The Late Mungers Vegetation Management Project includes two large, industrial timber sales on the ridge system dividing the Applegate from the Illinois Valley. This ridge system is important for habitat connectivity and includes a large block Late Successional Reserve (LSR) forest set aside to protect habitat for the northern spotted owl.
Located in the mountains above Williams, Oregon, we have reported extensively on the Penn Butte Timber Sale, which proposes logging units on Mungers Creek, China Basin Creek, and Powell Creek above the pastoral Williams Valley and the small hamlet of Williams, Oregon.
However, another timber sale is also being proposed in the mountains between Murphy in the Applegate Valley, and Selma in the Illinois Valley. Known as the Late Mungers Timber Sale, the BLM has proposed logging a series of timber sale units totaling approximately 500 acres of LSR forest.
Recently, we visited the Late Mungers Timber Sale which targets mature, late successional and old-growth forest with heavy industrial logging. Although the treatments proposed throughout the timber sale will be damaging, this post will identify the worst units we have surveyed in the Late Mungers Timber Sale.
Unit 5-1 is located at the headwaters of both Black Canyon Creek and Grays Creek. These obscure tributaries flow north into the Applegate River from the forested ridgeline below Pennington Butte, downstream of Provolt, Oregon.
Small portions of the unit extend below road 38-5-6.1 in the Black Canyon Creek watershed, while other, more intact portions are located above the road and extend to a forested ridgeline, then into the headwaters of Grays Creek. These more intact portions of the unit include mature and late successional forest, along with a significant block of old-growth, surrounded on two sides by young, dense stands regenerating from previous clearcut logging operations. This corridor of old forest provides connectivity in an area otherwise devoid of mature and late successional habitat. Unfortunately, this corridor of habitat is also proposed for logging in the Late Mungers Timber Sale.
Much of this beautiful stand is relatively open spaced, with groupings of mature and old-growth trees growing in a diverse clump formation. The stand contains important closed forest habitat, dominated by large, old trees between 20″ and over 50″ diameter, including Douglas fir, ponderosa pine, and sugar pine. Between the large conifer groupings a well developed mosaic of live oak and madrone woodland has colonized the canopy gaps and matured into a diverse and productive mixture of habitat types.
At the headwaters of Grays Creek, the unit contains mature, mid and late successional forest habitats, including closed stands of pine and fir targeted for aggressive group selection logging and heavy commercial thinning operations.
The proposed tree removal mark throughout this unit is extremely heavy handed and will damage LSR forests, late successional habitat values, habitat connectivity, and habitat complexity. In many locations, trees between 30″ and 45″ diameter have been identified for removal, and in other locations, entire old forest groupings dominated by large, carbon and habitat rich trees are proposed by the BLM for removal. This includes a number of large, old Douglas fir trees up to 45″ diameter and open-grown ponderosa pine trees up to 30″ diameter. (Note: The Late Mungers Timber Sale is “leave” or “retention tree” marked, meaning only trees marked with red or yellow paint would be retained in timber sale units. Trees that will be logged are not marked with spray paint.)
Many of the trees targeted for removal exceed the 36″ diameter and 156-year-old tree removal limits identified in the BLM’s 2016 Resource Management Plan (RMP). The removal of these trees is a violation of existing management plans, is inconsistent with LSR management and will impair northern spotted owl habitat values for decades to come.
Unit 5-1 contains important old forest habitat that should be retained as high quality northern spotted owl habitat, for its carbon storage, and for its naturally high levels of fire resistance.
On the northern slope of the ridgeline dividing Powell Creek from Murphy Creek, unit 7-1 is located at a higher elevation than most of the Late Mungers Timber Sale, and extends into a more productive montane forest of Douglas fir and scattered white fir at the headwaters of Murphy Creek. The stand contains mature to late successional forest components, large old trees, a closed canopy, and patches of structural complexity.
Unit 7-1 surrounds a large block of nesting habitat for the northern spotted owl, and although not identified as such by the BLM, it appears to support nesting habitat as well. Given the relatively productive forest conditions, this stand will continue developing habitat complexity, accumulating and recruiting large snags, downed wood and living trees through forest succession and time. The logging proposed in the Late Mungers Timber Sale will only disrupt this process, degrade habitat conditions, and remove important habitat elements.
This stand is also relatively fire resistant with a high canopy, a dominance by large trees, and relatively cool, moist habitat conditions. The canopy shading provided by large old trees also serves to suppress understory growth, and in so doing, naturally reduces fire risks.
The dramatic canopy cover reduction, the removal of large, fire resistant trees, and the alteration of microclimate conditions proposed in the Late Mungers Timber Sale will trigger both stand drying and the development of dense, woody understory fuels as young, highly flammable trees and shrubs regenerate and fill in the canopy gaps created by group selection logging and heavy commercial thinning operations.
Additionally, roughly one mile of new road is proposed for construction on the beautiful ridgeline above and across the steep mountain slopes of unit 7-1. This new road will impact intact habitats, increase noxious weed spread, create excessive erosion, and encourage illegal OHV use, while facilitating commercial logging that will degrade forest habitats, increase fire risks and contribute to the climate crisis.
Unit 22-1 is located at the headwaters of Murphy Creek in an area heavily logged decades ago. Much of unit 22-1 is a plantation forest recovering from previous logging treatments, yet the narrow eastern portion of the unit contains a beautiful mature and mid-successional mixed conifer forest with snags, downed wood, some large dominant trees, and generally complex forest habitats that have never been logged. The soils are extremely rocky with some impressive rock outcrops and very little understory growth. Understory fuel development is currently moderated by overstory canopy growth, keeping fire risks to a minimum. The lower portion of the stand also contains a beautiful mountain spring at the head of Murphy Creek.
We found a few 30” diameter trees and a large 38″ diameter tree identified for logging in this unit, and if implemented, enough canopy would be removed through logging to both trigger an understory shrub response and significantly degrade habitat conditions for the northern spotted owl.
Unit 15-1 straddles the ridgeline between Deer Creek and Murphy Creek, and contains some large, old trees over 50” diameter. The south-facing slopes in the Deer Creek watershed contain mixed conifer and hardwood groves with intact stands of live oak and madrone woodland. Patchy, low density groves of large, fire-resistant conifer species growing as islands among the canopy of hardwood trees that have colonized this harsh, ridgetop since the last mixed severity fire.
The forest and woodland in unit 15-1 do not need fuel reduction or forest health treatments and are maturing nicely without intervention. Despite minimal overstory conifer growth, trees up to 36” are identified for removal in the stand, removing some of the most fire resilient, mature trees to pierce through the canopy of hardwood forest.
This unit also extends onto the north-facing slope which contains a significant hardwood component and younger stands of Douglas fir.
The logging proposed in the Late Mungers Timber Sale would dramatically reduce canopy cover, remove large, fire resistant trees, alter microclimate conditions, degrade habitat complexity, damage northern spotted owl habitat, reduce old forest, snag and downed wood recruitment, release abundant stored carbon and increase fire risks.
Recent research by scientists at Oregon State University has demonstrated that the logging and wood products industry are the biggest producers of greenhouse gas emissions in the state of Oregon (Law. 2018). The type of old forest logging proposed in the Late Mungers Project is particularly troubling because it proposes to transform our beautiful old forests from important carbon sinks into dangerous carbon sources. The Medford District BLM is steadily converting carbon rich old forests across southwestern Oregon into carbon bombs that will only further compound current climate impacts.
The agency is also steadily converting fire resistant old forest, with currently cool, moist habitat conditions, into hot, dry, windswept habitats dominated by young, highly flammable regeneration. The removal of large, old trees and excessive levels of canopy cover (to as low as 30%) would increase fire risks on BLM lands and threaten nearby communities. The large, dominant trees proposed for logging in the Late Mungers Timber Sale and the excessive canopy reduction identified on the ground will dramatically increase fire risks on both the stand and landscape scale.
The Late Mungers Timber Sale and the old forest logging it proposes is a violation of President Biden’s Executive Order on forests and an unacceptable impact to the mature and old-growth forests that stabilize our climate, maintain fire resilience, and safeguard our clean water. We ask the Medford District BLM to comply with President Biden’s Executive Order on old forest and climate, to become part of the solution, and to cancel the Late Mungers Project!
The Medford District BLM recently approved the Integrated Vegetation Management for Resilient Lands (IVM) Project, a purposefully misleading attempt to conflate their proposals for heavy industrial logging with so-called “forest resiliency” work.
At our recent Provolt Rally, a sign was displayed by a particularly astute local resident declaring the IVM, Intentionally Very Misleading — we could not agree more!
To sign our Late Mungers Petition follow this link.
The Applegate Siskiyou Alliance has been tracking and actively opposing the IVM Project since its initial proposal in 2019, and now that the IVM has been approved, the BLM has proposed to begin implementation of the IVM Project in the mountains between Williams and Murphy, Oregon in the Applegate River watershed.
This first project, called the Late Mungers Vegetation Management Project, includes the Late Mungers and Penn Butte Timber Sales. Located in a Late Successional Reserve (LSR) forest designated to protect and develop old forest habitat for the northern spotted owl and other forest dwelling species, these timber sales extend across the Mungers Creek and Powell Creek watersheds above the Williams Valley, across numerous tributaries of the Applegate River, including Murphy Creek, and small portions of the Deer Creek watershed above Selma. Together the timber sales would log 8 million board feet of timber on 800 acres of LSR forest.
Although the BLM claims these projects will build fire resilience, restore fire-adapted stand conditions, reduce the relative abundance of “overly dense” closed canopy forest stands on the landscape scale, and develop northern spotted owl habitat through heavy industrial logging, we strongly disagree.
We disagree with the following BLM claims for the Late Mungers and Penn Butte Timber Sales:
1. The treatments proposed in the Late Mungers and Penn Butte Timber Sales are necessary, beneficial or are intended to increase fire resilience;
2. The logging treatments proposed will actually increase fire resilience on the stand or landscape level;
3. The logging treatments proposed are actually targeting “overly dense,” forest stands that are “departed” from the range of historic variability; and
4. The logging treatments proposed will develop complex forest habitat for the northern spotted owl through large tree removal and heavy canopy reduction.
For over a month, we have been out monitoring timber sale units throughout both the Penn Butte and Late Mungers Timber Sales. During that time we have found many examples of fire resilient, mature, late successional or old-growth forests proposed for logging; however, unit 26-1A is among the most egregious examples.
Unit 26-1A contains mature, montane fir forest located at roughly 5000′ elevation on the eastern face of Morgan’s Buckhorn and at the headwaters of Powell Creek. The forest in unit 26-1A burned at low severity in the 2018 Spencer Creek Fire, a complex of three small fires that burned approximately 200 acres in the mountains between Murphy, Williams, and Selma.
