Would you be concerned if your favorite backcountry trail was proposed as a 1000′ wide fuel break without adequate public involvement or environmental review? Do you think intact roadless areas, botanical areas and Forest Service recreation areas should be turned into “fuel breaks” far from homes and communities, even if they do not represent fire risks? That is exactly what is being proposed by the Rogue River-Siskiyou National Forest along the spectacular McDonald Peak and Wagner Butte Trails, the Elliott Ridge/Stein Butte Trail, and the Sevenmile Ridge Trail near Big Red Mountain.

The agency has released a Scoping Notice for the Siskiyou Mountains Ranger District Fuel Break Project which would build many miles of fuel breaks across the Applegate River watershed, on the face of some of the Siskiyou Crest’s highest peaks, and in some of the region’s most intact habitats. Proposed to take place up to 500′ on both sides of roads and backcountry trails, the fuel breaks would affect a wide variety of ecosystems from high to low elevations.

What the scoping notice does not do is describe what will be done in these sites and along these popular and well-loved recreational trails. How would these diverse ecosystems be “treated”? We simply do not know, and based on the information currently available, the Forest Service intends to approve these projects using Categorical Exclusions, meaning they will be largely excluding the public involvement process and the necessary environmental and scientific reviews, in some of the most botanically diverse places in the region.

Although these so-called treatments would include only non-commercial thinning, they would still have significant impacts to these intact ecosystems, especially in mid to low elevations in chaparral, montane chaparral, live oak woodland, oak woodland and mixed hardwood habitats. Plant communities at high elevations would also be impacted, including unique sagebrush clearings and aspen groves, ancient mountain mahogany groves, serpentine influenced Jeffrey pine woodlands, and montane snow forests, including mountain hemlock and red fir at up to over 6,800′ elevation on the face of McDonald Peak, and over 6,400′ at Wrangle Gap and around Wrangle Camp.

What little we know about the project, is that four large fuel breaks are proposed sprawling across many, many miles of National Forest land and consisting of up to 4,290 acres of public land.

This includes fuel breaks:

1. Along Elliott Ridge and Yellowjacket Ridge from Silver Fork Gap to the Applegate Reservoir, including the Elliott Ridge/Stein Butte Trail;
2. In the Wagner Butte/McDonald Peak area along the entire McDonald Peak Trail and the upper half of the Wagner Butte Trail;
3. On Sevenmile Ridge along the Sevenmile Ridge Trail and adjacent to Big Red Mountain;
4. From O’Brien Creek to Palmer Ridge in the upper portions of Carberry Creek and the Upper Applegate.

What we also know is that these proposed fuel breaks would be located on the Siskiyou Crest, and in surrounding areas far from homes or communities. They are not being proposed where they could most effectively protect communities. Yet, they are proposed in some of the most cherished recreational areas on the Siskiyou Mountains Ranger District, in some of the most intact lands, some of the most diverse plant communities, and in some of the district’s most scenic landscapes.

Below is the little we know about each individual fuel break proposed in the Siskiyou Mountains Ranger District Fuel Break Project:

Wagner Butte/McDonald Peak Fuel Break

The Forest Service has proposed turning the southern slopes adjacent to the McDonald Peak Trail into a 500′ wide fuel break for the entire length of the trail, from south of McDonald Peak to the Wagner Butte Trail. This portion of the trail extends through high elevation sagebrush clearings, montane chaparral, and montane conifer forest between 6,400′ and 6800′ elevation. This includes habitats at the headwaters of McDonald Creek, Split Rock Creek, Jim Creek, Corral Creek and Greeley Creek.

We are concerned that chaparral clearing in proposed fuel breaks would damage the area’s unique ecosystem and the protected plant communities in the McDonald Peak Botanical Area, an area specifically designated to protect the area’s unique botanical resources and rare plant species. It will also impact recreational values in a large Special Interest Area intended specifically to protect the scenic values of the Siskiyou Crest.

The proposal also includes a swath 500′ wide on both sides of the upper Wagner Butte Trail from Wagner Glade Gap to near the summit of Wagner Butte. This section contains unique plant communities with a significant “east side” or Great Basin influence in the Siskiyou Crest Special Interest Area. The area was also a candidate Botanical Area due to the usual east side plant communities, biodiversity and rare plant species.

Plant communities affected would include the trail’s charismatic mountain mahogany groves, sagebrush clearings, quaking aspen groves and montane snow forests of mountain hemlock and red fir. These plant communities are the highest elevation subalpine habitats in the Siskiyou Mountains and are not well adapted to frequent fire or manual fuel treatments. Instead, these habitats are adapted to a mixed severity fire mosaic and continue to maintain very healthy, diverse and dynamic ecosystems with relatively low fire risks and abundant fire refugia. These areas do not need and will not benefit from fuel reduction treatments.

The entire length of this proposed fuel break is also located in the McDonald Peak Inventoried Roadless Area, an approximately 10,000 acre wildland at the headwaters of Ashland Creek and the Little Applegate River. This large intact area is important for habitat connectivity, contains many rare plant populations and unique plant communities, and includes some of the most beautiful and accessible high country in the Siskiyou Crest region.

Together these two trails are among the most popular and well-loved in the region, yet the proposed fuel break would significantly impact the area’s wild, natural setting, intact scenic value and recreational qualities, while degrading unique plant communities and introducing disturbance adapted non-native plant species. It will also degrade the area by surrounding the trail in plastic covered burn piles, sterilizing the soil and destroying vegetation as the piles are burned, leaving black charcoal pits that take years to revegetate, and leaving fragments of black plastic from burn piles scattered throughout the trail corridor. This is an unfortunate, yet common site along trails in the Applegate watershed, where plastic remnants from burn piles are frequently left as garbage after “fuels treatments.”

