Clean Water

The Westside Story

Wednesday, April 15th, 2015
By

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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
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Westside photo 2

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

 

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

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

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

westside photo

North Fork salmon River Salmon Salvage Timber Sale 2013

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

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

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

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

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


Update on Caltrans’ Last Chance Grade Project

Thursday, February 19th, 2015
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Drilling Last Chance Grade

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

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

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

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

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

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


EPIC in Review

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

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

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

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

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

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

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

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

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

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


Save Richardson Grove: Think Globally, Act Locally

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

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

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

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

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

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

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

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

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

•Ensuring best management of public forestlands; and

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

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

 


Caltrans Setting Sights on Redwood National Park

Thursday, January 15th, 2015
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Last Chance GradeCaltrans is in the beginning stages of planning for the Last Chance Grade Project along Highway 101 (10-miles south of Crescent City), where the highway is slipping into the Pacific Ocean. This project would have significant environmental impacts, as the highway would likely be rerouted to the east through Redwood State and National Parks.

EPIC is committed to finding the least environmentally destructive alternative for this project and will work tireless to hold Caltrans to the law. We need your help. Please attend the meeting most convenient to you. We need to show Caltrans that the community is paying attention to this project and let them know we will protect our ancient redwood forests and coho salmon-bearing streams. Click here to learn more about the project.

A series of community workshops will be held to get public input and ideas on a range of possible alternatives for Last Chance Grade. Come to a workshop to learn more and share your ideas:
Crescent City – Monday, January 26, 2015
5:30 p.m. – 7:30 p.m.
Del Norte County Fairgrounds
Arts & Crafts Building
421 Highway 101 North

Eureka – Tuesday, January 27, 2015
5:30 p.m. – 7:30 p.m.
Wharfinger Building
Great Room
Eureka Public Marina, #1 Marina Way

Klamath – Wednesday, January 28, 2015
5:30 p.m. – 7:30 p.m.
Yurok Tribal Office
Klamath Community Room
190 Klamath Boulevard

These meetings are being characterized as a series of workshops, with small breakout groups. There are six different preliminary alternatives for consideration that will be further analyzed as part of the design engineered feasibility study that will be completed by July 2015. All meetings will be verbally recorded so that the content is sufficiently captured. We have seen no notification to the public regarding these meetings.


Thank You Jared Huffman!

Wednesday, January 14th, 2015
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HuffmanEPIC would like to thank Representative Jared Huffman for his outstanding work on environmental issues affecting Northern California. Huffman has a long history of championing environmental causes. Prior to serving California’s Second Congressional District, he worked as an environmental attorney for the Natural Resources Defense Council. Since first being elected in 2012, Representative Huffman has:

  • Protected Humboldt County’s water rights from encroachment from Central Valley irrigators;
  • Expanded the California Coastal National Monument off the Mendocino coast;
  • Fought trespass marijuana grows in public forestlands; and
  • Defended the Arctic National Wildlife Refuge from development.

For these things, and many more, EPIC is thankful. Help us thank Representative Huffman by calling his D.C. office at (202) 225-5161 and telling him to continue the good fight!


Dear Santa: Save our Beautiful Wild Rivers from Strip Mining

Friday, December 12th, 2014
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Santa and river image for alertTake Action: All we want for Christmas is a mineral withdrawal

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

Here’s what’s at stake:

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

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

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

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

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

 

 

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

EPIC in Review

Monday, November 24th, 2014
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Redwood Tree Sit

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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


Take Action to Avoid Another Catastrophic Klamath River Fish Kill

Tuesday, August 5th, 2014
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DSCF3762Click here to take action now: Right now, an estimated 93,000 fall Chinook salmon are in the ocean off the Northern California Coast waiting to enter the Klamath. The conditions they will be met with as they begin their journey to reproduce are currently equivalent to a death sentence. In 2002, low flows and warm water temperatures caused by dams and diversions in the Klamath Basin resulted in the largest fish kill in U.S. history, when an estimated 60,000 fall Chinook perished. Since the fish kill, the Bureau of Reclamation (BOR) has released a preventative pulse flow into the Trinity River from Lewiston Dam when conditions existed that were similar to 2002. Currently, Klamath River flow is lower than it was in 2002 and temperatures are consistently higher than the acute stress level for Chinook, 72 degrees Fahrenheit. If this trend continues, a large-scale fish kill is likely and the Klamath could lose the entire run, which would have huge implications, environmentally and economically, costing taxpayers millions in relief and mitigation costs.