In unit 26-1A the fire backed downhill and burned moderately beneath groves of large, relatively open spaced Douglas fir. The fire burned through duff layers, downed wood, young understory trees and stump sprouting shrub species without altering overstory canopy conditions. The stand’s closed canopy sheltered the area from strong winds and intense sunlight, and suppressed understory growth enough to naturally moderate fuel loading. These factors combined with favorable weather conditions to limit fire intensity in unit 26-1A, maintaining fire-adapted stand conditions and rejuvenating understory vegetation, including young trees, shrubs and herbaceous species.
Four years later the forest floor contains very little dead material, virtually no significant fine fuel, and fresh, green growth, including young shrubs, herbaceous flowering growth and a new cohort of Douglas fir seedlings. The current mixture will remain largely unburnable for the next few years, and having survived the last fire unscathed, the overstory fir trees maintain high levels of fire resistance.
Ironically, despite the extremely positive fire effects sustained during the 2018 Spencer Creek Fire, the agency has decided that the fire did not kill enough trees in this stand or create the arbitrary stand conditions that BLM claims are most beneficial. The agency is now proposing to log off many of the large, fire resistant trees in unit 26-1A that survived the 2018 Spencer Creek Fire.
Utilizing a so-called “Ecosystem Resilience-open” prescription, the agency has proposed logging, large, fire resistant trees over 30″ diameter and reducing canopy cover to as low as 30% in this stand. This would require removing more than half of the stand’s living trees, and rather than restoring habitat conditions, these treatments would replace functional closed canopy forests with a mere scattering of open grown trees. The logging proposed would eliminate protective cover important for wildlife species, including the northern spotted owl, degrade canopy conditions, eliminate significant habitat complexity and contribute to microclimate alterations that will dry out forest stands, increase temperatures, and regenerate highly flammable young trees and shrubs where fire resistant forest once stood.
Unit 26-1A is “leave” tree or “retention” tree marked, meaning only those trees marked with red paint will be retained if the Penn Butte Timber Sale is implemented and old forest logging occurs. The proposed logging would degrade this currently intact, beautifully fire-adapted forest and undermine the benefits of the Spencer Creek Fire by removing fire resistant trees and damaging the natural post-fire rejuvenation and new cohort of young conifer seedlings sprouting up after the fire. The logging will also impact sensitive fire-affected soils and spread noxious weeds in currently intact fire-adapted, native plant communities.
Unit 26-1A does not need “treatment” to maintain fire-adapted forest conditions, benefit the northern spotted owl or enhance native plant communities, — the 2018 Spencer Creek Fire naturally achieved these goals.
The logging treatments proposed in unit 26-1A of the Penn Butte Timber Sale have no credible biological justification, just clear economic motivations. Despite the BLM’s rhetoric regarding “forest restoration” and “forest resilience,” the Penn Butte and Late Mungers Timber Sales are the latest and perhaps most brazen examples of industrial, old forest timber sales masquerading as restoration projects on public lands in southwestern Oregon.
To sign our Late Mungers Petition follow this link.
You can find more information on this project on recent Applegate Siskiyou Alliance blog posts. The public comment period ends on June 28.
The IVM Project is a massive, landscape-scale logging proposal recently approved by the Medford District BLM in southwestern Oregon. The IVM Project would allow for the implementation of up to 20,000 acres of commercial logging and 90 miles of new road construction in the next ten years, with virtually no site-specific environmental analysis, scientific review or public input. It would also specifically target Late Successional Reserve (LSR) forests set aside to protect habitat for the northern spotted owl and other species dependent on mature or old-growth forests.
These mature and old-growth forests are increasingly rare and increasingly important for the habitat they provide, the carbon they store, and the watershed values they protect. They are also increasingly threatened as the Medford District BLM proposes to implement the IVM Project.
Unfortunately, the BLM has proposed to begin implementation of the IVM Project with the Penn Butte and Late Mungers Timber Sales in the mountains between Murphy and Williams, Oregon. These timber sales are located, at least partially, in the rain forests of the Applegate, on Mungers Creek and upper Powell Creek. On the western margin of the Applegate River watershed, these drainages receive abundant rainfall, and dense coastal fog often pours over the ridgeline from the Illinois Valley in the winter months. This fog and rain tends to settle in these forested canyons, sustaining lush habitats indicative of the Pacific Northwest, but with a Siskiyou Mountain flare.
Forests of the endemic and threatened Port Orford-cedar grow in upper Williams Creek, along with productive forests of Douglas fir and tanoak. These habitats support plant communities not commonly found in the dry forests of the Applegate Valley, including a coastal understory shrub association of evergreen huckleberry, red huckleberry, salal, and vine maple.
Yet the BLM portions of Mungers Creek and upper Powell Creek are not just lush, carbon-rich forests; together, these drainages also contain one of the largest blocks of old forest remaining in the Mungers LSR. This large, relatively intact block of moist forest habitat is particularly important for the northern spotted owl, the Pacific fisher, the Humboldt marten and other wildlife species. Unfortunately, this same area contains a significant concentration of commercial logging units in the Penn Butte Timber Sale.
Recently, we have been out monitoring these timber sale units and below is what we found.
Units covered in this post
Unit 25-1A is part of a beautiful and highly diversified forest straddling the ridgeline between Mungers and Powell Creek, at the heart of the Mungers LSR. The unit spills over the ridge into both watersheds and contains mature and late successional forest habitat proposed for logging “treatments” that would fragment forest canopy and remove large, fire resistant trees throughout this spectacular stand.
The south-facing slopes support relatively dry forest associations of pine, fir, incense cedar and madrone, draining into the North Fork Mungers Creek. The north-facing slopes on the other hand, contain more mesic conditions. These north-facing forests contain beautiful groves of Douglas fir, incense cedar, tanoak and madrone, with thickets of young Port Orford-cedar in slight topographical depressions. This stand contains a much higher percentage of large incense cedar than other units in the Penn Butte Timber Sale and represents a forest association that is relatively unique in the planning area.
Although not identified as such on BLM maps, these forests also contain all the necessary characteristics for northern spotted owl nesting habitat and should be withdrawn from commercial entry in the Penn Butte Timber Sale. Additionally, the south-facing slopes and the remainder of unit 25-1 contain important connectivity habitat and unidentified nesting habitat. These stands tie together high quality blocks of northern spotted owl habitat in both upper Mungers and upper Powell Creek.
Logging treatments in unit 25-1A and across the larger landscape will fragment habitat connectivity, reduce suitable habitat available for the northern spotted owl and other wildlife species and degrade the old forest values remaining in the Mungers LSR, in both the long and short term.
Although unit 25-1A contains spectacularly beautiful forest habitats, the unit is also proposed for some of the heaviest logging prescriptions authorized under the IVM Project. Ironically, called “ecosystem resilience-open” prescriptions, these treatments allow significant canopy removal down to as low as 30%. Due to the heavy prescription proposed and the old forest targeted for logging, this unit likely contains the largest concentration of trees over 30” diameter proposed for removal in the entire Penn Butte Timber Sale, and the treatments proposed are inconsistent with both species recovery for the northern spotted owl and the mandates of the BLM’s 2016 Resource Management Plan (RMP), which promotes the development of additional northern spotted owl habitat in the LSR forest network.
The old trees in unit 25-1A are either relatively open grown or grow in complex clumps or groupings of older, more dominant trees. Neither these groupings or individual dominant trees should not be altered by industrial logging, as they currently provide the most important late successional forest characteristics within this beautiful stand.
Healthy groves of hardwoods such as madrone and some tanoak form a secondary canopy, clumps of young Port Orford-cedar also add to the structural diversity and canopy layering, while scattered old snags are distributed throughout the stand, and large downed wood lies strewn across the forest floor, creating diversity, holding moisture and providing structural complexity.
Unit 25-1A needs no “treatment” to maintain its health, the area is not unnaturally dense, and the area does not sustain a heavy fuel load; however, these productive old forests contain abundant standing timber volume and BLM intends to convert large portions of this old forest into lumber for local mills. This would be done at the expense of old forest values, fire resilience, wildlife habitat, the area’s spectacular scenic qualities, and nearby local communities.
Unit 25-1A demonstrates everything that is wrong with the Penn Butte Timber Sale. This unit, along with the entire Penn Butte Timber Sale, should be withdrawn and the area’s old forests should be maintained for the purposes the Mungers LSR was designated for, namely, the protection, not the destruction of old forest habitat.
Directly below unit 25-1A and directly below road 38-5-15, unit 25-1B is located on a south-facing slope at the headwaters of North Fork Mungers Creek. This stand contains relatively productive forests of Douglas fir, ponderosa pine, sugar pine, incense cedar and madrone. Old, dominant trees grow in natural groupings or as individual trees scattered throughout the stand with a younger, but mature cohort of fir, cedar and madrone filling in canopy space.
Like other units we have visited, unit 25-1B was previously thinned in the Deer Willy Stewardship Project, which focused on small diameter tree removal and non-commercial fuel reduction treatments. According to the analysis that led to this project, the treatments were focused on maintaining large trees, restoring habitat conditions and reducing fuel loads. While these objectives may have been met to various degrees in the original treatments, the BLM is now treating these previous projects as “pre-commercial” thinning in preparation for the Penn Butte Timber Sale and it’s overstory tree removal.
The heavy commercial logging proposed in unit 25-1B is counterproductive and inconsistent with the goals and objectives of the of the previously approved Deer Willy Stewardship Project, which was implemented by the Lomakatsi Restoration Project in roughly 2010. By logging off trees previously targeted for retention and “release,” previous stewardship efforts are being undermined and reversed. Additionally, fire risks and understory fuel loading will increase as dense, woody vegetation fills in the group selection clearcuts and canopy gaps created by commercial logging.
The targeting of previous so-called “forest restoration” work and non-commercial thinning done by groups such as Lomakatsi Restoration Project, for industrial logging by the BLM, makes you wonder if all the “forest restoration” work being done is just setting up the BLM for future logging operations, and are in-fact being treated by BLM as pre-commercial thinning treatments intended to facilitate the more efficient removal of old forest habitat at a later date. In this case “restoration” is a guise for commercial timber production and industrial timber management on federal lands.
This unit is also located within the largest block of relatively connected old forest habitat in the Mungers LSR and is vital for the connectivity of old forest habitats in the Mungers and Powell Creek watersheds. It also contains significant late successional forest characteristics, and many of the area’s important habitat features would be removed if the proposed logging treatments occur.