The McDonald Peak and Wagner Butte areas have been designated specifically to promote scenic, recreational, botanical and biological values, and to many local residents they are cherished backcountry trails. They should not be managed as fuel breaks that degrade the natural habitats and scenic qualities people from across the region come to enjoy, and the agency’s Land and Resource Management Plan specifically tells the Forest Service to protect.

The McDonald Peak/Wagner Butte Fuel Break should be canceled and a more effective approach implemented that focuses directly on protecting communities, public safety and infrastructure from wildfire impacts. These efforts should be located near homes, rather than remote, high elevation, backcountry habitats far removed from the values at risk.

Elliott Ridge & Yellowjacket Ridge Fuel Break

Elliott Ridge is a long east-west spur ridge dividing the Elliott Creek and Teel Creek watersheds, and an extremely popular backcountry recreation area, accessible by the Elliott Ridge/ Stein Butte Trail system. Starting at Seattle Bar and extending for many miles through the citizen identified Elliott Ridge Roadless Area, the Elliott Ridge/Stein Butte Trail is among the most popular recreational trails in the Siskiyou Mountains Ranger District.

Generally accessible year-round, the trail climbs steeply up switchbacks above Seattle Bar at the south end of Applegate Reservoir through relatively open mixed conifer forest to the rocky spine of Elliott Ridge. The trail alternates back and forth from the forested north-facing slopes of Elliott Ridge to the rocky, sunbaked southern face covered in montane chaparral, stump sprouting hardwoods, live oak woodland, patches of mixed conifer forest and large stands of knobcone pine. The area is highly scenic, largely intact, and well-loved by local residents.

Due to the location of the trail, its steep switchbacks and its movement back and forth from the north to south facing slopes, it makes for a very ineffective and unsafe fireline, that in reality would never be used for fire containment. Fire managers simply would not place firefighting hand crews on fire containment lines with switchbacks or that alternate across the ridgeline. Thus, the ability of this fuel break to serve its intended purpose and act as a fire containment feature in future wildfires is both unrealistic and highly unlikely. From a practical standpoint, this fuel break provides almost no effective use.

Ironically, it also supports numerous plant communities adapted to mixed and even high severity fire that respond poorly to manual fuel reduction and “restoration” treatments. These are not plant communities adapted to frequent low severity fire and open grown vegetative conditions. In fact, rather than restoring habitat conditions through manual treatments, the opening of these habitats for fuel reduction has been shown to damage natural vegetative structure, increase non-native grasses and noxious weeds, impact wildlife habitats and have generally non-restorative effects. At the same time, damaging these plant communities will significantly impact the intact character of the land, its scenic qualities, and important recreational values.

This proposal would turn the entire Elliott Ridge Trail and 500′ on either side into a fuel break for approximately 7 miles from Seattle Bar, past Stein Butte and east to the headwaters of Mallard Gulch. Yet, the proposal does not end there, it would continue for 500′ along both sides of the road along Elliott Ridge, traversing the south slope of Elliott Ridge, then switching back to the northern face before winding back to Maple Dell Gap. From Maple Dell Gap the fuel break would continue an additional 3 miles along the southern face of Yellowjacket Ridge transitioning into montane conifer forests, serpentine influenced slopes below Yellowjacket Mountain, and ending up at Silver Fork Gap.

We believe the Elliott Ridge Trail section is an ineffective fuel break, would badly impact chaparral and woodland habitat along the trail, degrading the recreational experience for generations to come, and increasing fire risks when tree form live oak resprout into thickets and highly flammable non-native grasses invade previous chaparral and woodland sites. The Elliott Ridge Trail section of the fuel break should be canceled, and as one of the area’s most popular recreational trails, we hope the Forest Service can maintain the irreplaceable biological, scenic, and recreational qualities of the Elliott Ridge Trail.

Sevenmile Ridge Fuel Break

The proposed Sevenmile Ridge Fuel Break would start along the Little Applegate River, wind into Glade Creek, and climb Sevenmile Ridge to the western flank of Big Red Mountain on the old Sevenmile Ridge Trail. The proposed fuel break then switches back past Wrangle Camp to Wrangle Gap at over 6,400′ elevation on the Siskiyou Crest.

The proposal extends through mixed conifer forests and hardwood stands at mid-elevations and through high elevations and montane forest habitats, including large areas of moist meadow, high elevation bunchgrass clearings, alder glades, serpentine barrens, picturesque Jeffrey pine woodlands, and other highly fire resistant habitats near Wrangle Camp, on the western flank of Big Red Mountain.

Big Red Mountain is a broad red mound of serpentine rock and supports naturally sparse montane vegetation. Covered in snow much of the year, the area sprawls across the headwaters of Glade Creek and the Little Applegate River. Already an effective natural fuel break, these habitats and the fire refugia they create cover a large area, and have refused to burn in the 1987 Quartz Fire, the 2001 Quartz Fire and the 2018 Hendrix Fire. Each fire burned on the slopes below, but was naturally “contained” in the sparse vegetation and broad, rocky slopes extending down the flanks of Big Red Mountain. The mountain is already both a natural and highly effective fuel break.

It is also a spectacular biological wonder, known for its unique serpentine geology, unusual serpentine plant communities, rare plant species, and highly scenic natural habitats. Big Red Mountain has been designated as a large Research Natural Area in the Monogram Lakes Basin, a Botanical Area, and a Special Interest Area. These areas are intended to protect the biological values, intact natural environments, unique plant communities, and recreational values of the region.

The proposal includes a 500′ fuel break on either side of the Sevenmile Ridge Trail (1,000′ total), despite large portions of the trail having very little fire risk. Much of the upper trail is proposed to run through large bunchgrass clearings, wet meadows, seeps, springs, headwater streams and moist alder glades. Additional portions extend through beautiful, fire resilient old-growth forests, montane forest, and relatively open spaced Jeffrey pine woodland. The trail and proposed fuel break would also extend through both snag forests burned at high severity and forests underburned in the 2001 Quartz Fire and the 2018 Hendrix Fire. Neither of these areas currently support significant fire risks or are heavily altered environments in need of restoration.

We believe significant trail maintenance alone this long unmaintained trail would suffice as a fuel break along the Sevenmile Ridge Trail. This would provide as much of a fuel break as the typical handline used to suppress wildfires. Given the fire refugia and minimal fire risks on this section of trail, it would be a potentially successful and appropriate treatment for the area, while enhancing public access to the important scenic, recreational and biological values of the Sevenmile Ridge Trail.

The lower portions of the proposed fuel break would follow road systems on lower Sevenmile Ridge down to the Little Applegate River near Brickpile Ranch. These portions include both plantation stands and mature, relatively open pine, fir and cedar forests growing on serpentine influenced soils. These areas have already largely been “treated” with non-commercial fuel reduction thinning and also maintain fairly minimal fire risks. In the years since the initial treatment, shrubs and regenerating trees have recolonized the understory and could be burned in a patchy prescribed fire intended to reduce, but not eliminate this young vegetation. This would create a mosaic of vegetation, would reduce the flammable fuels in the forest floor, regenerate native herbaceous vegetation and restore fire as a long suppressed natural process in these forests.

The lower section of Sevenmile Ridge could benefit from some strategic maintenance burning and manual thinning around the private inholding at Brickpile Ranch. These areas have been logged, leaving dense patches of skinny young trees, scattered old trees and large, open spaces filled with stumps from previous commercial logging operations and dense shrub species. These areas have not burned in recent history, and having been both heavily logged and lie adjacent to the private land inholding at Brickpile Ranch, they would be a far more appropriate location for fuel reduction than the intact lands above on the Sevenmile Ridge Trail.

We recommend trail maintenance on the Sevenmile Ridge Trail and judicious, non-commercial thinning in the lower sections of Sevenmile Ridge where heavy historic logging and unnatural habitat conditions surround the residence at Brickpile Ranch.

Grayback Fuel Break

The proposed Grayback Fuel Break would start at the O’Brien Creek Trailhead on O’Brien Creek Road and extend downstream along road 1005 to its intersection with Carberry Creek Road. The proposed fuel break would then drop into Carberry Creek and climb back up road 1010 to Youngs Gap, a low saddle between Carberry Creek and Brush Creek near Steamboat Mountain. The fuel break would then again drop back into Trail Creek and extend along the Brush Creek canyon before again climbing to the ridgeline dividing Thompson Creek from the Upper Applegate.

Winding along backcountry roads, this fuel break does not follow natural, containment features that would be utilized as fireline during future wildfire events. Instead, this proposed fuel break would be ineffective and dangerous from a fire suppression standpoint, being both unsafe for fire crews and difficult to hold as fireline. In reality, no fire manager would use this fuel break as a fireline, although some portions of it could be utilized in smaller fire events.

The area contains montane conifer forests and intact mixed conifer forests on O’Brien Creek in the Kangaroo Inventoried Roadless Area, low elevation conifer forests on Brush Creek, large knobcone pine stands, live oak woodlands, mixed hardwood stands and unique chaparral communities.

The manual thinning treatments proposed would badly damage the non-forest plant communities found near Youngs Gap, in the Brush Creek watershed, and on the ridgeline divide. Like in some many other locations these plant communities are naturally dense and support a mixed severity fire regime with a significant high severity fire component. Treating these communities to open habitats for fuel break construction will degrade these naturally resilient plant communities.

Additionally, large portions of the proposal are located in Riparian Reserves along O’Brien Creek, Trail Creek and Brush Creek in locations where fire danger is already relatively low compared to the surrounding terrain.

We recommend altering this proposed fuel break to eliminate the extensive riparian reserve thinning and either exclude areas of chaparral, hardwood groves and live oak stands or treat them to maintain canopy cover and reduce stump sprouting by minimizing tree removal. In many locations, previous fuel reduction treatments on the Siskiyou Mountains Ranger District have increased fire risks, reduced scenic values, and damaged important habitats in these ecosystems. We hope the agency will not repeat these mistakes.

Conclusion:

At Applegate Siskiyou Alliance, we question the strategy and effectiveness of backcountry fuel breaks, when unprepared communities are burning to the ground. We also question the utility of fuel reduction treatments in high elevation fire refugia, areas with low fire risks, far from communities, and in some of our last intact environments. Fuel reduction and community fire safety efforts should be focused on homes, communities and critical infrastructure. This project fails to address the critical concerns surrounding home ignition and community wildfire safety during fire events. Fiddling in the backcountry while our communities burn is unacceptable, and a more effective, nuanced, appropriate approach should be taken on the Rogue River Siskiyou National Forest.

