The public deserves a safe, beautiful, natural experience on their public lands. The BLM has an obligation to provide this experience, yet in many places around the Applegate Valley they have failed to do so.
Lack of enforcement capacity and lack of motivation to responsibly deal with various irresponsible recreational activities has turned our spectacular backyard landscapes, such as Anderson Butte, into trashed-out playgrounds for unauthorized OHV users and irresponsible shooting. ANN believes this issue affects the quality of habitat on our public lands; we also believe it impacts the quality of life available to surrounding communities. Rather than beautiful vistas, gorgeous wildflowers and spectacular habitats, what we see are shot gun shells, shell casings, shot-up TVs and appliances, illegal dumping, damaging OHV trails and bullets whizzing by on hiking trails — this is what one remembers when visiting portions of our public land. Many in the Applegate Valley have had enough. Have you?
Below is a letter submitted by ANN to the Medford District BLM regarding unsafe and irresponsible target shooting near Anderson Butte. This issue is becoming increasingly dangerous and is displacing other forms of public use, such as hiking on the nearby Jack-Ash and Sterling Ditch Trail systems, botanizing, birding, mountain biking, driving for pleasure, etc.
If you are a landowner in the area or spend time in the area, please contact Medford District BLM, District Manager, Elizabeth Burghard, and share your concerns regarding unsafe target shooting, unauthorized OHV use, illegal dumping, and other forms of inappropriate and impactful public use in the Anderson Butte area.
Ms. Elizabeth Burghard
3040 Biddle Rd
Medford, OR 97504
Applegate Neighborhood Network (ANN) would like to provide input on the management of our public lands in the Applegate Valley. More specifically, we would like to provide input on long-standing problems associated with unsafe target shooting and tannerite use in the Anderson Butte area. In recent years, unsafe target shooting has become an increasingly dangerous and damaging use of our public lands around Anderson Butte. Target shooting and illegal dumping seem to be closely associated in the area. The vast majority of old log landings, quarries, and pullouts along the road system have become illegal dumping and target shooting sites.
Irresponsible target shooting is currently a significant public safety risk with shooting enthusiasts firing across open BLM roads, off steep hillsides, towards hiking trails, and towards residences along Griffin Lane, Sterling Creek Road, Little Applegate Road and in the few private residential inholdings in the area.
In January of 2016, residents on Griffin Lane had a bullet from the Anderson Butte area lodge in their front door. Nearby homeowners are subjected to daily safety risks on their own property due to unsafe target shooting on BLM lands. In fact, BLM signage is currently encouraging unsafe target shooting in the area. For example, on an exposed ridge above Grub Gulch, the BLM has posted a sign stating, “Caution, Homes Below, Know Your Backstop.” The sign encourages shooting enthusiasts to utilize the exposed ridgetop for shooting and draws attention to the site. Ironically, no safe backstop exists on the ridgeline and homes are located directly below, in range of stray bullets.
Hikers, mountain bikers, recreational drivers, botanists, mushroom pickers, hunters and other forest users are routinely put at risk due to unsafe target shooting. Major BLM recreational improvements and trailheads for the Wolf Gap Trail, Jack-Ash Trail, and Sterling Ditch Trail have become target shooting areas, putting non-motorized trail users at significant risk. The BLM must act before someone is hurt or killed. Currently, other public land users are abandoning premiere recreational facilities, including the only Oregon State Scenic Trail, the Sterling Mine Ditch Trail, due to valid safety concerns.
Much of the current problem comes from a complete lack of management and law enforcement. For many years, the Anderson Butte region has been a free-for-all, with blatant unauthorized OHV use tearing up the hillsides, unsafe target shooting, illegal dumping, and other forms of inappropriate use degrading public lands and spilling out into nearby communities. BLM land managers have refused to address these issues with appropriate action and have set a precedent of impunity and inaction. As a direct consequence, one of the region’s most cherished backyard recreational opportunities is being abandoned by responsible recreational users and destroyed by a combination of inappropriate public use and BLM inaction.
