Protect Fire-Affected Forests on the Siskiyou Crest!
As described in my previous blog post, the Slater Fire began east of Happy Camp, California on the evening of September 7, 2020. Pushed by unusually strong easterly winds and historically low humidity levels, the fire burned quickly to the west, tragically burning through the community of Happy Camp and up Indian Creek to the Siskiyou Crest.
For the first 24-36 hours the fire burned over 100,000 acres and ripped over the Siskiyou Crest near Bolan Lake. Large swaths of forest on Indian Creek in the Klamath National Forest burned at high severity during this extreme weather event. Relatively large swaths also burned in the headwaters of Althouse Creek and Sucker Creek, near Bolan Lake and Bolan Mountain, as well as in upper Dunn Creek above Takilma, Oregon on the Rogue River-Siskiyou National Forest.
Since the Slater Fire, the Rogue River-Siskiyou National Forest has been logging the Takilma-Happy Camp Road with no public input or oversight. In fact, long before the fire was even considered fully contained, loggers were felling and decking trees along the Takilma-Happy Camp Road, likely using emergency fire suppression funds. Five million board feet of live and dead trees have been removed, including massive old-growth trees which were sold to Swanson Group Manufacturing LLC.
Additionally, the Rogue River-Siskiyou National Forest has just proposed a large, post-fire logging project along roads in the Slater Fire area, the project has been slyly named the Slater Fire Safe Re-entry Project. In this project the agency has called for post-fire hazard tree logging along public Forest Service roads at the headwaters of the East Fork Illinois River watershed, from the East Fork Illinois River drainage and Dunn Creek above Takilma, to the headwaters of Althouse Creek and Sucker Creek near Bolan and Tanner Lakes.
Although some level of hazard tree mitigation may be necessary along open Forest Service roads, and we support taking action to address true public safety concerns, this project will go above and beyond by removing both snags and also live green trees up to 200′ on either side of open Forest Service roads. The project will create 400′ linear clearcuts along 85 miles of road and on 4,106 acres of public land. The agency has estimated that approximately 20 million board feet of timber will be harvested from the Slater Fire area.
According to the Scoping Notice for the project, these treatments will occur in the Bolan Lake Botanical Area, on over 2,000 acres in a large block Late Successional Reserve forest set aside for the protection of the Northern spotted owl, in Designated Backcountry Areas, Riparian Reserves, Special Wildlife Sites, and adjacent to the Red Buttes Wilderness and Siskiyou Wilderness Area boundaries; however, no project design features or mitigation measures were included to ensure consistency with management guidelines in these important conservation areas.
Logging treatments proposed in the Slater Fire Safe Re-entry Project would remove all dead standing trees within 200′ of a public road, as well as logging potentially large, living trees that survived the Slater Fire. The agency has proposed removing living, green trees based on the level of canopy scorch sustained during the Slater Fire. Unfortunately, the agency is identifying trees with only moderate levels of crown scorch as “dead,” and prioritizing them for removal. For example, large sugar pine trees receiving over 55% canopy scorch, large ponderosa and Jeffrey pine receiving over 35% canopy scorch, and large Douglas fir trees with over 70% canopy scorch will all be considered “dead,” and logged within 200′ of public roads.
The Forest Service is proposing these treatments through the use of a Categorical Exclusion, which will allow them to avoid further public comment periods, site specific scientific analysis, and the full disclosure of the associated impacts. According to the Scoping Notice, 4,106 acres will be treated with hazard tree logging prescriptions, while another 2,662 acres that burned at lower severity are proposed for hazard tree felling, but felled trees will be left on site. In all, 6,768 acres would be treated, exactly 2,568 more acres than are legally allowed under a Categorical Exclusion.
Why are snag forests important?
It is important for the Forest Service to reduce hazard tree removal areas to the smallest footprint necessary to protect public safety, while allowing for natural fire regeneration, especially in Late Successional Reserves, Botanical Areas, Designated Backcountry Areas, Riparian Reserves and Special Wildlife Sites. Large snag patches created by high severity fire leave behind abundant biological legacies in the form of snags and downed wood. These biological legacies provide structural complexity, build soil, hold moisture, cast shade and create favorable microclimates for regenerating forest species. These functions are particularly important because the fire killed trees will create the only input of large diameter snags or downed wood until late successional forest habitats have regenerated in the high severity fire patches of the Slater Fire area.
Snags and living trees in the Slater Fire area are also critically important for wildlife. They provide nesting and denning habitat for a wide variety of wildlife species from bats, insects and song birds, to black bears and the Pacific fisher. If located in proximity to living forest habitats, the Northern spotted owl will also utilize snag patches to forage for dusky footed woodrats. Snag patches attract large populations of white headed woodpeckers that live here at the western edge of their range, and they will provide benefits to wildlife for decades to come.
Research has shown that fire killed trees release carbon slowly over decades and accelerate the development of forest regeneration. On the other hand, post-fire logging releases large volumes of carbon more quickly and hinders the regeneration of complex, carbon rich forests into the future.
Take action now and send in a comment letter for this important project! Ask the Forest Service to retain all living trees and protect special management areas such as LSR forest, Botanical Areas, Wilderness Areas, Designated Backcountry Areas, Riparian Reserves, and Special Wildlife Sites in the Slater Fire area. Below are talking points and information necessary to comment on this project.
The following talking points are based on the management guidelines in the Siskiyou National Forest Land & Resource Management Plan, which currently guides management on the Rogue River-Siskiyou National Forest. To abide by these management guidelines, the following minimum measures must be met.
- Do not cut living trees in the Slater Fire Safe Re-entry Project. Living trees are critically important for wildlife and forest regeneration in the Slater Fire area.
- Cut only dead standing snags that will fall directly into the public roadway and represent clear public safety hazards.
- Reduce hazard tree removal areas to the smallest footprint necessary to protect public safety, while allowing for natural fire regeneration.
- The acreage proposed for treatment in the Slater Fire Safe Re-entry Project is more than is allowed for Categorical Exclusions. The Forest Service must either reduce the acres treated or analyze the project with a full Environmental Analysis.
- Protect Late Successional Reserve forests and Designated Back-Country Areas by retaining all living trees and felling and leaving the largest standing snags, including all snags over 36″ DBH. This should apply only to those standing snags that will directly fall into roads. If they will not fall into the road the standing snags should be retained.
- Protect Riparian Reserves, Special Wildlife Sites and the Bolan Lake Botanical Area by retaining all living trees, felling only clear roadside hazard trees and leaving all felled trees on site.
- Ensure that no snags are felled inside the Siskiyou and Red Buttes Wilderness Area. Reduce impacts within 100′ of wilderness boundaries by retaining all living trees, and felling and leaving the largest standing snags on site, including all snags over 36″ DBH.
This should apply only to those standing snags that will directly fall into roads. If they will not fall into the roads, the standing snags should be retained for wildlife and forest regeneration.
Send comments to the Forest Service by February 18, 2021
Comments can be filed electronically at: