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Nedsbar Timber Sale Decision Record Released: BLM Betrays the Applegate Community and Approves Old-Growth Logging

This photograph shows the first Nedsbar field trip with the BLM and the public in November, 2014. Many local residents worked to have their voice heard and their values respected by the BLM in the Nedsbar Planning Process. Interest in the Nedsbar Timber Sale in the Applegate Valley community has been high due to the diverse and important resource values present in the planning area.



BLM Releases the 
Nedsbar Timber Sale Decision Record



After two years of effort and thousands of volunteer hours invested by the Applegate Valley community, the BLM has chosen to disregard the community’s comments and concerns about the Nedsbar Forest Management Project (i.e. Nedsbar Timber Sale), as well as the Community Alternative, Alternative 5. The Community Alternative was widely supported in the Applegate Valley where 330 people signed on in support. 


The BLM released its Decision Record (DR) for the Nedsbar Timber Sale on Thursday, September 1, 2016, and unfortunately this decision will implement the most timber-heavy alternative proposed. The BLM has betrayed the Applegate Valley community by failing to adequately consider or even analyze our concerns and comments in the DR or Final Environmental Assessment. Medford BLM field manager, Kristi Mastrofini, signed the DR for the Nedsbar Timber Sale, approving a slightly modified version of Alternative 4, the alternative favored by the timber industry. 

The field manager’s decision reflects an inability on behalf of the BLM to meaningfully collaborate with the Applegate community, address our concerns or implement responsible land management decisions. This highly controversial decision will impact our valley, its recreation based economy, our scenic views, our old-growth forests, roadless wildlands, local hiking trails, endangered species habitat, and the future of collaboration in the Applegate Valley. It will also drastically increase fuel loads and fire hazards adjacent to our community and our homes. In short, the decision is a giant step backwards and could reinitiate the timber wars of the 1990s in the Applegate Valley. 


Read the Documents
The Final EA, DR, and FONSI for the Nedsbar Timber Sale are available on the BLM’s ePlanning website at:



What’s Approved?
The DR approves 1,122 acres of commercial logging, 1.3 miles of new “temporary” road construction, 0.43 miles of new permanent road construction and the creation of 7 new helicopter landing pads. The decision will approve logging in units within late-seral and old-growth forest stands, important northern spotted owl habitat, citizen-identified roadless areas and vital habitat connectivity corridors. The decision includes no upper diameter limit, meaning the BLM is free to log large, old-growth trees. Currently trees up to 42″ in diameter are marked for removal in approved Nedsbar Timber Sale units. 

A 42″ diameter tree marked for removal in unit 35-32 at the headwaters of Grouse Creek. The unit and the old trees marked within it are now approved for logging by the Medford District BLM.

The BLM Ignores the Community Alternative
Although the BLM claims to have blended “components from Alternative 4 and Alternative 5 [the Community Alternative],” (DR P.9 ) it is very difficult to understand exactly what components of the Community Alternative are approved for implementation. The BLM is apparently just playing lip service to the Community Alternative.


None of the basic principals of the Community Alternative, Alternative 5, will be implemented in the DR. 

  • Not a single unit will be treated with the detailed and scientifically valid prescriptions designed by the community in the Community Alternative
  • No prescriptions in commercial units approved in Alternative 4 will be modified in any way
  • No diameter limit will be implemented 
  • Canopy cover levels will be reduced far below those recommended in the Community Alternative
  • Roadless areas will be logged
  • New roads will be built in watersheds already suffering from high road density 
  • Riparian Reserves recommended for protection in the Community Alternative will be logged
  • Black plastic will be used to cover piles (only OR and NM allow for the burning of black plastic on burn piles)
  • There will be no altered prescriptions for unusual plant species, such as the snow bramble (Rubus nivalis), identified in the Community Alternative

Large Tree Retention
During the supposed collaboration with the Community Alternative Working Group (CAWG), metrics were developed and agreed upon by both the BLM and the CAWG. These metrics would inform and provide transparency to the decision making process. One of the key metrics was to quantify the number of large trees over 20″ in diameter removed in timber sale units. The BLM did quantify large tree removal in the initial EA, and when community members identified that the number of large trees listed was highly inaccurate, the BLM addressed this significant error by issuing an errata with updated, yet still highly inaccurate information. 

