Cascade Siskiyou National Monument Management Plan: A Blueprint for Logging and Grazing, not Conservation!
Although the Cascade-Siskiyou National Monument was designated to protect and restore biodiversity, habitat connectivity, and ecological integrity at the critical intersection of the Cascade Mountains and the Siskiyou Crest east of Ashland, Oregon, the management plan currently proposed by the BLM looks more like an industrial logging and grazing plan than a blueprint for effective conservation.
In 2017, a science-based expansion of the Cascade-Siskiyou National Monument was designated by President Obama, expanding outward to the north and east. This triggered the development of a new management plan and in typical fashion BLM has used the opportunity to undermine the monument by attempting to expand the footprint of commercial logging, maintain both the status quo and the habitat degradation associated with livestock grazing, and codify unauthorized and environmentally damaging off-road vehicle routes throughout the National Monument. Certainly not conservation based, the BLM is proposing land management activities that are inconsistent with the mandates of the Cascade-Siskiyou National Monument and the associated Presidential Proclamations.
Likely both unable and unwilling to manage for conservation, the BLM has demonstrated with its actions, including recent commercial logging and heavy handed fire suppression activities that it cannot be trusted to manage the area for conservation or the benefit of future generations. Meanwhile, this proposed management plan intends to manage the Cascade-Siskiyou National Monument as an extension of the BLMs harvest land base, rather than for its biological values.
Currently this misguided management plan is open for public comment. Please consider commenting before the July 5 deadline at the following website: https://eplanning.blm.gov/eplanning-ui/project/2023675/510
Click on the “participate now” button on the left hand side of the page and provide you comments.
Background:
The Cascade Siskiyou National Monument was initially designated by President Clinton in 2000, as the first and only National Monument designated to protect biodiversity. Located at the intersection of the Cascade and Siskiyou Mountains, the area is botanically rich, highly diverse, and important for landscape scale habitat connectivity. Originally consisting of approximately 53,000 acres, the monument was expanded in 2017 by President Obama to its current size of 113,820 acres.
This expansion was unsuccessfully litigated by the timber industry claiming that the monument could not be designated on the BLM’s O&C lands in western Oregon. The courts disagreed, recently affirming both the designation of the Cascade-Siskiyou National Monument and its valid conservation purpose. Yet, it seems BLM did not get the message, and the recently proposed Resource Management Plan fails to comply with either the Presidential Proclamations or with the intent of recent Appeals Court rulings.
Instead, BLM is attempting to manage the Cascade-Siskiyou National Monument as an extension of their Harvest Land Base, as a pasture for privately owned livestock, and as a playground for unauthorized off-road vehicle use, all of which directly and significantly impact the values of the monument. The agency has been directed to protect the areas unique biological values by the President of the United States, by the court system and by the US Supreme Court, which refused to hear the timber industry challenge to the Cascade-Siskiyou National Monument thereby affirming it legality on O&C lands. Yet, to date the BLM has not risen the challenge and adequately protected the monument from damaging management practices and public uses.
Logging in the Monument
The currently proposed management plan includes multiple alternatives, and all of those alternative include some form of commercial logging. True to form, BLM is attempting to ignore the clear limitations place on logging in the original National Monument proclamation and replace them in this management plan with mandates to log, rather than preserve habitat.
Although the mandate for land managers in the CSNM is to protect biodiversity, connectivity and ecological integrity, and recent court decisions have affirmed that O&C timber production is not required within the National Monument, the current BLM proposals including logging trees from up to between 20″ and 36″ DBH, along with group selection logging “openings” otherwise known as clearcuts up to 4 acres in size. Each action alternative proposes significant canopy reduction and large tree removal which will degrade, diminish, and in some cases both destroy suitable Northern spotted owl habitat and badly damage late successional or old growth characteristics.
Alternative B proposes logging trees up to 36″ diameter and the creation of up to 4 acres clearcuts under the euphemism of “group selection” logging, and it proposes these treatments across 20% of the so-called “restoration” acres per decade. The agency’s “preferred” alternative, Alternative C proposes logging trees up to 20″ in diameter and artificially cleared openings of no more than 2 acres in size. Alternative D proposes logging trees up to 20″ diameter when thinning around legacy trees and no group selection logging.