Using the heavy handed “ecosystem resilience-open” prescriptions, the BLM is proposing significant canopy reduction, converting this relatively closed forest to a mere scattering of trees. Canopy cover could be reduced to as low as 30% and many dominant, old trees over 30” diameter would be removed. Such activity provides no benefit to the Mungers LSR, and instead will damage and degrade the old forest values this area was designated to protect.
Units 25-1C, 25-1D, 25-1E, 25-1F and 25-1G
Unit 25-1 is a massive sprawling complex of commercial logging units, spread across the Mungers Creek watershed. Each sub-unit contains slightly different stand conditions and management histories. Some sub-units contain more large, old trees, and others contain more dense stands reproducing after previous logging operations. Some are located high on the ridgeline, on relatively exposed south-facing slopes, while others are located deep in the North Fork Mungers Creek canyon, adjacent to nesting, roosting and foraging habitat for the northern spotted owl.
Most of these units are mature and mid-successional stands with scattered old, dominant trees. They include forest of Douglas fir, sugar pine, ponderosa pine, the occasional incense cedar, wide branching live oak and beautiful madrone. The prescriptions in the Penn Butte Timber Sale throughout this area are among the most intensive in the entire timber sale area and include both large tree removal and group selection logging.
Group selection logging is a form of staggered clearcut forestry that would remove whole groves of mature, dominant trees. The goal is to create openings and dense young stands of regeneration. According to BLM analysis these treatments will increase fire risks, future fire intensity and resistance to control. Contrary to the rhetoric surrounding the IVM Project and the Penn Butte Timber Sale, these treatments will increase fire risks, reduce habitat quality, and degrade old forests habitats, while sacrificing our LSR forests to the timber industry.
Unit 25-2 contains mature to mid-successional stands dominated by Douglas fir and white fir, with scattered populations of large, old sugar pine and Douglas fir. In an effort to create very open stand conditions under the “Ecosystem Resilience-Open” prescription, a number of large, old, open grown trees are targeted for removal.
Additionally, the more closed, north-facing slopes would be dramatically opened through group selection logging and commercial thinning prescriptions, converting currently mid-successional, closed canopy stands into disturbed, open canopied stands that will soon fill in with highly flammable young vegetation.
Unit 25-3 contains closed canopy stands of mature and mid-successional forest. These stands contain mostly Douglas fir and white fir between 24” and 40” in diameter, with scattered old-growth sugar pine and Douglas fir trees over 5 feet thick.
The south-facing slopes above road 38-6-25.5 drain into the North Fork Mungers Creek and contain closed canopy, but relatively open spaced stands. In these areas, canopy shade is suppressing understory fuel development and has created an equilibrium where overstory growth dramatically minimizes young, shrubby in-growth and conifer regeneration. Dominated by large trees, the stand is naturally fire resistant, was previously treated for small diameter fuels and is in the process of developing late successional forest conditions, heterogeneity, large diameter snag habitat and coarse downed wood.
The north slope of the unit is more productive, but was also historically more heavily logged. It also naturally contains a higher percentage of white fir than surrounding habitats, due to the protection and microclimate conditions associated with less solar exposure. Currently, old-growth groupings, groves and scattered individual sugar pine, ponderosa pine and Douglas fir trees grow above a more uniform layer of mid-successional forest and pole stands. These mid-successional cohorts have regenerated after previous BLM logging projects and are the most dense where previous canopy removal occurred.
The logging prescriptions proposed for unit 25-3 have been identified as “near term” treatments intended to maintain northern spotted owl habitat and 60% canopy cover. The agency is implementing this prescription with a slightly altered form of group selection logging, where, in theory, all trees up to 36” for Douglas fir and pine species and 40” for white fir would be removed within a 60’ radius of trees marked for retention. Trees marked for retention and radial tree removal have been identified on site with double red bands of paint and are widely scattered throughout the unit.
Currently, the BLM claims this unit has been fully marked, but trees both within the 60’ radius and over the stated diameter limit are not marked for retention. This includes trees up to 45” diameter with significant old-growth characteristics.
At a recent BLM field trip, the agency identified the area as a “prescription by designation” unit. This means that the loggers themselves will determine which trees are removed within the currently completely undefined 60′ radius from marked leave trees. Apparently, the BLM believes the loggers will measure the 60′ radius accurately, judiciously measure each individual trees diameter, and determine which trees will be removed with no bias, no self interest and no commercial value in mind.
When the public questioned the BLM on the recent field trip, why the BLM could not just mark all “reserve” trees beyond the stated diameter limit and identify the 60′ radius on the ground, BLM silvicultural staff told us that they did not want to take the time to mark the trees for retention and that the paint they used was prohibitively expensive. Apparently, according to BLM silvicultural staff, large old trees in LSR forest are not worth the time it takes or the aesthetically unpleasing paint necessary to “reserve” them from timber harvest. Concerned residents and the public would disagree.
In some places these radial group selection cuts appear to be specifically designed to target significant concentrations of large trees for removal within 60’ of a massive old pine tree. This includes stands where an old-growth sugar pine would be cleared out to 60’, allowing dozens of large Douglas fir and ponderosa pine trees between 20” and 36” (or more) to be removed. In other locations, smaller Douglas fir trees have been marked for retention, allowing a dozen or more trees of similar or even greater size to be removed in the 60’ radial group selection cut.
We have significant concerns regarding the size of trees targeted for removal in this unit, the impact this removal will have on microclimate and stand conditions following commercial logging operations, and the economically motivated tree removal throughout the Late Mungers Project Area and Mungers LSR. The removal of large old trees in this unit will dry out forest stands and trigger an aggressive understory shrub response, increasing fire risks and fuel loading with dense, young vegetation and logging slash. It will also degrade habitat conditions for the northern spotted owl by reducing the density of large, dominant trees, reducing canopy cover, impairing habitat complexity and disrupting snag and downed wood recruitment.
The current marking strategy will lead to the removal of large, old trees that exceed the upper diameter limit identified in the 2016 RMP and the IVM Project Decision Record. We cannot support, and the BLM cannot justify, allowing the logging company themselves to interpret and implement BLM logging prescriptions on the ground.
We also believe that removing white fir trees up to 40” in diameter in LSR forest is damaging to the values intended for protection in the Mungers LSR and cannot be justified, especially in stands like 25-3, where the north-facing slope recruits and sustains white fir, as a natural component of the forest community. Unit 25-3, the Late Mungers Project and the entire IVM Project should be canceled to protect public involvement, old forest values, and northern spotted owl habitats.
The Mungers LSR was designated specifically to maintain connectivity between old forest habitats and northern spotted owl populations in the Applegate and Illinois River watersheds. In the upper Mungers and Powell Creek watershed connectivity between old forests is relatively high, and some of the most intact forest habitats remaining in the Mungers LSR can be found.
Unit 30-2 contains two separate, but nearby stands at the headwaters of North Fork Mungers Creek. These uncut, mid-successional forests contain a scattering of large, old-growth trees directly adjacent to one of the largest blocks of northern spotted owl nesting habitat in the area. The forest in unit 30-2 provides dispersal habitat between watersheds and plays a very important role in the connectivity between old forest habitats in the Mungers LSR.
The northern portion of unit 30-2 contains largely mid successional Douglas fir groves between 18” and 40” diameter. The canopy of these large overstory trees pierce through a dense layer of multi-stemmed live oak that dominates the upper portions of the slope. Growing near the ridgeline and extending deep into the interior of unit 30-2, these live oak stands and the mid-successional Douglas fir groves scattered within them, have clearly regenerated from previous wildfires of relatively high severity. The now maturing groves of Douglas fir found within this unit, break up the live oak woodland, providing important structural diversity and high levels of fire resistance.
Douglas fir trees up to 35” diameter have been identified for removal and whole groves near the ridgeline are proposed for group selection logging, which proposed removing groupings of trees between 24” and 35” in diameter and up to two acres in size.
Logging this unit would also require new road construction, built across a previously unimpacted ridgeline. The development of this logging road will impact forest soils, increase the potential for noxious weed spread, facilitate illegal OHV use, damage existing native plant communities, and require the removal of many trees and forest canopy. This additional tree removal will increase the effect of stand drying, solar exposure and accelerated windspeeds. These influences will in turn desiccate fuels, alter microclimate conditions and regenerate dense woody vegetation, creating potentially more explosive fire spread and higher severity fire effects.
The southern section of unit 30-2 also clearly regenerated from the same historic wildfire event. Located lower on the slope, the area contains a few more legacy trees than the higher, drier northern section. The large old trees in this stand appear to have survived the historic, mostly stand replacing fire and now, provide continuity between the old and the new.
By surviving the previous wildfire, these trees became the foundation for both forest regeneration and future forest complexity. Widely scattered and relatively open grown, these large old trees grow amongst a mature, mostly even-aged cohort of Douglas fir between 20” and 30” diameter. Creating more closed stand conditions as it matures, this cohort is now suppressing understory growth, maintaining less flammable microclimate conditions, creating canopy shade, and higher levels of natural fire resistance. As this stand continues to mature, the development of favorable habitat conditions will increase and the mid-successional portions of the stand will transition towards more pronounced late successional habitat characteristics.
This southern portion of unit 30-2 proposes the removal of large, dominant trees over 30” in diameter, the creation of group selection openings and the fragmentation of mature forest groupings through large tree removal. Our monitoring found a relatively, open grown, old ponderosa pine tree identified for removal. This 33” diameter ponderosa pine tree, growing with an even larger sugar pine, is part of a dominant tree grouping that survived previous fires, droughts, and all forms of adversity. Unfortunately, after surviving everything mother nature has thrown at it for perhaps hundreds of years, the tree would be removed if the Penn Butte Timber Sale is approved.
Unit 35-1 is a moist and highly productive forest habitat with significant populations of coastal forest species such as salal, pacific yew, red huckleberry, scattered tanoak and Port Orford-cedar.
The stand was historically high graded in previous BLM logging treatments, removing the largest overstory trees in what was likely a very dense, closed canopy stand of Douglas fir and Port Orford cedar. Today, after the historic logging impacts, the lower portion of the stand, closer to Munger Creek, supports patchy groves of mature Port Orford cedar and Douglas fir between 18” and 40” diameter, while higher on the slope patches of Douglas fir and sugar pine grow among remnant old-growth hardwoods and patches of madrone.
The gnarled old-growth hardwoods include some of the most impressive golden chinquapin in the Applegate watershed and are remnants of the previous old-growth forest that survived in this location for hundreds of years before BLM logging operations. These old chinquapin trees over 40” in diameter, contain twisted old canopies, internal cavity habitat, complex branch structure and important old forest characteristics.
