader and shallower and the water table drops; riparian vegetation is damaged or removed; wetlands dry out and eventually disappear and late summer and fall base flow in streams below is reduced. In this way, grazing in Northern California’s wilderness headwater basins is producing negative consequences for salmon, steelhead, rainbow trout, tailed frogs, Pacific Giant salamanders and the other critters that depend on cold, high quality water. It is ironic that those wilderness basins which should be producing the nation’s highest quality water are so often degraded and diminished as a result of unmanaged grazing.

Working for Reform

Decades of unmanaged grazing have degraded, fragmented and dried out headwater willow wetlands

Decades of unmanaged grazing have degraded, fragmented and dried out headwater willow wetlands

To reverse the degraded condition of Northern California’s grazing allotments, the Project to Reform Public Land Grazing aims to change the way public land grazing is managed. Over the course of the past seven years we’ve produced 27 Grazing Monitoring Reports on 17 national forest grazing allotments located within three national forests. Each report contains recommendations to Forest Service managers, as well as state and federal regulators, on the changes needed to improve grazing management in order to comply with the Clean Water Act, the National Forest Management Act, and other applicable laws, plans and regulations You can read or download these reports, as well as our annual reports and presentations on Dropbox at this link.

The Project uses photo and field documentation of grazing management problems to advocate that Forest Service managers require that owners of livestock grazing on our national forests implement modern grazing management systems and techniques in order to protect water quality, as well as fish and wildlife habitat. We also use documentation produced by others, including water quality monitoring findings and reports produced by the Quartz Valley Indian Reservation. And we constantly invite Forest Service managers and those who hold public land grazing permits to join with us in a collaborative approach to grazing reform.

However, in spite of seven years advocating public land management reform and clear documentation indicating that current management is not protecting water quality, riparian areas and wetlands, Forest Service officials have so far refused to make the management changes that are clearly needed. And so the Project, EPIC and the Project’s other sponsors have begun to raise the stakes. We are now going over the heads of the District Rangers who are responsible for assuring proper grazing management to the regional forester and state water quality officials, asking them to intervene to require grazing management reform. And we are considering filing a complaint with the Department of Agriculture’s Inspector General as well as strategic litigation to force the needed reforms.

Forest Serviced grazing managers have stuck their heads in the sand and refuse to see the obvious problems with the manner in which national forest grazing is managed. We aim to force them to remove their heads from the sand and do what is right. If grazing is going to continue on our public lands, managers must require the modern grazing management methods needed to limit negative impacts to water quality, riparian areas, wetland habitats, aquatic species and terrestrial wildlife.

Why not volunteer?

The Project To Reform Public Land Grazing wants more volunteers so that we can monitor more grazing allotments on more Northern California national forests and on BLM administered public land. As the Project’s coordinator, I go out with new volunteers onto grazing allotments they choose to teach them how the Project documents grazing management problems. Volunteers can then monitor on their own or join the Project’s monitoring expeditions into wilderness areas and on other Northern California public lands.

If you would like to volunteer with the Project, or just learn more about what we do and why we do it, give me a call at 707-954-6588. And whether or not you volunteer with the Project, please report to the Project and to EPIC the negative impacts of grazing which you observe while recreating or working on our public lands. If you will share them with us, we pledge to take up your concerns with the Forest Service or BLM managers who are supposed to make sure public land grazing is done responsibly. Use the “Contact Us” link on this web page for a range of contact options.

Public land grazing is deeply entrenched; arguably it is our most intractable public land management problem nation-wide. But by raising the profile of the poor manner in which public land grazing is managed, enlisting Clean Water and other regulators to also advocate for management reform, recruiting other citizens to get involved on-the-ground as reform advocates, and by refusing to accept bad and discredited grazing management, we believe public land grazing can and will be reformed.

If modern grazing management technologies and regular herding were required, those owners unwilling to devote the energy needed to properly manage their livestock on public lands would voluntarily relinquish their grazing permits; those who remain would put in the time and energy required to manage grazing responsibly. That is the Project’s goal: if grazing is to continue on the public’s land it must be managed responsibly.mmm


Westside Rip-off

Wednesday, August 3rd, 2016
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The Westside salvage logging project on the Klamath National Forest (KNF) is having more than severe ecological costs. The Forest Service forecasted making over ten million dollars in timber sale revenue. In reality, the agency brought in less than 5% of that estimate. Timber corporations paid $457,000 to log 13,000 acres in the heart of the Klamath Siskiyou bioregion.

