Klamath Forest Alliance
P.O.Box 820 Etna, California 96027
Ph: 916-467-5405 Fax: 916-467-3130
E-mail: klamath@snowcrest.net
From: Felice Pace
Subject: Update on Dillon Creek, the latest atrocities, needed actions
Date: August 31, 1996
First Dillon Creek: The good news is that Ag Secretary Glickman's
Directive has resulted in delaying the still roadless portions of the
sale. The bad news is that 1. a decision is immanent for a 6 MMBF
sale in the "roaded" portion. We have not yet seen the unit map for
this sale but it could potentially have impacts on the biological
corridor which links the Siskiyou, Marble Mountain and Trinity Alps
Wilderness areas. More bad news is that the FS is expected to issue
a draft EIS to enter the roadless area soon after the January 1, 1997
or earlier. We must keep the pressure on Holder, Sprague, Thomas,
Glickman and Panetta to unequivocally cancel this and all roadless
sales before the election.
As soon as Dillon was delayed, Happy Camp district ranger George
Harper issued a decision to implement road decommissioning planned as
part of the "Dillon Recovery Project". He claimed that the decision
was not subject to appeal. Unfortunately, it's a very bad decision
which decommissions the wrong roads (see discussion of Elk Creek road
appeal at the end of this memo). We have asked Steve Volker of
SCLDF-SF to look into the legality of this action.
Dillon Creek is a large portion of an even larger concentration of
Wild Forest habitat that extends from the Siskiyou Wilderness
southeastward, encompassing the mouth of the Salmon River and the
Salmon/Klamath/Trinity divide to the New River section of the
Trinity Alps Wilderness. Ultimately connecting to another
concentration of Ancient Forests on and around South Fork Mountain.
Based on analysis of infrared Landsat imagery, we believe the Salmon
Divide Area is the largest block of relatively intact Ancient Forest
remaining in Northern California and perhaps along the entire West
Coast. Recent research, including the analysis being conducted by
Reed Noss and his students, suggests that this area contains the most
healthy population of Pacific Fishers in the Pacific States and
perhaps in the West. Wolverine have also been sighted.
Ancient Forests in this area are now under heavy attack by the
Forest Service. Claiming that Winter "blowdown" must be removed to
(you guessed it) prevent future catastrophic fire, the FS is quickly
moving forward to sell a series of timber sales, many within units
of the large Orleans Mountain Roadless Area. These sales are all
essentially the same: they are planned for less than 1 MMBF and
therefore utilize a "categorical exclusion" to avoid preparation of
an environmental assessment, they seek to utilize a single,
programmatic biological assessment (or carbon copies of essentially
the same BA), they include entry into Riparian Reserves to remove
"excess" heavy fuels (typically large Old Growth standing snags or
down green trees), and they promise "fuel treatment' but defer that
to the future without any guarantee that the funds will be available
to do the work. Planned sales have potential to impact trails and
sites sacred to the Karuk and Hoopa Tribes which are located in the
vicinity of the Klamath-Salmon Divide.
The sales are located on the Orleans and Lower Trinity Ranger
Districts of the Six Rivers National Forest in Boise, Red Cap, Mill
and Horse Linto Creeks. Some logging in the "roaded" portion have
already completed or are in progress now. The roadless portions
should be covered by Glickman's Directive but soon after it was
issued Six River's Forest Supervisor Martha Ketelle flew back to DC
to lobby for an "exemption". Martha can be very persuasive. Ryan
Henson of the California Wilderness Coalition has learned that the
fate of "Martha's Exemption" is in the hands of Jack Ward Thomas.
Scientists who know Jack should weigh in. While blowdown has been
locally extensive, the area is not subject to high fire risk because:
the blowdown is concentrated in riparian areas which remain more
moist through the Summer, much is at or near the true fir zone
(circa 5000 feet) where fire return intervals average 45 years,
inadequate slash treatment is likely since it is not required by the
timber sale contract and stumpage prices remain low. In addition,
activities in steep, unstable Riparian Reserves in an area and
elevation prone to "rain on snow" events are likely to trigger
extensive landsliding during the next big storms. The drainages
which would be impacted are primarily key watersheds and much of the
area is designated LSR.
Some activities are already underway to fight "Martha's Exemption".