Although the agency claims the prescription for this unit emphasizes fuel reduction, it targets many large, fire resistant overstory trees and proposes the creation of group selection openings in moist, coastal influenced forests. These forests are more likely to act as fire refugia, than to burn at high severity. Growing low on the slope near Mungers Creek and a small tributary stream, the area is lush, moist, and highly productive, with forest associations more adapted to high rainfall and fog than frequent fire. The specific location of this unit, is perhaps one of the least likely areas to burn at high severity on this landscape and the most likely to develop high quality northern spotted owl habitat conditions if left undisturbed.
Located in high relative habitat suitability for the northern spotted owl, logging these stands will degrade northern spotted owl habitat, reduce forest complexity, degrade canopy conditions and reduce available denning habitat for the Pacific fisher, while also increasing fire risks and impacting scenic values.
Our monitoring efforts identified many Douglas fir trees between 30” and 33” in diameter identified for removal in unit 35-1. The removal of these large overstory trees along with the surrounding cohorts, will dramatically open canopy cover in moist, temperate forests that naturally support dense, closed canopy forest types. Unit 35-1 is not a dry, frequent fire forest and does not require logging treatments to maintain its health (no forest does). In fact, if anything it is still recovering from previous BLM logging treatments and must be allowed to mature to both reach its full stand development capacity and to maintain northern spotted owl habitat conditions in the Mungers LSR.
Although stand conditions vary throughout the large footprint of commercial logging units proposed on Mungers and Powell Creek in the Penn Butte Timber Sale, we have found numerous common threads throughout the timber sale area. These commonalities pertain to the inappropriateness of logging treatments proposed in the Mungers LSR, the proposed removal of large, fire resistant trees, the dramatic reduction of canopy cover, the loss of forest complexity, and the degradation of northern spotted owl habitat. It also pertains to the consistent increase in fire risks that would occur if the industrial logging prescriptions in the Penn Butte Timber Sale were implemented.
Rather than restore or protect forests and communities from wildfire, the Penn Butte Timber Sale will threaten forests and communities with increased fire risks. According to the BLM’s own research the type of logging proposed tends to create brush and slash fuel types that are, “more volatile and susceptible to high rates of fire caused mortality. Stands could exhibit higher flame lengths, rates of spread, and fire intensity. Fires started within these stands could be difficult to initially attack and control,” and “the overall fire hazard would increase in these stands.”
Under the current climate scenario, we cannot afford to damage these old forests any further. They are vitally important for carbon storage, for climate mitigation, for connectivity, biodiversity, and watershed health. The Penn Butte Timber Sale, the Late Mungers Timber Sale and IVM Project should be withdrawn, LSR forests should be expanded as carbon reserves on federal lands, and the last old forests remaining on BLM lands should become part of the solution, rather than being managed to perpetuate the problem. Stop the IVM and Late Mungers Project!
The Medford District BLM recently approved the Integrated Vegetation Management for Resilient Lands (IVM) Project, which allows the agency to implement up to 20,000 acres of commercial logging and 90 miles of new road construction per decade without additional site-specific scientific analysis or meaningful public involvement opportunities. To make matters worse, this proposal focuses its commercial logging activities in areas outside the BLM’s “timber harvest land base” including Late Successional Reserve (LSR) forests designated to protect old forest habitat for the threatened northern spotted owl.
When authorizing the IVM Project, the BLM approved a theoretical “program of work” and has begun implementation of this project in the Applegate Valley by proposing the Late Mungers Vegetation Management Project, including both the Penn Butte and Late Mungers Timber Sales. Located in the mountains between Williams and Murphy, Oregon the agency has designed these timber sales and marked trees for removal without any public input or transparency, and has released a Draft Determination of NEPA Adequacy, tentatively approving the project before engaging the public.
These timber sales target some of the last intact forests in the Mungers Late Successional Reserve, an area intended to protect the connectivity of old forest habitat between the Applegate and Illinois River watersheds. Large, old trees up to 40” diameter have been authorized for removal in the Late Mungers and Penn Butte Timber Sale and significant canopy removal is also proposed. These activities will increase fire risks, damage our climate, degrade important old forest habitat, and impact scenic values in this unique and beautiful region.
Additionally, the forests proposed for logging are important to the surrounding communities and for outdoor recreation. In fact, large portions of the area were designated as the Mungers Butte Recreation Management Area in the 2016 RMP due to the area’s beautiful forests, scenic vistas and its proximity to nearby communities.
Unfortunately, none of these site-specific impacts have been adequately analyzed in the IVM Programmatic EA or the Draft Determination of NEPA Adequacy, and the public involvement process for the Late Mungers Project is severely lacking. We ask the Medford District BLM and Department of Interior to withdraw the IVM Programmatic EA and the Late Mungers Vegetation Management Project, neither project serves the public interest and neither will lead to positive, restorative outcomes.
Please comment on the Late Mungers Project. We only have until June 28 to make our voice heard. Below are talking points intended to help identify key issues to address during the comment period. Please comment now! Additional links and information on providing public comment are included at the end of this post.
Late Mungers & Penn Butte Timber Sale Talking Points:
The scope, scale and intensity of logging, road building and vegetation management activities proposed in the Late Mungers Vegetation Management Project will have significant environmental impacts. The analysis and disclosure of these impacts should require a full Environmental Assessment (EA) or Environmental Impact Statement (EIS).
The BLM is inappropriately using a Determination of NEPA Adequacy (DNA) Worksheet to implement the Late Mungers Project. DNAs can only be utilized if site-specific analysis has already been conducted and documented in a prior NEPA document such as an EA or EIS. Because the IVM Programmatic EA did not analyze and disclose site-specific impacts for the Late Mungers Project, a DNA worksheet is not sufficient for complying with NEPA requirements. The Late Mungers Project requires the BLM to conduct a site-specific EA.
The Late Mungers Vegetation Management Project was not frontloaded with appropriate levels of public involvement before project objectives, treatment areas, and prescriptions were identified.
The range of alternatives considered in the Late Mungers Vegetation Management Project was inadequate and was not informed by public scoping comments as required under the National Environmental Policy Act (NEPA).
Contrary to the rhetoric of the BLM, the Late Mungers & Penn Butte Timber Sales will not create restorative outcomes or increase forest resilience. Instead, the projects propose old forest logging, significant canopy reduction, the removal and downgrading or suitable northern spotted owl habitat, and the removal of large diameter trees up to 40” in diameter. These activities will degrade forest habitats, increase fire risks, reduce resilience, impact nearby communities, and impact recreational opportunities.
Neither the Draft Determination of NEPA Adequacy (DNA) nor the IVM Programmatic EA adequately considered the projects site-specific impacts or environmental conditions.
Neither the Draft Determination of NEPA Adequacy nor the IVM Programmatic EA appropriately analyzed or disclosed the site-specific impacts of project activity on the climate, watersheds, communities, and wildlife of the Late Mungers Planning Area.
Neither the Draft Determination of NEPA Adequacy nor the IVM Programmatic EA adequately analyzed or disclosed the site-specific impacts of proposed project activity on the Mungers Late Successional Reserve (LSR) or considered the consistency of this specific project with the old forest, carbon and connectivity values of the Mungers LSR.
Neither the Draft Determination of NEPA Adequacy nor the IVM Programmatic EA adequately analyzed or disclosed the site-specific impact of project activities on the northern spotted owl or its habitat.
Neither the Draft Determination of NEPA or the IVM Programmatic EA analyzed or disclosed the site-specific impacts of proposed project activity on the surrounding communities or the Mungers Butte Extensive Recreation Management Area.
Implementation of the Late Mungers and Penn Butte Timber Sale will threaten the communities of Williams and Murphy in the Applegate Valley with increased fire risks associated with large tree removal, canopy reduction, and significant microclimate alterations from commercial logging “treatments” proposed in the Late Mungers Vegetation Management Project.
Please withdraw the IVM Programmatic EA and the Late Mungers Determination of NEPA Adequacy document. Neither serve the public interest or encourage appropriate levels of public involvement on public lands.
For more information on the Penn Butte Timber Sale including maps of the proposed units follow this link.
To provide public comment on the Penn Butte Timber Sale click here.
The Medford District BLM recently approved the Integrated Vegetation Management for Resilient Lands (IVM) Project, a large, landscape-scale industrial logging project dressed up in the language of so-called “forest restoration,” and designed to undermine the public involvement process.
The IVM Project would authorize the BLM to log up to 20,000 acres and build up to 90 miles of new road per decade without site specific environmental or scientific review, no public disclosure of impacts and dramatically reduced public involvement processes. To make matters worse, the project is designed specifically to log Late Successional Reserve (LSR) forests set aside to protect habitat for the imperlied northern spotted owl and other areas currently outside the agency’s “timber harvest land base.”
The BLM intends to begin implementation of the IVM Project this coming fall with the Penn Butte and Late Mungers Timber Sales, west of Williams, Oregon. The proposed Penn Butte Timber Sale is located in the old forests of the Mungers Late Successional Reserve, and the BLM is currently designing the project with absolutely no public transparency or accountability. In fact, despite the repeated requests of residents from Williams and the Applegate Valley, the BLM has refused to provide maps or information on the timber sale, while at the same time marking trees and timber sale unit boundaries adjacent to our homes and communities.
In an attempt to shed some light on the BLM’s secretive timber sale plans, ANN has been scouring the landscape for marked timber sale units above Williams. On a recent weekend we were out monitoring the timber sale mark in the Penn Butte Timber Sale on Mungers Butte, as well as in the Mungers Creek and Marble Gulch watersheds, both of which are tributaries of West Fork Williams Creek.
Despite the rhetoric of forest restoration and resilience, and the claims of benevolence in the Environmental Assessment (EA) for the IVM Project, the real intent of the project becomes very clear as the tree removal mark is reviewed in the field. Although the BLM claims that the IVM Project and the Penn Butte Timber Sale will be beneficial to the forests of southwestern Oregon, the tree removal mark demonstrates otherwise, and the project is, in fact, a derisive and shameful attempt by the BLM to circumvent important public involvement processes, manipulate science, mislead the public and log some of the last mature forests in our region under the guise of “restoration” and “resilience.”
The Impacts of the IVM Project & the Proposed Penn Butte Timber Sale
The Penn Butte Timber Sale was designed by the BLM to target relatively intact, mature and old forest stands with industrial logging prescriptions. Although the agency claims otherwise, the project will produce timber for the industry at the expense of public values, environmental concerns, and recreational values.