We are concerned that the Forest Service is proposing this massive, fuel break project in extremely intact areas and conservation/recreation based land use allocations on the Siskiyou Crest. We are also concerned that the agency is “scoping” all these projects at once and will not be doing either a full public involvement process or environmental analysis to analyze our concerns, disclose potential impacts and consider the potential environmental effects. This means that treatments implemented in some of the most cherished wildland habitats and most popular backcountry trails would be done with less analysis and less public involvement than regular federal land projects.

The Forest Service is also considering the declaration of a wildfire emergency in the Siskiyou Mountains Ranger District, despite currently having no large wildfires and only two large wildland fires in the last 22 years (2017 Abney Complex and 2001 Quartz Fire. This “emergency declaration” would serve to eliminate administrative remedies, shield the project from regular legal processes and expedite the project’s implementation, while minimizing public involvement. We do not believe this approach is honest, acceptable, or collaborative and should be withdrawn from further consideration.

Please comment on this project (by October 9, 2023) at the following link, where maps and the limited information available can be reviewed: https://www.fs.usda.gov/project/?project=63141&exp=overview

Talking Points for Public Comment

• The Wagner Fuel Break along McDonald Peak and the Wagner Butte Trail should be canceled.
• The trail sections of the proposed Sevenmile Ridge Fuel Break should be canceled and trail maintenance implemented instead.
• The western portions of the proposed Elliott Ridge Fuel Break on the Elliott Ridge/ Stein Butte Trails should be canceled.
• The agency must fully analyzed and disclose the impact of proposed project activities on Inventoried Roadless Areas, Botanical Areas, Special Interest Areas, wildlife habitat, native plant communities, wildland habitats, connectivity, rare plant species and other issues of concern in an Environmental Assessment.
• Declaring a wildfire emergency to eliminate public involvement, environmental analysis and legal processes is unacceptable and creates incentives for the Forest Service to circumvent normal legal and administrative processes.
• A Categorical Exclusion would not allow for sufficient public involvement, does not adequately address the broad range of potential impacts, the importance of the lands proposed for treatment, or the consistency of proposed project activities with the regulations and land use allocations in existing management plans. At a minimum an Environmental Assessment should be prepared individually for each proposed fuel break.
• The use of emergency declarations and Categorical Exclusions for this project is inconsistent with the mandates of the Applegate Adaptive Management Area (AMA) which promotes and encourages community based collaboration and robust public involvement. The approach taken on this project is inconsistent with the mandates of the Applegate AMA and should be restructured to maximize, not minimize public involvement.
• Chaparral, oak woodland, live oak woodland and madrone stands must be protected from project activities that are not restorative and either increase non-native grasses and/or increase understory fuels through excessive stump sprouting. This requires maintaining hardwood canopies and retaining large, dense patches of contiguous chaparral.
• The Forest Service should be conducting fuel reduction near homes and communities where it is both needed and effective, not in remote backcountry habitats.

From October 2019 to August 2022, Applegate Siskiyou Alliance and residents across southwestern Oregon opposed the Bear Grub Timber Sale, a large BLM timber sale in the mountains of Sterling Creek and the Little Applegate Valley, along the East Applegate Ridge Trail, in the beloved Wellington Wildlands, and on Woodrat Mountain above Ruch, Oregon.

Much of the timber sale proposes “group selection logging,” a form of staggered clearcut logging that removes whole groves of mature trees up to 36″ in diameter. Implemented only in mature forests, this type of logging “treatment” creates “openings” or “canopy gaps” up to 4 acres in size and across up to 30% of a mature forest stand.

Group selection logging damages old forest habitat, degrades the climate refugia our wildlife depends on, and releases abundant carbon stored in the old forests and trees this form of logging targets for removal. Additionally, the removal of these large, fire resistant trees combined with increased aridity, stronger winds, and the young, dense, highly flammable growth this type of canopy removal creates has significant impacts to future fire risks. In fact, according to BLM’s own analysis, this form of logging will increase fuel loading, fire intensity, rate of fire spread, and resistance to wildfire control for a minimum of 5 to 20 years, making fires burn hotter, faster and more severely.

Yet, despite these implications, BLM approved the project and immediately sold the timber sale to Timber Products company. It also received 18 Administrative Protests from environmental organizations, including Applegate Siskiyou Alliance, and local residents in the Applegate Valley and beyond. These protests officially challenged the projects authorization and questioned the validity of the underlying scientific analysis. In response, the BLM withdrew the timber sale in August 2022, and acknowledged that they had not adequately considered the project’s effects on the Pacific fisher, a rare forest mammal that uses mature and old-growth forests for hunting, denning, and raising their young.

Although we had hoped the Bear Grub Timber Sale would be permanently withdrawn and we would never see these special places proposed for logging again, we also know all to well, unfortunately, that the Medford District BLM has a singular focus on timber production. Rather than shelve this controversial, environmentally damaging, climate change fueling project, the BLM has doubled down and Bear Grub is back. The agency simply changed some of the language in its analysis and re-proposed the Bear Grub Timber Sale in all the same inappropriate locations, in all the same mature and old forest stands, and with the same damaging group selection logging proposal.

The Bear Grub Timber Sale proposes logging stands of mature, fire resistant forest dominated by large, old trees directly adjacent to and in the immediate viewshed of the East Applegate Ridge Trail, a spectacular and extremely popular non-motorized trail built by Applegate Trails Association and the local community. It also proposes logging beautiful and spacious old stands of Douglas fir at the headwaters of China Gulch in Wellington Wildlands, a 7,526-acre roadless area located between Humbug Creek and Ruch, Oregon. The Bear Grub Timber Sale would also log the face of Woodrat Mountain, the hills of Sterling Creek, on the flank of Bald Mountain near the headwaters of the Little Applegate River, and in some of the last mature forests in the heavily clearcut mountains above Talent and Phoenix in the Rogue Valley.

