The 2020 Slater Fire was a massive wind driven wildfire reportedly lit by downed powerlines on Slater Butte above Happy Camp, California. The fire raged into Happy Camp, tragically burning large portions of the town and the surrounding homesteads, then burned north towards the Oregon-California border to the edge of Takilma, Oregon. Directly after the 2020 Slater Fire had cooled, the Rogue River-Siskiyou National Forest began logging the Takilma-Happy Camp Road and quickly approved the Slater Fire Re-entry Project, a massive post-fire, hazard tree logging project that would have “treated” nearly all existing roads in the Slater Fire area. This project was ultimately litigated by Klamath Forest Alliance and withdrawn by the Forest Service in an out of court settlement, but only after significant damage had already been done. The entire Takilma-Happy Camp Road, along with Road 48 leading across the Siskiyou Crest to Bolan Lake Campground, and numerous other roads were logged before the project was canceled. Yet, unfortunately, the story does not end there.

The Rogue River-Siskiyou National Forest has proposed yet another massive roadside logging project in the 2020 Slater Fire footprint at the headwaters of the Illinois River. This time called the Slater Fire Road System Risk Reduction and Safety Project, the project proposes to “treat” 200′ on either side of nearly every road in the Slater Fire area, totaling 194 miles.

Although the agency claims that the Slater Fire Road System Risk Reduction and Safety Project is motivated by public safety and is in the public interest, the agency has failed to justify the scope, scale and intensity of the roadside tree and snag removal proposed. It has also failed to adequately consider the direct and cumulative impacts of the project, and has failed to consider an adequate range of action alternatives in the EA. Finally, the agency has failed to justify or disclose the massive public investment of Disaster Relief Funding proposed for use by the Forest Service to subsidize and facilitate the implementation of this project.

According to Wild Rivers District Ranger Scott Blower, over $30 million is being allocated to subsidize and facilitate this project, yet many of the roads proposed for hazard tree removal are redundant, unnecessary, roads to nowhere, provide no legitimate public purpose, do not access recreational resources, trailheads, campgrounds or popular disperse camping areas, provide no strategic forest or fire management purpose, and are simply not worth the public investment.

The project also comes with significant biological impacts to the incredible biodiversity, habitat connectivity, carbon storage, and watershed values of the Siskiyou Crest region and the upper Illinois River watershed. We believe that the agency is misusing public disaster funding to implement this marginally useful and extremely environmentally damaging project. The use of public funds to subsidize this damaging roadside logging, on remote roads to nowhere, is fiscally wasteful and provides little to no public benefit.

We are recommending a more thoughtful, strategic approach that effectively mitigates public safety hazards while maintaining biological, recreational and scenic values, and responsibly spending public funds for public benefit. This approach should include a new Environmental Assessment with Action Alternatives that would close and decommission unnecessary, redundant or damaging roads in the planning area and implement reasonable, scaled back post-fire hazard tree removal activities on ingress/egress roads, evacuation routes, roads to trailheads, roads to campgrounds and on other roads with a legitimate public or administrative use.

We also believe that in general, the 200’ area identified for roadside tree felling and removal is excessive and could be reduced to 100’ without compromising public safety, and without sustaining the level of impact associated with the proposed action. Currently, the Forest Service is proposing 200’ wide clearcuts on either sides of the road and in many portions of the project area, this will create 400’ wide linear clearcuts along existing Fores Service roads. These “treatments” will include commercial timber harvest, biomass removal and/or tree removal on an astounding 8,917 acres. The end result will be much like the clearcut tree logging that has already occurred under the now withdrawn Slater Fire Re-entry Project.

We acknowledge that public safety must be protected along high use roads necessary for public and administrative uses. This can include roads needed for ingress, egress and evacuation during wildfire events, that provide access to recreational resources such as trailheads, campgrounds, or popular dispersed recreation areas, are necessary for legitimate administrative uses and management, or are strategically located to provide holding features during a future wildfire events. These areas could be treated to mitigate legitimate dead standing hazard trees including only those that are likely to actually fall directly into the road prism.

Treatments should prioritize tree felling (not removal) and coarse wood retention wherever possible by maintaining felled trees on the forest floor. This serves to maintain the carbon longer on site, builds soils, encourages water retention, and provides habitat, while not significantly contributing to overall fire risks, which are driven by post-fire vegetation patterns, not standing snags or large downed wood. Such an alternative would be effective, far more fiscally responsible than the currently proposed Alternative 2, and far less environmentally damaging.