Under the provisions of the IVM Project, the BLM has identified trees up to 36″ in diameter and over 150 years old for removal . They are also proposing to reduce canopy cover down to as low as 30%-40%, removing extensive suitable northern spotted owl habitat designated for protection in the Mungers Late Successional Reserve. They also intend to implement damaging group selection logging prescriptions. These activities will downgrade or remove thousands of acres of northern spotted owl habitat, pushing the species further towards extinction.
According to the Decision Notice for the IVM Project, group selection cuts with either no tree or minimal tree retention can occur in up to 20% of a timber sale area, and would consist of a staggered patchwork of 2 acre clearcuts embedded within mature forest stands also subjected to heavy commercial thinning. BLM staff have describe this as the “swiss cheese” treatment, where whole groves of mature forests are logged off, creating gaping holes in the forest canopy.
Yet, even BLM’s own analysis of the effects of group selection logging admits that dramatically reducing forest canopy and embedding young regeneration within mature forest stands will increase fire risks. According to the BLM, group selection logging will create brush and slash fuel types that are “more volatile and susceptible to high rates of fire caused mortality. Stands could exhibit higher flame lengths, rates of spread, and fire intensity. Fires started within these stands could be difficult to initially attack and control,” and “the overall fire hazard would increase in these stands.”
These same mature forests proposed for logging in both the IVM Project and the Penn Butte Timber Sale store abundant carbon in the trees, snags, downed wood and forest soils. When logged these forests are quickly converted from carbon sinks to significant emission sources, releasing large volumes of stored carbon as they are converted from living trees, logged, and then made into wood products.
Mature forests store moisture, hold humidity on the landscape, and maintain cool, moist habitats in a warming climate. These habitats, in turn, provide climate refugia for plant and wildlife species requiring persistent forest habitat. Opening these stands with commercial logging, removing large trees and reducing forest canopy significantly alters microclimate conditions, increases temperatures and wind speeds, dries forest soils, increases drought stress, and encourages climate induced mortality.
After a weekend hiking the units of the Penn Butte Timber Sale, we can definitively say that implementation of the IVM Project and the Penn Butte Timber Sale would make these forests more inhospitable to species like the northern spotted owl and would undermine the purpose of LSR forest designations. The proposed logging would also release large amounts of carbon currently stored in mature trees, contributing to a more extreme, dangerous, and unpredictable climate. Finally, implementation of the IVM Project would dramatically increase fire risks for the neighboring communities, making wildfires more fast moving and severe.
The Penn Butte Timber Sale is a direct outcome of the BLM’s approval of the massive IVM Project and it is just the first timber sale proposed for implementation, but is a sign of what the BLM intends to do across the 800,000-acre IVM Planning Area. While the BLM’s rhetoric surrounding the IVM Project is meant to mislead and confuse the public, the combined impact of IVM implementation, in the Penn Butte Timber Sale and many other timber sales to come, is dramatic and clear. If implemented, local communities would be negatively impacted, forests would be degraded, carbon would be released, wildlife would suffer, recreational opportunities would be diminished or destroyed and the public’s ability to participate in local public land management planning would be dramatically curtailed.
For the climate, for the wildlife, for our watersheds, and for the people of our region and the world, the mature forests of southwestern Oregon are best left standing. The BLM must cancel the IVM Project and the Penn Butte Timber Sale, become part of the solution, safeguard our climate and protect our diverse, fire resistant, and carbon rich forest habitats!
Below is a description of units ANN has recently monitored in the Penn Butte Timber Sale above Williams, Oregon, as well as directions on how to get there, so you can access these units yourself to see the old trees BLM intends to log.
Marble Gulch & North Fork Mungers Creek Units
Unit 31-1 is a large timber sale unit sprawling across a wide variety of habitats. In general, the stand consists of mature and late successional mixed conifer forest of Douglas fir, incense cedar, ponderosa pine, sugar pine, live oak, tan oak and madrone. Portions of the unit are located on Mule Gulch, a tributary of Marble Gulch, while other portions of the unit are located just over the ridge in the North Fork Mungers Creek watershed.
Most of the stand maintains a closed canopy, and scattered clumps or groupings of dominant overstory trees are found across the unit. Beneath these dominant, old-growth trees, grows a younger cohort, creating a secondary or layered canopy which shades the forest floor, suppresses understory growth and reduces the development of dense understory fuel beds, while also supporting important northern spotted owl habitat.
The unit is leave tree marked, meaning only the trees marked with yellow paint would be retained, and any tree left unmarked in this stand would be targeted for removal in the Penn Butte Timber Sale. The unit includes areas proposed for heavy commercial thinning, while other portions would be subjected to group selection logging, a form of staggered clearcut forestry.
In unit 31-1 we measured Douglas fir trees up to 35″ in diameter and likely over 180 years old proposed for removal. We also found group selection cuts marked that propose the removal of whole groves of mature trees between 24″ and 35″ in diameter. Contrary to the claims in the IVM Project EA, the Penn Butte Timber Sale would heavily fragment and degrade the Mungers LSR, increase fire risks, and reduce forest complexity.
Unit 31-1 can be accessed by walking up the gated Marble Gulch Road (39-5-5) and heading left at the first intersection on road 39-5-31.4. Look for bright flagging, unit boundary signs and yellow painted trees. The unit is flagged on the boundary. Head up into the forest and zigzag back and forth through the unit to see the old trees BLM intends to log.
Unit 31-2 is located on Marble Gulch Road (BLM Road 39-5-5 and 39-5-31.3) below the Jones Marble Quarry. Long a landmark and hiking destination in the Williams area, residents frequently hike the closed road to the mine through the mature and late successional forests below. These beautiful old forests are the attraction for this hike and are well loved by local residents in the Applegate and Williams Valleys. Unfortunately, the BLM is targeting these spectacular forests for logging in the Penn Butte Timber Sale.
Much of unit 31-2 is located on south facing slopes, but maintains mature forest cover, consisting of Douglas fir, incense cedar, ponderosa pine and sugar pine. The stand also supports beautiful hardwoods, including madrone, live oak and tanoak trees. Relatively open spaced, the groves proposed for logging include many large, old trees and diverse forest habitats.
The unit has a leave tree or retention tree mark, meaning only those trees identified with yellow paint will be retained if logging occurs. During our visit we measured ponderosa pine trees up to 34″in diameter, Douglas fir trees up to 33″ in diameter and incense cedar over 24″ in diameter identified for removal.
Both unit 31-2 and most of unit 31-1 have been previously thinned in the Deer Willy Stewardship Project, which was touted as a “restoration” and fuel reduction project, but is now clearly being used as a “pre-commercial thin,” in which non-merchantable and marginally merchantable material was removed in preparation for the BLM’s timber-heavy Penn Butte Timber Sale. The 2010 Deer Willy Stewardship Project thinned the small trees, and now the BLM is going after the old trees in the same area.
Rather than working to restore forest habitats or minimize fire risks, the BLM is instead implementing the Penn Butte Timber Sale to produce logs for the timber industry at the expense of wildlife habitat, the health of our forests, and in a manner that maximizes rather than minimizes fire risks.
Unit 31-2 can be accessed by walking up the gated Marble Gulch Road (39-5-5) and heading right at the first intersection on road 39-5-31.3. Look for bright flagging, unit boundary signs and yellow painted trees to identify the proposed timber sale unit. A walk up road 39-5-31.3 to the Jones Marble Quarry offers hikers the ability to enjoy a relatively easy old forest hike near Williams, Oregon and the opportunity to view firsthand the logging proposed by BLM in the beautiful forests of Marble Gulch.
Unit 25-1 is located on a southeastern face high in the North Fork Mungers Creek watershed, just off Upper Powell Creek Road (BLM Road 38-5-15) and near the wide intersection with the gated BLM road 38-6-25.
The stand proposed for logging in unit 25-1 consists of largely closed canopy Douglas fir, ponderosa pine, sugar pine and madrone, with a significant mature, mid-successional forest component and scattered groupings of large, old trees.
As you can imagine, removing whole groves of large fire resistant trees is detrimental to the northern spotted owl and other species dependent on late successional forest habitat such as the Pacific fisher. In LSR forest designated specifically for the protection of late successional forest habitat, the large tree removal, group selection logging, and dramatic canopy reduction proposed in the IVM Project and the Penn Butte Timber Sale is both highly problematic and inconsistent with the goals and objectives of LSR designation.
Like other units we visited, unit 25-1 was previously thinned in the Deer Willy Stewardship Project, which focused on small diameter tree removal and largely non-merchantable, non-commercial fuel reduction treatments. According to the analysis for the Deer Willy Project, which was ultimately implemented by the Lomakatsi Restoration Project, the treatments were intended to restore habitat conditions and reduce fuel loading. To some extent these initial stewardship treatments may have met some of these objectives, yet the BLM is now proposing large tree removal, heavy industrial logging and significant canopy reduction in these same locations, using former “restoration” treatments as a “pre-commercial” thins in preparation for the Penn Butte Timber Sale and the removal of large, old, fire resistant trees.
Heavy commercial logging is counterproductive and inconsistent with the goals and objectives of the formerly implemented Deer Willy Stewardship Project. By logging large, old trees previously targeted for retention and “release,” previous stewardship efforts are being undermined and reversed.
Like the other units we have reviewed in the Penn Butte Timber Sale, unit 25-1 is leave tree or retention marked, meaning only trees marked with yellow paint would be retained if logging operations take place. If such logging was to occur in unit 25-1, many large, old trees would be removed and significant canopy fragmentation would occur, creating a loss of natural fire resistance and northern spotted owl habitat.
To access unit 25-1 drive Upper Powell Creek Road (Road 38-5-15) along beautiful Powell Creek, then switch back to the ridge. At the ridgeline, you will see a wide pullout at the intersection of gated roads 38-6-25 and 38-6-25.5. The area between Upper Powell Creek Road and road 38-6-25 is proposed for logging in the Penn Butte Timber Sale as unit 25-1.
Powell Creek Units
Unit 26-1 is located on an east-facing slope at over 4,000′ on the flank of Mungers Butte near the headwaters of Powell Creek. Being higher in elevation than other timber sale units we have recently surveyed, unit 26-1 contains a more montane forest habitat dominated by Douglas fir and grand or white fir, along with an understory of chinquapin and Cascade Oregon grape.
Like other units, the stand is leave tree or retention marked, but unlike other units, crews utilized red paint to identify trees for retention. Again, these stands were lightly thinned in the Deer Willy Stewardship Project, which removed largely small diameter trees, along with some young hardwood trees and shrub species. These previous management efforts maintained canopy conditions and did not trigger an extensive understory shrub response and fuel increase.
The logging treatments proposed in the Penn Butte Timber Sale would reenter these stands with a more industrial commercial logging prescription, reducing canopy cover, breaking up naturally complex tree groupings, removing much larger, more mature trees, and encouraging the regeneration of dense, young, and highly flammable vegetation where logging occurs.