Please consider commenting on this project and let BLM know that clearcutting our public forests, under misleading euphemisms like “group selection logging,” is unacceptable. Below are talking points to help inform your comments.

Additionally, in an attempt to further reduce the voice and involvement of the public, BLM has allowed only 18 days to comment on this controversial old forest logging project. Currently the comment period ends on June 26, 2023. Please contact Medford District Manager, Elizabeth Burghard (eburghar@blm.gov) immediately and ask her to encourage public involvement by extending this shortened comment period to at least the customary 30 days or more.

Talking Points

1. The Bear Grub Timber Sale is inconsistent with the Biden Administrations climate and forest policy (Executive Order 14008 and Executive Order 14072), as well as the recently proposed BLM rulemaking intended to increase conservation “use” on public lands, maximize carbon storage and encourage natural climate solutions such as intact forest habitats.
2. BLM must withdraw the controversial Bear Grub Timber Sale from further consideration and work with the surrounding communities to address fire risks, increase carbon storage, and protect important mature and old forest habitats.
3. Cancel all “group selection” logging and maintain all northern spotted owl habitat by retaining at least 60% canopy cover and implementing a 20″ diameter limit across the entire project area.
4. Cancel all timber sale units within the 7,526 acre citizen-identified Wellington Wildlands. This must include units: 8-1, 8-2, 17-1b and 17-3.
5. Cancel all timber sale units adjacent to or in the direct viewshed of the East Applegate Ridge trail. This must include units: 13-1, 13-5, 13-6, 13-7, 13-10 and 14-2
6. Cancel all timber sale units on Bald Mountain including units 27-4 and 27-8. These forests are simply to precious and are among the last mature and old-growth forest habitats remaining in the Wagner Creek drainage.
7. Build no new roads either “temporary” or permanent.

Comments can also be sent to: BLM_OR_AFO_VMP@blm.gov  with “Attention: Bear Grub VMP” in the subject line

As part of our work with the Climate Forests Coalition, Applegate Siskiyou Alliance has been working hard to encourage the Biden Administration to protect our nation’s last climate forests. These include a wide variety of carbon-rich, mature and old-growth forest habitats spread out across the country, including right here in the Applegate River watershed. These forests mitigate the worst effects of climate change by storing carbon, providing habitat and climate refugia for wildlife, protecting watersheds and water supplies, and safeguarding biodiversity.

Although the Biden Administration has technically embraced the 30X30 concept, to protect 30% of our country’s land and water by 2030, very little meaningful action to implement this ambitious proposal has occurred. On Earth Day 2022, the administration also announced its intent to conserve mature and old-growth forests as natural climate solutions, by maximizing carbon storage on federal lands. Yet, the administration has also taken no meaningful action to provide lasting protections for these forested habitats, and federal land managers are actively working in the opposite direction.

Currently, both the BLM and Forest Service are working to increase timber production and old forest logging under the guise of “fuel reduction” and/or “forest restoration.” This includes logging larger trees, removing more canopy cover and implementing these “treatments” across much broader areas. The loss of habitat, stored carbon and forest resilience associated with these federal land logging practices is expanding exponentially across the landscape with devastating consequences for our global climate, local watersheds, regional wildlife, and biodiversity.

Fortunately, in response to President Biden’s Executive Orders on forests and climate, both the Department of Interior (BLM) and the Department of Agriculture (Forest Service) finally released their first nationwide inventory of mature and old-growth forest habitats. The inventory found 110 million acres of mature and old-growth forests remaining on federal lands, include over 32 million acres of old-growth. This includes the lush rainforests of the Pacific Northwest and Alaska, the dry pine forests and pinon-juniper woodlands of the interior West, the boggy forests of the Southeast and the vast, productive hardwood forests of the East Coast. These forests represent a potentially powerful climate solution and conservation opportunity. They store vast quantities of carbon and support irreplaceable habitat. Unfortunately, however, the mature and old forest inventory only identifies these important forests, it does not protect them.

According to the Biden Administration, protecting mature and old-growth forests would be achieved by implementing the recently published draft “conservation” rules meant to create new public land policy on both BLM and Forest Service lands in the United States. Both agencies have initiated comment periods on new planning rules emphasizing forests as natural climate solutions and a need for new management and protection strategies. This blog will focus on the BLM planning rule with a second post to follow that will cover the Forest Service process. Both the BLM and Forest Service are accepting comments until June 20, 2023, so get your comments in as soon as you can to take action to protect mature and old-growth forests.

The Proposed BLM Planning Rule

The initially released BLM draft planning rule includes numerous positive things, some that are so basic that much of the public likely believes such rudimentary conservation measures are already in place; some that could be used to support broad-scale conservation across federal lands; and some, that if not properly implemented could do more harm than good. Other provisions are downright concerning, and are likely to encourage poor land management practices and a more pronounced corporate influence on federal lands.

Interestingly, for the first time, this draft planning rule finally proposes to put conservation “on par” within the agency’s multiple use mandate, in theory, making the protection or preservation of these lands as important to BLM land managers as the extractive industrial uses they have historically encouraged, including logging, mining, grazing and oil development. Some might be surprised that for the very first time conservation could actually be part of the BLM’s mission, rather than something that can be considered only after their logging, mining, grazing and oil development priorities are met.