Last week, the BOR announced that it would not release the preventative flows needed to avert a fish kill. Instead, they will wait until salmon show signs of disease and start dying, and would only release an “emergency flow” that would take at least four days to reach infected salmon in the Lower Klamath. It is widely accepted fact that once salmon are diseased and dying to the extent that the emergency flow criteria is met, an attempt to minimize losses will be too late and a large-scale fish kill in the Lower Klamath would already be well underway.

The water is available, but according to the BOR saving the lives of 93,000 spawning salmon is not a priority. Of the 2,900 cubic feet per second (cfs) flowing through the Trinity system from Clair Engle Lake, only 490 cfs are being released into the Trinity River downstream of Lewiston Dam, roughly 17%. The BOR is sending the rest of the available water, roughly 2400 cfs or 83% to the Central Valley Project to meet the demands of large-scale agriculture like the Westland’s Water district, and to meet recovery requirements for the endangered Delta Smelt that are facing extinction due to large ag interests including Westlands diverting water in the Smelt’s native habitat—the Sacramento and San Joaquin Deltas.

The Klamath River is home to the third largest salmon run on the West Coast and is thought to have the highest potential for complete salmon recovery in the United States. Currently, the Klamath River is blocked by six dams. Efforts are underway to remove the four largest dams that obstruct fish passage through historic agreements between tribes, environmental groups, fishing groups, government agencies and the company that owns the dams, PacifiCorp.  The Klamath Basin Restoration Agreement and Klamath Basin Hydro-Settlement Agreement have been combined and introduced in Congress as the Klamath Basin Community and Economic Recovery Act. While these worthy efforts are underway and the prospect of a restored Klamath Basin is becoming a reality, it is critical that the remaining salmon and steelhead runs are protected until the dams come out, which is expected to happen around 2020.

Klamath salmon need your help! We need to convince the Bureau of Reclamation, the Secretary of the Interior, Sally Jewell, and President Obama to release preventative flows into the Trinity River to save the fall salmon run from river conditions that are even more severe than those that caused the country’s largest fish kill in 2002. Please click the link below to send a letter to decision-makers, asking them to reduce flows to irrigators and increase flows into the Trinity River from Lewiston Dam, and into the Klamath River from Link River Dam.

Click Here to Take Action!


EPIC in Review

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

EPIC Bay Delta Conservation Plan Comments 

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

Letter to Evans & Chesbro Regarding Groundwater Regulations

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

Community Letter Opposing H.R. 1363

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

Oppose HR 4742 Community Letter

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

Oppose the Anti-National Wildlife Refuge Rider

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

Oppose Toomey Amendment

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

Opposition letter S 2363 Sportsmens Act 2014 – 7.8

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

Sage Grouse Rider Letter

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

TRI_Slider_comments

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

Native American Notification Comments EPIC

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

Passenger Pigeon Proclamation Request Letter from 137 Organizations and Institutions

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

OSV Rule – Comment Letter

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

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

 

 

 


Caltrans Agrees to Reevaluate Impacts of Del Norte Highway Project on Endangered Salmon

Tuesday, July 15th, 2014
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SmithIn response to a lawsuit by EPIC and other conservation groups, Caltrans has agreed to reassess impacts of a controversial highway-widening project in Del Norte County on protected salmon and their habitat along the Wild and Scenic Smith River. A settlement agreement will keep in place a court-ordered halt of construction work until Caltrans completes consultation with the National Marine Fisheries Service under the Endangered Species Act and Magnuson-Stevens Fisheries Conservation Act.

“The North Coast community deserves a project that does not put salmon and the Smith River at risk, as well as an honest assessment of the impacts of highway development on the region,” said Natalynne DeLapp with EPIC. “This is an opportunity for Caltrans to reassess whether this project is in the best interests of taxpayers and the environment.”

Caltrans is attempting to widen narrow sections of highways 197 and 199 along the Smith River in California’s remote Del Norte County to provide access for oversized trucks. Construction would increase erosion and delivery of sediment into the Middle Fork Smith River, harming habitat for threatened coho salmon runs that already face a high risk of extinction. The project would undermine public safety by increasing heavy and oversized truck use on narrow roadways along the Smith River Canyon; it would hurt tourism and local residents.