In public comments to the initial EA, the Applegate Neighborhood Network (ANN) identified significant errors remaining in the analysis of large tree retention laid out in the BLM’s errata. Based on on-the-ground field monitoring the estimate was that at least three times as many large trees were marked for removal than were analyzed in the BLM’s Environmental Assessment.


The fact that the local Applegate community has performed more on-the-ground monitoring than the BLM to field check the amount of large trees being removed in the Nedsbar Timber Sale, and the fact that the BLM has had to admit that their numbers are so inaccurate, casts doubt on the BLM’s ability to accurately quantify and analyze the amount of large tree removal in the DR. 


The BLM is using the numbers in the errata in their Final Environmental Assessment despite considerable doubt in regards to their accuracy. The BLM has simply not quantified the number of large trees to be removed in the majority of timber sale units. In addition, in the DR, they negate the importance of quantifying the number of large trees proposed for removal and they throw this agreed upon metric out the door, refusing to abide by their initial agreement to incorporate this analysis into the DR. 


The DR states, “there are no requirements that mandate the BLM to disclose the precise number of trees to be harvested of any diameter. Public disclosure and Agency consideration of the exact number of trees to be harvested is not necessary for a reasoned choice among alternatives for a project.” (DR A-8)

The only alternative that clearly analyzed and quantified large tree removal in the Nedsbar EA was the Community Alternative, where no large trees over 20″ in diameter would have been logged. The BLM has not provided accurate information regarding large tree removal in the Final EA or DR.

Fire Resilience and Fuel Reduction
The Community Alternative was focused on fire resilience and fuel reduction; however, the decision in the DR does not emphasize fuel reduction or fire hazard reduction in the Applegate Valley. The DR makes this clear: “Not all treatments are designed to reduce fire hazard. Forest thinning proposed under the Nedsbar Forest Management Project…does not aim specifically to address fire hazard.” Instead, the BLM “chose the Selected Alternative as it best meets the 1995 RMP direction for timber resources.” (DR A-3)


Field Manager Mastrofini said, “Based on my obligation to implement the intent of the 1995 Medford District RMP, I cannot select the community’s Alternative 5 as designed, as it represents an unwarranted departure from the Timber Resources Objectives on the BLM’s Resource Management Plan.” (DR P.10 )


Clearly, one single objective dominates BLM land management: timber production.

Without specifically aiming to address fire hazard, the BLM is simply logging to benefit the timber industry at the detriment of the Applegate Valley and its residents. The Applegate will be left with increased fire hazards, degraded forests and forever altered wildland habitats after the implementation of the Nedsbar Timber Sale.

Unit 28-10A of the Nedsbar Timber Sale is located in the Bald Mountain Roadless Area and Jack-Ash Trail corridor. The stand includes large, old, closed canopy forest that is naturally resilient to fire, insects and disease. The area is in an important wildfire connectivity corridor and has been approved for logging by the Medford District BLM.

Roadless Areas and the Recreation Economy
A strong emphasis within the Community Alternative was the protection of citizen-identified roadless areas and the enhancement of economic values associated with outdoor recreation in the Applegate Valley. Unfortunately, the BLM will not address or emphasize these important community values in the DR.

Field manager Mastrofini explains her reasoning: “While BLM recognized these areas are important to the Community Alternative Working Group and the community members they represent…these areas do not meet the size criteria as defined in the…Wilderness Act to possess wilderness characteristics. The BLM is directed by the 1995 RMP to manage these areas for sustainable forest and timber production.” (DR P.16)


Community values, a recreation economy, and roadless wildlands — supported by many throughout the region and beyond — are simply not considered in the decision framework outlined by field manager Mastrofini in the Nedsbar DR.


“Alternative 5 (the Community Alternative) was strongly influenced by the community’s desire to preserve areas within the planning area as unmanaged. This aspect of Alternative 5 is inconsistent with the1995 RMP as the decision to manage these lands for timber production occurred in 1995.” (DR P. 9)


New Road Construction
The Community Alternative proposed the development of no new roads; however, the BLM has approved 1.3 miles of “temporary” roads and 0.43 miles of new permanent roads, along with 7 new helicopter landings. Despite the fact that Applegate residents opposed it, a large section of new “temporary” road will be built within and adjacent to the Riparian Reserve on Lick Gulch. The BLM has admitted that this will contribute high levels of sediment to an already impaired stream with high road density. 
  
