For the past number of months, ASA has been out on the ground monitoring proposed timber sale units in the BLM’s Cedar Flat Timber Sale in the upper Williams Creek watershed. The sale proposed to log 3,222 acres, including 2,493 acres in Late Succcessional Reserve forest designated to protect habitat for the northern spotted owl. This proposal would have logged significant mature, old-growth and primary unlogged forests on the flank of Grayback Mountain, in upper Rock Creek, Glade Fork, West Fork Williams Creek, on Little Sugarloaf Peak, and on the eastern flank of Holcomb Peak.

ASA was publicly opposing these mature and old-growth logging units, had visited every proposed logging unit in the timber sale, was working to draft technical comments on this project, and had begun organizing a public campaign; however, the Medford District BLM just canceled this controversial timber sale!

Although a significant, but perhaps short-lived victory, the BLM has indicated they hope to reconsider this timber sale in early 2025. We invite our supporters to contact BLM and ask them to cancel the mature and old-growth logging units previously proposed in the Cedar Flat Timber Sale. Please let them know that these units should not move forward in future BLM timber sales.

Talking Points:

1. Although we support the cancellation of the Cedar Flat Timber Sale, we are concerned that controversial mature and old-growth logging units may be included in future timber sales proposed in the area. If the Cedar Flat Timber Sale, or a new project based on this timber sale is proposed, we suggest that the BLM focus on the abundant plantation stands found in the area.
2. The Cedar Flat Timber Sale proposed logging units that included some of the last mature and old-growth forest in the Williams Creek watershed. These forests must be withdrawn from further consideration and should not be proposed for logging in any future timber sale.
3. Located in Late Successional Reserve forest, designated to protect habitat for the northern spotted owl, these mature and old-growth forests should be deferred from treatment due to their important habitat values. This includes proposed logging units on the flank of Grayback Mountain, along the Grayback Mountain Trail, on upper Rock Creek, Glade Creek, West Fork Williams Creek, and upper Bill Creek, on Sugarloaf Peak, and on the eastern flank of Holocomb Peak.
4. Ask the BLM to institute a 20″ diameter limit, require the retention of at least 60% canopy cover, limit commercial logging to plantation stands, focus non-commercial thinning adjacent to homes and communities, remove all stands over 80 years of age from logging treatments, and build no new roads if timber sales are proposed in the future.

Contact:

District Manager, Elizabeth Burghard: eburghar@blm.gov

Grants Pass Resource Area Manager, Heidi Lowrey: hlowery@blm.gov

With the fall weather comes the end of the public land grazing season on the Siskiyou Crest. Fall is a good time to go out and monitor the impact of grazing allotments on the public lands of the Siskiyou Crest, including the headwaters of the Applegate River, located on the northern slope of the Siskiyou Crest. The area is filled with sensitive wetlands, meadows, seeps, springs, and headwater streams that become heavily damaged each season by unmanaged cattle, utilizing what the agency calls “passive season long grazing.”

What this means is that cattle are dropped off in the spring and allowed to forage largely unmanaged throughout the grazing season, congregating in wetlands and meadows, along streams and other areas that are sensitive to livestock grazing. The result is the degradation of water quality, impacts to the spongy headwater basins that support water flows during the summer in the Applegate River, damage to willow wetlands, trampling of streambanks, the lowering of water tables, impacts to native vegetation, impacts to wildlife habitat, and increased competition between cattle and native grazing species such as elk and deer.

Each summer there are at least 10 active grazing allotments on the Siskiyou Crest on both the Rogue River-Siskiyou National Forest and the Klamath National Forest, and although stocking levels may change from year to year, there can be up to 2,000 cows permitted on the different allotments on the Siskiyou Crest each year, resulting in long-term ecological impacts.

The Forest Service often claims that historic overgrazing is responsible for the dramatic impacts we see today. Although historic grazing impacts were severe all across the eastern Siskiyou Crest in the historic era, these effects are compounded and reinforced by the overgrazing that continues to occur on public land grazing allotments to this day.

This past October, we visited the Silver Fork Basin in the Beaver-Silver Allotment and Alex Hole basin in the Upper Elliott Allotment, two of the most overgrazed meadow systems and headwater basins in the Applegate River watershed and on the eastern Siskiyou Crest. We found both areas heavily overgrazed.

Watch ASA’s new video about public land grazing on the Siskiyou Crest.

In particular, we found Alex Hole and the surrounding meadows heavily trampled and “over utilized,” meaning palatable vegetation had been eaten down to the nub, precluding both flower production and seed production for many species. Denuded to ground-level, the meadows and streams in the Alex Hole basin support almost no forage for native ungulates such as deer and elk, and cannot provide stream shade due to heavy browsing by cattle in the summer and fall.

Earlier this summer we had visited Alex Hole on the second day of grazing season and found it to have already been significantly overgrazed, just two days into the season, meaning the cows had been there before they were permitted to be there.

Currently riparian habitats throughout the watershed within federal grazing allotments are collapsing, streams are downcutting, noxious or non-native weeds are spreading, and native riparian vegetation, such as willow, is being denuded across entire stream reaches. Waterways and springs are also filled with cow excrement, and deep “punching” where cattle hooves sink deep (6″-10″) into moist soils, damaging wetlands, seeps, springs and streams through excessive trampling, excessive soil disturbance, damage to native vegetation, hydrological impacts, downcutting and the slow, steady de-watering of these habitats through the compounding impacts.

In many favored grazing sites, cattle have eaten sedges, grasses and other herbaceous species to the ground, leaving little for wildlife, including deer and elk that also forage on these same native plants and in these same native plant communities. Additionally, aspen habitats have been heavily impacted on Alex Creek, including some of the region’s only tree-form aspen stands which are now heavily degraded, unable to regenerate, and slowly dying out due to extreme and continuous grazing impacts to aspen groves on Alex Creek.

Numerous sensitive wildlife species, such as the willow flycatcher, a small song bird that utilizes mature willow stands for nesting and foraging are also being impacted by overgrazing on the Siskiyou Crest at the Applegate’s headwaters. Willow flycatcher habitat requires dense, continuous willow stands, which are heavily fragmented by cows within the tiered meadow system of the Alex Hole basin, as well as in Silver Fork basin, and in some areas the willows have been entirely extirpated from specific stream reaches due to heavy trampling and grazing.

Sensitive species like the Sierra Nevada blue butterfly utilize the high elevation alpine shooting stars (Dodecatheon alpinum) as a larval host plant; however, cattle trample these larvae, eat the larvae while gazing, and target shooting star flowers and stalks as a favored species to eat early in the season. This precludes flower production and seed production of alpine shooting stars, limiting the geographic extent of this species and hindering its natural regeneration process, thereby impacting the ability of the Sierra Nevada blue butterfly to live in these meadows because they can’t complete their lifecycles without their larval host plant.

In fact, the federal livestock grazing program is heavily subsidized by the public. In 2015 resource economists studied the costs of livestock grazing on public lands. They found that the federal lands grazing program generated $125 million less than what the federal government spent on the program in 2014. Further, they found that federal grazing fees are 93 percent less than fees charged for non-irrigated Western private grazing land, or just $1.69 per animal per month for each cow and calf that grazes the public land. It costs more to feed a house cat, and this year’s fees are even less — in 2024 the fee was a paltry $1.35.

Public land grazing has many impacts, both contemporary and historic, but the negative effects of current public land grazing practices are clear to see on the Siskiyou Crest. These public lands contain important biological, recreational, scenic, and watershed values; yet, they are being managed as private feedlots, for federal grazing permittees, who both benefit from and significantly impact federal lands. Who does not benefit is the public, who is forced to socialize both the costs and impacts of this management.

Please help us bring public land grazing in the Applegate into the 21^st century. This begins first and foremost, with the Siskiyou Mountains Ranger District completing an Environmental Impact Statement for all grazing allotments in the Applegate, utilizing the best available modern science and research. It also begins with your advocacy, asking Forest Service managers to adopt and implement site specific Best Management Practices (BMPs) for each grazing allotment, along with publicly available Annual Operating Instructions (AOIs), that:

1. Incorporates the new mandates of the North Coast Water Quality Control Board that now requires Annual Operating Instructions (AOI) for all federal grazing allotments within its management area, including the headwater streams of the Applegate on the Siskiyou Crest. The Rogue River-Siskiyou National Forest must comply with the Clean Water Act management requirements adopted by the North Coast Water Board in its Federal lands Permit.
2. Requires electronic (virtual) fencing for cattle on the Siskiyou Crest to allow land managers to better track their location, manage their movements, document cattle “drift” or trespass into unauthorized areas, and to help reduce impacts to sensitive habitats and species by herding cattle that congregate in specific habitats, especially wet meadows and rare plant populations.
3. Mandates site specific BMPs the grazing permit holder must implement to prevent unacceptable levels of water quality, riparian and wetland degradation, including but not limited to, instructions on rotating grazing among different areas, and the frequency and type of herding needed to avoid unacceptable levels of degradation.
4. Requires the agency to commit to a number of monitoring visits to each allotment on an annual basis. The agency should document the number of times and time periods that Forest Service staff will check each allotment to verify that the required grazing management actions specified in the AOI are being adequately implemented.
5. Requires mitigation in basins and watersheds that are listed as “impaired” due to sediment, water temperature or nutrient conditions. Mitigation measures should require at least a year of rest for watersheds in which the annual Multiple Indicator Monitoring (MIM) reading finds bank disturbance equal to or greater than 10%.
6. Mandates protections for rare and unusual plant species and Botanical Areas on the Siskiyou Crest, including both sensitive plants and unique plant communities like quaking aspen stands.
7. Mandates protections for the Pacific Crest Trail, its trail side camps, water sources, and scenery.
8. Requires additional protections and mitigation measures that benefit wildlife, including deer and elk.