“Caltrans should reevaluate the whole premise of this expensive, unnecessary project that would cause erosion and sediment impacts to critical salmon habitat,” said Jeff Miller of the Center for Biological Diversity. “Caltrans has already wasted more than $9 million of taxpayer money by starting major construction work along a pristine river without first doing a valid environmental review.”

Friends of Del Norte, the Center for Biological Diversity and the Environmental Protection Information Center filed lawsuits in state and federal court in 2013 challenging Caltrans’ approval of the $26 million “197/199 Safe STAA Access Project” due to inadequate review of the environmental impacts. The state agency began cutting trees and removing vegetation close to the Smith River in January and was scheduled to begin major earthmoving and construction work in May.

“Caltrans and the National Marine Fisheries Service should have pursued a scientific study to start this process rather than pay lip-service to written environmental law, said Don Gillespie with Friends of Del Norte. “The important issues of highway motorist safety on Highways 199/197 can be addressed on a smaller scale, without the massive erosive bank cuts required to allow STAA truck passage, that endanger the Smith River water quality and threaten our vital fisheries.”

A Northern District Court judge issued a preliminary injunction in early May stopping Caltrans from doing any further work, citing substantial violations of the Endangered Species Act, a “haphazard” consultation process with the federal fisheries agency, and the potential for irreparable harm to the Smith River and salmon habitat. The court characterized both agencies’ biological assessment documents for the project as “contradictory and unclear.”

As part of the new settlement, Caltrans has now reinitiated consultation with the National Marine Fisheries Service to properly analyze whether the project would jeopardize threatened coho salmon and their critical habitat in the Smith River or adversely affect the essential fish habitat of all salmon species in the river. The conservation groups retain the right to challenge any further agency decisions or environmental documents for the project.

Caltrans has not considered alternatives besides widening the highway and tried to downplay project impacts on salmon habitat and water quality along the Smith River. The agency refused to evaluate safety hazards from increased truck traffic and ignored the cumulative impacts of numerous other associated Caltrans highway-widening projects in Northern California for oversized truck access. Despite the Fisheries Service’s own data on the imperiled status of coho salmon in the Smith, the fisheries agency rubber-stamped the original project without sufficient review. The plaintiffs are represented by attorneys Stuart G. Gross and Sharon Duggan and the nationally recognized firm of Cotchett, Pitre & McCarthy.

Background

Highway 199 is a scenic byway along the Smith River Canyon that passes through the Six Rivers National Forest and the Smith River National Recreation Area and provides access to Redwood National and State Parks. The Smith River is the only undammed river in California, with the longest stretch of designated “wild and scenic” river in the lower 48. A 1989 Caltrans report acknowledged the physical constraints of the narrow, steep and rocky Smith River Canyon and concluded that environmental concerns make Highway 199 “a poor candidate for extensive upgrading.”

Highway 197 is a seven-mile, two-lane country road that runs north to south along the lower Smith River just northeast of Crescent City. It is a rural-residential route with 72 driveways directly entering onto the road. In order to avoid Jedediah Smith State Park at the western edge of the project, oversized trucks would divert off Highway 199 and travel along Highway 197 to the north of Crescent City to reach Highway 101.

Court challenges to the related Caltrans road-widening project through Richardson Grove on Highway 101 in Humboldt County have resulted in rulings determining that Caltrans failed to adequately analyze the potential impacts of highway development on the ancient redwoods protected in Richardson Grove State Park.

A recently released independent review of Caltrans called for sweeping reforms of the agency and cited a “culture of fear” within Caltrans when it comes to deviating from standard policies. The statewide Caltrans Watch coalition has highlighted the agency’s pervasive refusal to consider reasonable alternatives to massive highway projects, shoddy environmental review, lack of transparency, reliance on flawed data and disregard for public input.

Click here to view the Order of Stipulation

Click here to view the Official Press Release


Smith River Threatened by Strip Mining

Wednesday, July 2nd, 2014
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Smith-River

Update9/29/14: Based upon its findings and comments received, the Oregon Department of Water Resources “finds that with the data available there is no basis for appropriate conditions that can be applied to mitigate likely impacts to water quality and sensitive, threatened, and endangered species.” Read the full Final Order to Deny Red Flat Nickel Mine here: Final Order to Deny Red Flat Nickel Mine

Take Action! The Wild & Scenic North Fork Smith River is being targeted for a large nickel mine that would devastate the area for recreation, pollute public drinking water in California, damage critical habitat for the federally threatened coho salmon and other fisheries, and destroy the purest waters in the West.