Located in both the officially designated Mungers Late Successional Reserve and the Mungers Butte Extensive Recreation Management Area, the unit would impact the scenic, recreational, and late successional forest values these areas were designated to protect.
Unit 26-1 is accessible by driving Upper Powell Creek Road (road 38-5-15) past unit 25-1 to the end of the pavement. Shortly after the gravel road begins, you will see bright flagging, unit boundary markers and trees marked with red paint. The unit extends out along the road as it runs up the ridge and then parallel to the slope.
Help us stop the Penn Butte Timber Sale & the IVM Project!
After the bigleaf maple leaves fell in the canyons, bright red berries covered madrone trees, and oak woodlands turned the foothills a vibrant golden hue, winter cast its spell across the Applegate Siskiyous. Although relatively mild and dry this season, snow has accumulated in the high country, and at times, blanketed the region from the valley bottom to the highest peaks. Rains have poured from dark clouds obscuring the mountains, filling our rivers and streams with runoff. Winds have howled across the Siskiyou Mountains, blowing down trees and bringing the fire killed snags from the recent Abney, Burnt Peak and Creedence Fires crashing to the forest floor.
The low winter sun has also brightened the grassy balds, dormant oak trees and manzanita thickets, while casting dark, cold shadows across the canyon bottoms and north-facing slopes for months at a time. Each clear, starry night has left sparkling, white frost across the landscape, which accumulates in the shade and melts off each morning in more exposed locations.
With winter waning and spring just around the bend in the Applegate Valley, we ask you to take a moment to appreciate the beauty of winter by viewing this Winter Wild and Scenic Photo Essay, highlighting streams proposed for protection in the River Democracy Act, co-sponsored by Senator Wyden and Senator Merkley.
Initiated with an open, public nomination process, the River Democracy Act empowered local citizens to nominate worthy stream segments for Wild and Scenic River protections. In response, ANN got to work documenting and nominating streams across the Applegate River watershed for Wild and Scenic River designation.
From the sparse serpentine canyon of Slate Creek, with fragrant azaleas, charismatic cobra lily fens, and elegant, streamside Port Orford-cedar, to the arid oak woodlands of the Little Applegate River, and to the headwaters of the Applegate River in deep forested canyons below the Siskiyou Crest, the proposed Applegate Wild and Scenic River contains a wide variety of beautiful streams in need of protection.
This post highlights the beauty of the Applegate River and its many wild tributary streams. Please support the River Democracy Act and the designation of Applegate River tributary streams as new Wild and Scenic River segments.
Support Clean Water and Wild Rivers! Here’s how:
Write to Oregon Senators Wyden and Merkley, thanking them for introducing the River Democracy Act. In your letter express your support for the inclusion of Applegate River streams, full, mile-wide stream buffers for all protected streams, and a full mineral withdrawal (allowing no new mining claims) on all protected streams.
2. Submit Letters to the Editor in local newspapers supporting the River Democracy Act and the inclusion of Applegate River streams.
3. Hike a trail, raft a river, and get to know the wildlands in our region. Those who know and love the region are often its best advocates.
4. Encourage your friends, family and neighbors to support the River Democracy Act and fall in love with the Siskiyou Mountains!
In September of 2021, the Klamath National Forest (KNF) approved the Road 20 Project, which proposed to pave forest roads to the summit of Mt. Ashland and out to Grouse Gap Shelter, a rustic snow shelter built along the Pacific Crest Trail at the headwaters of Grouse Creek on the Siskiyou Crest. The KNF claimed the gravel Forest Service roads had historically been paved and approved the Road 20 Project with a Categorical Exclusion for “routine road maintenance and repair.”
However, this project was approved with absolutely no public notification, no public involvement, no public comment period and no public analysis of potential impacts or environmental concerns — it was also based on faulty information.
In response to the Road 20 Project, Applegate Neighborhood Network and our allies at Klamath Forest Alliance filed suit with local residents Luke Ruediger and former Ashland City Councilor, Eric Navickas as plaintiffs. Our lawsuit claimed, the roads south of Mt. Ashland had never been paved and could not be legally paved utilizing a Categorical Exclusion.
Following the filing of our lawsuit, the Klamath National Forest conducted additional research and analysis into the issue, and discovered what many of us all knew: Road 20 on the south side of Mt. Ashland had never been previously paved. Based on this information, the agency was forced to withdraw the project and halt all road paving activities.
As the highest summit on the Siskiyou Crest and in the Siskiyou Mountains, Mt. Ashland is a special place, but its unique character does not end there. The Mt. Ashland region is particularly diverse, even for the Siskiyou Mountains. It has also been designated by the Klamath National Forest as a Botanical Area to protect the area’s rare plant species, including the Mt. Ashland lupine (Lupinus aridus spp. ashlandensis), which is found only on Mt. Ashland and is one of the rarest plant species in the Pacific Northwest.
Additional rarities include the world’s largest population of Henderson’s horkelia (Horkelia hendersonii), a Siskiyou Crest endemic found in about 8 locations between Dry Lake Lookout and Mt. Ashland, and Jaynes Canyon buckwheat (Eriogonum diclinum), which is endemic to approximately 12 locations in the northern Klamath-Siskiyou region.
The last documented sighting of the endangered Franklin’s bumble bee in 2006 was on the southern slope of Mt. Ashland, adjacent to the proposed paving area in the Road 20 Project. The direct and indirect impacts of road paving would have degraded habitat conditions through road renovation work and the increased public use, the paving would have facilitated.
The Mt. Ashland area is already very accessible and recreational use of the area is very high, including non-motorized use of the roads proposed for paving in the Road 20 Project, which are popular for hiking, botanizing, butterfly watching, bird watching, mountain biking, jogging, dog walking and other uses. These uses would have essentially been eliminated on Road 20 if paving occurred and driving speeds were increased. The additional traffic, driving speeds and access would have also damaged the backcountry experience on the Pacific Crest Trail on the southern slope of Mt. Ashland and around the Grouse Gap Shelter.
We believe the withdrawal of the Road 20 Project is the best outcome for the Mt. Ashland area, the Mt. Ashland/Siskiyou Peak Botanical Area, rare plants that inhabit the region, the endangered Franklin’s bumble bee, and for the residents of southwestern Oregon and northwestern California who appreciate the area’s wild character, botanical diversity, scenic values and existing recreational experience.
We thank the Klamath National Forest for withdrawing the Road 20 Project and look forward to working with the agency to reallocate the road maintenance funds where they could be put to a much better use, with far less impact to the important recreational, botanical and biological values of the Siskiyou Crest region.
For more information, check out these great news stories on the Mt. Ashland road paving controversy.
To support our work on behalf of the biodiversity, wildlands, forests and connectivity of the Siskiyou Crest region, please consider a generous, tax deductible donation to ANN.We need your support to continue protecting the beauty and biological integrity of the Siskiyou Crest and the Applegate River watershed.
Applegate Neighborhood Network (ANN) works at the intersection of community and conservation in the Applegate Valley. We strive to build a stronger sense of place in the Applegate River watershed, through education, stewardship, and activism.
Our goal is to inspire a culture of advocacy in the Applegate Siskiyous and to empower both friends and residents of the region to become a voice for all things wild.
As an organization and as individuals, we take pride in both the unique diversity of our region and the strength of our community. We are inspired each day by the region’s rugged beauty and have made a commitment to protect the lands that surround us. We are also inspired by our friends and supporters who make this work possible and share our passion for this spectacular landscape.
The Integrated Vegetation Management for Resilient Lands (IVM) Project
For the past two years ANN has been opposing the Bureau of Land Management’s (BLM) massive Integrated Vegetation Management for Resilient Lands (IVM) Project. Although cloaked in misleading euphemisms and language, the project is not about “restoration” or land resiliency, and instead proposes widespread industrial logging across 800,000 acres of Medford District BLM lands in southwestern Oregon. This includes forests in the Aplegate Valley, the Illinois River watershed, the Rogue Valley, in the Rogue River watershed, the Cow Creek watershed near Glendale and in many other locations throughout the region.
In fact, if approved, the IVM Project would allow the BLM to log up to 20,000 acres and build up to 90 miles of new roads per decade without additional site specific scientific review, public comment, public involvement or the disclosure of environmental impacts. By reducing or eliminating many of the processes intended to infuse public interest into public land management planning, the BLM is attempting to circumvent its obligation to the public under the National Environmental Policy Act (NEPA).
The intent of the project is simple: to increase timber production on BLM lands by cutting the public out of the process. Rather than allow the public to participate in the planning and approval process, under the provisions of the IVM Project, the BLM would approve timber sales before announcing them to the public, before providing meaningful information to the public about these timber sales, and without offering the public an opportunity to participate.
To make matters worse, the IVM Project specifically proposes this logging in Late Successional Reserve (LSR) forests set aside to protect old forest habitat for the Northern spotted owl and in other locations outside the current “timber harvest land base” identified in the BLM’s 2016 Resource Management Plan.
If approved, the IVM Project would allow the logging of trees up to 36″ DBH and over 150 years of age, the reduction of canopy cover to as low as 30%, and the implementation of “group selection” logging, a form of staggered clearcut logging that specifically targets mature forest habitats. These activities have been documented to increase fire risks, eliminate suitable Northern spotted owl habitat, and degrade scenic values that are important for the local recreation economy.
Please sign our petition to Secretary of Interior Deb Haaland, asking her to withdraw the IVM Project, maintain the NEPA processes and encourage meaningful public involvement on public lands. The IVM Project intends to eliminate the public’s influence by reducing public input, accountability, transparency and removing regulatory hurdles that promote the protection of biological values, endangered species habitat, and fire resilient old forests. Throughout the last two years ANN has been organizing against this vast and damaging timber project — this opposition will continue and intensify in 2022.
Despite having no authorization to do so, the Medford District BLM, Grants Pass Resource Area, has already begun planning projects under the provisions of the IVM Project. This includes the Late Mungers and Penn Butte Timber Sales near Mungers Butte and in the mountains between Williams, Murphy, and Selma, Oregon.
These projects, located in proximity to rural communities in the Applegate and Illinois Valleys, would increase fire risks, damage habitat conditions, and impact carbon sequestration and storage, while degrading the scenic values for which these areas are known.
Located in a large Late Successional Reserve (LSR) forest and in an important connectivity corridor between the Red Buttes Wilderness, the Siskiyou Crest and the wildlands of the Kalmiopsis, the region contains high biological values, important old forests habitats, dense coastally influenced forests, and unique serpentine soils supporting intact plant communities, spectacular wildflower displays and open stands of sugar pine, western white pine, Jeffrey pine, incense-cedar and fir.