Klamath Forest Alliance opposes the Slater Fire Road Risk Reduction and Safety Project as currently designed, but believe an acceptable compromise could easily be reached if the Forest Service would consider a more holistic, varied and responsible approach to hazard tree management on high use public roads and roads used by the Forest Service for legitimate administrative uses or management needs. Logging roads to nowhere, at an economic loss to the tax payers, with no legitimate public use or purpose does not serve the public interest or responsibly protect public safety!

Natural post-fire vegetative response near Bolan Lake.

Post-fire hazard tree logging on Road 48 near Bolan Lake.

Please consider commenting on the Slater Fire Road Risk Reduction and Safety project. The Forest Service is accepting comments until May 8, 2023.

Comments can be sent to the following email: comments-pacificnorthwest-siskiyou-wildrivers@usda.gov

For more information and to submit comments on the Forest Service’s online portal at this link: https://www.fs.usda.gov/project/?project=62020

Talking Points for Public Comment:

• The Forest Service failed to consider direct and cumulative project level impacts, failed to provide adequate Alternatives for analysis, and failed to disclose the massive public subsidy required to implement the Slater Fire Road Risk Reduction and Safety Project.
• The lack of analysis and failure to consider a range of alternatives requires the development of a new Environmental Assessment that addresses these issues with robust analysis and a more sufficient range of action alternatives.
•  The agency currently proposes only 100′ stream buffers and 25′ no harvest zones adjacent to streams. Riparian Reserve management consistent with the Northwest Forest Plan and Aquatic Conservation Strategy requires 150′-200′ stream buffers on perennial non-fish bearing streams and 300′ on fish bearing streams.
• Hazard tree felling should be focused on public safety, not hazard tree removal for commercial timber or biomass energy  production. Hazard tree felling can be used to address public safety concerns, while removing trees and snags at a public expense, does not provide a public benefit. Once a tree is felled it no longer threatens public safety in anyway, and also provides an important ecological function on the landscape. Removing these trees at a loss, is not an appropriate use of public funds and does not meet the projects Purpose and Need.
• The agency failed to implement site specific treatments appropriate for the areas varied land use allocations including Late Successional Reserves, Riparian Reserves, Botanical Areas, and Special Wildlife Sites. Currently, the project proposes virtually the same treatments in all land use allocations, despite widely varying management direction.
• A more effective approach to protecting public safety and more responsible utilization of tax payer funds would entail closing roads not necessary for public and administrative use including dead-end spur roads to nowhere and roads that are no longer needed for management, recreation or access purposes. administrative uses.
• The agency should alter Fuel Management Zone prescriptions to allow for the development of shaded fuel breaks within 200′ (rather than 400′) of high priority roads, rather than maintaining these areas as open habitats. The open conditions the Forest Service has proposed in this project are subject to significant increase fuel loading from woody tree and shrub regeneration, long-term maintenance issues, and hot, dry conditions conducive to spotting in future wildfire suppression efforts. FMZ’s should instead be maintained to develop shaded fuel breaks as the forest matures by recruiting, culturing and maintaining post-fire regeneration.
• Fuel Management Zones should be managed only along roads necessary for ingress/egress and evacuation routes and on roads with a high potential for use as firelines in future wildire events. This would include  ridgelines and canyon bottoms, not mid-slope roads, roads with significant switchbacks and other non-defensible roads with a low probability of use as future firelines.
• Do not cut or remove any “green” or living trees that survived the Slater Fire. The generally high severity fire effects throughout large portions of the Slater Fire area make large living trees extremely important from a biological perspective. Additionally, young living trees provide important age-class diversity which will be lacking as the forest regenerates in the Slater Fire area. No green or living trees that survived the Slater Fire should be felled or removed in the Slater Fire Road Risk Reduction and Safety Project.

The effects of the 2020 Slater Fire & the impact of post-fire hazard tree logging in its aftermath

Large portions of the Slater Fire were affected by high winds, record low humidity, and burned at high severity including the upper Althouse Creek watershed.

A view from Bolan Peak in the Slater Fire area with high severity fire on the ridges and low severity fire around the Bolan Lake..

A view from Tanner Mountain into the Sucker Creek watershed where significant low severity fire occurred.

Meadows and burned forest at the intersection of the Bolan Lake and King Saddle Trails.

A freshly cut hazard tree logging unit along Road 48 west of Bolan Peak in the summer of 2022.

200′ swaths were clearcut along either side of the Takilma-Happy Camp Road, leaving behind highly flammable logging slash, damaged soils, and significantly simplified post-fire habitat.

Post-fire hazard tree logging along Takilma-Happy Camp Road.

Post-fire hazard tree logging at the Page Mountain Sno-Park.