Red Flat Nickel Corporation, a foreign-owned mining company, has submitted plans to the Rogue-Siskiyou National Forest to conduct exploratory drilling in the Baldface Creek/North Fork Smith River watershed. The company has also applied to Oregon Water Resources Department for a five-year limited license (LL-1533) to extract thousands of gallons of public waters from tributary streams of the North Fork Smith River.

In the plans, Red Flat Nickel Corporation has proposed flying equipment and personnel into the mining site by helicopter to drill 59 three-inch-diameter core samples 50 feet into the ground. The proposed mining site is 3,980 acres of federal mining claims, which are also in the watershed of the Wild & Scenic North Fork Smith River and the Inventoried South Kalmiopsis Roadless Area on the Rogue River-Siskiyou National Forest in Curry County, Oregon.

The information gathered from this exploration will be used to advance mine development of the area. The EPA says the threat of metal mining is the largest toxic polluter in the United States. If one mine starts operating, thousands of acres of other nickel claims could be developed on nearby federal public lands—impacting designated and eligible Wild & Scenic Rivers, and turning one of North America’s most important rare plant centers, imperative habitat for fisheries, and clean water supplies into an industrial wasteland.

A foreign corporation should not be allowed to pollute and despoil the public waters and land resources relied on by local citizens, fisheries, and our ecosytems. Help protect the Wild & Scenic Smith River from devastating foreign strip mining exploration.

This article was composed by Taylor Morrison, an intern with EPIC for the 2014 summer. Thank you to the Kalmiopsis Coalition and the Smith River Alliance for contributing content for this action alert.


Old Growth, Climate Change and Connectivity

Wednesday, July 2nd, 2014
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Old Growth.K.BakerGlobal warming is changing the planet’s ecosystems. The largest oldest trees store the greatest amounts of carbon and play a major role in regulating the Earth’s climate. The movement to protect our vital forests is building rapid momentum.

More than 75 scientists recently requested that the President direct his Secretary of Agriculture and Chief of the U.S. Forest Service (USFS) to craft a National Old Growth Conservation Policy that fully protects the remaining old-growth forests on all national forests. The signatories include PhD professors from throughout the country and Canada, retired state and federal resource agency biologists and two former USFS Chiefs.

The Federal Forest Carbon Coalition—a new first-of-a-kind consortium of over 60 national, regional and local organizations, including EPIC, focused on forests, biodiversity, fisheries, rivers, faith and spirituality, Native American treaty rights, youth, rural communities and climate disruption—recently issued a suite of science-based recommendations to the Obama Administration. Entitled Modernizing Federal Forest Management To Mitigate and Prepare For Climate Disruption, the recommendations for our public lands include permanently protecting all high-biomass forested areas (older forests; live, dead and fallen) from logging, recognizing carbon as a significant public resource, increasing carbon storage, restoring mature forests, promoting more natural fire regimes and a moratorium on fracking.

The U.S. Forest Service manages some of the highest density carbon stores on earth—our  remaining old growth and mature forests. Large old fire resilient trees are the guardians of our air, water, wildlife and forests.  Connecting and protecting older forests will provide refuge and crucial habitat linkages for a wide range of species, allowing for the movement of plants and animals in response to a warming climate.

Federal forest agencies need to make a major shift in policy and practice. While extensive research and collaborative climate adaption strategies have been completed, there has been no significant change in law. Environmental laws are essential to provide the framework and safeguards necessary to protect the thousands of species that make up the web of life.

Climate Change demands political change. Be part of the movement. Please sign and share the Connecting Wild Places petition.

The goal is to reach 50,000 signatures by Sept. 3, the 50th Anniversary of the Wilderness Act.


Off Road Vehicles Proposed by Forest Service in the Smith River National Recreation Area

Tuesday, July 1st, 2014
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Smith River NRAEPIC, Klamath Siskiyou Wildlands Center and other conservation allies submitted comments regarding the Draft Environmental Impact Statement (DEIS) for the Smith River National Recreation Area (NRA) Restoration and Motorized Travel Management on June 9th, supporting a travel management decision that protects the outstanding natural values found in the Smith River NRA by reducing road maintenance costs, protecting and restoring aquatic and terrestrial ecosystems and reducing the spread of Port Orford cedar root disease through road and route decommissioning.