Some of the local grazing allotments have not been meaningfully reviewed or received updates to their management plans since 1964, clearly it is time for an update and a shift towards more a modern, responsible approach to federal land management. The current management plans are badly outdated and the allotments are badly damaging habitats.

Finally, any new management plans developed by the the Rogue River-Siskiyou National Forests should allow buyout options for federal grazing allotments and permits. This would allow grazing allotments to be publicly bought out and retired to protect and restore the biological, scenic and recreational values of the Siskiyou Crest region.

With both a warming climate and a looming biodiversity crisis, we should be protecting, not trampling and degrading our headwater streams. We should also be protecting our rare plant populations and designated Botanical Areas, our native pollinators, wildlife and aquatic species from unnecessary degradation. The current grazing program has significant impacts to the land, no benefit to American taxpayers, and acts as a subsidy for specific economic interests and individual families who benefit financially from the massive handouts, and leaves behind significant impacts for the public to address.

Contact the following Forest Service employees and help us support the many important values of the Siskiyou Crest. Our public lands should be managed as far more than a feedlot for private grazing interests!

Contact the following Forest Service employees with your concerns surrounding the public land grazing program and your support for updates to grazing management plans in the Applegate River watershed and in the spectacular high elevation habitats of the Siskiyou Crest.

Forest Supervisor Molly Juillerat: molly.juillerat@usda.gov

District Ranger Jen Sanborn: Jennifer.Sanborn@usda.gov

Impacts from public land grazing allotments aren’t limited to Forest Service land in the Applegate, they happen on BLM land too. Additionally, contact Senator Wyden’s office and tell him not to cosponsor the Operational Flexibility Grazing Management Program Act (S.4454, 118th Congress), which would remove the administrative control the BLM has over the grazing of livestock on 155 million acres of federal public lands. The Applegate has one grazing allotment on BLM land, the Lower Big Applegate Alloment, that could be affected by this legislation, but the impacts to BLM land throughout the West would be huge if this legislation passes.

From Andy Kerr’s blog post: Wyden’s Unilateral Public Lands Livestock Grazing Giveaway

The Medford District BLM has been busy spinning false narratives about their proposed “salvage” logging projects in the Applegate Valley. Claiming to be targeting “dead and dying” stands and trees with the Boaz Salvage Timber Sale, the actual tree removal mark tells a very different story. Yet the BLM simply declaring living, green trees and stands that were largely unaffected by the recent flatheaded fir borer mortality events as “dead and dying,” does not change the reality on the ground — these trees survived the recent beetle outbreaks and have demonstrated either genetic or microsite related resilience.

The BLM has told the public that they must clearcut these stands — leaving, on average, 3.3 trees per acre — and kill these trees to save them from mortality. We find that logic backwards, Orwellian and wildly dishonest. In fact, both the BLM’s blatant lies and the impact of the project to forest habitats in the area are unacceptable. Only by removing all accountability, analysis and public involvement could such clearly false statements be used to justify this project.

Unfortunately, despite significant public opposition, the BLM recently proposed, retroactively approved, and sold the Boaz Salvage Timber Sale in the Applegate Valley to Mineral Creek Logging and Hauling currently based out of Eagle Point, Oregon.

The public is outraged that BLM can announce a timber sale to the industry and fully design it in a timber sale prospectus before even approving a project or disclosing the effects of the project to the public. People are also outraged that after many years of conflict with the Applegate community over its timber management program, the agency is now resorting to deception and Categorical Exclusions to increase timber production in the face of public opposition.

Medford BLM District Manager, Elizabeth Burghard, committed, in writing, back in 2016, to move forward with projects in the Applegate working in the “spirit of the Applegate Adaptive Management Area (AMA).” The Applegate AMA required community-based collaboration and adaptive management; however, Elizabeth has gone back on her word and has instead dismantled collaboration in the Applegate. In fact, in this project the BLM has used exclusionary NEPA processes specifically to avoid any level of public input or accountability.

While the BLM tries to deceive the public, Applegate Siskiyou Alliance will continue bringing you the truth and fighting for the land. The ecological integrity of the Applegate is our highest priority, and our goal is to challenge projects that damage our environment, like the Boaz Salvage Timber Sale. Please support our work as we expose this damaging timber project and oppose its implementation!

The Boaz Salvage Timber Sale is another shameful timber grab by the BLM. It is also being justified using misleading information, unfounded assumptions, and by cutting the public out of the process. Contact your elected officials and the BLM to express your opposition to the Boaz Salvage Timber Sale.

Get involved! Two things you can do to help us stop the Boaz Salvage Timber Sale:

1. ATTEND A FIELD TRIP! Join Applegate Siskiyou Alliance (ASA) as we lead a field trip to the proposed timber sale units. See the misleading narrative of the BLM firsthand and visit the threatened Boaz Salvage Timber Sale with ASA.

Boaz Salvage Timber Sale Field Trip with ASA

When: October 20, 2024 10:00 AM

Where: Meet up in Ruch in the Sunshine Plaza parking lot for the carpool.

What: We will carpool up to the Boaz Salvage Timber Sale where we will stop to look at the proposed timber sale units and discuss the project. Field trip participants can look into most units from the side of the road, but we will also provide optional off-trail opportunities to walk into the units to experience these beautiful forests more closely. Bring trekking poles if you want to walk into the units, as some are fairly steep. Any walk into a unit will be short and less than an 1/8th of a mile.

Please RSVP at the following email to attend the field trip: luke@applegatesiskiyou.org

2. CONTACT BLM land managers and your elected officials!

Medford District Manager, Elizabeth Burghard: eburghar@blm.gov

Field Manager, Lauren Brown: lpbrown@blm.gov

Talking Points:

—Ask BLM to cancel the Boaz Salvage Timber Sale and other so-called logging projects that target living, green trees and stands. Many stands proposed for “salvage” logging are mischaracterized as “dead and dying.”

—Withdraw the inappropriately applied Categorical Exclusion used to authorize the Boaz Salvage Timber Sales. Logging the resilient trees and stands that survived the recent beetle outbreaks is counterproductive, unacceptable, and irresponsible.

—Implement land management activities on BLM lands that respect public involvement, and conduct appropriate levels of scientific and environmental analysis. A Categorical Exclusions does not provide adequate public involvement, analysis, or public disclosure of the project’s environmental effects.

—The BLM must not circumvent the NEPA process to avoid public accountability, the public disclosure of impacts, or to avoid public comment and input. Public lands should be managed with transparency and accountability, and projects of this scope, scale and intensity should be analyzed with at least an Environmental Assessment.

—The environmental impact of proposed project activities are simply too high and should not be approved. The retention of only 3.3 trees per acre and the removal of existing forest canopy, including large diameter trees, will increase fire risks, damage habitat values, and contribute to climate change.

In the spring and summer of 2023, portions of the Applegate Valley experienced a significant, episodic flat headed fir borer mortality event. These native beetles chew into Douglas fir trees, disrupt the flow of water and nutrients and kill drought and/or heat stressed trees as beetle populations grow. Although historically a rather benign wood boring beetle that unobtrusively killed some trees here and there, in recent years, droughts, heat domes, and other manifestations of climate change have triggered fairly large-scale outbreaks in portions of the Applegate River watershed. Although the most recent outbreak has largely subsided due to more favorable local climatic conditions, and because the most susceptible trees have already been affected, the BLM has continued using this mortality event to promote unsustainable, environmentally damaging clearcut logging in the Applegate Valley.

The Medford District BLM recently identified two new logging projects that claim to focus on the “salvage” of beetle killed trees in the Applegate Valley. These projects include the Boaz Salvage Timber Sale and the Forest Creek Salvage Timber Sale. Both timber sales are being proposed under the false pretense that the stands and trees targeted for removal are “dead and dying.” In many units proposed for logging this is clearly not the case, and instead the BLM is targeting many living, green stands that did not sustain significant mortality during the recent beetle outbreaks.

Shockingly, the BLM is scheduled to auction off these timber sales on September 26, despite not having provided the public with the proper notification or appeal opportunities. The Timber Sale Notices for these projects were released and advertised on September 5th and 6th, yet the Categorical Exclusion document authorizing the Boaz Salvage Timber Sale was signed just two days ago (9/13/24), and the Forest Creek Salvage Timber Sale Categorical Exclusion simply has not been posted on the BLM’s E-Planning website at the time of publishing of this blog post. The Medford District BLM was advertising these timber sales without official approval, and they plan to sell the timber sales before the appeal period has even ended.

So what does this all mean? It means the BLM is scheduled to auction off the Boaz Salvage Timber Sale just 13 days after they signed the decision document — the “decision document” being the signed Categorical Exclusion — and they still haven’t posted a signed Categorical Exclusion for the Forest Creek Salvage Timber Sale on their E-Planning site, even though they have it scheduled for auction on September 26th. It also means that the BLM announced the timber sale auctions to the timber industry before project approval!