Although very basic, this new mandate could lead to significant improvements on federal land, but only if we speak up during this comment period, demand meaningful change, and work to make this planning rule more robust and effective.

According to the BLM, the proposed planning rule would:

1. Move forward the BLM’s multiple use mandate by prioritizing the health and resilience of ecosystems across BLM lands.
2. Protect intact landscapes, restore degraded habitats, and encourage science-based management.
3. Apply land health standards to all BLM-managed public lands (currently this applies only to so-called rangelands).
4. Elevate conservation as a valid “use” of BLM lands within the multiple use framework.
5. Implement existing, long standing, but underutilized regulations by prioritizing the designation and protection of Areas of Critical Environmental Concern on BLM lands
6. promote the use of so-called conservation leases, allowing industry groups, corporations, non-profits and other entities to lease and manage federal lands for supposed “restoration” and to mitigate otherwise damaging projects

While many of these proposed changes sound positive at face value, they also depend heavily on the strength of the final federal rulemaking and on the integrity of implementation by the BLM and local land managers. Unfortunately, neither local, regional or national BLM managers have historically, voluntarily applied conservation measures or implemented conservation mandates. For example, nearly the entire BLM Conservation Lands System has been designated by Congress or by Presidential decree under the Antiquities Act, and very little, if any meaningful conservation-based protections have been implemented by local BLM districts.

Unfortunately, this proposed rulemaking would leave implementation up to local land managers during Resource Management Planning (RMP) processes, but in places like western Oregon, where the BLM’s most carbon rich mature and old-growth forests still exist, an RMP was approved in 2016 that is encouraging heavy industrial logging in mature and old-growth stands. This includes both the Timber Harvest Landbase and so-called “reserve” designations, such as Late Successional Reserve (LSR) forests which were set aside to protect and restore old forest habitat for the imperiled northern spotted owl. Currently, these LSR forests are being logged at an alarming rate and with particularly damaging levels of intensity under projects like the Medford District BLM’s IVM Project.

Although we can support some of the general concepts put forward, we are concerned that the necessary protections will not be put in place to achieve the true conservation and climate benefits envisioned, and we are also concerned that some of the most important benefits of this rulemaking will not be realized.

Additionally, although the BLM claims to be focused on achieving ecosystem resilience, they completely fail to mention the major contributors to ecosystem declines, biodiversity loss, and carbon pollution on BLM lands in the proposed rulemaking documents. These major contributors include logging, mining, grazing and oil development, and it remains extremely dubious that BLM is proposing to prioritize the health and resilience of ecosystems, protect intact habitats, restore degraded habitats, and elevate conservation to a valid use of public lands, without addressing the very practices that created many of the problems in the first place. Sadly, these damaging extractive uses continue to degrade BLM lands, but are not directly curtailed or adequately addressed in this proposed rulemaking.

Area of Critical Environmental Concern (ACEC) designation

This proposed rulemaking would encourage an increase in Area of Critical Environmental Concern (ACEC) designations. ACECs have historically been designated on federal lands to both protect intact landscapes and provide special management for historical, cultural and scenic resources, high quality fish and wildlife habitats, dynamic natural processes, and to protect natural hazards such as geologically unstable areas. Currently, on the approximately 1.2-million acre Medford District BLM, only 3% or 36,194 acres are protected as ACECs.

While we support the increased use of ACEC designations and have proposed a comprehensive network across the Medford District BLM as part of our comments on this proposed rule, we are also concerned that the current rulemaking will water down their protection. Currently, the Federal Lands Policy and Management Act (FLPMA) gives “priority to the designation and protection of Areas of Critical Environmental Concern,” and proposes this designation to “protect and prevent irreparable damage to important historic, cultural, or scenic values, fish and wildlife resources or other natural systems or processes, or to protect life and safety from natural hazards.”

Under this rulemaking, BLM would alter these clear directives to designate, protect, and prevent resource damage, and instead proposes to prioritize the “designation and management” of ACECs. In western Oregon, we know what BLM management means, and it almost always translates to heavy commercial logging.

We support the designation of a more robust ACEC network on BLM lands, including the original emphasis on “protecting and preventing irreparable damage” to natural, cultural or historic resources. Our proposal includes the expansion or designation of 36 ACECs on 208,065 acres of BLM land. With the existing 28 ACECs, this would bring the total ACEC network to 244,259 acres, or 20% of Medford District BLM lands. Additionally, we propose that all old-growth and mature forests inventoried by the federal government be protected with ACEC designation. This would start to put conservation “on par” with other extractive uses on public lands and would enable the BLM to sufficiently focus on their climate and conservation mandates for the first time since it was established in 1946.

Under this proposal protecting at least 30% of BLM lands would be achievable and would include the most intact and diverse landscapes, with rare and unusual plant species or plant communities, along with all mature and old-growth forests, significant climate refugia, and important habitat connectivity corridors. The designation of these ACECs directly addresses President Biden’s policy support for the 30X30 concept, the biodiversity crisis and the climate crisis in one robust, comprehensive action. If done across BLM lands it could become one of the most consequential conservation action available to the BLM, preserving our imperiled environment and climate. We strongly urge high level officials at the BLM to direct local BLM land managers to protect at least 30% of all BLM lands with robust, well connected ACEC networks.