Westside implementation on steep and unstable slopes with small trees left behind. Photo courtesy of KS Wild.

Westside implementation on steep and unstable slopes with small trees left behind. Photo courtesy of KS Wild.

“Required costs to restore the project landscape through site preparation, planting and fuels reduction are estimated as $27,487,000.” -Westside Final Environmental Impact Statement (EIS).

That leaves twenty-seven million more dollars needed to pay for 8,000 acres of replanting, 23,000 acres of fuels reduction treatments and for cleaning up logging slash. Replanting clear cuts, known as plantation forestry, creates highly flammable conditions for decades. The KNF claims it is accelerating reforestation and recovery; however natural regeneration is and was already taking place. Fuels reduction on 23,000 acres is needed to remove the smaller trees and shrubs with no commercial value, which will likely not happen, due to a lack of funding. It is these smaller and finer fuels that are shown to exacerbate fire behavior. The entire premise of the project was based on fuels reduction. Less than 2% of the money needed for these activities was made though timber sale receipts.

Westside logging implementation newly constructed landing site. Photo courtesy of KS Wild.

Westside logging implementation: newly constructed landing site. Photo courtesy of KS Wild.

Patty Grantham, KNF Supervisor and decision-maker for Westside, stated in a recent federal court declaration that without restoration (plantation creation) and fuels treatments, the area would remain at heightened risk for landslides and burning again at high severity. She stated that, funding for fuel reduction work is tenuous, typically very limited and must be appropriated by congress (your tax dollars), and therefore not guaranteed. Grantham also said that, a primary purpose of treating the project area is to restore the forest.

On top of those costs, the cost of repairing one third of the nearly 1,000 legacy sediment sites in the project area, which are road related chronic sources of sediment to our waterways, was estimated at over twelve million dollars. All 802 miles of the rivers and streams, including 101 miles of Coho critical habitat in the Westside project are listed as impaired under the Clean Water Act, which means that current conditions do not meet water quality standards. The KNF stated that, controlling legacy sediment sources and design features would offset much of the increase in cumulative disturbance. In order to get a water quality waiver, the Forest Service came up with a schedule for repairing only 350 legacy sites over the next twenty five years without a guarantee for any funding.

The Westside: Record of Decision; the EIS; all of the supporting reports (hydrology, geology, wildlife, aquatics, recreation, botany et.); consultation with US Fish and Wildlife; National Marine Fisheries Service and approval by the North Coast Water Quality Control Board all relied on plantation creation, fuels reduction and legacy sediment site repair actually taking place.

The claimed purposes of the Westside “recovery” project are for public and firefighter safety for community protection, economic viability, benefiting local communities and restored and fire-resilient forested ecosystems. Without further funding, river communities are more at-risk of high severity fire and have not benefitted, the economics are not viable, thousands of acres of natural restoration and recovery are being damaged and forest ecosystems are less resilient with a higher risk of severe wildfire, chance of landslides and loss of soil stability. At two dollars per truckload of the largest trees, the only benefit went to timber corporations.

The ecological costs of Westside salvage logging deserve attention. Westside will harm or kill an important source population of the Northern spotted owl, which was known to be one of the most productive populations in the entire range of the species. Creeks providing cold water refuge for wild and suffering salmon will be affected. The Caroline Creek bald eagles are expected to abandon their nest site, after decades of re-populating the mid-Klamath region. Endemic Siskiyou Mountain Salamanders, fishers, hawks and nearly every wildlife species in these watersheds may be negatively impacted. Logging is within Wild and Scenic River corridors, mature forest reserves, streamside areas, adjacent to the Pacific Crest Trail and on 2,000 acres of unstable slopes. Implementation of the project will disturb water quality, landscape connectivity and natural recovery. The loss of big trees impacts complex forest structure, carbon storage, shade, cooler microclimates, soil nutrients, and high quality habitat and slope stability.