Ryan Henson, for example, is promoting listing one or more of the
sales in the upcoming New York Times ad which will cover "exemption"
sales around the West. Anthony Ambrose has documented with photos
and field reports, the devastation that has already taken place in
the "roaded" portions of the area. More, however, needs to be done. I
suggest the following are priority actions which should take place
during the next two weeks:
Get forest scientists focused on the area: I have been told that Dale
Thornburg (HSU) has expressed reservations and may be opposed. Bill
Ferrell and/or Dave Perry should be flown down from Corvallis for a
review, Bob Curry up from Santa Cruz, Terry Roeloffs, Pat Higgins and
other fisheries scientists, including those working for the Hoopa,
Karuk and Yuron Tribes should be asked to get involved. A sign on
letter from scientists to JWT should be circulated immediately.
Forest scientists working for the FS should be encouraged to send
electronic messages to JWT and/or talk to the press about their
reservations. The Riparian Reserve entries are particularly
vulnerable since the FS is not conducting analysis adequate to
determine if the material is "excess" to what is needed to achieve
the objectives of the Aquatic Conservation Strategy or for habitat
connectivity. Also, they are using inappropriate fuel models to
argue that there is high fire danger in the riparian areas.
Prepare a map and briefing package on the area for use in DC and with
the press. KFA will coordinate this and is already at work. Send
photos, unit maps, and other information on the sales to us. We want
to have a package ready to send back to DC with Julie Norman of
Headwaters who will be leaving around September 10th.
Take legal action! The series of Categorical Exclusions impacting
the Orleans Mountain Biological Corridor is really one action which
is split into many smaller actions solely to avoid the kind of
environmental analysis which is needed in order to determine if the
action is consistent with the NW Forest Plan, the Aquatic
Conservation Strategy, Clean Water Act, WSRA, etc. The problem here
is: Who will take the case? Activists should approach experienced
forest lawyers with the prospect. Any volunteers?
Pressure the Clinton Administration and California Delegation: the
most important pressure points include: Leon Panetta, Dan Glickman,
Barbara Boxer, Diane Feinstein, George Miller, Vic Fasio. My guess is
that we should push Boxer and Feinstein for a combined letter to
Glickman. Institute Direct Action! With the election close this may
be our best bet. I would like to see actions take place: in the
woods (there are roads ripe for blockade and sale activity now in
progress), at the Six River's Forest Supervisors Office in Eureka
(Six River's forest supervisor Martha Ketelle is clearly the person
who is driving this effort. We should let the community know that
"Martha's Exemption" is a blatant attempt to sacrifice salmon and
forest ecosystem health in order to satisfy the front men for
California's timber barons: Riggs and Herger), at the Regional Forest
Service HQ in San Francisco (Clinton's campaign will take note).
Contact the cooperating federal agencies (USFWS, EPA, NMFS) at all
levels to express concern about the impact of Martha's Exemption.
Question whether these activities comply with the Interagency
Memorandum of Agreement concerning implementation of the Rider.
Explain to them why the exemption does not make sense for the
resource they are sworn to protect and ask them to take action to let
JWT and their higher ups know that this exemption should not be
granted.
Activities planned by groups should be coordinated through the
California Stop The Rider! Campaign office at the California
Wilderness Coalition office in Davis. Ryan Henson chairs this
campaign and Paul Spitler works full-time on it from that office. A
schedule of planned events and decisions on coordinated action should
take place as part of the California Ancient Forest Alliance meeting
on September 8th in Davis. I will ask chair Jim Eaton to reserve a
place on the agenda for both updates and scheduling/action
coordination.
Other Updates:
There is good news from Jim Pentrack, forest monitor on the Shasta
NF. The Deer Creek TS, an LSR entry in the headwaters of the
Sacramento River, has been modified as a result of relentless
pressure brought to bear by Jim. Modifications include: dropping
units and changing haul routes to avoid potential introduction of
root rot to the Port Orford Cedar stands, dropping proposed
activities in the vicinity of a Northern Spotted Owl nesting area,
placing an upper diameter limit of 18" dbh on the "thinning"
prescription. We are still concerned and opposed to FS plans to
remove large overstory trees from a "fuelbreak" area on a ridge and
use of the ridge for skidding logs. There is no justification for
reducing canopy closure in a shaded fuelbreak area since that would
lead to increased sprouting and growth of brush and hardwoods and
increased drying of the area.
Bad news from the Shasta is that the planned entry into the Iron
Canyon LSR has significant problems. The FS proposes reducing basal
area to 125 cu feet per acre which is not appropriate for mixed
conifer stands. Also proposed is an upper diameter limit of 20" dbh
for trees to be logged. KFA does not generally oppose thinning of
younger stands like most of those proposed in Iron Canyon. However,
we believe the largest trees in the stand should be retained in
numbers sufficient to provide a minimum 60% crown closure. This
typically results in a 12" to 16" diameter limit. The FS currently
proposes "thinning" a couple of older stands in Iron Canyon. We are
strongly opposed.