If the IVM Project is approved, both the Late Mungers and Penn Butte Timber Sales could be implemented without site specific scientific review, the disclosure of direct, indirect or cumulative impacts, adequate public involvement or meaningful public comment periods. The impacts would be devastating to the wildlands of the area and to the surrounding communities.
In 2021, we led public hikes into the area and conducted field monitoring to document the old forests targeted for logging. We also organized with local partners on the ‘Protect Mungers Wildlands’ campaign, and have been working to engage the affected communities to oppose the IVM Project and the associated timber sales. In 2022, ANN will continue focusing on our opposition to the IVM Project, the Late Mungers Timber Sale and the Penn Butte Timber Sale.
For more information on the IVM Project and Late Mungers Timber Sale visit our campaign website:
In late 2020, ANN and Klamath Forest Alliance worked to document the many important biological values of the Pipe Fork watershed, a tributary of East Fork Williams Creek. We then nominated the watershed for Wild and Scenic River protection in the River Democracy Act.
Located on the northern slope of Sugarloaf Peak in the Kangaroo Inventoried Roadless Area, the area is the most intact drainage in the Williams Creek watershed. The spectacular Pipe Fork begins at Larkspur Spring, then pours down bedrock cascades and over log jams as it rushes through slopes of old-growth forest into the easternmost stand of Port Orford-cedar in Oregon.
Large portions of the watershed are located within the Pipe Fork Research Natural Area intended to protect this rare stand of Port Orford-cedar from logging, development and infection with the deadly Port Orford-cedar root rot (Phytophthora lateralis). Port Orford-cedar stands across its limited range have become infected by this non-native pathogen and are dying en mass in many watersheds. Yet, the Pipe Fork watershed remains intact, largely unlogged and uninfected by this devastating pathogen.
Unfortunately, while we work to secure Wild and Scenic River protections for federal lands in the watershed, the Josephine County Forestry Department is heading in the opposite direction and has proposed clearcut logging on a 320-acre parcel along the stream’s lowest reach. Our partners at the Williams Community Forest Project (WCFP) have been working to secure a conservation buyout of these threatened private lands and stop Josephine County’s shortsighted timber sale plan. ANN has played a supportive role in this effort and we encourage our supporters to get involved with WCFP and the campaign to save the Pipe Fork.
In 2022, ANN will continue supporting the proposed conservation buyout on lower Pipe Fork. We will also continue working towards the permanent protection of the adjacent federal lands as a Wild and Scenic River segment in the River Democracy Act.
For more information on the threats to Pipe Fork, read our blog:
The Rogue Gold Timber Sale is located in the mountains between Rogue River, Gold Hill and Jacksonville, on the ridgeline divide between the Applegate and Rogue River watersheds and has been proposed by the Medford District BLM. Located predominantly in Kane, Galls, and Foots Creeks, the project proposes to log the last old forest habitats remaining in these already heavily fragmented watersheds, and either remove, downgrade or degrade the last islands of suitable Northern spotted owl habitat in the area.
The removal of large, old trees up to 36″ DBH, the removal of significant forest canopy and the implementation of “group selection” logging will not only impact endangered species habitat, but it will also increase fire risks in the watershed’s last, fire-resilient, old forest habitats.
In 2021, ANN conducted extensive on-the-ground monitoring of timber sale units and submitted extensive public comments in the BLM’s Scoping process. We intend to continue tracking this project and advocating for the retention of old trees and old forests in the Rogue Gold Planning Area in 2022.
For the past five years, ANN has engaged in a collaborative process surrounding the Upper Applegate Watershed Restoration (UAW) Project, which was approved by the Forest Service (Siskiyou Mountains Ranger District) in July 2020. Throughout the planning process we worked to protect intact habitats, reduce impacts to the environment, and focus the project on the needs of the land and the community.
When the decision was released approving this project, we were happy with significant portions of the project and disappointed by others. We were disappointed by some of what was included, such as the highly controversial OHV trails on Beaver Creek that are inconsistent with the project’s stated “restoration” goals. We were also disappointed by some of what was not included, such as the pollinator and native plant restoration sites proposed by the community, and the Applegate River Ditch Trail, a proposed hiking trail that was also both envisioned and heavily supported by the community. Finally, we were hopeful that the agency would continue working with our community into the project implementation stage.
For the past year, our goal has been to improve the implementation of those portions of the project we do support, such as the extensive plantation thinning and fuel reduction treatments near communities in the Upper Applegate Valley. Yet, despite repeatedly promising to continue collaborating with our community, the Forest Service has been largely unresponsive since the project’s approval.
In late 2020 and early 2021, ANN organized a community implementation review team to monitor the fuel reduction and commercial logging units in the UAW Project. We visited the proposed thinning sites, led review team field trips and submitted a written document to the Forest Service outlining the portions of the project we support and the portions of the commercial logging mark that we believe could be improved. After almost a year, the Forest Service has yet to respond and the thinning projects are unfortunately moving forward without the promised community collaboration.
In 2022, we will continue our advocacy in the UAW Project area and continue striving for real community collaboration. We will also continue working to design, map and encourage the designation of the proposed Applegate River Ditch Trail. Our goal is to improve outcomes in the UAW Project for both the environment and residents of the Upper Applegate Valley.
Envisioning the Future of Conservation in the Applegate
Siskiyou Crest Coalition
In 2021 ANN worked with partner organizations and supportive individuals to start the Siskiyou Crest Coalition. The goal of the Siskiyou Crest Coalition is to promote and secure permanent habitat protections for the Siskiyou Crest and the surrounding mountains.
Our vision for the future of the Applegate includes broad protected landscapes, rewilding projects, the restoration of natural processes, the maintenance of our region’s world-class biodiversity, thriving rural communities connected to the landscape that surrounds them, and sustainable outdoor recreation. We are actively working with rural communities in southwestern Oregon to promote this vision for the future
In 2021, ANN and the Siskiyou Crest Coalition joined forces on a series of public hikes into the wildlands of the Siskiyou Crest, sponsored online webinars exploring the area’s complex ecology, and hosted the premiere film showing of Sagebrush to Sea: A Journey Across the Siskiyou Crest.
In 2022, we will continue our advocacy for the Siskiyou Crest through coordination with the Siskiyou Crest Coalition.
After working to nominate numerous new Wild and Scenic River segments in the Applegate River watershed, we are now collaborating with both the Siskiyou Crest Coalition and the Oregon Wild and Scenic River Coalition to amplify our voice and more effectively promote our proposals.
Currently, public lands throughout the Applegate River watershed are proposed for permanent protection as Wild and Scenic River segments in Senator Ron Wyden’s River Democracy Act. The legislation calls for the protection of portions of the Middle Fork Applegate River, Butte Fork Applegate River, Elliott Creek, Carberry Creek, tributaries of the Upper Applegate River, the Little Applegate River canyon, Pipe Fork, Long Gulch and Slate Creek.
ANN will be working in 2022 to secure passage of the River Democracy Act and gain permanent watershed protections for these iconic Applegate River tributary streams.
For more information on our proposal read our blog:
Although technically outside the Applegate River watershed, Mt. Ashland is the highest peak on the Siskiyou Crest and is threatened by a road paving project proposed by the Klamath National Forest. This project proposes paving Forest Service Road 20 from the Mt. Ashland Ski Area parking lot to Grouse Gap Shelter at the headwaters of Grouse Creek, and to the very summit of Mt. Ashland. We believe this project is not only completely unnecessary, but damaging to the environment, to numerous rare plant species, and to the current recreational uses in the area.
Paving these roads will create direct, indirect and cumulative impacts that were not adequately considered by the Klamath National Forest when they approved this project, with absolutely no public input or scientific analysis.
Our vision for the future of Mt. Ashland and the Siskiyou Crest does not include additional development, road paving, the encouragement of overuse, and/or the degradation of the unique natural values found on the highest peaks in the Siskiyou Mountains. We will continue working in 2022 to oppose this project and protect the many important biological and recreational values of the Mt. Ashland area.
In 2o21, ANN worked across the Applegate watershed advocating for conservation and community values. We opposed those projects that threatened our environment and our community, we led hikes to regional wildlands; we hosted educational presentations; we advocated for the permanent protection of regional rivers and streams, and began organizing to implement our vision for the future of the Applegate River watershed. We look forward to 2022, and working with you to protect, defend and restore the wildlands, wildlife and biodiversity of the Applegate Siskiyous!
The vast majority of ANN’s funding comes from supporters like you. Donate Now!
Although just outside the Applegate River watershed, at 7,532′ Mt. Ashland is the highest peak on the Siskiyou Crest, a botanical paradise, and one of the most beautiful and accessible landscapes in the region. Important as the gateway to the Siskiyou Crest, and located at its intersection with the Cascade Mountains in the nearby Cascade-Siskiyou National Monument, the area is also very important for its habitat connectivity and contains extremely high biological, botanical and scenic values. It is also a very popular recreation area, offering world-class hiking on the Pacific Crest Trail, mountain biking and hiking in the adjacent Ashland Creek Watershed, hiking in the McDonald Peak Roadless Area, incredible botanizing, pollinator viewing, and camping at the two primitive campgrounds, including the Mt. Ashland Campground and Grouse Gap Shelter, a CCC-era snow shelter built in the Grouse Creek Basin.
The area is wild and spectacularly beautiful despite being easily accessible from the town of Ashland, Oregon. It is only a short distance from Interstate 5 on the Mt. Ashland Ski Road to the Mt. Ashland Ski Area. However, the mountain’s southern face remains accessible only by gravel roads that extend from the pavement’s end at the Mt. Ashland Ski Area. This gravel road access helps to retain the area’s incredible backcountry charm and reduce the impact of overuse on both the ecology of the mountain and the recreational experience it provides.
Unfortunately, the Klamath National Forest has proposed paving Forest Service Road 20 from the Mt Ashland Ski Area overflow parking lot, around the southern face of Mt. Ashland to the Grouse Gap Shelter, and up to the very summit of Mt. Ashland. This project, although completely unnecessary, comes at a high price to the region’s incredible botanical diversity, biological values, habitat connectivity, and recreational experience.
Currently Road 20 is particularly popular for dog walking, jogging, mountain biking and hiking directly on the gravel road surface, past the Mt. Ashland Ski Area overflowing parking lot. If paved, traffic and driving speeds would dramatically increase on Road 20, leading to a total loss of this currently popular recreational resource. Paving these roads will negatively impact Mt. Ashland’s two backcountry campgrounds. The traffic, increased driving speeds, noise, increased use and the loss of solitude in the area will also impact recreation on the Pacific Crest Trail and on adjacent trails in the Ashland Creek watershed, degrading one of southwestern Oregon’s most important recreational resources.