Ironically, despite significant emphasis being placed on the preservation of late successional and old-growth habitat in the monument’s Presidential Proclamation, not a single alternative being considered prohibits commercial logging. Even, the “no action” alternative would not restrict logging because it would revert back to the clearly inappropriate timber production model, proposed in the 2016 RMP.
We believe the forest of the Cascade-Siskiyou National Monument should be allowed to heal from decades of commercial, heavily industrialized high-grade and clearcut logging activities. Additional logging proposals, especially those that remove large trees, dramatically reduce canopy cover, and create staggered clearcuts, misleadingly called “group selection” openings are working in the opposite direction.
Do not allow the BLM to turn the Cascade-Siskiyou National Monument into a stump riddled, heavily degraded habitat, with staggered clearcuts fragmenting forest stands, damaging the areas world-class habitat connectivity, impacting wildlife habitat, and diminishing biodiversity. Please comment on the Management Plan and advocate for a no commercial logging alternative.
Grazing in the Monument
After designating the initial acreage of the Cascade Siskiyou National Monument, the BLM undertook significant scientific study to determine the impacts of grazing to monument resources. The conclusion of multiple rigorous studies was that cattle grazing was impacting native plant communities, spreading noxious weeds, creating competition with ungulate species such as elk and deer, damaging wildlife habitats, and degrading seeps, springs, and waterways throughout the monument area.
Yet, this new management plan ignores the extensive science produced by the BLM and proposes to largely maintain the status quo with only one of the alternatives proposed in the Management Plan (Alternative D) including provisions to phase out livestock grazing through non-renewal of the grazing permits currently located with in the Cascade-Siskiyou National Monument.
Support the non-renewal of grazing allotments in the Cascade-Siskiyou National Monument to protect, preserve and to help restore important biological values and monument resources.
Off-Road Vehicle Use in the Monument
The BLM failed to consider what they call Travel Management Planning in the proposed Cascade-Siskiyou National Monument Resource Management Plan. This means that issues surrounding off-road vehicle use and road related impacts are not being adequately addressed.
In the current alternatives, no more than 35,516 acres would be closed to motorized use off designated routes, while no less than 72,190 acres would be designate with a limited to existing classification. This limited to existing designation is both inappropriate given the areas management direction and its unique botanical, biodiversity, connectivity, and aquatic conservation values. It is also meaningless and unenforceable without a full inventory of unauthorized, user created off-road vehicle routes.
For example, in both 1990 and 2016, the Medford District BLM required a full Travel Management Plan for all district lands, but this document has never been produced. The 2016 RMP required full Travel Management Planning across the entire district with 5 years of authorization, yet now 8 years later not a single plan has been produced. Additionally, because the agency created a limited to existing designation, but did not inventory the existing routes, the designation is entirely meaningless and unenforceable. In reality, since 2016 when the RMP was approved, this designation has officially limited nothing in regard to off-road vehicle use and illegal off-road vehicle trails continue to proliferate. To allow the same in the Cascade-Siskiyou National Monument is entirely inconsistent with the protection of monument values and the monuments Presidential Proclamation.
Do not let the Cascade-Siskiyou National Monument become more impacted by off-road vehicles. Ask the BLM to close the entire Cascade-Siskiyou National Monument to motorized use off designated roads. You cannot protect botanical, biological, and aquatic values in the monument without strong prohibitions on off-road vehicle use.
Snowmobile Use in the Monument
The Presidential Proclamation for the Cascade-Siskiyou National Monument allows for snowmobile use only if it is “consistent with the care and management of” the objects of interest and protection in the monument. These objects of interest include biodiversity, botanical diversity, aquatic habitats, and habitat connectivity. Yet, these values would be impacted by snowmobile use, especially habitat connectivity which for many species is highest in the winter and early spring before snowmelt. Far ranging carnivores such as the wolverine and wolves would be more likely to traverse this area if snowmobile use was limited or prohibited. Snow adapted species like the American marten, snowshoe hare, and others would also be impacted by continuing snowmobile use. Snowmobiles have also been shown to be damaging to wildlife, aquatic habitats, and vegetation.