The Region 5 FS office in SF has released a list of timber sales
"Affected by Secretary Glickman's Salvage Directive". Let us know if
you want a copy of this list. We have confidential information from
inside the beltway, however, that one Klamath National Forest sale
not on the list has been placed back into the normal (appealable)
timber program. That sale is the Canon TS on the Scott River RD.
This is clearly the worst green sale on the Klamath. Canon targets
the largest block of Mixed Conifer and True Fir Old Growth on the
District, is in an unstable area adjacent to the Marble Mountain
Wilderness which has high recreational use (Lover's Camp, Canyon
Creek and Box Camp Trails), and the watershed (Canyon Creek) is a
critical source of cold water essential to the survival of salmon and
steelhead in the Scott River. In addition, the sale will result in
increased fuel loading placing both the wilderness and a high density
of Northern Spotted Owl nesting areas at risk. The word from DC is
that this sale "no longer meets the definition of immanently
susceptible' to fire or insect outbreaks. The same source told me
that immanently susceptible' language in Glickman's directive is the
key to exemption decisions.
KFA recently filed three appeals challenging actions on the Klamath
National Forest:
The Sharp TS on the Goosenest RD, a green sale that
lies outside the range of the NSO, is subject to appeal. The issue
is (as usual) big trees, in this case scattered yellow pines. The
sale is located in a big game management area which the forest plan
says should have no scheduled timber cutting.
The Cuddihy Grazing Allotment EA is the first of many planned on the
KNF during the next two years. With a completely inadequate EA and
BA, the FS proceeded to issue a decision which continued the status
quo. This is unacceptable. KFA will continue to challenge grazing
allotment decisions until the FS complies with their own laws and
regulations. At minimum they must assess the condition and trend of
streams and riparian areas over time based on aerial photography,
survey for sensitive species like Great Grey owl, Willow flycatcher,
and various amphibians, identify areas where grazing is
inappropriate, and put in place a monitoring program which includes
tracking water quality and riparian condition. KFA is advocating
eliminating grazing from the Wooley Creek Watershed - a biological
refugia at the heart of the Marble Mountain Wilderness and from other
areas where it is not appropriate, where resource damage is occuring
and where severe conflicts are occuring with recreation and other
uses. More grazing decisions are immanent and more appeals are
likely.
The Travel and Access Environmental Assessment for the Elk
Creek Watershed Transportation System has been appealed. Under the
NW Forest Plan, a program of road improvement and decommissioning is
mandated. The primary purpose of that program is to remove the most
significant threats to aquatic resources, with a focus on key
watersheds. Furthermore, scientists "viability ratings" for
salmonids, performed as part of the Option 9 EIS, assumed effective
watershed rehabilitation programs emphasizing elimination of chronic
and episodic sedimentation from roads. Unfortunately, the FS does
not appear to have the will to hydrologically decommission the many
roads on the Klamath and elsewhere that, as last Winters floods and
Spring thunderstorms have proven, are "time-bombs aimed at our rivers
and streams". The Decision on Elk Creek key watershed was to
decommission the wrong roads - spurs and landings high in the
drainage that pose no significant threat to attainment of ACS
objectives and/or roads which Mother nature has already
"decommissioned". Furthermore, if successful, the FS can "bank" these
road miles in order to build new key watershed roads later. This
challenge is extremely important and should be duplicated as
necessary elsewhere. Those wishing to weigh in can comment within 15
days of the August 30 appeal filing date by writing to regional
Forester Lynn Sprague in SF (attention appeals coordinator). Such
letters could be very important.
Here are the relevant officials and addresses to which you should
direct your advocacy:
Leon Panetta, The White House, Ph: 202-456-6797, Fax: 202-456-2883
Dan Glickman, USDA, Ph: 202-720-3631, Fax: 202-720-2166.
Jack Ward Thomas, FS-DC, Ph: 202-205-1760, Fax: 202-205-1765.
Lynn Sprague, FS-R5, Ph: 415-705-2874, Fax: 415-705-1166 or 415-705-1127
Martha Ketelle, FS-6Rivers, Ph: 707-441-1742 or 3534, Fax: 707-442-9242
Diane Feinstein (Kathy Lacy): Ph: 202-224-3841, Fax: 202-228-3954
Barbara Boxer (Linda Delgado): Ph: 202-224-3553, Fax: 202-228-0026
Warm regards to each of you and keep up the pressure. The time
between now and the election is a window of opportunity which we must
exploit as fully as possible.
Yours via electronic means,
Felice
Felice Pace
Klamath Forest Alliance
PO Box 820 Etna, Ca 96027
916-467-5405 916-467-3130 (fax)