The Forest Service needs to refrain from adding routes and motorized trails to the road system that occur within occupied sensitive plant habitat as well as fully analyze and disclose the impacts of foreseeable illegal off-road use. In addition, the Forest Service must disclose the actual efficacy of agency road gating, blocking, and closure mechanisms. Furthermore, the final travel management decision must contain meaningful and substantive protections for Port Orford cedar populations across the planning area.

The DEIS for the Smith River NRA Restoration and Motorized Travel Management was released to the public on April 11, 2014. The aim of the project is to make changes to the National Forest Transportation System (NFTS) and Motorized Vehicle Use Maps , including adding, upgrading, downgrading, and decommissioning roads to provide for recreation opportunities, administrative needs, and to reduce risk.

In the Smith River NRA DEIS, six alternatives were identified. The Forest Service prefers Alternative 6. Unfortunately, Alternative 6 is primarily based upon the preferences of a collaborative group whose stated purpose was to determine how to add “high risk” controversial user-created routes to the Smith River NRA NFTS. These “high risk” routes provide no administrative or recreational purpose other than to fulfill the desire to engage in extreme off-road travel. In addition, the preferred alternative would add routes and motorized trails to the NFTS that occur within occupied sensitive plant habitat. It is undeniable that the existing network of roads and routes within the NRA are major causes of chronic sedimentation problems in streams, cause damage to rare and endemic plant populations, contribute to the loss of roadless wildland recreational opportunities, and increase the spread of Phytophthora lateralis (plant pathogen that causes Port Orford cedar root disease). Although the Forest Service acknowledges these problems, it plans to monitor less than 1 in 5 of these “high risk” routes over the next 10 years if funding is even available.

Under the Smith River National Recreation Act, the Forest Service has a responsibility to preserve, protect, and enhance the unique biological diversity of the NRA. EPIC and its supporters feel that the Forest Service’s preferred alternative, which favors the interests of 1.1% of the Six Rivers Forest visitors, does not adequately protect the significant ecological, recreational, and hydrological values the Smith River NRA is charged with protecting. EPIC and its allies  hope that the preferred action is not pre-ordained and that its substantive, technical, and site-specific comments are adequately acknowledged and addressed.

This article was written by Jason Landers, an intern with EPIC for the 2014 summer.

Click here to read the full comments.


EPIC in Review

Tuesday, July 1st, 2014
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EPIC Kate Wolf 2014-2The Environmental Protection Information Center has no problem keeping busy. This last weekend EPIC staff reached out to thousands of people at the Kate Wolf Festival, gathered hundreds of signatures to Connect Wild Places, and to oppose the Bay Delta Conservation Plan. At this event, we quickly realized that people are deeply concerned with the fate of our environment, and want to know what is going on, and how they can contribute towards safeguarding the ecosystems that we all depend upon. We greatly appreciate these opportunities where we get to know the roots of our community and build the lifelong bonds that fuel our work. For those of you who do not have the opportunity to meet with us in person and get updates on our work, we hope the digest below will keep you informed on some of the most contemporary issues that we are currently addressing.

Federal Forest Carbon Coalition letter to the Obama Administration to mitigate and prepare for climate disruption – Science-based recommendations in response to the President’s November 1, 2013 Executive Order: Preparing the United States for the Impacts of Climate Change.

Comment letter to Redwood National and State Parks for Bald Hills Road Pavement Project – This letter urges the consideration of an alternatives that would not include paving Bald Hills Road.

Comment letter regarding second growth thinning for Middle Fork Lost Man Creek – A letter of support for thinning over-dense second-growth forest stands in Redwood National Park.

Letter of opposition for the Vessel Incidental Discharge Act of 2014 – S. 2094 is a bill that would perpetuate a regulatory scheme that continues to place the economic burden associated with invasive species on the nation’s taxpayers rather than shifting it to the industry responsible for bringing those species into the nation’s waters. Click here to view the Fact Sheet relating to S. 2094.

Letter of support for the Mokelumne River Bill – SB 1199 would designate the Mokelumne River as a Wild and Scenic River, which would permanently protect 37 miles of river.

Letter opposing the Lowering Gasoline Prices to Fuel an America That Works Act of 2014H.R. 4899 would undermine how the Department of Interior manages federal lands to prioritize oil and gas development over alternative uses of federal lands and waters.

Letter of appreciation to the California Fish and Game Commission thanking the Commission for taking action to protect the gray wolf under the California Endangered Species Act.