Temporary Good News With Lots of Work to Come
On a more positive note, 3 of the 25 controversial units identified by the community have been “deferred from treatment” and 4 others are now proposed for fuel reduction only. Unfortunately, BLM is making it clear that they still intend to log these units in the
future. 



“It is important to note that my decision to implement
the Selected Alternative for the Nedsbar Forest Management Project does
not permanently defer timber harvest for those units not chosen for
implementation at this time,” Field Manager Mastrofini wrote in the DR. (DR P. 3)



In other words, the fact that these few controversial units have been dropped and/or altered in the sale is only temporary good news, and unfortunately our work is far from done — 450 acres in 18 controversial timber sale units have still been approved for logging!

We did it! BLM canceled unit 28-10B in the Bald Mountain Roadless Area; however, many units have been approved for logging in wild, fire resilient forest just like unit 28-10B. The agency admits in the DR, “not all units are designed to reduce fire hazard.” Instead they “chose the Selected Alternative that best meets the 1995 RMP direction on timber resources.” We need your help to save the last old, fire resilient forests in our region. Join us!

What You Can Do

Please consider contacting your local congressperson, state representative and regional BLM officials. Express your opposition to the Nedsbar Timber Sale and your support for Alternative 5, the Community Alternative. In the Applegate Valley we are ready for a new era of collaboration and conservation based management on public lands. Will the BLM join us? 

Applegate Neighborhood Network (ANN) and others will be filing a formal protest of this timber sale and will continue working for community and conservation in the Applegate Valley. Consider supporting their efforts with a donation. ANN is fiscally sponsored by KS Wild, please note that the donation is for ANN/Nedsbar.


Write An Official Protest


Anyone who wrote a comment for the Nedsbar Timber Sale Environmental Assessment (EA) can write an official protest of the Decision Record and Final EA. 


Contact Your Public Officials
Ron Dutton, State BLM Director
Senator Kevin Talbert
Sen.KevinTalbert@state.or.us
 Senator Merkely

https://www.merkley.senate.gov/contact
 

Representative Peter Buckley:
Rep.PeterBuckley@state.or.us
Sally Jewell, Secretary of the Interior:
exsec_exsec@ios.doi.gov
Senator Ron Wyden:
Representative Greg Walden

Below is a photo essay of a few of the Nedsbar Timber Sale units approved for logging by the Medford District BLM. 

Units 33-30 & 34-30

The units are located in the Boaz Mountain Roadless Area and include many large, old-growth trees. The stand is open spaced and naturally fire resilient. Unit 33-30 has been approved for “regeneration harvest,” a form of timber management that has been shown to greatly increase fire hazards by “regenerating” young understory growth. The unit is located directly adjacent to the most densely populated portion of the Upper Applegate Valley. Unit 34-30 has been approved as a “group selection” unit. Both stands should be canceled. 

Units 33-30 & 34-30 on Boaz Mountain viewed from just above Star Ranger Station. Unit 34-30 has been approved for a “structural retention regeneration harvest,” meaning the canopy will be reduced to roughly 30%. Unit 34-30 is a group selection cut, and according to BLM staff will look like “swiss cheese” when logging operations are finished.
Open, fire resilient forest conditions in unit 33-30. The stand will be logged to between 18 and 20 trees per acre. The “structural retention regeneration harvest” proposed in this stand will create increased understory density, contributing to an increase in fire hazards following logging treatments.
Unit 34-30 is a variable density, mid-seral stand with scattered old trees and fire resilient stand conditions. The entire stand of conifer trees in this photo is marked for removal. The removal of overstory canopy will increase fuel risks by creating dense understory fuel. Based on years of monitoring, local environmentalists have documented a vigorous “shrub response” filling in canopy gaps and heavily thinned stands, increasing fuel hazards and understory competition.