According to the RMP, the Sterling Mine Ditch Trailheads and Jack-Ash Trailheads are “closed to shooting.” Likewise, the entire Anderson Additions Extensive Recreational Management Area is under a firearms restriction, including buffers along “trail corridors and trailheads to provide public safety.” The BLM has an obligation to immediately implement these management directives in the Anderson Butte area, before someone is killed.
The BLM must close the entire Anderson Butte area to target shooting. The 2016 RMP gives the BLM the authority to immediately take action, close and post the trailheads for the Sterling Ditch Trail and Jack-Ash Trail, “Closed to Target Shooting.” Our immediate concern is the safety of the public who uses these lands and the nearby residents. The current status quo at Anderson Butte is unacceptable.
We urge the BLM to consider an area-wide closure to target shooting on all BLM land between Wagner Creek Road, Griffin Creek Road, Griffin Lane, Sterling Creek Road and Little Applegate Road. The BLM should also increase law enforcement patrols to limit violation of the target shooting closure and reduce illegal dumping. The public deserves a safe space to recreate on Anderson Butte and enjoy their public lands.
Thank you for your time,
Luke Ruediger/Program Coordinator
Applegate Neighborhood Network
Throughout the past year Applegate Neighborhood Network (ANN) has worked on numerous major campaigns to protect, restore and rewild the Applegate Valley and Siskiyou Crest. We are proud of our achievements in 2017 and look forward to doing even more in 2018.
Pickett West Timber Sale
The BLM’s Grants Pass Resource Area proposed the Pickett West Timber Sale in late 2016. The project proposed extensive old-growth forest logging, with nearly half the timber sale involving units between 150 and 240 years old. The BLM also proposed new road construction, riparian logging and severe impacts to the proposed Applegate Ridge Trail.
The massive timber sale became a major focus of our work in 2017. The Pickett West Timber Sale extended across a 200,000-acre planning area, from the Wild and Scenic Rogue River near Galice and Hellgate Canyon, to the mountains surrounding Selma, Oregon, and large portions of the Applegate Valley near Wilderville, Murphy and North Applegate Road.
ANN took a leading role by monitoring units in the Applegate Valley, Illinois Valley and the Rogue Valley. We worked with Klamath Forest Alliance and the Deer Creek Association to coordinate monitoring efforts across southern Oregon. ANN documented high priority red tree vole habitat on the Rogue River and outside Selma, Oregon in beautiful old-growth forest proposed for logging. We also documented road construction and old forest logging that would irreparably alter the proposed route of the Applegate Ridge Trail.
We publicized our findings and advocated for withdrawal of problematic units. We also utilized our monitoring efforts to write detailed public comments and administrative protests. We provided reports to Fish and Wildlife detailing our monitoring results and documenting inaccurate Northern spotted owl habitat designations. In many units we documented unacceptable impacts to the Northern spotted owl’s main food source, the red tree vole.
The BLM canceled numerous of the worst Pickett West units on the Rogue River, dropping a few hundred acres from the project. Unfortunately, the BLM then sold a reduced timber sale in the Rogue River area, called Pickett Hog. This sale is currently on hold until ANN’s administrative protest, and the 28 other administrative protests they received for the original Pickett West Timber Sale, are resolved. ANN will keep you posted on the administrative protest process.
In the meantime, Fish and Wildlife ordered the BLM to review many of the Pickett West units ANN identified as problematic in the mountains around Selma, and the BLM ended up withdrawing the entire Selma portion of the Pickett West Timber Sale, including 1,584 acres of old-growth forest. Although a spectacular victory for local environmentalists, rural residents, and scientists who opposed this sale, BLM has, unfortunately, initiated a Scoping Notice on a greatly reduced and new timber sale in the Selma area called Clean Slate. Although reduced in size, the Clean Slate Timber Sale still has units containing old-growth forests. The BLM is accepting public comments about the Clean Slate project until December 8, 2017.
Finally, in the Applegate Valley, the BLM is proposing to move forward with the original Pickett West Timber Sale planning by implementing what they are calling the Savage Murph Timber Sale near Wilderville, Murphy and North Applegate. ANN will continue working to stop the old-growth logging and road building proposed in the Savage Murph Timber Sale in 2018. We are committed to detailed, site-specific, on-the-ground timber sale monitoring and documentation of what is truly at stake should these projects go through.
Siskiyou Crest Post-Fire Logging
The Gap Fire burned over 30,000 acres on the southern slopes of the Siskiyou Crest in the summer of 2016. The Gap Fire burned through the Klamath National Forest (KNF) to the spine of the Siskiyou Crest, near Condrey Mountain. In the high country around Condrey Mountain the fire burned in a natural, mixed-severity fire mosaic, leaving green forests, lush high mountain meadows, headwater springs, and burned snag forests interspersed in a diverse patchwork of habitats.
On the south slope of Condrey Mountain, near the summit of the Siskiyou Crest, the KNF proposed to log fire-affected, old-growth forest at the headwaters of Buckhorn and Middle Creek. Although just barely outside the Applegate Watershed, the proposed clear-cut, post-fire logging would have impacted the Siskiyou Crest and the important habitat connectivity corridor that connects the Coast Range to the Cascade Mountains and the Great Basin. This connectivity corridor feeds and maintains the continued outstanding biodiversity of the Applegate Valley.
ANN worked with the Klamath Forest Alliance as the only environmental organizations to conducted on-the-ground field monitoring of the eighteen, high-elevation logging units and new road construction proposed near Condrey Mountain and Dry Lake Mountain.
We publicized our findings and utilized our monitoring results to inform our extensive public comments on the project, and four units near Dry Lake Mountain were immediately withdrawn. The KNF approved the remaining fourteen units and new road construction around Condrey Mountain. ANN, Klamath Forest Alliance and others responded with detailed administrative protests, putting the project on hold. The KNF resolved our administrative protest by withdrawing the remaining fourteen units and 450 acres of high elevation forest on the Siskiyou Crest from the timber sale proposal. We are very proud of this victory for the Siskiyou Crest!
Over the last two years ANN has worked on a large, collaborative project in the Upper Applegate Watershed with both the BLM and Forest Service called the Upper Applegate Watershed (UAW) Restoration Project. The project is being implemented through the Applegate Adaptive Management Area and has included extensive public involvement. Members of ANN have been at all of the many public meetings and field trips associated with UAW project planning. We have attended these workshops, field trips and planning meetings to ensure conservation issues are addressed in the project. We also provided detailed public comment during the scoping period.
The UAW collaborative project is working towards the development of an Environmental Assessment (EA) before a final project is approved. Currently, ANN supports many of the proposals and has steered the agencies away from ecologically sensitive areas and towards responsible land management practices. Proposals we support include: new non-motorized trail development, large-scale prescribed fire, fuel reduction maintenance around rural residential communities, pollinator habitat restoration, ecologically-based commercial thinning in managed stands and noxious weed removal. We are opposing a handful of commercial logging units located within roadless areas, and we are strongly opposing numerous new OHV trails also being proposed in roadless areas. If new OHV trails are approved through this project it will no longer meet the intended “purpose and need” of the project, which has been focused on habitat restoration. New OHV trail construction in roadless areas is the antithesis of habitat restoration.
Middle Applegate Timber Sale
ANN has participated in the early stages of project planning with the BLM on their proposed Middle Applegate timber sale. The project area extends from Bishop and Forest Creeks, to Thompson Creek and across the Middle Applegate watershed, over to Slagle Creek. ANN has attended numerous community meetings and coordinated with local community members to advocate for implementation of the Applegate Adaptive Management Area and meaningful community involvement in the planning process. We are advocating for protection of the Wellington Butte Roadless Area, old forest habitats, and the proposed Applegate Ridge Trail corridor. We appreciate the efforts of Applegate community members who have attended the meetings and voiced their support for conservation during the early planning stages for the Middle Applegate timber sale project. ANN will keep you posted if there are any further developments.
ANN has continued to monitor unauthorized and damaging OHV activities in the Applegate Valley and on the Siskiyou Crest. Over the course of the last year, ANN has successfully advocated for the obliteration of one OHV trail on BLM land near Anderson Butte. We have also worked to include one unauthorized OHV trail obliteration project into the UAW Restoration Project.
OHV Categorical Exclusion
In April 2017, the Medford District BLM approved a Categorical Exclusion to avoid environmental analysis and public comment on the “maintenance” of 65 miles of unauthorized OHV trails in the Forest Creek, China Gulch and so-called Timber Mountain/John’s Peak area. BLM’s goal is to legitimize these illegally created, unauthorized OHV routes, mask the environmental impacts for upcoming environmental analysis, and cut the public, including residents of the Applegate Valley who are negatively impacted by the project, completely out of the process. The Categorical Exclusion excludes the requirement that land managers conduct a thorough review of the cumulative environmental and social impacts. It also excludes the requirement that land managers provide a public comment period and address the concerns, science, and information identified in the public comment process.
The 65 miles of OHV trails in question are highly erosive, user-created routes that have never been subjected to environmental review or approved through a legal NEPA process. The unauthorized trails impact rare plant habitat, wildlife habitat, hydrology, water quality, soils and a myriad of other forest resources. They also encourage and facilitate private land OHV trespass by officially maintaining routes that include or continue onto adjacent private lands. These private lands include the homes and backyards of many Applegate Valley residents.
Although the BLM approved the project with no public comment, ANN promptly filed an administrative protest, demanding the project be withdrawn and that BLM conduct Travel Management Planning as required in the 2016 Resource Management Plan.
Unfortunately, BLM denied our protest and intends to move forward with OHV trail maintenance in the area. ANN will continue to watch the BLM, document the impact of OHV use and advocate for closure of damaging OHV trails. For now the BLM can maintain these user-created trails but they have not been officially authorized. We are gathering evidence and stand ready to oppose these illegal OHV trails as soon as BLM proposes them for approval in the future.
Applegate Grazing Complex
ANN has been monitoring grazing allotments on the Siskiyou Crest throughout the summer of 2017. We are documenting the ecological impact of public land grazing in preparation for the upcoming Applegate Grazing Complex allotment renewal in 2020.
The Forest Service will be updating management plans for grazing allotments in the Applegate watershed, a task that has been neglected for many decades. Some of these grazing allotments have not had an updated management plan since 1956! Our goal is to document impacts to water quality, soils, wildlife habitat, pollinator habitat, botanical resources, and designated botanical areas to inform the planning process. We are monitoring four grazing allotments that cover large portions of the Siskiyou Crest from Dutchman’s Peak to Carberry Creek.
The Miller Complex Fires defined the summer of 2017. Combined, the fires burned nearly 40,000 acres in the Applegate watershed from mid-August to the first fall snow. The fires burned in a natural, mixed-severity fire mosaic and provided significant ecological benefit to the forests and wildlands of the Applegate watershed
While the fires were burning, ANN tracked their progress and informed fire managers of important ecological considerations within the fire area. We also advocated for responsible fire management, effective community protection and the protection of roadless habitats from fire suppression impacts.
ANN has been monitoring the fires and fire suppression activities in the Miller Complex. We are currently preparing the Miller Complex Fire Report in order to share our findings with local conservationists, residents, scientists, politicians and land managers. This report will explore the fire effects, fire suppression impacts, and long-term implications of the Miller Complex Fire.
ANN worked hard in 2017 to educate the public about the important role fire plays in the Siskiyou Mountains. We are using the Miller Complex Fire to explore the region’s fire ecology and pyrodiversity.
Thankfully, the Forest Service is not proposing post-fire logging in the Applegate Valley portions of the Miller Complex Fire. This is a huge victory for our diverse, fire-adapted Siskiyou Mountain forests and the post-fire environment, and it will provide an opportunity to research and monitor the natural process of renewal following wildfire. ANN intends to utilize the Miller Complex Fire area as a living laboratory. We hope to educate both the public and federal land managers regarding the benefits of wildfire in the Siskiyou Mountains.
What lies ahead for 2018?