Beyond the thousands and perhaps millions of dollars taxpayers spent planning the project; we are now on the hook for forty million dollars more to pay for restoration and fuels reduction. Wild places, wildlife, water quality and communities are paying an immeasurable and long-term cost, while timber corporations benefit. The irreversible damage to the value of intact complex forest ecosystems and the services they provide has not been calculated. The Westside salvage project adds up to an unnecessary colossal waste and possible environmental catastrophe.

Click here to learn more about the ecological costs of the Westside project.

 Natural recovery taking place around these trees proposed for extraction in the Westside project. Photos courtesy of Kimberly Baker.


Environmental Groups Move to Intervene in Elk River Water Quality Lawsuit

Tuesday, March 15th, 2016
By
Elk River Flooding

Flooding of Elk River

Arcata, Calif. – The Environmental Protection Information Center (EPIC), the Pacific Coast Federation of Fisherman’s Association (PCFFA), and the Institute for Fisheries Resources (IFR), filed paperwork this week to intervene in a lawsuit to defend clean water from logging pollution.

EPIC and allies seek to defend the North Coast Regional Water Quality Control Board’s May 20, 2015 decision to not authorize discharges of sediment and other associated waste into waters of the Elk River watershed from logging operations under Humboldt Redwood Company “McCloud Shaw” Timber Harvest Plan (1-12-110HUM). Humboldt Redwood Company brought suit in Sonoma Superior Court to force the Water Board to allow it to pollute.

The Elk River watershed, located just south east of Eureka, California, was declared significantly adversely and cumulatively impacted by discharges of sediment and other waste as a result of reckless and poorly-regulated timber harvesting operations conducted in the watershed by the then-Pacific Lumber Company, under the ownership of MAXXAM Corporation and Charles Hurwitz.

Water quality impacts include significant reductions in stream and channel capacity resulting from overwhelming sedimentation, resulting in increases in the frequency and intensity of flooding and destruction of traditional domestic and agricultural water supplies, and the destruction of salmon habitat. Because of its impaired state, the Elk River watershed was added to the list of impaired waterbodies in Section 303(d) of the federal Clean Water Act in 1998. An October 2015 report on the conditions of the river and sediment impacts from ongoing logging now being conducted by Humboldt Redwood Company found that the company’s timber operations are still polluting the Elk River, and that the watershed’s condition continues to worsen.

Elk River Rd Flooding

North Fork Bridge on Elk River Road at intersection with Wrigley Road. Note, only the guardrails of the bridge are visible. Photo taken by Kristi Wrigley on January 17, 2016

In the nearly 20 years since the declaration that the watershed is cumulatively impacted and the 303(d) listing, the North Coast Regional Water Quality Control Board, the state agency responsible for administering the PorterCologne Water Quality Control Act, and protecting, enhancing, maintaining and restoring the quality and beneficial uses of waters of the state, has undertaken a 2 number of regulatory and non-regulatory actions aimed at addressing the sediment impacts and correcting the ongoing discharges of sediment and other waste resulting from industrial timber operations in the watershed.

“The time is long past due to address the sources of pollution and recover the Elk River,” said Rob DiPerna, EPIC’s Forest & Wildlife Advocate. “The forest, and the watershed and its residents have suffered long enough.”

Humboldt Redwood Company’s lawsuit comes against the backdrop of the North Coast Regional Water Quality Control Board’s plans to adopt a Total Maximum Daily Load for Elk River, and to adopt a newer, and more restrictive water quality control permit for the company, at its April 7, 2016 meeting, to be held in Eureka, California.


Westside Community Meeting in Orleans September 11th

Monday, September 7th, 2015
By

Westside from BR Lookout

This Friday, concerned community members will be meeting to discuss impacts of the Westside project on our communities. In the coming days, the Klamath National Forest plans to auction off 14 timber sales, that have been analyzed as part of the Westside post-fire logging project, a large commercial salvage logging proposal that covers over 30,000 acres of management including logging on about 10,000 acres of forests affected by the Whites, Beaver and Happy Camp fires of 2014. Areas proposed for logging are adjacent to wilderness areas, the Pacific Crest Trail, within Wild and Scenic River corridors, critical habitat for coho salmon and northern spotted owls and wildlife corridors that are important for providing linkages between the islands of protected areas. The timber sales proposed in the Westside project are all located within the blue circle on the map (below). The Klamath National Forest has not yet released the Record of Decision, which was expected this week, and has not completed formal consultation with the U.S. Fish and Wildlife Service or National Marine Fisheries Service. The Klamath National Forest has not yet received a water quality permit from the North Coast Regional Water Quality Control Board.