The Categorical Exclusion used by the BLM is authorized for post-disturbance mortality salvage, yet these so-called “salvage” projects target many forest stands that survived the recent flatheaded fir borer outbreak and they remain living, green canopied forests. The beetle outbreak came and went, leaving the most resilient trees unscathed — perhaps they are trees with genetic adaptation to better resist drought and insects, or they were growing in more productive, moist or sheltered locations that help them withstand drought and beetle events. These surviving habitats are essentially refuges from drought and beetles, where even under heat domes, extended droughts, and less frequent cold snaps, these forests can and will maintain significant cover, especially on north- and east-facing slopes, in drainages, on lower slope positions, and at mid to high elevation habitats.

That is not to say that beetle mortality events will not occur in the future. Beetle mortality will most likely occur in response to future climactic events, but the BLM will be limiting the available host species, perhaps concentrating beetle mortality during those events and compounding whatever mortality does occur.

For example, according to the Timber Sale Prospectus for both the Boaz and Forest Creek Timber Sales, they will log tens of thousands of mature, living trees that survived the recent beetle outbreaks, leaving behind only between 3.3 (Boaz) and 4.9 (Forest Creek) trees per acre when they are done with the logging — equivalent to clearcuts.

This means, if beetles, wind throw, fire, drought, extreme heat and other natural disturbances kill those 3 or 4 trees over time, the agency will have entirely removed the conifer component, and shifted the once mature, fire and beetle resilient stands into young, more flammable and far less fire resilient vegetation types. It also makes these few remaining trees more exposed to the elements and more susceptible to wind throw, extreme heat, drought, snow damage and other forms of mortality or tree stress.

The BLM is not saving the forests of the Applegate, they are finishing them off. They are not protecting against forest loss, they are creating it.

Boaz Salvage Timber Sale

The Boaz Salvage Timber Sale is located on Cinnabar Ridge and near Boaz Mountain in the Boaz Gulch and Neds Gulch watersheds in the Upper Applegate Valley, and at the headwaters of Grouse Creek, as well as directly above Buncom in the Little Applegate Valley.

The timber sale contains some areas affected by beetle mortality, but large portions of the timber sale target living, green trees in stands that did not sustain elevated levels of fir mortality. These are not dead or dying stands as the BLM claims, they are drought and beetle resistant stands that survived the most recent beetle outbreak and continue to provide important forested habitat for wildlife, wildfire resistance, and climate resilience. In this project the BLM proposes to log an estimated 22,199 merchantable trees on 250 acres, and identified only 849 trees for retention. This translates to the retention of only 3.3 trees per acre and the clearcutting of vast swaths of green, living forest on the ridge above Buncom in the Little Applegate and above Eastside Road in the Upper Applegate.

Additionally, many of the units were previously included in the Nedsbar Timber Sale, which was highly controversial in the community and ultimately withdrawn by the BLM. The BLM is now targeting these same stands by claiming they are “dead and dying,” which is entirely untrue, and are trying to implement the logging under a Categorical Exclusion. The BLM has decided to avoid the public accountability that a full NEPA process entails, avoid creating an Environmental Assessment, and they are refusing to include any meaningful scientific analysis, public input, or public involvement.

Although many living stands are targeted with logging in this timber sale, unit 35-5 is a particularly troubling example. Located in a large swath of mature forest at the headwaters of Grouse Creek on a north-facing slope and along a cool, moist drainage dominated by large, living trees, the area contains cool, moist habitat associations and represents clear climate refugia. In fact, on the boundary of the timber sale unit grows the only known population of dwarf snow bramble (Rubus nivalis) in the low elevations of the Applegate Valley, representing one of the most unusual populations known for this species, and it is located at the southern end of its range. Dwarf snow bramble is very uncommon in the Siskiyou Mountains and only survives this far south in cool, moist habitats, usually in high elevation subalpine forests. This population of dwarf snow bramble demonstrates that this specific forested stand contains some of the most resilient climate refugia in the Applegate Valley foothills, and is one of the most persistent, drought and beetle resilient conifer forests adjacent to the Applegate Valley on BLM land. It is exactly the type of forest we need to protect in the face of climate change.

In unit 35-5, nearly the entire stand of mature, old trees would be removed, leaving only a few scattered trees, where a forest once stood. The BLM reports that 3,371 trees will be removed in unit 35-5, and nearly all of those trees are living trees, located in a refuge from climate and beetles. The currently cool, moist habitat would be opened in logging operations, exposed to the climatic extremes, and converted to a much younger, drier, sun baked, and more flammable plant community with abundant brush, stump-sprouting hardwoods and even-aged conifer regeneration.

To make matters worse the BLM’s Timber Sale Prospectus for both timber sales calls for “lop and scatter” treatments, meaning slash from these clearcut logging operations will be left on site across all 450 acres of logging units, increasing fuels in the Boaz/Cinnabar Ridge region and on Forest Creek. The conditions created will exacerbate fire intensity, rates of spread, and fire severity during fire events, while the current stand conditions would moderate fire behavior and support fire resistance.

The BLM claims this stand and others are facing imminent mortality, yet the conditions on the ground show otherwise. In fact, the only signs of imminent mortality in some of these stands are the BLM timber sale markers.

Forest Creek Salvage Timber Sale

Last week we also monitored proposed logging units in the Forest Creek Salvage Timber Sale and found many of the stands contained significant living, green tree components that would be heavily logged under this so-called “salvage” logging operation.

The pattern was similar to the Boaz Salvage Timber Sale, where many of the trees that survived the beetle outbreak would be logged, leaving only a few trees exposed to the harsh, post-clearcut elements per acre. In fact, according the BLM’s own records, this project would remove 10,641 merchantable trees, while retaining only 983 trees on 200 acres. This translates to only 4.9 trees per acre remaining after the proposed industrial logging operations in living, green canopied stands on lower Forest Creek.

To make matters worse, unit 22-1 on the lower end of Forest Creek contains the only population of the incredibly invasive, non-native shiny geranium (Geranium lucidum) in the Applegate Valley. The species is known to spread quickly and smother native understory vegetation in forest and woodland habitats, suffocating native grasses and wildflower species, and creating dense monocultural populations. The problem is becoming very pronounced in the Willamette Valley, where shiny geranium has spread quickly and is decimating native plant habitats.

Clearly brought in through illegal off-road vehicle use on BLM lands, (the initial populations are all located on unauthorized dirt bike trails), the BLM has long refused to close these trails despite knowing the highly invasive nature of shiny geranium, and as a result it has spread quickly, covering at least 70 acres before BLM began any meaningful attempt to control the infestation.

In numerous recent timber sale proposals the BLM identified this area for logging, but later dropped the unit when environmental analysis and public input identified the potential problems with invasive weed spread. Yet, hungry for more timber, the BLM has decided to exclude meaningful environmental analysis and entirely exclude the public while planning the Forest Creek Salvage Timber Sale, thus ensuring that the spread of this noxious weed is not adequately considered.

Is the BLM so adamant that every acre be logged in the Applegate that they can’t even exclude 70 acres of a highly invasive plant from their logging plans?

Unit 22-1 is a 52-acre logging unit proposed for cable yarding, which will drag logs up the steep slopes, disturbing soils and potentially moving shiny gernanium all around the site. Any disturbed soil is a vector for spread of shiny geranium. After being dragged though the soil, the logs will be loaded onto trucks, contaminated with soil and weed seeds. The tires of the log trucks and the machinery used to yard logs and slash can, and most likely will, become contaminated, creating a significant risk for spread throughout SW Oregon.

The BLM will also conduct road upgrades and maintenance in the timber sale area, which has a high potential to further spread shiny geranium in the area. Logging this unit is incredibly irresponsible, and it facilitates additional weed spread, potentially damaging to habitats throughout SW Oregon.

Other units proposed for logging in the Forest Creek Salvage Timber Sale include living, green trees that survived the recent beetle outbreaks. The BLM is tipping “salvage” logging on its head, in many cases focusing its logging prescriptions in the areas that survived the beetle outbreak and/or by targeting the trees within a stand that survived the recent outbreaks.

Using the fear of beetles, rampant misinformation, and purposefully misleading narratives of “restoration” and “resilience,” the agency is taking advantage of the recent beetle mortality to clearcut living forests, which in turn contributes to the climate crisis, degrades forest habitat, removes climate refugia and increases fire risks. Although the BLM claims to be public servants, it is clear that no one will benefit from these logging projects except for the BLM’s only real partners in SW Oregon: the timber industry.

Bring accountability back to federal land management and please, help us oppose this appalling, dishonest and damaging timber grab by the BLM!

Contact BLM land managers and your elected officials

Medford District Manager, Elizabeth Burghard: eburghar@blm.gov

Field Manager, Lauren Brown: lpbrown@blm.gov

Senator Wyden’s Natural Resource Staff, Jacob Egler: Jacob_Egler@wyden.senate.gov

Senator Merkley’s SW Oregon staff, Dahna Black: Dahna_Black@merkley.senate.gov

Talking Points:

—Cancel the Forest Creek Salvage and Boaz Salvage Timber Sales and the logging of living, green trees. Many stands proposed for “salvage” logging are mischaracterized as “dead and dying.”

—Withdraw the inappropriately applied Categorical Exclusions used to authorize the Boaz Salvage and the Forest Creek Salvage Timber Sales. Logging the resilient trees and stands that survived the recent beetle outbreaks is counterproductive and unacceptable.

—Do not allow logging in existing population of shiny geranium in the Forest Creek watershed. The risk of weed spread and environmental damage is simply too high.

—Implement land management activities on BLM lands that respect public involvement and conduct appropriate levels of scientific and environmental analysis. The current Categorical Exclusion does not provide adequate public involvement, analysis, or public disclosure of the project’s environmental effects.