In 2018, ANN will continue working for the community and the environment of the Applegate Valley. We will continue our on-the-ground monitoring efforts and will advocate for conservation in federal land management planning. We expect the Savage Murph and Middle Applegate Timber Sales will be a high priority in 2018, along with ongoing OHV monitoring, monitoring of grazing allotments and collaboration in the UAW Restoration Project. On the Siskiyou Crest, ANN will oppose any post-fire logging proposed in the Abney Fire on Klamath National Forest lands. We will also continue providing information to the public regarding fire ecology and wildfire management. ANN is the only conservation organization focused solely on the needs of the Applegate Valley, the Siskiyou Crest and the important connectivity habitat that the region provides. Please consider supporting our work with a generous donation. Your support is vital to the wildlife and wildlands of the Applegate Valley!
The Grants Pass District BLM has released an Environmental Assessment (EA) for the Picket West Timber Sale and will be accepting public comment until June 29, 2017.
The Pickett West Timber Sale is huge, with units extending across southwestern Oregon, from Merlin and Galice on the Rogue River, to Selma in the Illinois River watershed, and in the Lower Applegate River watershed around Wilderville, Murphy and North Applegate Road.
The project proposes to commercially log over 6,000 acres of BLM land and build 14 miles of new road. 48% of the units proposed for logging are between 150 and 240 years old, making them old-growth by any credible definition. The BLM is proposing to log these old-growth stands to as low as 30% canopy cover with no upper diameter limit, meaning any size tree can be logged.
Join ANN and Tom Doty on July 15, 2017 for an evening of Native American storytelling around the campfire. Tom will share stories from local Native American tribes about the Rogue River and Applegate Valleys.
Tom Doty was born in southern Oregon. His family background is Irish, English, Taklema and Shasta. His Takelma and Shasta ancestral village is at Coyote’s Paw on the Klamath River. He studied writing and theater at Southern Oregon University and Reed College in the 1970s. He began storytelling when he returned to Southern Oregon in 1981, learning the craft from tribal elders. Tom is the author of a series of Doty & Coyote books and many of his stories have been broadcast on Public Radio. In 2001 he wrote and directed a play titled, Two Sisters, Two Brothers and a Journey, a story of the Takelma people of southern Oregon. Tom travels around the region telling his stories and keeping the tradition of Native American storytelling alive. Join us!
The event will be located at Flumet Flat Campground on Palmer Creek Road. We will have 50 camps available for overnight camping. We will also have an evening of fun, listening to bioregional stories and socializing with neighbors. The event will be free, but please consider a generous donation to ANN. More information will be announced soon. Please join us.
When: July 15, 2017 (time to be announced)
Where: Flumet Flat Campground on Palmer Creek Road
The BLM will be hosting a field trip June 17, 2017 to the Pickett West Timber Sale to view and discuss proposed units and treatment options. The field trip will include two separate stops. Please consider attending this important field trip and join ANN as we advocate for conservation.
The first stop will be on Upper Savage Creek Road to view a proposed timber sale unit in the Lower Applegate River Watershed. Meet at 9:00 AM at the Speedy Mini Mart at 6415 Rogue River Highway. We will be shuttled in BLM vans to Upper Savage Creek Road. The field trip will begin at 9:00 AM and end at around 11:30 AM.
The second stop will be at Robertson Bridge at 1:00 PM. We will drive up Pickett Creek Road to a parking area where BLM will shuttle us to unit 33-2. The field trip will begin at 1:00 PM and end at around 3:30 PM.
At the Applegate Neighborhood Network, we are working hard to develop a more profound sense of place. and a deeper appreciation for the ecology, beauty and diversity of the Applegate River Watershed. We are working to promote the the protection of wild places and the responsible stewardship of the more altered environments in the area. To achieve these goals we are working to connect people to this beautiful landscape.
Our member organization, Applegate Trails Association is designing, building and promoting the Applegate Ridge Trail (ART), an over 40 mile trail proposed to connect Jacksonville, Oregon and Grants Pass, Oregon through the hills of the Applegate Valley. The trail will cross the Wellington Butte Roadless Area and the wild country in upper Humbug and Slagle Creek. After years of organizing ATA has gained approval from the BLM to begin building the East ART, a 5.6 mile route connecting Sterling Creek Road to Highway 238.
