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EPIC and Allies File Objection to North Zone Hazard Tree Management Project

Updated: Jul 31, 2023

The North Zone of the R5 Project, including the Mendocino, Klamath, Six Rivers, and Shasta-Trinity National Forests and showing national forest boundaries and fire perimeters. Map from U.S. Forest Service Region 5 Post-Disturbance Hazardous Tree Management Project Documents.

EPIC has been monitoring the U.S. Forest Service’s Region 5 Post-Disturbance Hazardous Tree Management Project since it was first proposed in 2021. The Project is massive in its scope, covering 9 national forests that have burned in recent years and over 6,000 miles of roads and trails, many of which are seldom used or lead to dead ends. The project is so massive the Forest Service divided it into 3 zones. Our objection is focused on the “North Zone” of the Project, which encompasses the Mendocino, Klamath, Six Rivers, and Shasta-Trinity National Forests.

As currently proposed, the R5 project would permit logging, both snags and living trees, within 300 feet on either side of a road or trail. Green trees that have now survived multiple years post-fire and have 60% or more of their canopy scorched will be targeted. This means forest managers have an incredibly large amount of discretion in terms of deciding which trees to harvest.

Pair that discretion with the over 3,000 miles of roads and trails in the “North Zone” and the result is over 180,000 acres of land eligible for anything from selective thinning to a full-blown clearcut. It’s hard to speak confidently about a project that is so dependent on individual discretion, but in high-severity burn areas the Forest Service’s standard would likely result in 600-foot-wide clearcuts. Imagine 600-foot-wide clearcuts snaking through seldom-used areas of the forest all in the name of “safety”. While some hazard tree removal after a fire is to be expected, particularly on busy roads, the Forest Service’s strategy of painting with such a broad brush allows far more logging than is necessary to protect public safety.

Roadside logging after the 2021 Slater Fire on the Klamath National Forest, with a massive slash pile left behind. Photo by Kimberly Baker / EPIC.

Post-fire logging is an environmental disaster. Fire is a natural occurrence in our forests and our ecosystems are adapted to it. But post-fire logging disrupts their recovery and can permanently impair our forests. After a fire, increased sediment production is likely to naturally impair salmon bearing creeks and rivers like we have seen this week on the Mad River, which has been running chocolate brown for days. But, the disturbance caused by post-fire logging can turbocharge that sediment production, and compound the effects. The trees that do survive a fire are critical sources of seeds that can begin the process of forest recovery. But the Forest Service’s liberal guidelines regarding what constitutes a hazard tree will result in the loss of many of these critical seed trees, impairing post-fire recovery.

Post-fire forests also provide important habitat for many iconic species including the threatened Northern Spotted Owl. The R5 project would remove thousands of acres of habitat. On top of all of that, post-fire logging causes considerable greenhouse gas emissions. Contrary to popular belief, most of the carbon in a tree remains on the ground after a wildfire. Post-fire logging sends that tree to a mill where the majority of its carbon will be emitted into the atmosphere instead of slowly deteriorating and regenerating the forest.

When we submitted comments on this project, we urged the Forest Service to reduce the environmental impact by retaining living trees, focusing on high-severity burn areas, and limiting the Project to roads that are needed by the public. In addition, we advocated for reducing the extent of logging on either side of the road and to fully protect riparian reserves. We believe these are reasonable constraints on a project that otherwise looks more like massive timber sale than a safety measure.

Despite this, the Forest Service has moved forward with minimal changes. Our objection focuses on the lack of environmental review, particularly site-specific environmental review which is a natural result of the broad scope of the Project. Also due to the Project’s tremendous size, the Forest Service submitted documents with many factual errors and inconsistencies. California’s national forests, rivers, and wildlife deserve a better and finer approach to post-fire management.


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