—The BLM must not circumvent the NEPA process to avoid public accountability, the public disclosure of impacts, or to avoid public comment/input. Public lands should be managed with transparency and accountability, and projects of this scope, scale and intensity should be analyzed with at least an Environmental Assessment.

—The impact of proposed project activities are simply too high and should not be approved. The retention of only 3.3-4.9 trees per acre and the removal of existing forest canopy, including large diameter trees, will increase fire risks, damage habitat values, and contribute to climate change.

As the tallest summit on the Siskiyou Crest, Mt. Ashland is a sky island rising above the surrounding ridgelines and high above the Rogue and Colestin Valleys. Standing on the divide between the Ashland Creek Watershed, which ultimately drains into the Rogue River, and Cottonwood Creek, which drains into the Klamath River near Hornbrook, California, the Mt. Ashland area supports extensive subalpine forest, flower-filled meadows, colorful rock gardens, high elevation bunchgrass habitats, sagebrush clearings, and quaking aspen groves.

Although extremely popular for outdoor recreation and generally well known, the mountain also contains many obscure and little visited meadows, spectacular old-growth forests, rushing streams, and rare conifer species.

Many have been to Mt. Ashland hiking the PCT, mountain biking on local trails, driving road 20, cross-country skiing over deep winter snow, exploring the Grouse Basin and Grouse Gap Shelter, camping at the Mt. Ashland Campground, and visiting the mountain’s windswept summit, but have you explored Mt. Ashland’s truly wild side? You have a chance to on August 3rd for the final hike of the Siskiyou Crest Conifer Field Trip Series! The field trip is an opportunity to see Mt. Ashland in a new light though an informative and potentially adventurous hike on Mt. Ashland’s wild northern flank in the McDonald Peak Roadless Area.

Join us as we explore the wild side of Mt. Ashland, north of Road 20, west of the ski resort, and at the headwaters of Ashland Creek. We will visit and view Mt. Ashland’s rare conifer species, botanize the mountain’s dramatic summit filled with rare and unusual plants, thickets of montane chaparral, barren subalpine habitats, and massive granitic boulders.

At the summit, we will see one of only two stands of subalpine fir (Abies lasiocarpa) in the Siskiyou Mountains. The largest population on the Siskiyou Crest is found near the summit of Mt. Ashland, where stunted krummholz-form trees grow in blue-green mats surrounded by rock gardens and sparse subalpine flowers not more than a few inches high. More common to the north and east in the Rocky Mountains, Cascade Mountains and Blue Mountains, where heavy winter snow creates ideal conditions for subalpine fir, the Mt. Ashland population is disjunct from the majority of the species’ range .

We will also peer down from the summit into “the bowl,” a deeply scoured basin of granite, with mats of greenleaf manzanita and stunted conifer groves consisting of mountain hemlock, western white pine, and red fir. Within this habitat one can also find the last mature whitebark pine (Pinus albicaulis) tree on Mt. Ashland and in the Siskiyou Mountains. Although we do not know what the historic impact of ski resort development and/or communication tower development was on either subalpine fir or whitebark pine, we do know that whitebark pine was known to occur on the mountain in 1969, and as recently as 2003, only three mature whitebark pine trees remained on Mt. Ashland, along with a few planted seedlings.

Currently, only one mature whitebark pine is surviving on Mt. Ashland due to a combination of unfortunate factors, including a naturally small population size, the loss of winter snowpack, the non-native white pine blister rust, and bark beetles that have become more virulent and damaging throughout the range of the whitebark pine in recent years. With nowhere to escape at higher elevations, the whitebark pine is highly susceptible to climate change and remains precariously close to extinction in the Siskiyou Crest region.

After visiting the summit, we will drive down the mountain where the field trip offers two separate options. These options include a leisurely hike along the PCT and/or Rabbit Ears area with expert botanist Julie Kierstead, or a difficult and adventurous off-trail hike onto the wild side of Mt. Ashland through moist mountain meadows, intact bunchgrass clearings, and montane forests. The off-trail hike will lead to a meadow and wetland system on the East Fork Ashland Creek that supports beautiful stands of Engelmann spruce (Picea engelmannii).

Engelmann spruces is found only on Mt. Ashland in the Siskiyou Crest region, and in a few locations further south in the Russian Wilderness at the headwaters of the Salmon and Scott Rivers. Engelmann spruce is a tree of the Rocky Mountains, the Cascade Mountains, and the Blue Mountains, and is often associated with deep, snow and moist montane habitats. At Mt. Ashland, Engelmann spruce grows along meadows, wetlands and springs in the East Fork Ashland Creek watershed.

The journey in the McDonald Peak Roadless Area will show you the most remote, intact, and little visited corners of Mt. Ashland, along with some of the rarest conifers in the Siskiyou Mountains. We think it will also give you a whole different perspective of Mt. Ashland and its surrounding wildlands.

Join us on the wild side with an off-trail hike to spectacular meadows and Engelmann spruce groves, or botanize more accessible portions of the mountain with expert botanist Julie Kierstead.

Rising above the pastoral Williams Valley, Grayback Mountain is the signature peak of the area and holds a special place in the hearts of many local residents. Reaching epic proportions in local lore and revered by those who live at the mountain’s base, Grayback Mountain and the vast wildlands to the south, the Kangaroo Inventoried Roadless Area, tie directly into the Red Buttes Wilderness Area at the headwaters of the Applegate River. A north-south spur ridge of the Siskiyou Crest, the “Grayback Range” also connects the forests of the Applegate Valley directly to the Siskiyou Crest and its world-class botanical diversity and habitat connectivity.

The Grayback Range also divides the Applegate from the Illinois River watershed and contains the last significant block of uncut, old-growth forest visible from the Williams Valley. As the wild, forested backdrop to the Williams area, Grayback Mountain is flanked by Big Sugarloaf Peak, a broad forested knob dropping steeply into the headwaters of the Williams Creek watershed.

Grayback Mountain is cherished by local communities for the clean, cold water it provides, the ancient forests it still supports, the wildlife it harbors, and for the scenic backdrop and views. In fact, as an acknowledgment of their love for the mountain, community members have fought for these forests, including large-scale civil disobedience protests and mass arrests at the Sugarloaf Timber Sale in 1995 on Forest Service land, where massive old growth trees over 400 years old were logged by Boise-Cascade timber company. This was followed by spirited campaigns to stop the China Left Timber Sale (on Forest Service lands) further south and west in the Grayback Range between 1996 and 1997. During this campaign activists from Williams and throughout southern Oregon blockaded forest roads and set up the Sucker Creek Free State, protesting for two years to stop, slow and ultimately cancel the timber sale after many of the units had been logged.

Following the Sucker Creek Free State, community activist fought off the Scattered Apples Timber Sale on BLM lands in the Williams Creek watershed, and most recently Applegate Siskiyou Alliance and other environmental organizations across the region successfully challenged the BLM’s Late Mungers and Penn Butte Timber Sales in Williams Creek’s western tributaries.

In another expression of their love for this place, residents in the Williams Valley spent over 15 years working as dedicated volunteers to build the Grayback Mountain Trail. After years of backbreaking labor, sweat, sore muscles, and BLM red tape, the Grayback Mountain Trail is now a community asset and one of the region’s most popular backcountry hiking trails. The trail traverses old-growth forests on the flanks of Big Sugarloaf Peak and in the upper reaches of Williams Creek that are now threatened with the BLM’s Cedar Flat Timber Sale.

The Cedar Flat Timber Sale extends across BLM lands at the headwaters of Williams Creek, including both the East and West Forks. It also contains old-growth logging units surrounding the Grayback Mountain Trail. Recently ASA, set out for upper Williams Creek to monitor BLM logging units in the area and are outraged, but not surprised by what we found.

The Cedar Flat Timber Sale targets some of the last old stands remaining in the Williams Creek watershed, including the headwaters of Rock Creek and Glade Fork on the productive north-facing slopes of Big Sugarloaf Peak. These units contain moist forest associations, including lush Douglas fir forests, Port Orford cedar stands, massive old pines, beautiful wide-branching hardwoods and forests carpeted in understory species more common in the coast range than the interior Siskiyou Mountains. At the eastern portion of Port Orford cedar’s range in Oregon, the area represents a wet pocket of coastal forest, a significant climate refuge, and a massive concentration of carbon stored in forest soils, trees, snags, and downed wood.

The BLM’s proposal includes 3,222 acres of potential commercial logging, including 2,493 acres of Late Successional Reserve (LSR) forest, set aside specifically to protect old forest habitat for the northern spotted owl and other forest dwelling species. The logging proposed is likely to include a mixture of heavy commercial logging, group selection logging, Riparian Reserve logging, new road construction, and the logging of large overstory trees that support complex old forest canopies, important wildlife habitat, and high levels of fire resilience.

Based on what we have found so far in the Cedar Flat Timber Sale units, we believe significant mature, late successional and old-growth forest will be targeted with damaging commercial logging prescriptions. We also believe the controversy this sale sparks will ignite opposition, outrage, and protest like the BLM has never seen before!

Rock Creek/Grayback Mountain Trail Units

The so-called Cedar Flat Forest Management Project (i.e. timber sale) map provided with the recent scoping notice identifies a large sprawling “treatment area” in Section 29, below the summit of Big Sugarloaf Peak and at the edge of the Grayback Glades Research Natural Area (RNA). The proposed logging unit extends across the community built Grayback Mountain Trail and drops down the flank of the ridge into old-growth forests in both the headwaters of Rock Creek and the West Fork Williams Creek.