ATA has wasted no time, building trail in a frenzy of excitement and enthusiasm. ATA crews and Northwest Youth Corp made tremendous progress this week building roughly one mile of trail in a few short days. ATA hopes to have the trail completed by fall.
The Siskiyou Upland Trails Association (SUTA) has also begun building phase one of the Jack-Ash Trail that will ultimately extend from Jacksonville, Oregon to Ashland, Oregon. The Jack-Ash Trail will traverse the McDonald Peak Roadless Area, the Bald Mountain Roadless Area and the Dakubetede Roadless Area. SUTA has approval on the first phase of the trail near Anderson Butte and began building trail this past November. They have about 2.5 miles remaining to build.
The trails will allow local residents to develop more intimate relationships with the mountains of home. They will also provide additional incentives to protect the wild landscapes through which they traverse. We are working to promote conservation and responsible recreation on public lands in the Applegate Watershed and see these trails as an essential step towards a more sustainable future.
Join SUTA and ATA for upcoming volunteer trail building days.
Now is your chance to have your opinion regarding public lands grazing in the Applegate and on the Siskiyou Crest heard! The Rogue River-Siskiyou National Forest, Siskiyou Mountains Ranger District is beginning an Environmental Analysis (EA) process to update four local grazing allotments.
Applegate Grazing Complex
The proposed plan is to update four Allotment Management Plans (AMPs), collectively referred to as the Applegate Grazing Complex, including: Beaver-Silver, Carberry Creek, Elliott Creek, and Upper Big Applegate. The four allotments span across the vast majority of the Upper Applegate and Little Applegate watersheds, affecting hydrology, water quality, wildlife habitat, botanical values, roadless areas and pollinator habitat.
The Forest Service issued the Scoping Notice for the EA on February 16, 2017 and they are currently accepting public comments during the 30-day public comment period. The Scoping Notice states: “The purpose of updating the AMPs is to consider the reauthorization of livestock grazing on the four allotments. The intent of the reauthorization is to provide the Forest Service and permittees with an updated legal document that defines how livestock grazing will be managed. Grazing on the allotments have generally been permitted since the early 1900s. This effort would ensure updated information is provided for the sustained health of rangeland and forest ecosystems.
The AMPs for these allotments have not been updated since the 1960s; an evaluation of the condition and trends of vegetation and soils within the allotments needs to be conducted. Based on the results of the evaluation, the Forest Service wold either allow for continued permitted grazing for the established numbers and seasons, adjust the permitted numbers and seasons allowable for grazing, or discontinue the permitted grazing. The analysis would provide updated information that reflects current management direction and resource objectives. Updated AMPs would provide direction that maintain or improve vegetation and riparian conditions through effective livestock management while providing for other uses.”
Impacts of Public Lands Grazing in the Applegate and on the Siskiyou Crest
The Applegate Grazing Complex is located in Upper and Little Applegate watersheds and extends from the low elevation foothills to the high country of the Siskiyou Crest where most of the cows stay for the summer. Cattle routinely reach the Siskiyou Crest before the approved grazing season has begun and are often left to graze later in the season than is allowed under the current AMP, creating severe impacts and over-utilization of forage resources.
The grazing strategy currently employed is referred to as “passive season long grazing,” meaning little, if any, management occurs once the cows are placed on federal land. The cows simply manage themselves and congregate at preferred “pastures” in high-elevation wet meadows doing great damage to wetlands, streams and sensitive meadow habitat. Many sensitive habitats are being degraded or denuded by cows. Forage resources (grasses, forbs and shrubby growth) are being over-utilized by grazing cattle, leaving little for native elk and deer who prefer many of the same locations. Numerous springs, streams, wet meadows, and lakes that support populations of rare and sensitive plant species occur within the Applegate Grazing Complex.