EPIC Connecting Wild Places with Westside IDsmallOver the past year, our staff has read and commented on the Westside Environmental Impact Statement and attended the informational meetings put forward by the Klamath National Forest, and we have all agreed that the information and format that has been provided is less than helpful.

In order to better understand the landscape that will be affected by the proposed Westside Project, we have used the shape files for the project boundaries to illustrate aerial images from google earth. These maps more accurately depict the scale, magnitude and context of the proposed project by showing the project in relation to the watersheds that are at stake. These maps will be available at the community meeting.

The Karuk Alternative maps that were developed by the Karuk Tribe have proposed to reduce the project scope to focus on strategic ridge-top fuel breaks to protect rural communities so that fire can be reintroduced to the landscape. The Karuk Alternative is a third of the scale of the Klamath National Forest’s proposal.

Since the beginning of time, fire has shaped the landscape of the region, and it is well documented that cultural burning was used to thin the understory, and allow for healthy larger trees to thrive. prescribed fires were also used to encourage the growth of important resources such as acorns and bear grass, which is used by local tribes to make baskets. Over the last century, these mountains have endured the ecologically damaging practices of clear-cut logging, fire suppression, and plantation forestry, which shape most of the landscape we see today. If you live in or visit the Klamath-Siskiyou mountains and observe your surroundings, you have probably noticed the vicious cycle of:

1. clear-cut logging of the big old fire-resistant, shade-producing trees;

2. plantations that quickly become brush fields due to lack of funds to maintain them in an ongoing way;

3. fire suppression policy that continually increases the size and severity of fires that get away;

4. fire-fighting strategies that increase the size of the burned area; and

5. salvage sales that cost taxpayers more than the government makes on the sale, and in many cases leave huge amounts of slash on the ground, setting us up for the next fire. (And setting the fish up for a hot, sediment-choked, disease-prone environment.)

If you would like to learn about the size, scope and specifics of the Westside salvage sale and discuss potential consequences and community responses, you are cordially invited to come to this important informational meeting for Westside post-fire logging project on Friday, September 11, 2015 at 6:30 pm at the Karuk DNR-Department of Natural Resources Community Room, 39051 Highway 96. In Orleans, CA. All are welcome. Refreshments and dinner included, but bring a potluck dish to share if you can.

DIRECTIONS: Headed northeast on Highway 96, go one quarter mile past Orleans and cross the bridge over the Klamath. The parking lot is on the right hand side (Just after Red Cap Road). Cell phones and GPS Navigation systems do not work here, so you may want to map your route in advance. Allow ~2 hours of drive time from Arcata area.

RESOURCES:

Google Earth image maps with timber sale boundaries – Organized by timber sale and/or watershed.

Westside Fact Sheet and Agency Contacts for Westside Project – 1 page fact sheet for letter writing.

EPIC Guide to Groundtruthing trifold – An excellent guide for analyzing project impacts in the field.

The Westside Story – An in epic analysis of the wildlife, wild rivers, and wild places that would be affected by the Westside project.

Final Comments on Westside DEIS – EPIC, Klamath Forest Alliance and KS Wild comments on the Westside Draft Environmental Impact Statement.

The Westside Final Environmental Impact Statement – A link to all of the Klamath National Forest’s documents related to the Westside project.