Although not technically inventoried as roadless by the BLM, these stands are contiguous with old-growth forests flanking Big Sugarloaf Peak in the vast Kangaroo Inventoried Roadless Area on adjacent Forest Service lands. The proposed treatment area includes large blocks of relatively moist old-growth forest, including ancient Douglas fir trees up to 4 and 5 feet diameter. Diverse, complex, and important for numerous old-growth species, including the northern spotted owl, pacific fisher and perhaps, even the coastal marten. These ancient, closed forests are also important to the surrounding communities for their scenic and recreational value.

After years of effort working with the BLM to build the Grayback Mountain Trail, the community of Williams is outraged by the agency’s old-growth logging proposal along the trail and on the slopes below. These forests constitute some of the last old-growth forests remaining on BLM lands, and one of the largest blocks of old forest remaining in the area.

To log these forests is unconscionable, and in the era of climate change, profoundly irresponsible. They are treasures in the local community, islands of biodiversity, sources of clean, cold water for downstream watersheds, and by far the most resilient, diverse, and complex forests remaining on BLM lands in the Williams Creek watershed. These are not forests in need of restoration, fuel reduction or timber management, rather they should be managed for their biodiversity, their scenic qualities, and their carbon storage.

ASA has proposed these lands for protection as an expansion of the existing Grayback Glades Research Natural Area (RNA), and as part of a large addition to the Red Buttes Wilderness, including the entire Kangaroo Inventoried Roadless Area and adjacent, unprotected BLM lands.

The BLM has given the public until the end of 2024 to comment on this project. ASA would start by asking that all treatment units proposed in Section 29 and along or adjacent to the Grayback Mountain Trail be canceled, and added to the Grayback Glades RNA.

Glade Creek Units

At the headwaters of Glade Creek the BLM has also identified a series of logging units that include unroaded and unlogged forest habitat contiguous with the beautiful old-growth forests on Pipe Fork, the Grayback Glades Research Natural Area, and with the vast Kangaroo Inventoried Roadless Area to the south. Although not technically inventoried as roadless by the BLM, these stands are among the most intact in the Glade Creek watershed and provide connectivity from the Williams area to the wildlands of the Siskiyou Crest.

Starting at roughly 4200′ in elevation, these units extend into montane forest associations containing significant stands of white fir and lush high mountain understory communities. These primary, unlogged forests are foundational to the Glade Creek watershed, and create some of the most important wildlife habitat in the area. Consisting of mature, largely closed forests, they are currently developing naturally into late successional or old growth forests. Patches of mortality have begun generating large diameter snags capable of supporting significant cavity habitat, and large downed trees hold moisture and provide habitat complexity.

The trajectory of this beautiful forest is towards old-growth conditions and logging provides absolutely no benefit. Not in need of restoration or fuel reduction, we believe these stands deserve protection as part of an expanded Grayback Glades Research Natural Area. We also ask that BLM cancel the large “treatment area” in the southern portion of Section 34 and at the headwaters of Glade Fork. These forests are worth more standing!

Units 34-01, 34-02, & 34-03

The BLM has also begun marking unit boundaries on Glade Creek and has identified three timber sale units including 34-01, 34-02, and 34-03. These units contain a variety of forest and stand conditions, including younger plantation-like stands, high graded forests with dense young stands, and older forests with more complex habitat conditions. Portions of these stands have been heavily logged while others are primary forest with intact biological legacies.

For example, unit 34-03 shows clear signs of historic high severity fire with big fire scarred snags and downed trees. It also supports dominant overstory trees that have regenerated since the last wildfire. The lower end of 34-01 also contains mature and late successional forest and unit 34-02 contains mature forests with stands of Port Orford cedar. These mature stands are in need of protection and should be removed from the timber sale.

Conclusion

Residents in southern Oregon have fought lawless logging on Grayback Mountain and Big Sugarloaf Peak before, and will do so again if necessary. In fact, the Sugarloaf Timber Sale in 1995 kickstarted a series of timber sale protests across the region that became known as the “timber wars.” Enraged by the old-growth logging occurring on public lands, the public at large revolted, occupied National Forest lands, put their bodies on the line, got arrested en mass, and fueled a movement across the West to defend these last old forests. Some of us from ASA were there and remember this controversy well.

In spite of the history, BLM has never moved on or changed its ways, and like clockwork, after the local community and conservation organizations successfully sued on the IVM Project, as well as the Late Mungers and Penn Butte Timber Sales above Williams, BLM came back with yet another controversial old-growth timber sale, this time near our beloved Big Sugarloaf Peak, which many of us have worked hard to protect in the past.

Based on the BLM’s insistence on proposing illegal and highly controversial timber sales, they have been stymied by lawsuits and subjected to multiple rounds of recent protests in the Applegate Valley, including against the Bear Grub and Late Mungers/Penn Butte Timber Sales. They have also recently been subjected to tree sitting actions in the Poor Windy and Rogue Gold Timber Sales. The Medford District BLM appears poised to reopen the wounds still only partially healed after the timber wars of the 1990s by proposing late successional and old-growth logging projects throughout the region.

Steering recklessly towards conflict, the BLM is once again planning to target some of southern Oregon’s most beloved forests and will surely provoke a response. ASA will be working to stop the Cedar Flat Timber Sale and its old-growth logging proposals at the headwaters of Williams Creek and on the lush northern face of Grayback Mountain and Big Sugarloaf Peak. Please join us as we save Grayback Mountain from the BLM’s newest old-growth logging proposal.

For more information: Cedar Flat BLM Eplanning site

Comments are being accepted until the end of 2024. ASA will be providing information to the public as we monitor the timber sale units. We encourage you to comment and will share information throughout the process. Save Grayback Mountain! Stop the Cedar Flat Timber Sale!

Applegate Siskiyou Alliance worked this past winter with volunteer crews and funding from the Ashland Food Co-op Community Grant Program to build the Tallowbox Trail. We recently opened the trail to the public with a grand opening ceremony, a hike on the trail, and a side trip to the summit of Tallowbox Mountain.

Applegate Siskiyou Alliance is excited to open this new trail in the BLM’s Burton-Ninemile Lands with Wilderness Characteristics (LWC) and is grateful to all the volunteers who helped build the trail—we had one hell of a buckbrush clearing crew! We are also grateful to John MacKenzie for building the beautiful wooden Tallowbox Trail signs, the Ashland Food Co-op for additional funding, and Josh Weber from Green Path Landworks for helping with more technical sections of trail construction. It was a great community effort, is now a great community asset, and provides the Applegate with yet another beautiful hiking trail to enjoy the region’s spectacular beauty.

Below is a detailed trail description followed by detailed directions to both the lower Ladybug Gulch Trailhead along Star Gulch Road and the upper Tallowbox Trailhead above Cantrall Buckley Park.

The trail can be hiked from top to bottom as a relatively strenuous 4.2 mile hike (one way) and over 2000′ elevation gain. As a shuttle from trailhead to trailhead, or in smaller chunks from either the (lower) Ladybug Gulch or (upper) Tallowbox Trailheads.

Tallowbox Trail

The Tallowbox Trail is the Applegate Valley’s newest backcountry trail and a beautiful hike through forests, woodlands, grasslands, and thickets of chaparral, with commanding views across the Siskiyou Crest and the Upper Applegate River watershed.

The trail begins along Star Gulch deep in a forested canyon. A small cascade tumbles over bedrock in vine maple thickets along Star Gulch, while the trail starts up across the road on Ladybug Gulch. Pass the wooden Tallowbox Trail sign and hike onto an old road built historically to access the old Tallowbox Mountain fire lookout (burned by vandals in 2007 and never replaced). Today, this old road has been decommissioned and re-contoured by the BLM to reduce sedimentation and hydrological impacts on the stream, and to the fisheries of Star Gulch. Most recently, the old road has been converted into a non-motorized hiking trail by Applegate Siskiyou Alliance and now serves as the beginning of the Tallowbox Trail.

Ladybug Gulch is a beautiful seasonal stream surrounded in mature Douglas fir forest, stately canyon live oak, bright orange madrone, and a riparian area lined in alder, maple, and beaked hazel. The trail winds up this pleasant, shaded stream on a gentle grade, making a leisurely hike through wonderful mixed conifer forests. The trail crosses the small stream twice (just a step over the creek) and continues upstream to a final crossing where it then winds around a motor vehicle closure and onto an old road a little less than a mile from the trailhead. Follow the brown carsonite TRAIL signs up the old roadbed and into the upper Ladybug Gulch canyon through forested habitat with a few scattered openings of oak and chaparral.

Reaching a major saddle and road intersection, follow brown carsonite TRAIL signs to the right. As you climb the view broadens, the soils become more rocky, and the forest slowly gives way to live oak and madrone woodland. At about 2.5 miles from the trailhead and after a relatively gradual 2000′ climb, the Tallowbox Trail reaches a small grassy clearing directly below the summit of Tallowbox Mountain. The clearing dotted in rabbitbrush, silver lupine, and twisted oak trees can be quite colorful in the spring and early summer with beautiful wildflowers. As you continue hiking, the summits of the Siskiyou Crest can be seen in the distance, dominated by the rugged skyline of the Red Buttes Wilderness.

