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Dead & Dying? Really? BLM plans to clearcut the Applegate under a false pretense!

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.

Watch this video to see the reality of BLM’s proposal, and the dishonest narrative being used to clearcut our public lands.

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!

Unit 35-5 of the Boaz Salvage Timber Sale consists of living, green stands largely unaffected by recent beetle mortality. Literally every tree in this photograph is proposed for removal, clearcutting this stand supposedly to save it from tree mortality.

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.

This photo, taken last week, looks across the headwaters of Grouse Creek, an area that BLM dishonestly claims consists of “dead and dying” forest habitats. The agency has proposed to clearcut large swaths of living forest to “salvage” the supposedly dying trees. BLM records show that thousands of living trees will be logged at the headwaters of Grouse Creek in the Boaz Salvage Timber Sale.
The recent Lickety Split Salvage Timber Sale in the Little Applegate Valley clearcut vast acreages directly across the drainage from the Sterling Mine Ditch Trail and above the Little Applegate River in spring 2024. The project was approved using the same inappropriate Categorical Exclusion and the same misleading narrative used to justify the Boaz Salvage and Forest Creek Salvage Timber Sales. The results of the Lickety Split Timber Sale demonstrate the outcome of clearcutting both live and standing dead trees under this false narrative. Does this look like ecological forestry? BLM thinks it does.

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.

Every large overstory tree in this photo survived the recent beetle outbreak and would be logged in the BLM’s Boaz Salvage Timber Sale. This photo shows conditions in the supposedly “dead and dying” stand identified as unit 35-5.

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.

Dwarf snow bramble is found only in cool, moist habitats insulated from drought and beetle mortality like unit 35-5 of the Boaz Salvage Timber Sale.

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.

Timber sale marking crews marked trees with orange paint for retention in unit 35-5. With that in mind you can see that every large tree in this photo, except the tree on the right marked orange, would be logged. Leaving only approximately 3.3 trees per acre, the BLM would remove the mature overstory canopy, increase fire risks, degrade habitat values, reduce climate refugia, and release carbon stored in these large, old trees. Ironically, while claiming to want to reduce tree mortality, the BLM would log almost all of this resilient, old, cool, moist stand of trees.

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.

Canopy conditions in unit 35-5, which according to the BLM is a “dead and dying” stand. As you can see this forest is very much alive, but the BLM has proposed logging almost every tree in this photograph leaving as few as 3.3 trees per acre.

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.

Although unit 35-5 has sustained very little mortality from beetles in recent years, the BLM claims this mature stand, with a significant legacy tree component, is facing imminent mortality. Ironically, the only sign of imminent tree mortality is the BLM’s timber sale mark. In this photograph, only the orange marked tree would be retained and the nearly 40″ diameter tree adjacent would be logged.

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.

This large tree in unit 15-5 of the Forest Creek Salvage Timber Sale is over 36″ diameter and was originally marked for retention with orange paint. The tree was later blacked out for removal despite having a healthy green crown and growing in a stand that was largely unaffected by beetle mortality. Every tree in this photograph is proposed for logging.

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 the location of the only infestation of the noxious shiny geranium in the Applegate watershed. This invasive plant problem will be compounded with the proposed logging and soil disturbance, and logging trucks and equipment are a major risk for weed spread. The unit proposes to log off nearly all the living trees in the stand, supposedly to reduce mortality from future beetle outbreaks. So, BLM will be killing trees to ensure they don’t die?

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.

In unit 22-1 of the Forest Creek Salvage Timber Sale, all trees except the one large tree at the right-center would be logged, converting this forest into a dry grassland with a few savanna-form trees. Without forest cover and canopy the understory will likely regenerate into dense, young, highly flammable woody vegetation over time, including young conifer trees, hardwoods and shrub species. Replacing the mature trees for young growth will undoubtedly increase fire risks in this stand.

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.

The wild side of Mt. Ashland: Rare conifers, endemic plants, spectacular meadows, and expansive views

A double rainbow framing the Siskiyou Crest from the summit of Mt. Ashland

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.

Our off-trail hike to the Engelmann spruce will visit this beautiful meadow in the McDonald Peak Roadless Area, high in the Ashland Creek watershed.

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.

A view across the Ashland Creek watershed and McDonald Peak Roadless Area from near the summit of Mt. Ashland. The scrubby conifer trees in the foreground are subalpine fir.

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.

The only mature whitebark pine remaining on Mt. Ashland and in the entire Siskiyou Mountain range.

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.

Old-growth Engelmann spruce on East Fork Ashland Creek.

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.

These beautiful meadows are the off-trail hike’s final destination. The area contains intact meadow and wetland habitats, as well as robust populations of Engelmann spruce.

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.

Horsemint blooming in the meadows on East Fork Ashland Creek with groves of Engelmann spruce in the background.

Cedar Flat Timber Sale: Logging proposed on the flanks of Grayback Mountain and along the Grayback Mountain Trail

Old-growth forest targeted for logging in the Cedar Flat Timber Sale below the Grayback Mountain Trail.

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.

A proposed logging unit in Section 29 along the Grayback Mountain Trail.

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

Old-growth forest targeted for logging on Rock Creek below the Grayback Mountain Trail. The proposed logging unit contains mature and old-growth forests with minimal fire risks, large old trees, and important wildlife habitat.

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.

Mature forest proposed for logging on Rock Creek below the Grayback Mountain Trail.

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.

Old growth trees below the Grayback Mountain Trail and within the BLM’s sprawling “treatment area” in section 29.

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

A view from the Layton Ditch Trail to Big Sugarloaf Peak, Glade Fork and Rock Creek where significant old forest logging is proposed in the BLM’s Cedar Flat Timber Sale.

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.

Intact, unlogged forest at the headwaters of Glade Creek adjacent to both the Kangaroo Inventoried Roadless Area and the Grayback Glades Research Natural Area has been targeted for logging in the BLM’s Cedar Flat Timber Sale. An understory of vanillaleaf indicates a moist forest.

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.

Old forest proposed for logging in unit 34-01 of the Cedar Flat Timber Sale.

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!

Tallowbox Trail now open to the public!

Hikers at the Tallowbox Trail Grand Opening about 1 mile from the upper Tallowbox Trailhead in the mountains above Cantrall Buckley Park.

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.

Our volunteer buckbrush trail clearing crew on a cloudy October day.

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 flows through the Burton-Ninemile LWC along the lower end 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.

A view from near the intersection with the Tallowbox Lookout Road.

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.

Prairie slopes with big views on the Tallowbox Trail .

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.

Giant death camas (Toxicoscordion exaltatum)

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.

A hiker on the summit of Tallowbox Mountain enjoying the views.

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.

The Tallowbox Trail near the upper Tallowbox Trailhead with a view across the Siskiyou Crest region.

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.

The Tallowbox Trail shown in red follows single track hiking trail and old road through the Burton-Ninemile Lands with Wilderness Characteristics.

The Environmental Impacts of Salvage Logging in Southwestern Oregon: Post-disturbance logging in the Applegate Valley and city of Ashland forest lands.

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.

The slopes in the foreground were clearcut in unit 27-1 of the Lickety Split Timber Sale, a BLM salvage logging project in the Little Applegate Valley. Despite the rhetoric and greenwash, this is what salvage logging looks like when implemented by the Medford District BLM.

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

Clearcut logging in unit 28-2 of the Lickety Split Timber Sale.

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.

A “temporary” road built to access unit 36-2 of the Lickety Split Timber Sale. So-called “temporary” roads have permanent impacts.

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.

Salvage logging in the Lickety Split Timber Sale clearcut vast acreages, including the residual hardwoods and surviving conifer trees in many “treated” stands.

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.

Unit 27-1 of the Lickety Split Timber Sale was clearcut under the guise of salvage logging and is an example of the logging treatments being promoted by the BLM in beetle affected stands. Photo credit: Chas Rogers/Williams Community Forest Project

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.

Tree mortality during the recent beetle outbreak has been elevated in previously logged stands on city of Ashland lands. This photo shows a heavy tree removal mark above Lithia Park on the Bandersnatch Trail. Whole groves of dead standing trees are being logged (like the blue marked trees in this photo) and heavy thinning is being implemented in live, green stands that survived the recent beetle outbreak. The cumulative affect of previous and current logging activities in the Ashland Forest Resiliency Project has been to kill far more trees than the recent beetle outbreak.

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.

Significant green tree logging in the Acid Castle parcel demonstrates that live stands of trees that survived the beetle outbreak are being targeted with heavy commercial thinning and canopy reduction.

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.

A map from the aerial drone survey recently conducted by the city of Ashland. The map shows the Reeder Reservoir area, which will be logged to offset the cost of project activities. Notice that 93% of the trees are healthy and very little mortality (5.1% or 81 trees) was documented on site.

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.

An isolated wildlife snag approximately 30″ in diameter being targeted for removal in the Acid Castle area.

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.

Green tree logging in previously thinned stands along the White Rabbit Trail in Siskiyou Mountain Park.

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.

Green tree logging proposed in already relatively open stands of Douglas fir along the Red Queen Trail in the Ashland watershed.

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.

Soil damage and habitat destruction from clearcut salvage logging in unit 36-2 of the Lickety Split Timber Sale.

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.

BLM’s New SOS Project: Beetles, Drought & Post-Disturbance Logging

Flat headed fir borer mortality on Ferris Gulch in an area commercially thinned for “forest health” in the 1990s. Previous “forest health” thinning operations throughout the Applegate Valley are now sustaining high levels of beetle mortality.
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.

Flat headed fir borer mortality in the Little Applegate Valley.

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.

Old-growth ponderosa pine killed by pine beetles in a unit commercially thinned during the Ashland Forest Resiliency Project by the Lomakatsi Restoration Project. Located in the Ashland Research Natural Area, an area designated to study old-growth pine habitats, the units were logged to supposedly increase resilience to drought, beetles and fire, yet many of the stand’s old-growth pine have succumbed to beetle mortality and significant drought stress since the logging has occurred.

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.

Flat headed fir borer mortality is extensive in units thinned in the Lick Stew Project by the Lomakatsi Restoration Project. Implemented to “increase stand health and resilience,” the area is now being logged in the Lickety Split Salvage Project by the BLM. Over the course of a decade, this once forested stand was heavily logged using “restoration forestry,” sustained significant beetle mortality following the logging treatments, is now being subjected to post-disturbance logging, and has been deforested and/or converted to grassland.

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
The impact of post-disturbance or “salvage” logging of dead and “dying” trees on Ferris Gulch in the Applegate Valley.

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.

The SOS Project and its proposed post-disturbance logging would take place somewhere in the area identified on the map above. No site-specific units have been identified, making both credible scientific analysis and meaningful public comment nearly impossible.

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.

These photo above was taken adjacent to the photo below on Ferris Gulch in the Applegate Valley. The stand depicted above supports structurally complex, early seral habitat subjected to severe flat headed fir borer mortality, but not post-disturbance logging. The stand supports abundant hardwood regeneration, important biological legacies, snag habitat, and the building blocks for future forest or woodland complexity.
The stand in this photo lacks structure and diversity, resembles a clearcut, contains few biological legacies, supports far less regeneration than the stand above, and will lack complexity for many decades following the removal of dead and supposedly dying trees. The stand was “salvage” logged in the Squishy Bug Salvage Project on Ferris Gulch in the Applegate.

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

Addressing Threats Today and Building a Vision for the Future

2023: A Year in Review

Over the past year Applegate Siskiyou Alliance (ASA) has been working hard to address the immediate threats of today while building a vision for the future of the Applegate Siskiyou region. As an organization, we have focused on increasing our capacity, outreach and impact, while actively organizing within the community and through various environmental coalitions to support campaigns for permanent protection, and to stop projects proposed on federal lands that threatened the area’s unique biodiversity, spectacular wildlands, intact watersheds, and important wildlife habitats.

An ASA led hike to Lily Pad Lake and the Red Buttes Wilderness for the Siskiyou Crest Festival.

This includes monitoring federal land management activities across the region, reviewing those projects on the ground, writing detailed public comments and objections, and preparing for litigation if necessary. It also includes organizing local communities; leading public campaigns; hosting educational opportunities; lobbying in Washington DC; engaging elected officials, and increasing awareness for both the threats to this spectacular region and its incredible biological values.