Timber Sale Maps developed by the Klamath National Forest:

Whites Fire Salvage Heli Map

Walker Creek Fire Salvage Heli Map

Tyler Meadows Fire Salvage Heli Map

Tom Martin Fire Salvage Heli Map

Slinkard Fire Salvage Heli Map

Salt Creek Fire Salvage SBA Map

Middle Creek Fire Salvage Heli Map

Hamburg Fire Salvage Map

Greider Heli Fire Salvage Map

Cougar Heli Fire Salvage Map

Cold Springs Fire Salvage Map

Caroline Creek Fire Salvage Heli Map

Blue Mountain Fire Salvage Heli Map

Beaver Fire Salvage Timber Sale Map

 

FlyerWestsideMeeting


Take Action: Klamath River Runs Brown!

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

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

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

Salmon

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

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

Roads

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

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

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

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

The Past the Future and Westside

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

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

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

Rivers and Creeks up Close 

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

Klamath River

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

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

North Fork Salmon River

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

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

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

South Russian Creek and Music

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

Whites Gulch

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

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

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

 

Grider Creek/ No Name Creek (Grider Tributary)

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

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

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

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

 

Walker Creek

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

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

Elk Creek 

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

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

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

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

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

Beaver Creek

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

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

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

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

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

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

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


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

Wednesday, July 15th, 2015
By

Smith River by Amber Shelton SM

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

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

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

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

 


State of Elk River—Cumulative Impacts, Contemporary Challenges

Monday, June 22nd, 2015
By
Source: Lost Coast Outpost.  According to local Angela Tellez who took the photo, “It floods like this at least once a year, though this year this is the third time it’s flooded this much. It’s from the hole in the Headwaters, all the logging over here and it’s getting worse every year.”

Source: Lost Coast Outpost. According to local Angela Tellez who took the photo, “It floods like this at least once a year, though this year this is the third time it’s flooded this much. It’s from the hole in the Headwaters, all the logging over here and it’s getting worse every year.”

It is said that those whom forget history are doomed to repeat it. When it comes to the Elk River watershed, located just south of Eureka, in Humboldt County, California, perhaps the saying should read “those whom forget history are doomed to exacerbate its effects.”

Over 150 years of intensive forestland management in the Elk River watershed have profoundly changed the landscape, and left behind a legacy that continues to confound contemporary forest policy debate. The Elk River watershed has long been a focal point of EPIC’s advocacy efforts. While much of this effort has been focused on preserving the remaining old-growth of Headwaters Forest, the solutions to recovering the forest, watershed, and wildlife are much less clear.

There can be little debate that forest management practices in Elk River have improved dramatically over the last several decades. In particular, forest management has significantly improved on the former Pacific Lumber Company Lands, now owned by Humboldt Redwood Company (HRC). HRC serves as a stark contrast to the intensive liquidation logging conducted in Elk River by Pacific Lumber during the MAXXAM days. HRC has ended the practices of clearcutting and the logging of old growth, and has proven itself to be a law-abiding citizen, in stark contrast to its predecessor.

Questions remain, however, as to whether or not this change in heart and practice is enough. The forests of Elk River have been depleted, the watershed is in a state of disrepair, fish and wildlife species continue to struggle, and downstream residents continue to feel the effects of a century and a half of resource extraction. These cumulative impacts persist and serve to confound contemporary management, law, regulation, and policy.

While both HRC and Green Diamond Resource Company continue to produce forest products, conditions in the Elk River watershed have been slow to respond and recover from past management. While the debate about the effects of contemporary management rages on, the watershed, the wildlife, and downstream residents continue to suffer, thus begging the question about forest and watershed recovery. In-stream remediation projects which could benefit residents, fish, and wildlife, are mired in regulatory red-tape, and even the most optimistic estimates indicate that these projects could still take years to implement.

State regulatory mechanisms, which were largely responsible for enabling Pacific Lumber to perpetrate much of the contemporary damage that has been done to Elk River, have proven ineffective and inadequate to address pre-existing cumulative impacts in the context of modern timber harvest permitting. CAL FIRE continues to approve THPs in Elk River, while the Regional Water Quality Control Board flounders at its efforts to develop meaningful and effective regulations and permits to protect and recover water quality.

Clearly, a new approach is needed. EPIC is dedicated to working with land managers, agencies, residents, and restorationists to find collaborative, creative, and lasting solutions. Elk River is historically, biologically, and socially significant, and will be a focal point of our advocacy efforts going forward.