Shortly you will reach an intersection with the Tallowbox Mountain Lookout Road and the remainder of the Tallowbox Trail. The Tallowbox Trail is marked with another wooden Tallowbox Trail sign on your right. This is the highest point of the Tallowbox Trail at 4,600′. At this point, you can also make a detour up to the peak of Tallowbox Mountain. Although this is a detour off the official Tallowbox Trail, it is a worthy side trip (described at the end of this trail description).

If you remain on the Tallowbox Trail, it quickly enters an isolated stand of large Douglas fir and ponderosa pine trees with charcoal covered trucks from a previous prescribed burn. The stand is relatively spacious and dominated by large, old trees. A canopy shades the forest floor, which is subsequently open and relatively clear, creating picturesque stands that merge below with groves of live oak. The trail them drops past a narrow band of white oak woodland and into a sweeping, grassy clearing punctuated by a few tufts of dark bedrock and fields of California poppy.

The prairie-like slope offers dramatic views to the south and east across the Upper Applegate and Little Applegate River watersheds. In the winter and spring the line of distant snow-capped summits can be quite impressive, extending from Wagner Butte, Big Red Mountain and Dutchman Peak, to the rugged Condrey Mountain Roadless Area, and the dramatic Red Buttes Region. Star Gulch descends below in a long forested canyon, while Mount Baldy and Burton Butte rise dramatically to the east, looming above the Applegate Valley and the surrounding foothills.

Dropping steeply, the trail continues down this old road bed then reaches a more gentle ridgeline and traverses the slopes to the east through thickets of chaparral and openings filled with wildflowers in the late spring and early summer. This includes California poppy, California lomatium, fernleaf lomatium, large patches of cobwebby thistle, and populations of the rare giant death camas.

In the state of Oregon, giant death camas is found only sporadically in the mountains of the Upper Applegate Valley. The large white and yellow flowers of giant death camas grow in a relatively open panicle from large, green, strap-shaped foliage. Populations of this species are more abundant in California where it grows in the mountains and foothills adjacent to the Central Valley, but in Oregon the species is known from only a handful of populations in the Upper Applegate Valley, with the largest, most robust population being found on Tallowbox Mountain.

The beautiful views, wildflowers and chaparral continues to the upper Tallowbox Trailhead, located in a low saddle between Tallowbox Mountain and Mount Baldy at roughly 4,000′.

Optional Tallowbox Mountain summit detour:

From the high point on the Tallowbox Trail, instead of following the trail, turn north along the roadbed and quickly reach an intersection. Walk to the left, passing through a locked gate and continue along the lookout road through mature forests of white and Douglas fir. These more lush and productive forests on the mountain’s north and eastern slope contain patches of red flowering current, Oregon grape, and Rocky Mountain maple, along with western bleeding heart blossoms in the spring. The road hits a major switchback then enters more open slopes with blooming groundsel and balsamroot. The road then climbs to the summit, communication site and former lookout site. The summit although altered by lookout and communication site construction, contains robust populations of giant death camas, pink mats of spreading phlox, bright yellow carpets of sulphur buckwheat, clumps of pale yellow bigseed lomatium, and the rather non-distinct, pale pink Holboell’s rock cress.

The former one room lookout built on a 30 foot tower was originally built in 1918, but was damaged irreparably by vandals and arsonists in 2007, and removed. Although the lookout no longer exists and a communication site has been developed on top of Tallowbox Mountain, it remains interesting botanically and the view is incredible across the Applegate Valley, the Rogue Valley and the Siskiyou Crest region.

From the summit, you can gaze across the Siskiyou Crest From Mt. Ashland and Wagner Butte to Grayback Mountain, across the scenic Applegate Foothills and Applegate Valley below. To the south is a seemingly endless horizon of rugged ridges and canyons rising to the dramatic spine of the Siskiyou Crest. To the north and northwest, rugged foothills line the narrow Applegate River Valley, while the broad Rogue Valley to the northeast is bound by the Cascade Mountains, including views all the way out to the Crater Lake rim, the Sky Lakes Wilderness and the conical peak of Mt. McLaughlin.

Shorter Options on the Tallowbox Trail

Tallowbox Trailhead to Tallowbox Mountain section: Drive to the upper Tallowbox Trailhead above Cantrall Buckley Park. This option consists of a 1.5 mile hike and about 1000′ elevation gain (one-way) from the upper trailhead to the summit of Tallowbox Mountain. The hike offers exceptional views, diverse vegetation, and beautiful wildflowers.

Ladybug Gulch section: Drive to the (lower) Ladybug Gulch on Star Gulch. This option includes a roughly 1 mile hike with about 350′ elevation gain (one-way) in a shaded canyon of mature forest along Ladybug Gulch. The hike offers solitude, a relatively easy walk among mature conifer forest, and a beautiful seasonal stream.

Directions to trailheads

Directions to the upper Tallowbox Trailhead:

Starting from Ruch, Oregon, drive highway 238 west about one mile and turn left on Hamilton Road. In about one more mile turn right onto Cantrall Road. You will drive past Cantrall Buckley County Park, and through a residential area. Staying on the paved Cantrall Road up to the ridge and beyond as it winds around the eastern flank of Ben Johnson Mountain. Almost 6 miles from Cantrall Buckley Park the pavement ends. Continue along this relatively well graded, well maintained gravel road approximately 1.5 miles to a small pullout on the left, marked with a wooden “Tallowbox Trail” sign along the road.

Directions to the lower Ladybug Gulch Trailhead:

Starting from Ruch, Oregon drive Upper Applegate Road south to Star Gulch Road (just before Star Ranger Station). Turn right onto the paved Star Gulch Road and continue immediately over a concrete bridge. Drive 5.8 miles Up Star Gulch Road to the Tallowbox Trailhead, marked by a wooden Tallowbox Trail sign on the right side of the road. Parking is in a wide pullout across from the trailhead and just below a small concrete bridge over Ladybug Gulch.

In our last blog post, we explored the connection between BLM logging operations in the Applegate Valley and elevated levels of beetle mortality in recent drought events. We also examined the BLM’s currently proposed SOS Project which would log up to 5,000 acres of beetle affected forests throughout southwestern Oregon. This logging would include the removal of both live and dead standing trees, and in many cases will result in large-scale clearcut logging.

As a follow up to this previous post, we are now exploring two recent examples of so-called “salvage” logging in stands with varying levels of beetle mortality. Although you often hear land managers claim that these salvage logging treatments are focused on “fuel reduction” and “forest health,” the timber sale marks and the actual timber sale outcomes tell a very different story.

Salvage logging, by definition, is about recovering the economic value of dead trees, and most scientific studies have proven salvage logging to be ecologically damaging.

Below we will explore the actual result of these commercial logging, and often clearcut logging operations. Our case studies will include the Lickety Split Timber Sale implemented by the Medford District BLM in the Little Applegate Valley, and the helicopter logging recently approved by the city of Ashland, Oregon on city owned forest and park lands.

Lickety Split Timber Sale, Little Applegate Valley

While the BLM recently led a public field trip to greenwash their SOS Project logging proposals, they have at the same time, been clearcutting and otherwise heavily logging large swaths of public land in the Little Applegate River watershed in the Lickety Split Timber Sale. This salvage logging project removed both dead standing, beetle killed trees, and large, green trees that survived the beetle outbreaks.

These living, green trees support favorable genetic traits that could naturally regenerate or reforest the beetle affected stands with drought and beetle resistant trees; however, in the case of the Lickety Split Timber Sale, the BLM logged many of these surviving trees, removing the naturally resistant seed trees and undermining the selective pressures and evolutionary processes that build future resilience in our local forests.

Just like other recent Medford District BLM salvage logging projects, the Lickety Split Timber Sale was implemented within stands that had been previously thinned for “forest health” and to “increase resilience,” but have instead become more susceptible to drought and beetle mortality affects. In this case, the salvage logging is occurring within the 2013 O’lickety Timber Sale, purchased by Murphy Timber Company and logged by Bull Creek Logging, as well as the Lick Stewardship Project, which was purchased and logged by Lomakatsi Ecological Services (the for-profit wing of the Lomakatsi Restoration Project). Both of these projects were illegally over-cut when they were logged due to excessive tree marking by the BLM, have subsequently sustained high levels of mortality, and were salvage logged in the Lickety Split Timber Sale.

In response to the most recent mortality in these stands, the BLM has removed nearly all overstory canopy, and in many locations, has clearcut both dead standing and living green trees. The result of the Lickety Split Timber Sale in many units looks like a clearcut, functions like a clearcut, will be replanted in plantation stands like a clearcut, and will both damage habitats and increase fire risks like a clearcut.

Although the BLM often claims these salvage logging operations will favor and encourage hardwoods, oaks, pines and more drought resistant native vegetation, again, when you compare their claims to the actual outcome of their projects, it’s a very different story. In the Lickety Split Timber Sale, the agency removed not only living and dead standing conifer trees, but also cut, damaged, or otherwise destroyed nearly every hardwood (madrone, black oak, white oak, etc.) in the timber sale units. This left virtually nothing to replace the beetle killed stands. Additionally, the widely spaced and heavily isolated conifer trees, or very occasional hardwood tree that survived the logging operation, are now highly susceptible to increased windthrow during high winds or heavy snow events.