While working to protect these wildlands from immediate threats, we also understand that we need a long-term strategy and a comprehensive vision for the Applegate Siskiyou region. This strategy includes permanent habitat protections, broad shifts in federal land policy, and strong grassroots support for conservation in the area. To achieve these goals, we have begun working on a local, national and regional level through environmental coalitions and by organizing our local communities to more actively support the permanent protection of wildlands in our region.

Below are major projects undertaken in 2023 by ASA and our supporters in southwestern Oregon.

Addressing the Threats of Today

IVM/Late Mungers

These 37″ and 40″ diameter Douglas fir trees are proposed for logging in unit 5-1 of the Late Mungers Timber Sale.

For the past three years ASA has been opposing the massive IVM Project which would approve a series of timber sales allowing up to 20,000 acres of commercial logging and 90 miles of new road construction per decade on BLM lands. In particular, the project would target Late Successional Reserve forests set aside to protect habitat for the threatened Northern spotted owl. These reserves contain mature and old-growth forests with complex, closed canopy conditions, cool, moist habitat associations, large trees, large snags and large downed wood, important for carbon storage and climate moderation. They also provide vital habitat for the northern spotted owl.

Yet instead of protecting and maintaining old forest habitat for the owl, the BLM has proposed to log these areas using heavy industrial logging prescriptions that would downgrade or remove northern spotted owl habitat by logging large trees up to 36” in diameter and reducing canopy to as low as 30%. The proposal would also approve group selection logging, a form of staggered clearcut logging, that removes whole groves of mature forest, in patches up to 4 acres at a time and on up to 20% of a forest stand. To make matters worse, projects could be implemented with no meaningful public involvement and with very minimal, if any site-specific scientific analysis.

The first major timber sales proposed under the IVM Project are located above the communities of Williams and Murphy in the western Applegate Valley, and would log large old trees in some of the last old forests remaining in the Williams and Murphy Creek watersheds.

In opposition to both the IVM Project and the Late Mungers/Penn Butte Timber Sales above Williams and Murphy we filed suit on August 10, 2023 challenging this project in the Oregon District Court, Medford Division. ASA is being represented in the lawsuit by the Colorado University Natural Resource, Energy and Environmental Law Clinic, with local Applegate and Williams residents as standing declarants in the case.

Our suit brings forward claims that the BLM violated the National Environmental Policy Act (NEPA) and the Federal Lands Policy and Management Act (FLPMA) by failing to provide sufficient site specific NEPA analysis, failing to comply with the BLM’s 2016 Resource Management Plan (RMP), and failing to adequately consider numerous relevant issues. We hope to prevail in court and protect the last old forests above Williams and Murphy, as well as old forests throughout the Medford District BLM that could be targeted for logging under the IVM Project.

Bear Grub Timber Sale

A large, dominant tree marked for logging in the Bear Grub Timber Sale.

Unfortunately, after three years of opposition and the cancellation of the Bear Grub Timber Sale in response to official Administrative Objections filed by ASA and our allies, Bear Grub is back! In June 2023, the Medford District BLM again proposed the Bear Grub Timber Sale in all the same inappropriate locations, in all the same mature and old-growth stands and with the same damaging group selection logging prescriptions.

The project proposes logging in mature, fire resistant forests dominated by large, old trees directly adjacent to or in the immediate viewshed of the popular East Applegate Ridge Trail (East ART), in the Wellington Wildlands (an over 7,000-acre roadless area), as well as in the forests of Sterling Creek, the Little Applegate River, and around Ruch, at the heart of the Applegate Valley.

We expect BLM to make a final decision on this project sometime in 2024 and will remain vigilant in our efforts to save these spectacular forests, wildlands and important recreation areas from staggered clearcut forestry, euphemistically called “group selection” logging.

Siskiyou Mountains Fuel Break Project

On a field trip with the Forest Service on Elliott Ridge.

The Rogue River-Siskiyou National Forest has proposed a large scale fuel break project in the mountains of the Applegate River watershed, including some of the most intact roadless areas, Special Interest Areas, and Botanical Areas in the region, and along some of the area’s most beloved hiking trails.

The Siskiyou Mountains Fuel Break Project would conduct manual thinning treatments on 4,290 acres along the entire Stein Butte/Elliott Ridge Trail above the Applegate Reservoir in the citizen-identified Elliott Ridge Roadless Area, along the McDonald Peak and Wagner Butte Trails in the McDonald Peak Inventoried Roadless Area and McDonald Peak Botanical Area, and along the Sevenmile Ridge Trail in the citizen-identified Big Red Mountain Roadless Area. These treatments would take place from the canyon bottoms to over 6,800’ on the Siskiyou Crest in very sensitive habitats that neither contain a significant fire risk nor would benefit from manual thinning treatments.

ASA visited thousands of acres of public land monitoring this project, attended three field trips with the Forest Service, submitted an extensive 108-page public comment on the project, and proposed our own alternative that would reduce impacts on wildland areas, while focusing more appropriately on low elevation habitats adjacent to private residences or communities, and in previously impacted ecosystems that might benefit from thoughtful and strategically implemented restoration treatments.

In 2024, we will continue monitoring this fuelbreak project and advocating for the protection of wildland habitats, intact plant communities, undisturbed non-motorized recreational values, Botanical Areas, Roadless Area and other important values found throughout the Siskiyou Mountains Fuel Break Project. We believe we can make this project better with direct and strong engagement during the planning process and will continue to do so in 2023.    

Off-Road Vehicle Closures

Visiting an off-road vehicle closure site in the Mt. Ashland/Siskiyou Peak Botanical Area with the Forest Service

For the past decade ASA has been monitoring off-road vehicle damage throughout the public lands of the Applegate River watershed and the Siskiyou Crest region. We have been using this monitoring information to advocate for the closure of illegal motorized routes in designated Botanical Areas, in sensitive habitats, and in areas that impact the Pacific Crest Trail along the Siskiyou Crest.

In 2023 this work finally began to pay dividends with closures being installed at the Klamath Meridan Overlook in the Mt. Ashland/Siskiyou Peak Botanical Area, and with the initial supply of large boulders being delivered that will create additional closures near Bearground Springs on the northeastern flank of Big Ridge, at Sheep Camp Spring in the Observation Peak Botanical Area, at Mud Springs near Condrey Mountain, and in other areas on the Siskiyou Crest. We are also in the process of working with partners to secure additional closures near Big Red Mountain in the Big Red Mountain Botanical Area, near Observation Peak in the Observation Peak Botanical Area and at other locations on the Siskiyou Crest.

In 2024, we will continue both our monitoring and advocacy and hope to secure additional off-road vehicle closures on both BLM and Forest Service lands in the Applegate watershed and Siskiyou Crest regions.

Building a Vision for the Future

Siskiyou Crest Coalition

An ASA hike on the Butte Fork Applegate River in the Kangaroo Inventoried Roadless Area.

The Siskiyou Crest is a regionally significant connectivity and climate migration corridor, with world-class biological diversity and significant wildland habitats. Yet the region remains both underappreciated and under-protected. Working with the Siskiyou Crest Coalition, we are taking a very active role in the campaign to protect the Siskiyou Crest region, and this past summer, along with numerous conservation partners, we helped organize the Celebrating the Siskiyou Crest Festival. The festival was organized to bring attention to the region, it’s incredible biodiversity, and the need for increased habitat protections. ASA is working with the Siskiyou Crest Coalition to build support for these protections in the grassroots, with elected officials, within the conservation movement, and in local communities. Our ultimate goal is the permanent protection of deserving portions of the Siskiyou Crest region.

Wild and Scenic River Designation

An ASA hike down Butte Fork Applegate River trail, along what should be a Wild and Scenic River.

For almost four years now, ASA has been working to support the designation of new Wild and Scenic River segments on tributaries of the Applegate River under Senator Wyden’s River Democracy Act. Working with the Oregon Wild and Scenic River Coalition, we nominated streams in the Applegate River watershed and are working to secure protection for these streams under the Wild and Scenic River Act. Streams currently proposed for protection in the River Democracy Act include public lands at the headwaters of Slate Creek, on Pipe Fork, in the Little Applegate River canyon, on tributaries of the Upper Applegate River, and portions of Carberry Creek. Unfortunately, the wild California portions of the watershed are not included in this legislation and we are seeking other opportunities to protect these stream under California-based Wild and Scenic River legislation.

Non-Motorized Trail Development

A volunteer trail crew building the Tallowbox Trail.

ASA is currently working to build the Tallowbox Trail, a hiking trail that would extend from Ladybug Gulch, a tributary of Star Gulch, to a ridgetop saddle east of Tallowbox Mountain. It would also be the only official trail in the Burton-Ninemile Lands with Wilderness Characteristics (LWC).

We have conducted multiple volunteer trail building events with residents from the surrounding communities. We have also secured a small grant from the Ashland Food Coop to fund more technical segments of trail construction. Currently, the trail is cleared and tread construction is approximately half finished. We hope to open this trail in time for spring wildflowers in 2024, but will need local volunteers to get this done. Watch for opportunities to participate in the construction of the Tallowbox Trail.

We are also working on additional trail proposals in the Wellington Wildlands, known as the Wellington Mine Trail. This non-motorized trail would convert old mine road on the north-facing slope of Wellington Butte into a community trail. Please sign our petition to support this trail.

Federal Rulemaking

ASA Executive Director, Luke Ruediger, at the Department of Interior in Washington DC in March 2023, lobbying for the protection of mature and old-growth forests.

ASA has been engaging in federal rulemaking processes affecting all National Forest and BLM lands. Currently, the Biden Administration has released Executive Orders to both protect mature and old forests for climate mitigation and carbon storage, and to support the 30X30 Initiative, which proposes to protect 30% of our nation’s land and waters by 2030. To implement these Executive Orders, federal land managers are preparing new federal policy intended to protect mature and old forests on public lands, and these policies would be implemented through new federal rulemaking processes to protect forests and other intact, natural habitats.

We have been working closely with numerous non-profit organizations and nationwide coalitions to inform these proposals and to support policies that would protect mature and old forests from commercial logging and our nation’s last intact wildland habitats. We have submitted extensive, detailed public comments and documented local mature and old forest logging proposals in our region, which in turn have been identified as some of the worst commercial logging projects currently proposed in the entire nation. We have also traveled to Washington DC and the halls of our Capital to lobby for these protections with senate and congressional staffers, at the Department of Interior, and at the Council for Environmental Quality.

In 2024, we will continue working towards durable, long-lasting protections for intact natural environments and mature or old-growth forests on federal lands. We will also continue documenting local timber sales, opposing those timber sales through both local and national campaigns, and working to promote better policies to protect them from future logging projects and for future generations.

Siskiyou Ecological Research Project

ASA is working to document rare and endemic species in our area, such as the Applegate stonecrop (Sedum oblanceolatum).

This past year, ASA started the Siskiyou Ecological Research Project, a citizen-based science project documenting the biodiversity of the Siskiyou Mountains. More specifically, we have started publishing the Siskiyou Crest White Paper Series to disseminate information about the region’s biodiversity and unique natural habitats.

The goal is to fill in the gaps in the current academic literature, contribute to scientific knowledge surrounding the incredible biodiversity found in the region and build more appreciation for the area’s biodiversity. Due to the area’s rugged, remote terrain, distance from population centers and academic institutions, much of the region’s unbelievable biodiversity remains undocumented, poorly documented, or underappreciated. We hope to change that by documenting unique species, habitats, and biological values in the area. We also hope to  attract interest from academic institutions, universities, non-profit organizations and government agencies who might contribute to the exploration and documentation of the region’s biodiversity and other biological values.

The program is volunteer-based, and our goal is to make the reports both academically meaningful and accessible to the general public. We are interested in working with citizens, botanists, naturalists and biologists of all sorts to highlight the biodiversity of the region through the Siskiyou Crest White Paper Series. If you would like to participate, please contact us at: luke@applegatesiskiyou.org

Siskiyou Crest Festival

David Rains Wallace delivering his keynote presentation at the Siskiyou Crest Festival.