Conservation Leases

This rulemaking also proposes “conservation leases,” which are both a privatization scheme and appear to get the BLM off the hook for management actions that BLM is already required to take. It would allow entities with enough money to lease federal lands, “for the purpose of ensuring ecosystem resilience through protecting, managing, or restoring natural environments, cultural or historic resources, and ecological communities, including species and their habitats.” These leases would be for “conservation use” that would involve either “restoration or land enhancement” or “mitigation.”

These so-called conservation leases would be used to justify environmental damage by mitigating the impact to intact environments by other land management activities. The stated goal would be to “restore” habitat and encourage management activities under the guise of restoration. We are concerned that many of these activities would have the opposite effect.

For example, we know that logging mature and old-growth forest with staggered clearcuts (e.g. “group selection”), down to 30% canopy cover and trees up to 36” diameter in LSR forest is identified as “restoration” by the Medford District BLM in their IVM Project. Yet, once these so-called “restoration” projects are implemented, the public can and will only identify these “treatments” for what they are: commercial logging projects focused on producing timber for the agency’s industrial partners.  The “restorative effects” of this commercial thinning on BLM lands often does not materialize, and in many cases the loss of large, fire resistant trees and canopy cover is actually increasing fire risks.

That is not to say that positive and regenerative management activities could not take place on some previously damaged BLM lands, but as long as BLM refuses to acknowledge the disproportionate impact of its own extractive management practices, fails to require local land managers to protect these important landscapes, and promotes a shameless greenwash of their current management activities, that potential is minimal at best. You simply cannot make positive steps forward while you refuse to acknowledge the problem and you continue contributing to it.

Please help us make this once-in-a-lifetime opportunity the best it can be, and comment on the BLM’s draft planning rule. We hope to improve the final rule and we need your support to do so.

Talking points:

• Require local land managers to meaningfully curtail extractive or damaging land management activities such as logging, mining, grazing, oil development and off-road vehicle use on BLM lands.
• Curtail these damaging activities by codifying robust permanent protections for mature and old-growth forests and trees through ACEC designation. This is required to comply with President Biden’s recent Executive Order 14008 and 14072.
• Require land managers to upgrade existing Lands with Wilderness Characteristics areas to Wilderness Study Area designations, and in particular, re-inventory all wilderness quality lands in western Oregon with President Biden’s recent Executive Orders on climate and land protection, as well as this proposed rulemaking in mind. The previous inventory in the 2016 RMP for SW Oregon was not conducted in a manner consistent with the agency’s new policy direction.
• Follow the above-mentioned upgrade and reinventory with recommendations to Congress for Wilderness Designation in all Wilderness Study Areas.
• Increase the use of Area of Critical Environmental Concern (ACEC) designation by mandating specific levels of protection (a minimum of 30%) rather than limiting it to the discretion of local BLM managers.
• Require that all lands protected as ACEC or other conservation-based designations be withdrawn from mineral entry to protect them from future mining impacts.
• Support and designate an ACEC network on the Medford District BLM, as proposed by Applegate Siskiyou Alliance and Klamath Forest Alliance.
• Specifically identify additional conservation based “uses” in the BLMs multiple use framework, including carbon storage and sequestration, quiet landscapes, darkness, archeology, biodiversity, connectivity, intact lands, backcountry, old forest reserves, climate refugia, etc.
• Discontinue the proposed Conservation Lease program and instead create policies to encourage conservation on BLM lands and adequately fund them.
• Ensure that all conservation activities apply to O&C Lands in Western Oregon. Recent court rulings surrounding the Cascade-Siskiyou National Monument have affirmed that conservation is a valid use of O&C lands.  

In recent years Applegate Siskiyou Alliance (ASA) has been refining our vision, creating new connections, and bringing our advocacy to new levels. Our goal is to permanently protect the wildlands, old forests, biodiversity and wild rivers of the Applegate Siskiyou region. We have been working towards these goals by monitoring federal land management projects and filing lawsuits, objections and appeals, by organizing our community, joining national grassroots coalitions, advocating for legislative protections, supporting administrative policy changes that protect old forests across the board, educating the public, and traveling to Washington DC to lobby elected officials and federal agencies for these changes.

The citizens of the Applegate Valley and southwestern Oregon have a long tradition of forest activism and environmental advocacy, and their successes are written across the landscape wherever old forests still stand, unroaded landscapes still exist, and wild streams still run clear, cold and unencumbered by dams or other impediments. In recent years, residents in the area have worked tirelessly to oppose a seemingly endless barrage of BLM timber sales targeting old forest habitats across the Applegate River watershed and beyond. Yet, we have also found that as important and necessary as this activism is for the forests that surround us, we also need to adopt a more proactive approach advocating for stronger environmental policy, regulations, and habitat protections in our region.

Although we have been relatively successful in recent years in stopping numerous damaging timber sales throughout the region, from the Little Applegate River and Upper Applegate River watersheds, to Thompson Creek, Ruch, Murphy, Grants Pass, Selma, and along the Wild and Scenic Rogue River. We understand that sustaining this level of success through community-based activism under the land management mandates of the Medford District BLM, means a continual battle over timber sales, old-growth forests and unroaded wildlands. We also understand that our successes are temporary when a timber sale is canceled or withdrawn and our losses are permanent when a timber sale is logged.

With both of these realities and the incredible scenic, biological, recreational, biodiversity and connectivity values of our region in mind, we have gathered a coalition of local advocates and non-profit organizations together to form the Siskiyou Crest Coalition, with the goal of advocating for durable habitat protections in the spectacular Siskiyou Crest region.