Letter to Oregon Water Resources Department opposing the Red Flat Nickel Corporation’s mining proposal – The mining company has requested to use water for mining activities in the National Wild and Scenic North Fork Smith River and Baldface Creek watersheds.

Comment letter regarding AB 2082 – The bill proposes minimum resource conservation standards or minimum stocking standards pertaining to forest practices on private forestlands in California.

Letter regarding Notice of Intent to prepare an environmental impact statement that evaluates an amendment to the 2008 Tongass National Forest Plan – This coalition letter encourages a land management plan for Tongass National Forest that ends large-scale old-growth logging.


Take Action to Stop the Bay Delta Conservation Plan

Thursday, June 19th, 2014
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USBR Construction of pump station at Delta-Mendota Canal

USBR Construction of pump station at Delta-Mendota Canal

Take action now to stop the Bay Delta Conservation Plan. The $67 billion infrastructure project proposes to construct two massive tunnels that would funnel water from Northern to Southern California. The Plan calls itself a comprehensive conservation strategy aimed at protecting dozens of species of fish and wildlife, but in reality the 40,000 page document fails to disclose major irreversible impacts to fish, rivers and the economic stability of the state of California. River systems throughout California have been experiencing extreme drought conditions, and historic water rights have not been honored due to the lack of water in our rivers and reservoirs. Building two giant tunnels to transport water from the San Joaquin Delta is not going to carry out either of the Plan’s two main goals: to reliably transport more water to San Joaquin farms and Southern California cities, or to restore the fisheries and ecology of the delta.

The Draft Environmental Impact Report/Statement (DEIR/S) uses models based on over-allocated water rights to analyze the Plan’s environmental impacts, which would result in severe environmental consequences. Building more irrigation infrastructure, as the Plan proposes, is not going to fix drought problems in California. Instead, these projects will exacerbate drought conditions, resulting in greater impacts to endangered fish by reducing flows to impaired watersheds, draining estuaries that are essential to healthy river ecosystems, and allowing the continued operation of pumps that will kill fish that are protected under the Endangered Species Act. The “conservation plan” should instead reduce exports that take water out of rivers, prioritize delta recovery, and improve water conservation measures.

EPIC is part of the Environmental Water Caucus (EWC), which is a collective of environmental and water rights organizations that have joined forces to deal with water issues throughout the state of California. The comments we have developed are abbreviated and adapted from the EWC’s collective comments on the massive DEIR/S that has stirred controversy over the state’s scarce water resources. Help us stop this damaging project before irreversible harm is done to our rivers, fish and the state’s economic stability. Please click here to submit your public comment.

 


EPIC in Review

Friday, June 13th, 2014
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20140531_164412

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

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

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

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

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

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

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

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


Protect the Wild Salmon River – Stop “Salvage” Logging

Tuesday, June 10th, 2014
By

Photo#1_KellyGulchTake Action! The Wild and Scenic (W&S) North Fork Salmon River is threatened with post-fire “salvage” logging. The Salmon/Scott River Ranger District of the Klamath National Forest (NF) is proposing to streamline logging on over 1,000 acres of steep slopes, including road construction over trails and overgrown roads.  Over 60% of the project area is within Critical Habitat for the threatened Northern Spotted Owl.  The W&S North Fork Salmon River is designated a Key watershed, meaning it is critical for salmon recovery.  The river is also listed under the Clean Water Act as being impaired. This project jeopardizes the wild and rugged nature of the North Fork Salmon River.

The Klamath NF Environmental Analysis of the Salmon Salvage project continues to claim that no new roads are needed, however one of the “existing” roadbeds, nearly a mile long, has not been used for decade. It is grown over, laden with landslides and located on a steep and unstable hillside. Heavy equipment and severe earth moving would be required to make it ready for 18 wheeler logging trucks. Where there are roads, there are landings to accommodate heavy equipment.  Landings are bulldozed flats that are 1/2-acre to up to two-acre openings.

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Kelly Gulch A Spur “Existing” Road

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Same “road” look close for flagging, which indicates location of the road

Over 300 acres of the project is within larger forest stands.  One of these areas along the Garden Gulch Trail provides high quality Critical Habitat for the Northern Spotted Owl, and is a popular gateway that leads into the Marble Mountain Wilderness.  EPIC and the conservation community have been defending this beautiful forest stand for a decade, first fighting the Knob Timber Sale, and then recently in opposition to the Little Cronan Timber Sale.  The agency is calling the trail an “existing” road, and now proposes to open the Garden Gulch trail, which is adjacent to a creek, to 18-wheeler logging trucks, bulldozers and other heavy equipment.