Westside Fire Recovery Project a Hot Mess

Wednesday, April 29th, 2015
By

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

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

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

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

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

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

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


The Westside Story

Wednesday, April 15th, 2015
By

from_BR_Lookout_1314

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

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

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

OVERVIEW

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

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

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

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

7,900 acres of prep and plant aka: plantations

75 watersheds impacted

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

14 new stream crossings

152 new landings!

75 existing landings! That may require expansion

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

Whites Russian Fire

Whites Russian Fire

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

North Fork Salmon River

North Fork Salmon River

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

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

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

WESTSIDE WILDLIFE

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

Pacific Fisher

Pacific-Fisher_Bethany-Weeks-300x200

Photo Credit: USFWS

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

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

Bald Eagle

Photo Credit: USFWS

Photo Credit: USFWS

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

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

Northern Spotted Owl

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

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

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

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

Northern Goshawk

northern goshawk FWS

Photo Credit: USFWS

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

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

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

Siskiyou Mountains Salamander

Siskiyou Mountain Salamander photo credit: USFWS

Photo Credit: USFWS

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

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

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

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

Scott Bar Salamander

Salamander Plethodon Photo credit: USFWS

Photo Credit: USFWS

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

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

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

Photo credit: Oregon Dept. of Wildlife

Photo credit: Oregon Dept. of Wildlife

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

Willow Fly Catcher mapWillow Flycatcher

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

Western Bumble Bee

Photo Credit: USFWS

Photo Credit: USFWS

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

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

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

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

Franklin’s Bumble Bee

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

Peregrine Falcon

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

Snag Dependent Species

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

White-headed Woodpecker Photo Credit: USFWS

Photo Credit: USFWS

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

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

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

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

Hardwood Dependent Species

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

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

Neo-tropical Migratory Birds

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

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

American Marten

Photo Credit: USFWS

Photo Credit: USFWS

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

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

Wolverine

Wolverine Photo Credit: NPS

Photo Credit: NPS

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

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

WILD SALMON AND AQUATIC SPECIES

Elk Creek

Elk Creek

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

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

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

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

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

Wet Weather Logging in Klamath National Forest October 2014

Wet Weather Logging in Klamath National Forest October 2014

Roads, Landings and Water Drafting

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

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

Cumulative Effects

Whites Gulch

Whites Gulch

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

Management Indicator Species (MIS)

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

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

WATER QUALITY

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

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

Risk to Channel Morphology

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

Risk of Sediment Regime Alteration

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

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

Risk of Temperature Regime Alteration

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

Trend of Riparian Function

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

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

Key Watersheds and the Aquatic Conservation Strategy

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

Northwest Forest Plan (NFP) B-18

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

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

WILD AND SCENIC RIVERS

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

The project proposes:

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

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

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

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

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

WILD PLACES

Late Successional Reserves

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

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

Live Trees

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

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

Roadless Areas

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

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

Klamath-Siskiyou Bioregion

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

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

VISUAL QUALITY

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

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

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

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

SOILS  

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

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

Soil Stability

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

Surface Organic Matter

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

Soil Organic Matter

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

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

Soil Structure

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

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

GEOLOGY  

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

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

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

BOTANY

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

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

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

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

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

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

Sensitive Vascular Plants

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

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

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

Sensitive Fungi, Lichens and Bryophytes

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

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

Survey and Manage Plant Species

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

Survey and Manage Bryophytes 

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

Survey and Manage Fungi 

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

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

Non-native Invasive Species

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

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

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

CULTURAL RESOURCES

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

RANGE 

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

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

SOCIAL, ECONOMIC AND COMMUNITY IMPACTS 

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

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

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

CLIMATE CHANGE

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

Region 5 Ecological Restoration Implementation Plan

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

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

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

NATURAL REFORESTATION AND RESTORATION

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

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

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

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

CONCLUSIONS

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

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

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

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

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


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

Wednesday, March 25th, 2015
By
Westside photo 2

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

 

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

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

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

westside photo

North Fork salmon River Salmon Salvage Timber Sale 2013

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

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

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

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

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


Update on Caltrans’ Last Chance Grade Project

Thursday, February 19th, 2015
By

Drilling Last Chance Grade

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

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

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

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

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

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