The Siskiyou Crest Coalition strives to build the grassroots and political support necessary to achieve these goals, by sharing our love for the region, documenting its exceptional biodiversity, demonstrating its biological importance as one of the Pacific Northwest’s most important connectivity corridors, and generating a sense of pride in place that enables us to sustain our efforts and achieve our long-term goals.

For more information on the Siskiyou Crest Coalition, please visit the beautiful new webpage exploring the Siskiyou Crest region and highlighting our work!

Celebrating the Siskiyou Crest: A Festival of Arts, Culture & Science

Additionally, the Siskiyou Crest Coalition is organizing a Celebration of the Siskiyou Crest Festival to highlight the art, science, ecology and culture of the Siskiyou Crest region and its many important attributes. The event will include a series of regional hikes and field trips on July 14, as well as a Siskiyou Crest themed art show, panel discussions by respected local ecologists, keynote speakers, music, food, libations, and a good time with neighbors and supporters of the Siskiyou Crest on July 15-16. The art show, speakers, and other activities on July 15-16 will take place at the beautiful Pacifica Gardens in Williams, Oregon.

Festival organizers are currently accepting Siskiyou Crest inspired art for the juried art show portion of the festival, including poetry, music, video, dance, visual, textile, ceramic and sculpture arts. For more information and the application form, follow this link.

Help us bring our advocacy to the next level!

At ASA we believe advocating for the land or simply opposing the next public land timber sale is not enough, we also need to provide a vision for the future of the region and its human communities. We believe this vision must include protections for the world-class biodiversity, connectivity, and wildlands of our region. It must also include strong expressions of love for the region and a broad-based community of advocates who will act as its voice and support the protection of the Siskiyou Crest for future generations. Join us at the Siskiyou Crest Coalition and become a voice for the region!

Please support ASA as we strive to bring our work to a new level, provide a vision for the future of the Siskiyou Crest region, and organize our communities. Our goal is to both defend against immediate threats to our region and support its permanent protection. A generous donation, or recurring donation can help us build the capacity to achieve both these goals and continue leading the conservation community forward. Leave a lasting legacy for the Siskiyou Crest!

Applegate Siskiyou Alliance and our partners at Klamath Forest Alliance just released a short video about the Applegate Headwaters Wild and Scenic River proposal. The video highlights wild streams previously proposed for protection under Senator Wyden’s River Democracy Act, including the Middle Fork Applegate River, Butte Fork Applegate River, Cook and Green Creek, Whisky Creek, and Elliott Creek.

Unfortunately, Senator Wyden recently released a new version of his legislation and removed many streams in the Applegate River watershed from proposed protections, including all streams at the headwaters of the Applegate River in northern California. We are working to restore these streams to the River Democracy Act and support their protection as new Wild and Scenic River Segments.

Please sign our petition to protect these streams at the following link.

This weekend Applegate Siskiyou Alliance worked with a hardy group of 10 volunteers to plant over 1,800 native grass and wildflower plants at a habitat restoration site in the Upper Applegate Valley at Nick Wright Flat.

For six years Applegate Siskiyou Alliance has been stewarding this beautiful river terrace above the Applegate River. An unusual piece of publicly owned valley bottom land, nestled between homesteads and ranches, the site includes a large open meadow which has been largely converted to non-native grasses and weeds, along with some small remnants of native herbaceous vegetation. The site also includes open-grown ponderosa pine, Douglas fir, black oak, white oak, live oak and small tufts of bedrock protruding from the otherwise relatively level, meadowy river terrace.

Working in collaboration with the Rogue River-Siskiyou National Forest and Siskiyou Mountains Ranger District, who own the land, we have planted small areas within the grassy river terrace, year after year, in order to reintroduce native grasses and flowering species for the benefit of native butterflies, bees and other pollinating species. In some locations, older more established plantings are now providing both pollen and nectar for pollinators and beautiful floral displays that National Forest visitors can appreciate. In other locations plantings and seedlings are still getting established, and on our recent volunteer planting day new plugs, donated by the Rogue River-Siskiyou National Forest and Klamath-Siskiyou Native Seeds were planted in blocks throughout the site.

In this round of planting we planted six species and approximately 1,800 containerized plugs, including the following species: showy milkweed (Asclepias speciosa), narrowleaf milkweed (Asclepias fascicularis), cobwebby or western thistle (Cirsium occidentale), squirreltail grass (Elymus elymoides), and Roemer’s fescue (Festuca roemeri) donated by the Rogue River-Siskiyou National Forest.

A tray of 25 tall woolly wild buckwheat (Eriogonum elatum var. villosum), an uncommon species in Oregon, were donated by Klamath-Siskiyou Native Seeds for planting at the site. These plants were grown from seeds from existing tall woolly wild buckwheat plants that grow near the restoration site naturally. Tall woolly wild buckwheat only grows in a handful of locations along the rocky banks of the Applegate River today, but was likely much more abundant before historic mining impacts altered the Applegate River’s native flora, so we are pleased to increase this beautiful and important species’ population in its historic range along the Applegate River corridor.

We are both excited and proud to steward this beautiful piece of the Applegate Valley, by reintroducing native species and removing non-native and invasive plants throughout the site. We also enjoyed a beautiful winter day, under blue skies and beautiful mountain ridges, working with our friends and neighbors in the Applegate.

Thanks to the Rogue River-Siskiyou National Forest and Klamath-Siskiyou Native Seeds for the donated plant material, and thanks to the volunteers that came out and helped! We couldn’t do this important work without awesome volunteers!