In addition to projects like the Lickety Split Timber Sale, the Medford District BLM is administratively reclassifying many beetle killed stands as “young stands.” This allows the BLM to treat these stands using “pre-commercial” thinning prescriptions which remove virtually all hardwoods and purposefully reintroduces even-aged, plantation style forestry, instead of allowing the more resilient hardwoods, residual conifers, and naturally regenerating forests to develop after the beetle mortality events. Both the removal of more resilient, but less commercially valuable species, and the artificial reforestation or tree planting that follows such heavy industrial logging, will degrade habitats, simplify forest structure, reduce stand resilience and dramatically increase fire risks.

Don’t be fooled by the BLM’s rhetoric, the Lickety Split Timber Sale demonstrates exactly what the BLM’s proposed salvage logging in the SOS Project will create: clearcuts, heavy logging slash, extensive soil damage, stream sedimentation, an impediment to natural regeneration, new plantation stands and significantly decreased habitat values across broad landscapes. Fire risks will also increase in many of the forests that surround our communities due to the even-aged regeneration practices associated with clearcut logging and salvage logging operations.

The result of this project is quite literally clearcut, and the so-called benefits BLM speaks of are simply not part of the actual outcome from these logging operations. Rather than encouraging a natural, diverse, dynamic vegetative recovery following the recent mortality outbreaks, BLM is degrading habitats, developing plantations, and releasing naturally stored carbon through tree and snag removal operations. Rather than making our forests more resilient, the BLM and its salvage logging practices are fueling the climate and biodiversity crisis.

City of Ashland Helicopter Salvage Logging

The city of Ashland, under the leadership of Ashland Fire and Rescue, Wildfire Division Chief Chris Chambers, and with a $150,000 subsidy from the Lomakatsi Restoration Project, has also proposed a large scale helicopter salvage logging project on city owned lands, including much of the Ashland Watershed’s beloved trail system.

Similar to the salvage logging projects recently proposed or approved by the BLM, this project will “salvage” tree mortality that has occurred since previous “forest health” logging operations were implemented. Most of this project is proposed in previously “treated” stands, many of which were commercially thinned with helicopters during the Ashland Forest Resiliency Project.

Although often characterized as a beetle mortality or “salvage” logging project, the city has marked acres and acres of live, green trees that survived the recent beetle outbreaks. In fact, in our monitoring of the project it appears that more live trees will be logged than those that were recently killed by beetle infestation.

In fact, the timber sale mark (implemented for the city of Ashland by the Lomakatsi Restoration Project) did not appear to achieve overtly ecological objectives. Large snags with potential commercial value, often including the largest snags in a stand, are marked for removal. This often includes the biggest, most important wildlife snags and isolated snags that pose no risk to public safety or future fuel loading. In many cases, snags would be clearcut, or virtually clearcut, and stands of live, green trees would be heavily thinned, leaving them susceptible to the same problems, and suffering from the same fragility that the original Ashland Forest Resiliency Project thinning operations have created.

Rather than serving legitimate biological purposes, the green tree logging proposed will be used to offset the estimated $1.3 million cost of helicopter logging and the additional cost of hauling logs to the Timber Products mill in Yreka, California. The city estimates that as much as $686,000 will be made by selling both dead standing and live, green timber from the city watershed, but as much as $700,000 of city funds would be needed to cover additional project costs.

Recently, the Ashland City Council approved the logging of the Reeder Reservoir area to offset the extensive public cost of this largely unnecessary project. According to recent city drone surveys 93% of the Douglas fir trees in this area are healthy. Not exactly an emergency, the logging around Reeder Reservoir, the city of Ashland’s water supply, is being conducted to enhance the economic, not the biological value, of this shortsighted timber sale. Other areas supporting between 68% and 78% healthy Douglas fir trees would also be logged in this proposal, including Ashland’s beloved Siskiyou Mountain Park, along the White Rabbit Trail, along the Bandersnatch, Snark, and Red Queen Trails, in the Hitt Road/Acid Castle area, and on other portions of city owned land.

In fact, the city surveyed approximately 800 acres of publicly owned city park land and recreational areas using drone technology. On this 800 acres it found only 2933 dead trees or approximately 3.6 dead trees per acre. Although in some areas mortality has been more extensive, the overall effect is relatively minor, and perhaps even beneficial in the long run.

This pulse of beetle mortality would, if left unlogged, provide a necessary input of snags and downed wood in forests that are currently largely deficient in both. The beetle mortality naturally thinned forest stands, created gaps for hardwood and conifer regeneration, provides important habitat values, and significantly contributes to habitat heterogeneity.

Utilizing what we call “fear based forestry,” Chris Chambers has been quoted in local newspapers stating that beetle mortality threatens public safety, will increase fire risks, and even that dead standing trees may fall into Ashland Creek, somehow threatening downstream communities. He has also claimed that beetle mortality is threatening to convert the forests of the Ashland Watershed into grassland or shrubland habitat. Unfortunately, neither the science that has studied beetle mortality events, the severity of this particular beetle event, nor the facts of this project support this narrative.

Ironically, despite the claims of “firmageddon” in the media and the fear-based messaging of project partners, the cumulative mortality created by previous commercial thinning operations in the Ashland Forest Resiliency Project, and the additional green tree logging proposed in the Ashland watershed under the guise of timber salvage, has killed or will kill, far more trees than the recent beetle outbreak in the Ashland watershed.

The natural disturbance (in this case beetle mortality), although potentially accelerated by climate change and drought, is within the range of variability for this landscape and has likely happened before. Habitats in the transitional climate of southwestern Oregon are significantly influenced by natural disturbance episodes including drought, beetles, fire, snowloads, wind storms, and even native pathogen outbreaks. Plant communities shift in response to these disturbance episodes and mortality leaves important biological legacies that provide habitat, support complexity, hold moisture, build soil, and maintain continuity between habitats and successional stages.

Additionally, while the beetle mortality event killed genetically susceptible, less resilient trees and forests, the logging proposed will remove green, living trees that demonstrated significant resilience by surviving these droughts and subsequent beetle mortality events. These survivors may contain significant genetic adaptations important for building future resilience to drought and beetle outbreaks in our local forests, but unfortunately, the City of Ashland plans to remove many of them in helicopter logging operations.

Instead of focusing on legitimate hazard tree removal along forest roads, at trailheads, around public infrastructure and directly adjacent to communities, snag and live tree removal will be widespread throughout the watershed and will occur in relatively remote portions of these city owned properties. In many cases this will include stands far from trails, trailheads, or developed infrastructure. In these locations, public safety risks are either very minimal or non-existent. In fact, the Reeder Reservoir parcel is largely closed to the public and thus, no public safety risk can be credibly claimed. Instead, the logging proposed on the Reeder Reservoir property is purely economically driven and the live, green timber will be used to subsidize and/or offset the removal of dead standing snags throughout city owned land.

Furthermore, tree and snag removal will impact the scenic value of local recreational trails turning portions of these trails like the Bandersnatch Trail and White Rabbit Trail into extensive stump fields. Snag and tree removal will reduce wildlife habitat in the area, remove important biological legacies, leave future stands deficient in snags and downed wood, and open stands up to both increased aridity, increased drought stress and increased fire risks.

Snag and tree removal will also impact future soil stability, soil productivity, and soil moisture availability by removing snags or low vigor trees that would provide for the recruitment of coarse downed wood. Coarse downed wood is a critical component of old-growth forests, and if we want old forest habitats, we need both downed wood and big standing snags.

As for the concerns of snags falling in Ashland Creek, the science shows that has been happening for thousands and thousands of years, and is indisputably a good thing for the creek, for fisheries, and for aquatic species of all types. The reason watershed councils across the region spend millions placing large logs into streams, is because it’s good for riparian health and fish! The recent beetle outbreak provided a pulse of mortality recruiting snags, downed trees and instream wood which supports soil, wildlife and watershed health.

Conclusions

Despite the claims of logging proponents, a heavy dose of greenwash, and a persistent public relations campaign, the current push to “salvage” beetle killed timber in southwestern Oregon comes with significant environmental consequences and climate impacts, and very few benefits. Most definitely not a restoration or fuel reduction treatment, the logging currently being implemented and proposed across the region will simplify, degrade, and diminish the resilience, beauty, and biodiversity found in southwestern Oregon’s unique, highly diversified forests.

Neither the logging approved in the Ashland watershed or the Applegate Valley has positive biological outcomes; neither will meaningfully reduce fire risks; neither will restore ecosystem function, and neither will achieve the lofty objectives claimed by the city or by the BLM. These projects and their numerous undesirable outcomes should inform the conversation about future salvage logging in the BLM’s proposed SOS Project and similar projects likely to be proposed by both the BLM and other land managers.

Despite the forest health rhetoric, salvage logging is the worst form of industrial logging, with perhaps the most significant and lasting environmental impacts because it is often implemented as clearcut or heavy industrial logging. It is also often rushed to the mill and poorly designed without sufficient site specific analysis or adequate design features to mitigate impacts. In the case of the Lickety Split Project, it was also implemented during the rainy season maximizing the projects impact on soils, hydrology, sedimentation and watershed health.

We encourage folks to get out when the logging is finished in the Ashland watershed, or go for a drive up Lick Gulch Road in the Little Applegate River watershed. The consequences of salvage logging, the singular economic focus, and the false narrative spun by its supporters will quickly become evident.