In addition, access to the area on the existing high standard gravel roads is already completely adequate. In fact, if anything the area is already perhaps too accessible and suffers from impacts associated with overuse. Rare native plants are routinely walked on, driven over and crushed along the road systems on Mt. Ashland. Paving will only increase this impact.
As described above, paving these roads will impact the currently very popular forms of recreation found in the area today; however, the impacts will also be quite severe to the region’s important biological values.
As the axis of connectivity between the Siskiyou Crest and the Cascade Mountains, the old-growth forests, subalpine parklands, wet meadows, rock gardens and aspen glades in the area are highly important as both wildlife habitat and for their intact and exceptionally diverse botanical values.
Designated as the Mt. Ashland-Siskiyou Peak Botanical Area, the region contains the world’s entire population of the Mt. Ashland lupine (Lupinus aridis ssp. ashlandensis), along with numerous other rare wildflowers and two rare conifer populations. These populations could easily be impacted directly by the proposed road paving project and will certainly sustain impacts associated with overuse in the future if the road is paved. These impacts have already begun to mount in the area, forcing Forest Service action by closing down unauthorized parking areas and user-created trails to reduce impacts on rare plant species.
Ecological impacts will multiply exponentially with the increased use facilitated by the proposed Forest Service Road 20 Paving Project. The additional traffic and recreational use will increase the destruction of vegetation associated with user-created trails and excessive trampling. Very little parking exists along this narrow road system, and parking on roadsides and unauthorized parking areas will undoubtedly increase with the proposed road paving, leading to further vegetation damage, soil compaction, accelerated surface erosion, and gully creation on fragile decomposed granite soils. These impacts are inconsistent with the mandates in the Fish & Wildlife Service’s Conservation Agreement for the Mt. Ashland lupine and other rare plant species found on the mountain and should not be authorized.
This includes impacts to numerous rare plant species that grow directly adjacent to the roadway. Species impacted could include the only population of Mt. Ashland lupine in the world, one of only 8 populations of the endemic Henderson’s horkelia (Horkelia hendersonii) which is found only on the Siskiyou Crest, and one of only 8 populations of Jayne’s Canyon buckwheat (Eriogonum diclinum) which is endemic to the Klamath-Siskiyou Mountains. Impacts to these species will be particularly severe along the Mt. Ashland Summit Road and on the summit itself, where many rare species grow, including these unique wildflowers, along with the only population of whitebark pine (Pinus albicaulis) in the Siskiyou Mountains — the population consists of only a few vulnerable trees — and one of only two populations of subalpine fir (Abies lasiocarpa) on the Siskiyou Crest.
In recent years, increased use has compounded the impact of recreation on Mt. Ashland, including impacts to the important plant species mentioned above. Likewise, just this past summer, staff on the Rogue River-Siskiyou National Forest removed graffiti from large granite boulders near the summit of Mt. Ashland. Unsightly impacts such as graffiti will increase if the roads are paved and Mt. Ashland is made even more accessible.
To date, the Klamath National Forest has provided no real justification for the so-called Forest Service Road 20 Project and the agency has also worked to ensure the public has no voice in this process. The agency approved the project with no public notification (besides one, single facebook post), no environmental or scientific analysis, no public comment period, no disclosure of direct, indirect or cumulative impacts, and with no attempt at public transparency.
The authorization for this large road paving project on Mt. Ashland was authorized through a paltry, one-page Categorical Exclusion (CE). Read the Road 20 Road Paving Project CE here.
ANN opposes the Forest Service Road 20 Project and we invite you to join us in making our voice heard. Please help us stop the Forest Service Road 20 Project that proposes to pave roads on Mt. Ashland by both signing our petition and sending the District Ranger for the Happy Camp/Oak Knoll Ranger District, and the Forest Supervisor for the Klamath National Forest an email expressing your concerns.
Since the agency did not ask for our input, we must take the initiative ourselves and advocate for Mt. Ashland, the Siskiyou Crest and the area’s many important biological values. We have one very simple message: No new pavement on Mt. Ashland!
In January 2019, the BLM proposed the Anderson Butte Safety Project to address serious public safety concerns with inappropriate, irresponsible, and unsafe target shooting near Anderson Butte in the Little Applegate River Watershed.
For many years, the BLM has allowed unmanaged and irresponsible target shooting to expand across the face of Anderson Butte and throughout Medford District BLM lands. This activity has threatened lives, contaminated forest soils with lead bullets, encouraged illegal dumping on unauthorized shooting sites, and pushed other public land users off the landscape, literally out of fear for their own lives.
Also for many years, local community members and public land visitors have complained to the Medford District BLM about the obvious safety risks posed by people shooting down public roads, across public hiking trails and off big open spaces elevated directly above rural communities. In January 2016, a neighbor on Griffin Lane had a bullet fired from BLM land above her home and lodge into her front door. Other neighbors have also been threatened by stray bullets shot from BLM land towards their private residential properties. Likewise, many hikers, equestrians and mountain bikers utilizing the Sterling Mine Ditch Trail (an Oregon State Scenic Trail), the Jack-Ash Trail, and the Wolf Gap Trail have also been threatened by stray bullets while enjoying their public lands.
Public land managers across the country have begun limiting target shooting to safe and ecologically appropriate sites that do not threaten the safety of other public land users, yet our local BLM has allowed public safety concerns to escalate, and recreational shooting now overwhelms and displaces other users in the Anderson Butte area and throughout other portions of the Medford District. We do not believe going for a hike on public lands should be a life threatening experience, nor do we believe that nearby landowners should have to be regularly threatened by stray bullets on their own land.
Currently, the Medford District BLM’s so-called multiple use policy has been replaced and subverted, in many locations, by a “dominant use” policy, where the most intrusive, intimidating, damaging and dominant forms of recreational use are the most prominent, but not the most popular uses of public land.
At times, to truly provide for multiple uses and to accommodate a wide variety of public land users, the BLM must curtail incompatible uses to maintain both public safety and ensure enjoyable, high quality recreational opportunities are available to all public land users. Currently, the Anderson Butte area is suffering from agency neglect, indifference and bias that creates a de facto “dominant use” policy.
Although numerous trailheads in the region were “closed to target shooting” in the BLM’s 2016 Resource Management Plan, these closures have gone completely unenforced, and the problem only intensified following the development of the Jack-Ash Trail in 2017.
The Jack-Ash Trail was heavily supported by the surrounding communities and required significant collaborative efforts between the Siskiyou Upland Trails Association, the public and the BLM. The project was approved by the BLM and funded through private donations, grants, extensive volunteer efforts and agency support. Yet, rather than provide a safe recreational experience for the public, the BLM has allowed the situation to become extremely dangerous.
Unfortunately, many hikers, equestrians and mountain bikers have experienced the trauma of approaching a trailhead with excessive automatic gunfire occurring. They have felt unsafe and vulnerable to bullets raining down on designated recreational trails. The impact to trail users has created a situation where people decide to either risk their lives enjoying the Jack-Ash Trail, or avoid the area altogether. After the considerable collaborative and volunteer efforts to build this beautiful non-motorized trail, public members are frustrated and upset that basic public safety has not been maintained by our local land managers.
The situation is particularly problematic not only because of the level of recreational use and the number of residential properties surrounding the area, but also because of the open nature of the environment on Anderson Butte. Much of the area supports south- and west-facing slopes with broad sloping grasslands and large stands of chaparral. These areas do not provide an adequate backstop and bullets can fly unobstructed across long distances towards homes, communities and public recreational trails. The situation is extremely dangerous, and at some point someone could be killed or injured by stray bullets. We ask the BLM to act before that happens and close the area to recreational shooting.
Multiple fires have also been started in the Anderson Butte area since 2002 from irresponsible target shooting, further threatening the communities below. These human caused ignitions are preventable and can be reduced by prohibiting target shooting in the Anderson Butte area.
Finally, after decades of pressure by residents and other recreational users, the BLM proposed the Anderson Butte Safety Project. This project proposes the closure of 11 specific sites to recreational target shooting, totaling 50 acres on BLM lands near Anderson Butte. The closures are currently proposed for only two years and, unfortunately, the BLM is addressing this long-term public safety problem, with a temporary, short-term “solution.”
Way back in January of 2019, the BLM accepted public comments on the Anderson Butte Safety Project and the associated Environmental Assessment (EA). ANN and many others submitted substantive comments on the project and had hoped to see the closures move forward, but the project has been stymied since that time and no progress has been made. Now two years later, after as many years as the closure is proposed to last, the BLM has initiated an additional 60-day comment period before releasing a final decision and working to maintain public safety in this beautiful area.
Unfortunately, the 2019 John Dingle Jr. Conservation and Recreation Act, which contained many good provisions and new wilderness areas, also requires an additional 60-day comment period before the BLM can release a final decision and close small portions of the area to target shooting. That comment period extends to January 3, 2022. We hope you will again speak up for the safety of residents, trail users and other public land users on Anderson Butte.
Join us by commenting on this project and asking the BLM to:
Institute a permanent recreational shooting closure to restore public safety throughout BLM lands near Anderson Butte, including the area between Talent and Phoenix, Oregon, the Little Applegate River, Wagner Creek Road and Sterling Creek Road. The proposed two year closure on 11 specific sites is not adequate to protect and maintain the safety of other public land users and nearby private property owners.
Implement and fund aggressive monitoring, signage and enforcement of this closure to ensure compliance and maintain public safety.
Conduct a separate, comprehensive, district-wide NEPA project analyzing recreational shooting on Medford District BLM lands. This process should close most BLM land to target shooting, while designating a limited number of safe public shooting sites on BLM lands. These sites should be specifically chosen because they do not threaten nearby homeowners, do not conflict with other recreational uses such as hiking and driving on backcountry roads, do not create excessive environmental impacts, and will not contaminate soils in riparian areas with lead shot.
To be very clear, ANN does not oppose the Second Amendment and we understand the right of individuals to bear arms. We take no position on public land hunting and acknowledge ethical, backcountry hunting as a valid public land use. Yet, we do take a position on irresponsible, dispersed public land shooting. We are extremely concerned by the impacts associated with irresponsible shooting on our communities, to public safety and to our environment.
Click here for more information on the Anderson Butte Safety Project
Submit comments to: Tye Morgan, Ashland Planning and Environmental Specialist, by mailing the BLM,
You may also submit comments via BLM’s ePlanning register on the project’s website by selecting the “Participate Now” tab, or in the Documents section of the webpage. The comment period ends on January 3, 2022.