Medford BLM's latest old-growth timber sale is aptly named Last Chance
View into the Last Chance project. Credit: Haleigh Martin
The Medford District Bureau of Land Management's (BLM) old-growth logging program is relentless and uncompromising. Currently, the 8,150-acre "Last Chance" timber sale calls for logging most of the remaining mature and old-growth forests in the public lands foothills between Sunny Valley and Galesville in southern Oregon.
BLM timber planners regularly tell the public and the press that the agency no longer "clearcuts" public forest lands, yet the Last Chance old-growth timber sale Environmental Assessment (EA) tells a different story. We’ve reviewed the EA, and here’s what we found:
Gap Creation Clearcutting
Proposed clearcutting acres in the Last Chance project. Table 8.7 in the BLM's EA.
Page 14 of the EA indicates that the BLM intends to create 4-acre “gap creation” clearcuts throughout the Harvest Land Base (HLB) and Late Successional Reserve (LSR) land use allocations. Yet the number, location, and site-specific impacts of the proposed clearcutting are not disclosed in the EA.
Page 46 of the EA acknowledges that natural forest gaps in the project area (prior to BLM logging and fire suppression activities) were “historically less than 2 acres and generally less than 1” which calls into question the ecological resiliency justification of clearcutting—especially within the LSRs.
Late Successional Reserves
George, KS Wild Conservation Director, groundtruthing the Paul’s Payoff timber sale unit of the Last Chance project.
Despite our request during project scoping, the BLM elected not to disclose the site-specific forest stand conditions (such as age, density and conifer species composition) of any of the LSR forest stands proposed for logging. Page 17 of the EA asserts that the commercial logging of the LSRs will promote and develop spotted owl habitat and resiliency but these assertions are simply repeating the LSR management objectives of the 2016 Resource Management Plan (RMP).
The agency makes no attempt to link its commercial logging treatment to the alleged LSR objectives to develop northern spotted owl habitat. There exists no science whatsoever to support the BLM’s contention that 4-acre clearcuts are means to promote and develop spotted owl habitat and forest resiliency. As stated on page 5 of the EA, the primary purpose of such prescriptions is to produce “commercial value” from the reserves. As stated on page 54 of the EA, the BLM intends to remove (not develop) existing Nesting, Roosting and Foraging (NRF) habitat from the LSRs to facilitate logging road construction throughout the project area.
Page 62 of the EA is where the BLM would have provided quantitative data to support site-specific impacts analysis of the effects of its LSR logging scheme. No such data is provided because no such data exists. Further, it would be impossible for any data or modeling to demonstrate that establishing 4-acre clearcuts in the LSRs would not delay the establishment of Nesting and Roosting habitat by less than 20 acres. In fact, the clearcut stands will not achieve Nesting and Roosting habitat for at least a century.
Riparian Reserves
Page 18 of the EA indicates that the BLM intends to commercially remove large trees from approximately 1,297-acres in the Last Chance timber sale. This acreage figure is staggering. Here the BLM intends to log nearly 1,300-acre of streamside forests without the benefit of cumulative analysis, preferring instead to rely upon and tier to its RMP which mentions and analyzes zero of the riparian features in the Last Chance project area.
At B-92 the BLM asserts that it intends to allow an undisclosed number of cable yarding stream crossings and undisclosed locations without the benefit of any data or analysis at any scale.
At C-31 the BLM acknowledges that it intends to fell trees within the Inner Riparian Zone to facilitate any and all logging activities such as yarding, skid trails, and road construction. Where will these practices occur? How often will they occur? What are the site specific and cumulative impacts? Are the riparian reserves actually reserves if they are in fact subject to unrestrained and unanalyzed logging in every zone of the “reserves?”
Fire and Fuels
Should the BLM continue to pursue gap creation techniques that the agency acknowledges will increase fire hazard, then the agency must complete an Environmental Impact Statement (as opposed to an EA) for this project. Intentionally increasing fire hazard and fire suppression complexity is a significant and extremely controversial action. The 2016 RMP to which the Last Chance timber sale EA ties does not and cannot analyze the effects of increased fire hazard on this project area or nearby homes and communities.