“Livestock grazing alters the structure, diversity, and growth pattern of vegetation, which affects the associated insect community. Grazing during a time when flowers are already scarce may result in insufficient forage for pollinators. Grazing when butterfly larvae are active on host plants can result in larval mortality and high intensity grazing can cause local loss of forb abundance and diversity.” –Pollinator-Friendly Best Management Practices for Federal Lands
Much of the most intensive grazing occurs in designated Botanical Areas, established to protect botanical values; instead, grazing cattle heavily degrades many of these areas. Rare plant populations are being impacted by public land grazing and the intact habitats identified by the Forest Service for Botanical Area protection are being compacted, denuded, and mowed to the ground by unmanaged cattle grazing. Eight Botanical Areas are included within the Applegate Grazing Complex allotment boundaries: Lyman Gulch, Dutchman’s Peak, Observation Peak, Scraggy Mountain, White Mountain, Cook and Green Pass, Whisky Peak and Hinkle Lake.
Roadless Areas at the headwaters of the Applegate River are also being negatively impacted. Roadless areas within the allotment boundaries include: Observation Peak Roadless Area, Condrey Mountain Roadless Area, Kangaroo Roadless Area, and Whisky Peak Roadless Area. Low elevation roadless areas, including the Little Greyback Roadless Area, Collings-Kinney Roadless Area, Elliott Ridge Roadless Area and Boaz Mountain Roadless Areas would also be impacted by proposals to release cattle at lower elevations, allowing cattle to migrate upward as the snow melts. The release of cattle at the lower end of Mule Creek, Palmer Creek and Beaver Creek — all fish bearing streams — is proposed under the Applegate Grazing Complex Scoping Notice.
The proposal also includes grazing in the Red Buttes Wilderness, the largest intact wildland habitat in the Applegate River watershed. It has been many years since the Red Buttes Wilderness has been actively grazed.
Provide a Public Comment on the Applegate Grazing Complex
Applegate Grazing Complex Scoping comments are due on March 31, 2017.
Written comments can be sent to:
Donna Mickley, District Ranger, c/o Greta Smith
6941 Upper Applegate Road
Jacksonville, Oregon 97530.
Email comments may be submitted to:
For further information about the project contact Mark Hocken, Project Team Leader, Siskiyou Mountains Ranger District: email@example.com or via phone: 541-899-3830.
Sample Scoping Comment
Re: Applegate Grazing Complex Scoping Comment
Attention: District Ranger Donna Mickley c/o Greta Smith
6941 Upper Applegate Road
Jacksonville, Oregon 97530
Donna Mickley, District Ranger,
The Applegate Grazing Complex is a very significant land management project, encompassing vast acreages of federal land and creating both direct and indirect impacts across the Applegate River watershed and the Siskiyou Crest. Livestock grazing on public land is associated with widespread impacts to riparian areas, water quality, wetlands, fisheries, hydrology, native plant habitat, rare plant habitat, wildlife habitat and pollinator habitat. The scope and scale of the project requires an Environmental Impact Statement (EIS), rather than a less comprehensive Environmental Assessment (EA).
The Siskiyou Crest is a botanical wonderland and a regionally important connectivity corridor. It is one of the most significant concentrations of biological diversity on the West Coast of North America. For many years this botanical paradise has been subjected to severe overgrazing. Please consider the following substantive issues in the upcoming NEPA analysis for the Applegate Grazing Complex.
Consider discontinuing grazing allotments on the Siskiyou Crest, especially in allotments that are not currently meeting water quality standards; in allotments that have severe stream/wetland degradation; in allotments that have significant impacts to Botanical Areas and botanical values; and in allotments that create conflicts with other appropriate uses like the Pacific Crest Trail.
End “passive season long grazing” on the Siskiyou Crest and require all permittees to actively herd cattle from “pasture” to “pasture.” Do not allow cattle to congregate in preferred locations for more than 14 days.
As part of the environmental review, it is essential that qualified Forest Service specialists assess stream, wetland and meadow conditions in order to determine and disclose whether streams, wetlands and meadows are functioning properly ecologically. If there are streams, wetlands and meadows on these allotments which are not functioning properly, Forest Service managers must determine how cattle grazing is impacting properly functioning condition and adjust grazing practices, including the number of livestock allowed to graze, the season of grazing at different elevations, and the grazing system that will be used to end the degradation and return streams, wetlands and meadows to properly functioning ecological condition.