Directions to Lick Gulch Road and the Lickety Split Timber Sale: Drive highway 238 to beautiful Ruch, Oregon and turn south onto Upper Applegate Road. Follow Upper Applegate Road 2.9 miles to the intersection of Little Applegate Road. Turn left on Little Applegate Road and continue 4.9 miles to the pavements end and turn right on Yale Creek Road. Drive past a row of mailboxes, cross the Little Applegate River on a bridge and immediately turn left on the signed “Lick Gulch Road”, also known as BLM road 39-2-28 (denoted by a large brown BLM road sign). Follow this road past a few residences and onto BLM land. Immediately you will see Lickety Split Timber Sale units. Continue driving and turn right at the next intersection. You can drive this road for 3-4 miles driving in and out of timber sale units.

Flat headed fir borers, engraver beetles, and other wood and bark boring insects

Triggered by extended droughts, a significant lack of persistent winter cold snaps, stifling summertime heat domes, and a changing climate, flat headed fir borers and fir engraver beetles have become very active across interior southwestern Oregon. In fact, populations of these native wood boring beetles have exploded in recent years, creating significant Douglas fir mortality throughout the region.

A visceral sign of climate change, the mortality reached epidemic proportions in 2022 and 2023, when flat headed fir borers could literally be heard chewing through stands of Douglas fir in the foothills of southwestern Oregon.

Mortality was occurring in large patches at lower elevations, especially on droughty sites, harsh exposures, sites with poor soils, sites more conducive to oak woodland, chaparral, or mixed hardwood stands, and in many previously implemented “forest health” logging or commercial thinning projects.

Since the 1990s, the Medford District BLM and Rogue River-Siskiyou National Forest have been implementing landscape-scale logging, or commercial thinning projects, intended specifically to increase “forest health” and resilience to both drought and beetle mortality; however, in many locations these “restoration” thinning projects have had the opposite effect, and both the false claims used to justify the logging, and the forested habitats they have “treated” have begun to unravel.

Ironically, many of these previously implemented federal land timber sales have sustained significant flat headed fir borer mortality and are at the center of the region’s beetle induced Douglas fir mortality event. This includes numerous timber sales implemented by the BLM in the past 30 years in the Applegate Valley and the Ashland Forest Resiliency (AFR) Project in the Ashland Watershed. At the same time, droughty conditions and extreme temperatures are also increasing pine mortality associated with various bark beetles in both thinned and unthinned stands.

At best, the previous commercial thinning treatments failed to create the resilience or restoration predicted by the BLM and USFS in each timber sale’s scientific analysis and approval documents (e.g. Environmental Analysis, Decision Record, etc.), and the agencies need to stop promising outcomes they can’t actually create through logging.

At worst, the logging was actually responsible for the scale of the beetle outbreak by weakening whole stands of trees, and the agencies need to stop large-scale commercial logging that is contributing to the loss of regional forests.

The reality is likely somewhere in between. Climate conditions can trigger the outbreak, while in some places previous commercial thinning or logging operations have damaged soils, damaged trees, increased aridity, increased edge effect, increased air temperatures, made stands more susceptible to beetle impacts, encouraged beetle populations to expand, and contributed quite significantly to the mortality event.

In many ways, the BLM has been an active contributor to both the current climate crisis and the recent beetle mortality event, by creating extensive logging related carbon emissions that fuel climate change. Recent research found that commercial logging and timber manufacturing is the largest contributor of greenhouse gas emissions in the state of Oregon (Law. 2018), while regional research shows that commercial logging is responsible for 80% of the Forest loss in Oregon and Washington combined. It also found that logging in Oregon and Washington constitutes 67% of all forest loss in the 11 Western states where fire and beetle mortality are most acute. This makes logging, not beetle mortality, the most significant threat to the forests of the West, and in particular the most significant threat to forests in the Pacific Northwest. (Berner. 2017).

BLM’s Response: The SOS Project

In response to the recent increase in beetle mortality, the Medford District BLM has proposed the Strategic Operations for Safety (SOS) Project, a large-scale “salvage” or post-disturbance logging project sprawling across rural southwestern Oregon. Proposed under the pretext of public safety, the focus of the project would actually be to opportunistically log 1,000 acres, and roughly 10 million board feet of dead and supposedly “dying” trees to meet the agency’s 2024 timber targets.

Currently the BLM has identified a massive planning area sprawling across the BLM lands surrounding both the Rogue and Applegate Valley. Unfortunately, what the agency has not done, is identify where within this vast landscape that post-disturbance logging would actually occur. According to the Scoping Notice for the Strategic Operations for Safety Project (SOS Project), the BLM would log approximately 5,000 acres in still undisclosed locations.

These operations could occur along BLM roads, in what the BLM calls Potential Operational Delineation (POD) areas, and within 1 mile of developed areas or homesteads. They could also be implemented in Riparian Reserves, Late Successional Reserve (LSR) forests, along hiking trails and in recreation management areas, degrading the values these areas were designated to protect.

The agency claims this logging is benign or even beneficial, and is necessary for both public safety and future fire containment. Yet, the agency proposes logging over 500′ on either side of BLM roads and so-called POD areas, far beyond what can be credibly called “hazard tree” logging, and far beyond what is necessary for future fire containment. As currently designed the project is an excuse to log, not a valid public safety or fire risk reduction project.

The BLM also proposes logging both dead standing, beetle killed snags, and live, green trees that survived the beetle outbreak. Yet, these surviving trees contain either high genetic resistance, or grow in favorable microclimate conditions, allowing for their survival and persistence. Removing these trees will generate short-term profits for the industry, and provide board footage for the BLM’s annual timber quota, but will undermine long-term forest and climate resilience.

Snags provide important wildlife habitat and are the foundation of both stand recovery and future forest or woodland complexity. In fact, research conducted in southwestern Oregon following the 1987 Galice Fire found that large downed wood retained “tremendous quantities of water… Even after 77 days without rain and an intense wildfire.” The researchers literally wrung water out of downed logs which had 25 times more moisture on a weight basis than did soil samples. Researchers suggested that this moisture “may help pioneering plants become established where soil moisture is low,” making it “a requisite for maintaining long term forest growth” in the region. The author explains, “in the Klamath Mountains conifer seedling performance can depend on the ability of the soil to retain moisture and support nitrogen fixing and ectomycorhizal organisms. Removal of large amounts of organic material may result in difficult reforestation of these thin, droughty, and infertile sites.” (Amaranthus, 1990)

Following a significant mortality event, snags become the only large wood this system will produce for decades or even centuries, creating structure, diversity, habitat and favorable growing conditions for young, regenerating forests. Large, relatively rot resistant species can persist, provide continuity, and play functional roles in the regenerating ecosystem for centuries, if not removed in post-disturbance logging operations.

The reality is, that the BLM has a stocking requirement after “regeneration” logging. This usually means that they have to plant trees after clear cutting an area. This means that the “regeneration” logging proposed in the SOS project will be followed by tree planting and plantation development, creating dense, young, heavily simplified, and highly flammable vegetation that has been proven in multiple regional wildfires to increase fire severity and spread.

As currently designed the SOS Project will leave a lasting biological impact, provides little public safety benefit, and will produce low value timber that can only be implemented at a deficit to the taxpayer. Our forests and climate are sending out an SOS, and unfortunately, the BLM is responding in the only way it knows how: with a new timber sale to supposedly “fix” the problems the last one created. An endless cycle that needs to end for the sake of our forests and climate.

COMMENT NOW on the SOS Project.

Talking points for public comment:

• The project proposal lacks specificity, precluding meaningful public comment, agency analysis, and the disclosure of impacts as required by the National Environmental Policy Act (NEPA). Site specific unit boundaries must be identified to conduct a valid scientific and public analysis.
• The proposed logging of dead or dying trees up to 500′ from roads and PODS serves no public safety purpose. No trees in our area grow 500′ tall, and therefore, cannot pose a safety risk to roads 500′ away. Tree and snag felling for public safety and fire suppression purposes should occur no more than 150′ from main system, high-use BLM roads.
• Logging dead or dying trees up to 1 mile from developed areas serves no public safety purpose and will not reduce fire risks unless the the tree felling is limited to areas within 150′ of homes or developed areas, and within 150′ of ingress/egress roads.
• Tree removal from the site is unnecessary and serves no public safety purpose. Once felled, a valid hazard tree 150′ or less from a high-use BLM road has been fully mitigated of all public safety risks. Trees that pose actual public safety risks could be felled, but tree yarding and removal is necessary, especially because much of the low value dead standing material will be sold at a loss to the public. Trees felled into the road could be removed if necessary, but trees felled onto the slopes should be retained and left on site for biological values.
• Standing snags and large downed trees are important for carbon storage, soil development, forest and woodland regeneration, habitat, water retention, and are the foundation for future forest complexity. These biological legacies should be retained on site whenever possible. Large downed wood has been show to be essential for stand regeneration and serves to dampen fire activity.
• No live trees that survived the recent beetle outbreaks should be felled or removed in the project area. These trees likely contain genetic or situational advantages, that allow for beetle and drought resilience. These are the most site-adapted trees, will encourage resilience and are preferable for forest or woodland reestablishment. The BLM should maintain these living trees for seed production and regeneration as well as habitat value.
• Tree felling and removal should not take place in Riparian Reserves, and only valid hazard tree felling within 150′ of high-use BLM roads should be considered in Late Successional Reserve (LSR) forest.
• The BLM should not build new roads in the SOS Project.

All comments must be received by January 7, 2024

For more information: SOS Project Website

Click on “Participate Now” to comment

To comment send an email or letter to:

By email: BLM_OR_MD_Safety_EA @blm.gov

-or-
By mail or delivery service:
Attn: Strategic Operations for Safety EA

Medford District BLM

3040 Biddle Road

Medford, Oregon 97504