The Medford District BLM recently approved the Integrated Vegetation Management for Resilient Lands (IVM) Project, which allows the agency to implement up to 20,000 acres of commercial logging and 90 miles of new road construction per decade without additional site-specific scientific analysis or meaningful public involvement opportunities. To make matters worse, this proposal focuses its commercial logging activities in areas outside the BLM’s “timber harvest land base” including Late Successional Reserve (LSR) forests designated to protect old forest habitat for the threatened northern spotted owl.
When authorizing the IVM Project, the BLM approved a theoretical “program of work” and has begun implementation of this project in the Applegate Valley by proposing the Late Mungers Vegetation Management Project, including both the Penn Butte and Late Mungers Timber Sales. Located in the mountains between Williams and Murphy, Oregon the agency has designed these timber sales and marked trees for removal without any public input or transparency, and has released a Draft Determination of NEPA Adequacy, tentatively approving the project before engaging the public.
These timber sales target some of the last intact forests in the Mungers Late Successional Reserve, an area intended to protect the connectivity of old forest habitat between the Applegate and Illinois River watersheds. Large, old trees up to 40” diameter have been authorized for removal in the Late Mungers and Penn Butte Timber Sale and significant canopy removal is also proposed. These activities will increase fire risks, damage our climate, degrade important old forest habitat, and impact scenic values in this unique and beautiful region.
Additionally, the forests proposed for logging are important to the surrounding communities and for outdoor recreation. In fact, large portions of the area were designated as the Mungers Butte Recreation Management Area in the 2016 RMP due to the area’s beautiful forests, scenic vistas and its proximity to nearby communities.
Unfortunately, none of these site-specific impacts have been adequately analyzed in the IVM Programmatic EA or the Draft Determination of NEPA Adequacy, and the public involvement process for the Late Mungers Project is severely lacking. We ask the Medford District BLM and Department of Interior to withdraw the IVM Programmatic EA and the Late Mungers Vegetation Management Project, neither project serves the public interest and neither will lead to positive, restorative outcomes.
Please comment on the Late Mungers Project. We only have until June 28 to make our voice heard. Below are talking points intended to help identify key issues to address during the comment period. Please comment now! Additional links and information on providing public comment are included at the end of this post.
Late Mungers & Penn Butte Timber Sale Talking Points:
- The scope, scale and intensity of logging, road building and vegetation management activities proposed in the Late Mungers Vegetation Management Project will have significant environmental impacts. The analysis and disclosure of these impacts should require a full Environmental Assessment (EA) or Environmental Impact Statement (EIS).
- The BLM is inappropriately using a Determination of NEPA Adequacy (DNA) Worksheet to implement the Late Mungers Project. DNAs can only be utilized if site-specific analysis has already been conducted and documented in a prior NEPA document such as an EA or EIS. Because the IVM Programmatic EA did not analyze and disclose site-specific impacts for the Late Mungers Project, a DNA worksheet is not sufficient for complying with NEPA requirements. The Late Mungers Project requires the BLM to conduct a site-specific EA.
- The Late Mungers Vegetation Management Project was not frontloaded with appropriate levels of public involvement before project objectives, treatment areas, and prescriptions were identified.
- The range of alternatives considered in the Late Mungers Vegetation Management Project was inadequate and was not informed by public scoping comments as required under the National Environmental Policy Act (NEPA).
- Contrary to the rhetoric of the BLM, the Late Mungers & Penn Butte Timber Sales will not create restorative outcomes or increase forest resilience. Instead, the projects propose old forest logging, significant canopy reduction, the removal and downgrading or suitable northern spotted owl habitat, and the removal of large diameter trees up to 40” in diameter. These activities will degrade forest habitats, increase fire risks, reduce resilience, impact nearby communities, and impact recreational opportunities.
- Neither the Draft Determination of NEPA Adequacy (DNA) nor the IVM Programmatic EA adequately considered the projects site-specific impacts or environmental conditions.
- Neither the Draft Determination of NEPA Adequacy nor the IVM Programmatic EA appropriately analyzed or disclosed the site-specific impacts of project activity on the climate, watersheds, communities, and wildlife of the Late Mungers Planning Area.
- Neither the Draft Determination of NEPA Adequacy nor the IVM Programmatic EA adequately analyzed or disclosed the site-specific impacts of proposed project activity on the Mungers Late Successional Reserve (LSR) or considered the consistency of this specific project with the old forest, carbon and connectivity values of the Mungers LSR.
- Neither the Draft Determination of NEPA Adequacy nor the IVM Programmatic EA adequately analyzed or disclosed the site-specific impact of project activities on the northern spotted owl or its habitat.
- Neither the Draft Determination of NEPA or the IVM Programmatic EA analyzed or disclosed the site-specific impacts of proposed project activity on the surrounding communities or the Mungers Butte Extensive Recreation Management Area.
- Implementation of the Late Mungers and Penn Butte Timber Sale will threaten the communities of Williams and Murphy in the Applegate Valley with increased fire risks associated with large tree removal, canopy reduction, and significant microclimate alterations from commercial logging “treatments” proposed in the Late Mungers Vegetation Management Project.
- Please withdraw the IVM Programmatic EA and the Late Mungers Determination of NEPA Adequacy document. Neither serve the public interest or encourage appropriate levels of public involvement on public lands.
For more information on the Penn Butte Timber Sale including maps of the proposed units follow this link.
To provide public comment on the Penn Butte Timber Sale click here.