Page 48 of the EA acknowledges that “the 787 acres of variable retention harvest would convert the mature structure stage to early successional and stand establishment, delaying promotion of large fire resilient trees.” Is this the result that BLM timber planners hope to achieve? If so, and EIS must be prepared. Page 48 of the EA further acknowledges that the creation of 4-acre gap clearcuts will increase wind gust speeds thereby increasing fire hazard and fire suppression complexity. These results are antithetical to the alleged purpose of the project to reduce susceptibility to disturbance and achieve fuel reductions.
Northern Spotted Owls
Table B.32.1 at B-119 which hypothetically addresses habitat in the only six NSO sites that the BLM admits are occupied. The table contains no actual numbers. Where the numbers should be located is simply the figure “.” Either the BLM does not know the numbers, or it knows the numbers and doesn’t want the public to know the numbers, or BLM planners and decision makers are not interested and aware of the content of the analysis in the EA. This is not a simple typo or clerical error. It is clear evidence that the BLM is unwilling or unable to actually analyze the impacts of its old-growth logging agenda on occupied NSO sites and that the NEPA documents that are supposed to inform agency decision making are instead simply a paper exercise to backfill an inevitable logging decision that puts timber volume first and wildlife last.
Bureau Sensitive Animal Species
Johnson’s hairstreak butterfly. Credit: Washington Department of Fish & Wildlife
The BLM refuses to analyze the impact of the Last Chance old-growth timber sale on species of concern. At B-130 the agency states that the “BLM may or may not conduct field surveys as part of these evaluations for BSS wildlife species.” The agency misunderstands the purpose of the NEPA process. NEPA is intended to allow for informed public commenting and informed agency decision making. Stating that the agency may or may not conduct an activity to gather essential data and information does not contribute to NEPA objectives. Will the BLM conduct BSS surveys? Probably not. But how can we know?
What is disclosed to the public and the decision maker is that the BLM is unwilling to gather, provide, or analyze actual population or reproductive data about sensitive species. For instance, at B-134 the BLM indicates that old-growth mistletoe-associated butterfly species Johnson’s Hairstreak is suspected to be present in the vast acres of old-growth forests targeted for logging in this project. The BLM mentions that there are “no known occurrences” of the species. The BLM fails to mention that the agency has never conducted any surveys for species and has no site specific or cumulative data.
Western Pond Turtle
The proposal to modify nearly half of western pond turtle overwintering habitat in the project area is likely a death sentence for the local population and may contribute to the already established need to list the species under the Endangered Species Act. This is a significant action necessitating an EIS. It is this kind of cavalier treatment of wildlife that led to the listing of the northern spotted owl and marbled murrelet and will now lead to the listing of the western pond turtle. There have been no surveys, there is no data, and there is no analysis. The location of gap clearcuts and road construction through overwintering habitat is not disclosed. The BLM has provided a nothingburger to support its rapacious logging agenda at the expense of wildlife.
Soil Disturbance
The BLM is aware that at several sites its logging, road construction, landing and yarding activities will exceed (violate) the 20% soil disturbance threshold established in the 2016 RMP.
Watch the video where we break down the Last Chance EA here:
From our perspective outside the agency, it appears that achieving timber targets are the primary, and often only, objective of BLM managers. Involving diverse members of the public to identify project objectives can achieve the wide variety of values that Americans place on their public lands rather than focusing primarily or exclusively on meeting arbitrary timber production targets that the agency has established as its measure of management success.
Removing and reducing mature forest canopy is a shortsighted and counterproductive way of attempting to meet BLM timber targets. We ask that the BLM works with interested stakeholders to develop projects that increase—rather than decrease—forest and watershed health. Substantive partnerships that acknowledge all the interests in America’s public lands would better serve the BLM than continuing to develop projects that primarily serve a narrow set of timber interests.
Learn more about Last Chance
See sale statistics, documents, comments, photos, and more.