Garden Gulch Trail next to the creek and proposed road location

Garden Gulch Trail next to the creek and proposed road location

This particular forest stand, Unit 345, contains hundreds of big older trees, many of which are still very alive and green. It provides a vital link for wildlife connectivity and exemplifies high quality mixed conifer post-fire habitat.  The area burned at moderate to low severity contributing to the ecological quality of this ideal post-fire forest stand.  These trees are providing shade and valuable wildlife habitat, creating a healthy complex forest structure, all part of a natural process. Bulldozers, trucks, roads and landings do not belong on this trail or in this showcase post-fire habitat forest stand.

Southern Boundary next to the Garden Gulch Trail

Southern Boundary next to the Garden Gulch Trail

There are five Northern Spotted Owl (NSO) home ranges within the project vicinity.  Recent science shows that the owls benefit from burned forest stands and that post-fire logging has the potential to increase extinction rates, especially when done within core areas.  The NSO species Recovery Plans calls for “conserving and restoring habitat elements that take a long time to develop (e.g., large trees, medium and large snags, downed wood).

In their rush to implement this ecologically damaging project, the agency has sought an Emergency Situation Determination (ESD) from the regional forester.  If the request for an ESD were to be granted it would mean that trees can be cut down as soon as a decision is issued and a contract is signed, despite any appeal or claims brought in court.  Seeking an ESD circumvents judicial review, eliminating the public’s recourse in challenging poor decisions that threaten our public lands.

Take Action Today to Stop the Salmon River Salvage Project! Let Patricia Grantham, Forest Supervisor of Klamath National Forest know that you oppose post-fire logging that results in habitat destruction and road construction in designated Key watersheds like the North Fork Salmon River. Post-fire landscapes are considered to be one of the most rare, endangered, and ecologically important habitats in the western U.S.  They are rich, vibrant and alive and often provide more biodiversity than green forests.  Read more about the environmental effects of post-fire logging.  Take a walk in Garden Gulch.   See the overgrown unused Kelly Gulch A Spur Road on steep and unstable hillsides proposed for re-construction.  View more photos here.


EPIC In Review

Thursday, May 22nd, 2014
By

HolmFayMG_8852-copy-1024x682When it comes to getting work done, our little organization packs a giant punch.  In recent days, we have been involved in numerous campaigns and are excited to be a part of these grass roots efforts that are shaping our environment and our future. To keep you informed of our happenings, we have provided a sample of the work that we have been involved with over the past few weeks.

Comments to urge Del Norte County to better analyze the Tryon Bridge replacement project – As proposed, this project would result in impacts to the Smith River and steelhead, coho and chinook salmon populations.

California Drought Bill letter – The Drought Bill (HR 3964), proposes to waive major elements of state and federal environmental laws and de-designates a portion of the Merced wild and scenic river. EPIC has joined the Environmental Water Caucus in calling on Representatives to reject this environmentally damaging legislation.

Letter of Support for Humboldt County No GMO Ordinance – This letter urges Humboldt County Board of Supervisors to pass an ordinance that would ban GMOs in Humboldt County. The County had the opportunity to enact the ordinance without going before voters, but voted instead to put it on the November Ballot.

Environmental Coalition Letter to Feinstein and Boxer – As written, Senate Bill 2198 would exacerbate impacts on the environment and the salmon industry without addressing the underlying causes of water shortages. This letter urges Senators Boxer and Feinstein to ensure that their legislation reduces the impacts of the drought on California’s environment and the salmon fishery.

Grassroots Fracking Letter – This coalition letter urges members of the California Legislature to support SB 1132, which will impose a moratorium on fracking, acidizing and other will stimulation techniques.

Request for comment time extension of Bay Delta Conservation Plan – As proposed, BDCP is lacking an implementation agreement, which defines obligations, provides assurances, ensures adequate funding, specifies responsibility for implementing measures, provides for enforcement and remedies for failure, and establishes the process for changes. In this letter, EPIC and others request an extension of the public comment period since the BDCP is incomplete without the implementation agreement because it does not specify any commitments the parties have made to fund and promote mitigation measures.

These efforts would not be possible without your financial contributions. Please consider making a donation to help us continue protecting your wild back yard.