This past summer, we worked with our partners at the Siskiyou Crest Coalition to sponsor the Celebrating the Siskiyou Crest Festival. The festival focused on the arts, culture and science of the Siskiyou Crest region with a large multimedia art show, music, a series of 10 hikes and field trips, and excellent speakers from across the region. The event was held at Pacifica Gardens in Williams, with hikes being offered from the Illinois, Rogue and Applegate watersheds.

The festival included extremely high quality presentations by top scientists and naturalists around the region. This included excellent keynote speakers such as longtime advocate for the region, David Rains Wallace, author of the Klamath Mountain classic book, The Klamath Knot. Additional keynote speakers included Joe Scott, a Siletz tribal member and active cultural practitioner, Michael Kauffman and Justin Garwood, biologists and editors of the The Klamath Mountains: A Natural History, and ASA’s own Executive Director, Luke Ruediger. The event was a huge success and we believe it enhanced the public’s understanding and appreciation for this spectacular region. We also believe it helped increase interest in protecting the region and its unique natural values.

Looking ahead in 2024

Our focus in 2024 will be on both opposing projects that damage the biological values of the region and working to better protect those values in the future. We will continue working towards creative, proactive solutions to achieve these goals, while also addressing immediate threats as they arise throughout the Applegate Siskiyou region and on our local public lands.

Please support our work with a generous year-end donation. To continue growing and expanding our programs, our influence, and our effectiveness throughout the region, we need increased financial support in 2024. Please make a tax-deductible donation. Any donation helps, and all are highly appreciated, but reoccurring donations made monthly, quarterly or annually are particularly helpful. In addition, larger donations of over $1000 will help us build the capacity we need to achieve our broad, bold goals for the Applegate River watershed. Join us as we work to protect the Applegate Siskiyou!

Siskiyou Mountains Ranger District Fuel Break Project: A Misguided Approach to Fuel Reduction on the Siskiyou Crest

The proposed Wagner Fuel Break extends through large high elevation sagebrush clearings in the McDonald Peak Inventoried Roadless Area and Botanical Area along the Wagner Butte and McDonald Peak Trails.

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.

The Sevenmile Ridge Fuel Break follows the Sevenmile Ridge Trail through vast high elevation meadows, wetlands and alder glades with relatively little fire risk.

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 proposed Wagner Fuel Break would follow one of the highest elevation ridge systems on the Siskiyou Crest from McDonald Peak to Wagner Butte through broad sagebrush clearings, intact forests and a very wide variety of ecosystems in the McDonald Peak Inventoried Roadless Area.

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.

Curly leaf mountain mahogany along the Wagner Butte Trail.

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.”

Quaking aspen along the Wagner Butte Trail.

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

The Elliott Ridge Trail contains vast stands of chaparral, knobcone pine and live oak on extremely rocky, rugged slopes. The clearing of these plant communities in proposed fuel breaks would damage what is likely one of the best examples of intact habitat in the region. It would also significantly impact the trail’s scenic values.

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.

A view from the Elliott Ridge Trail across the Elliott Creek canyon to the Siskiyou Crest. The area is a vital connectivity corridor connecting low elevation and high elevation habitats in the Siskiyou Crest region.

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.

A natural, unthinned live oak stand along the Grouse Loop Trail with woodland form and very little understory fuel.
A stand directly adjacent to the photograph above that was thinned approximately 10 years ago in the UAR Project near Applegate Reservoir. Notice the dense stump sprouting shrub form live oak in the understory and the dramatic increase in density. Removing canopy shade and thinning woodland form stands damages habitat and increases fire risks by making stands hotter, dryer and by generating dense, highly flammable vegetation in the understory.

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

Extremely low fire risks characterize the upper Sevenmile Ridge Trail proposed for fuel break construction. The area contains a diverse mixture of bunchgrass clearings, montane forest, wet meadows and alder glades at the headwaters of Glade Creek.

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.

The upper reaches of Big Red Mountain are a mile wide, highly effective natural fuel break that has stopped numerous wildfires burning on the slopes below.

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.

Open, fire resistant Jeffrey pine woodland along the Sevenmile Ridge Trail has very low fire risks and already acts as a natural fuel break. Fuel break construction is simply not necessary given the conditions on the ground.

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.

Unthinned, woodland form live oak stands along the proposed Grayback Fuel Break.
A live oak stand recently thinned in the UAW Project and within the proposed fuel break area. Notice how the large piles are likely to scorch the retention tree when burned. The project will convert live oak woodland into a hot, dry, brushy patches of dense resprouting live oak. These very dense, low statured resprouting live oak contain ample volatile oils and will dramatically increase the flammability of this stand, while also badly degrading woodland habitats.

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.

Should this intact, fire adapted old-growth forest along the Sevenmile Ridge Trail be prioritized for fuel reduction, while far higher fire risks directly adjacent to communities remain unaddressed?

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.

Are intact high elevation habitats like those in the McDonald Peak Roadless Area the biggest fire risk on our landscape? We strongly urge the Forest Service to address the real fire risks and conduct fuel reduction where it is appropriate, directly adjacent to communities.

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.

Bear Grub is Back! Comment Now!

The trees marked with white paint throughout this blog post would be logged under the Bear Grub Timber Sale. This often includes whole groves of mature trees and some of the largest trees in a stand.

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.

What will be left for future generations?

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.

Everything goes! The BLM has proposed logging this entire stand of mature, open grown Douglas fir below the East Applegate Ridge Trail.

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.

Unit 13-6 directly adjacent to the East Applegate Ridge Trail proposes removing whole groves of mature, fire resistant forest.

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.

Unit 8-2 of the Bear Grub Timber Sale contains open, fire resilient forest proposed for group selection logging at the headwaters of China Gulch in the Wellington Wildlands outside Ruch, Oregon.

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.

This map show the proposed “group selection openings,” that would be clearcut into mature forest in the Wellington Wildlands at the headwaters of China Gulch under the Bear Grub Timber Sale. The timber sale unit is identified inside the grey polygon and labeled with the unit number and the acres proposed for logging. The staggered clearcuts would be located within the embedded lighter polygons and would constitute a significant portion of each stand.

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

ASA board member, Marty Paule speaking about the Bear Grub timber sale in his backyard
We’ve been protesting the BLM’s Bear Grub Timber Sale since the pandemic, and since Applegate Siskiyou Alliance was formerly named Applegate Neighborhood Network. It’s been years now!
Wildlife in the Bear Grub Timber Sale
Bear Grub Timber Sale unit 13-6 along the East Applegate Ridge Trail
Bear Grub Timber Sale Auction Rally (Under the revised Bear Grub Timber Sale, if approved, BLM will still award the sale and rights to log these beloved Applegate forests to Timber Products Company, the same company that bought the sale at this auction two years ago!)

BLM Rulemaking on Conservation & Land Health: Help us advocate for old forests, wildlands, watersheds, and wildlife on all BLM lands!

A spectacular view from the proposed Bald Mountain ACEC in the Little Applegate River watershed.

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.

Logging large trees like those marked with white paint in this photograph is characterized as “restoration” by local BLM land managers.

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

Old-growth forest in the proposed Wellington Wildlands ACEC near Isabelle Springs on Medford District BLM lands.

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.

This 36″ diameter Douglas fir is proposed for logging in unit 26-1A of the Penn Butte Timber Sale despite being designated Late Successional Reserve forest. This unit is “leave-tree marked” meaning only the trees that are marked with yellow will remain after logging.

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

Applegate Siskiyou Alliance has proposed a major expansion of the ACEC network as part of this rulemaking process, including significant additions to the existing Dakubetede ACEC in the Little Applegate River watershed.

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.

The proposed Wellington Wildlands ACEC in the foothills of the Applegate Valley.

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.

The Medford District BLM calls “group selection” logging forest restoration, like this unit in the Sterling Sweeper Timber Sale. In reality, this logging released significant carbon pollution, degraded old forest habitat for species like the northern spotted owl, and in the years following, logging treatments will fill in with dense, highly flammable young vegetation.

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.

A view from the summit of Bolt Mountain in the proposed Bolt Mountain ACEC.

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.