 

 
Unit 35-32

Some of the largest trees marked for removal in the Nedsbar Timber Sale are located in unit 35-32. The stand is unusually moist for the Little Applegate watershed and includes the very uncommon snow bramble (Rubus nivalis), a plant species associated with moist forests and high canopy cover levels. The snow bramble growing in the dry foothills of the Little Applegate Valley is a disjunct population at the southern extent of its range. This unusual stand is approved for logging to 40% canopy cover. The BLM states in the DR: “R. nivalis’s range is the west coast extending into Canada at higher elevations. The species is uncommon, but not rare, and does not require special attention under BLM policy.” (DR )

True community collaboration would include plant buffers or deferred units for important ecological and/or botanical values identified by collaborative partners (i.e. the community). Snow bramble should be provided some special attention to maintain our internationally renowned biodiversity in the Applegate/Klamath-Siskiyou Ecoregion. Without attention to the unique needs of the landscape all claims of “restoration” are unjustified.  Without meaningful alterations to unit prescriptions for community-identified special plants, wildlife, or natural features, collaboration is insincere. 

Unit 35-32 at the headwaters of Grouse Creek contains many large, old trees and resilient stand conditions. All trees not marked yellow for retention would be removed under the DR signed by the BLM and canopy cover would be reduced to 40%.
The two large trees in the foreground are marked for removal in unit 35-32. Trees up to 42″ in diameter are marked in the unit. In total, 145 trees over 20″ in diameter are marked for removal on 27 acres, a rate of 19 large trees per acre. Canopy cover will be reduced to 40%, badly impacting a unique and disjunct population of snow bramble at the southern extension of its range.

 

Units 14-30 & 15-30

Located in the Buncom Roadless Area, these late-seral stands provides healthy, fire resilient conifer forest habitat within large stands of white oak and chapparal. Unit 15-30 was burned in a wildfire in 1987, creating open, fire resilient forest conditions. Both unit 14-30 and 15-30 should be canceled.

Unit 14-30 is located in the Buncom Roadless Area, just above the confluence of the Little Applegate and Applegate Rivers. The unit would be logged to 40% canopy cover, removing many large, old, fire resilient trees. The stand is open, spacious and supports very little understory fuel. Logging this stand will impact the area’s roadless character, fire resilience and wildlife habitat.
Unit 15-30 sustained an understory fire in a 1987 wildfire and supports open, fire resilient conditions. It is a fire refugia within a sea of chaparral and will serve to moderate future fires. The BLM has targeted the stand for 40% canopy cover and will remove many large, old trees.

 

 Units 25-20, 25-21, 25-22 & 25-23

Located in the Trillium Mountain Roadless Area and in the viewshed of the Sterling Mine Ditch Trail, these units sustain healthy, fire resilient forests of dry Douglas fir and ponderosa pine. Unit 25-20 would include a new “temporary” road and helicopter landing pad in the Trillium Mountain Roadless Area. Units 25-20, 25-21, 25-22 & 25-23 should be canceled.

Unit 25-23 is a model for forest health in the Applegate Valley. This mixed stand is dominated by open groves of large, fire resilient trees. It is also located in the Trillium Mountain Roadless Area. The stand needs no treatment whatsoever, yet the BLM has approved logging groupings of large fir trees, some well over 30″ in diameter.
A right of way will be cleared, a “temporary” road built to haul timber, and a helicopter landing pad will impact this wild, roadless ridge on Trillium Mountain. The new road and helicopter pad will be utilized to log the roadless northern face of Trillium Mountain above the Little Applegate River canyon.

Unit 28-10A, 28-11A, & 28-11B

Located in the Bald Mountain Roadless Area, unit 28-10A includes many of the timber sale’s largest trees. 273 trees between 20″ & 40″ in diameter are marked for removal in unit 28-10A alone. The unit includes a diverse mixture of serviceberry, old-growth Douglas fir, moist mountain springs and rocky outcrops. The area is important connectivity habitat between low and high elevation habitats in the Little Applegate watershed and is important for wildlife migration.

 The stand in unit 28-10A is open, fire resilient and dominated by large, old trees, 273 of which are marked for removal. Trees marked white are marked for removal.

Unit 28-10A is some of the most beautiful forest in the Little Applegate River canyon. It also provides important connectivity habitat. The unit is likely the worst still included in the Nedsbar Timber Sale and should be canceled immediately to protect the roadless area’s old forest habitat, scenic vistas and the recreation economy of the Applegate Valley.
Applegate Valley residents enjoy the backcountry of the Bald Mountain Roadless Area in Nedsbar unit 28-10A. Many large trees would be removed and canopy cover reduced to 40%. The logging will forever degrade some of the last intact, old-growth forest in the Little Applegate Valley.

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