The current management plan contains little real analysis of these impacts and instead proposes to maintain snowmobile use on existing roadbeds in portions of the monument and even in Alternative B, to expand snowmobile use to include cross-country use near Surveyor Mountain. In all proposed alternatives, except Alternative D which prohibits snowmobile use, snowmobile use will damage monument values and resources.
Please support closure of the entire Cascade-Siskiyou National Monument to snowmobile use to both maintain and support habitat connectivity, biodiversity, aquatic habitats, and solitude in the region.
Habitat Protection in the Monument
While the Cascade-Siskiyou National Monument was designated specifically to support conservation in the region, the BLM is proposing in some alternatives to eliminate or nearly eliminate important habitat protections like Areas of Critical Environmental Concern, Lands with Wilderness Characteristics, and Research Natural Areas.
Especially given the BLM’s inability to manage for conservation, it is imperative that these habitat protections are both maintained and expanded in the Cascade Siskiyou National Monument. Please support the protection of all existing and nominated Areas of Critical Environmental Concern, Lands with Wilderness Characteristics, and Research Natural Areas. These areas are important for the biological diversity, habitat connectivity and ecological integrity of the region and need special management and habitat protection.
Please comment on the proposed Cascade Siskiyou National Monument Management Plan!
Talking Points:
1) Commercial logging is inconsistent with the Presidential Proclamation designating the Cascade-Siskiyou National Monument. Logging that removes large trees between 20″ and 36″ diameter, implements group selection logging and dramatically reduces canopy cover will damage northern spotted owl habitat, while increasing fire risks and reducing climate resilience. We ask for no commercial logging in the monument, as the removal of large trees is not only unnecessary, but damaging to the values proposed for protection.
2) Grazing is not compatible with the proper management of monument values and all grazing allotments should be phased out through non-renewal of BLM grazing permits.
3) To protect monument values and resources, the BLM must limit motorized use to designated roads and prohibit snowmobile use. The agency must also include a full Travel Management Plan in the Final Environmental Impact Statement (FEIS)
4) Conservation areas within the Cascade-Siskiyou National Monument area are in need of additional habitat protections and special management. This should include the designation of all proposed Areas of Critical Environmental Concern, Research Natural Areas and Lands with Wilderness Characteristics.
5) The BLM must find ways to limit the use of damaging, industrialized fire suppression impacts when fires occur, while also adequately protecting nearby communities. This should include the utilization of Minimum Impact Suppression Tactics throughout the monument, as well as exclusion zones to protect cultural, biological, scenic, botanical and recreational values. These exclusion areas would contain particularly intact native plant habitats, wildland habitat conditions, rare plant species, archeological sites, clear flowing streams, and important wildlife habitats that should be protected from dozerline construction, fire retardant application, helipad, hoist and landing construction, and motor vehicle use.
6) Fuel reduction and non-commercial thinning operations should be limited to those areas adjacent to homes and communities, along important ingress and egress corridors, and in plantation stands less than 60 years old. Prescribed fire and managed wildfire should be considered in locations throughout the monument, but prescribed fire treatments should avoid stands of chaparral, oak woodlands with a significant non-native annual grass population, and heavily invaded grasslands dominated by non-native annual grasses.
7) An exception to these prohibitions on prescribed fire use could include experimental controlled burn applications implemented in open, heavily invaded grasslands. Prescribed fire should be implemented in the fall when native species are dormant and ground-nesting species are less susceptible to impacts. Burn areas should be seeded with native grasses and wildflowers to restore native plant communities and subjected to long-term monitoring to determine effectiveness.
Please consider commenting before the July 5 deadline at the following website: https://eplanning.blm.gov/eplanning-ui/project/2023675/510
Click on the “participate now” button on the left hand side of the page and provide you comments.