Stream, riparian and wetland exclosures should be established, and where they have been removed, they should be restored. Livestock exclosures are the only valid method to determine if grazing is significantly altering the composition and structure of riparian and wetland vegetation.
Analysis must identify all provisions of the Clean Water Act that apply to the grazing allotments and require all grazing allotments to be consistent with the mandates of the Clean Water Act.
Analysis must identify impacts to Botanical Areas and require that AMPs are consistent with Botanical Area designation.
Analysis must identify impacts associated with early season grazing along low-elevation stream corridors, especially along fish bearing streams such as Beaver Creek, Mule Creek, Palmer Creek and Kinney Creek.
Analysis must identify the impact of competition between cattle and the growing elk population on the Siskiyou Crest. Cattle numbers, seasonality of use, intensity of use and the lack of herding must address the issue of competition between cattle and elk for available forage resources.
Analysis must identify the existing condition of willow flycatcher habitat (an agency sensitive species) in the EA, document impacts associated with cattle grazing, and limit the number of cattle or seasonality of use to mitigate impacts to willow flycatcher habitat.
Implement the recommendations for Livestock Grazing written in the Federal publication, Pollinator-Friendly Best Management Practices for Federal Land. Utilize these guidelines for pollinator habitat and to identify impacts to pollinator habitat from grazing activities. Limit the number of cattle and seasonality of use to mitigate the impacts of grazing on pollinators. Special attention should be taken to restore, enhance and promote the maintenance of habitat for the Sierra blue butterfly (an agency sensitive species), Western bumble bee, Franklin’s bumble bee, and the monarch butterfly.
Analyze the impact of historic grazing on dry bunchgrass habitat and in “cattle barrens” created by historic and contemporary overgrazing. Review the restoration of dry bunchgrass habitat in vacant or unused areas and compare them to areas that are actively grazed. Create guidelines within the AMPs to address the loss of historic dry bunchgrass habitat and the restoration of these communities due to non-use.
The Applegate Neighborhood Network (ANN), Klamath Forest Alliance (KFA), and the Siskiyou Crest Blog have joined forces to monitor Off-Road Vehicle (OHV) use on the Siskiyou Crest. We monitor a vast region in the eastern Siskiyou Mountains from Grayback Mountain to Mount Ashland. For the past two years we have been publishing Siskiyou Crest OHV Monitoring Reports. We spend countless hours walking the ridges and forests of the Siskiyou Crest, following and monitoring OHV trails. Our goal is to document the impacts of illegal and unauthorized OHV use, notify the agency of violations, and advocate for ecological values.
The Forest Service, although the land managers in the area, are not always aware of the impacts that are occurring from unauthorized OHV use on the public land they manage. The Siskiyou Crest OHV Monitoring Reports have documented significant impacts to the region’s Botanical Areas, Roadless Areas, and to the non-motorized experience on the Pacific Crest Trail. We have recently been meeting with both the Rogue River-Siskiyou and Klamath National Forests to address OHV impacts and eliminate unauthorized routes. We intend to protect the important habitats and non-motorized recreational experiences of the Siskiyou Crest.
These places are too special, and the ridges and meadows too beautiful to be turned into unauthorized roads, motorcycle paths or OHV routes.
We are also currently working on a BLM OHV Monitoring Report focused on the foothills of the Applegate Valley, specifically the numerous roadless areas on BLM land, including the Dakubetede Roadless Area and Wellington Butte Roadless Areas. Our current project area extends across the Applegate Valley on all BLM lands.
If you see OHV damage while hiking the Siskiyou Mountains, take pictures, document the impacts and please contact ANN at firstname.lastname@example.org
ANN & KFA want to thank you for your continued support of our annual OHV Monitoring Reports. Your support has made this important work possible!
The Applegate Trails Association (ATA) has worked for many years to gain approval for the East Applegate Ridge Trail, and this week the BLM approved the trail through a Decision Record. This means trail construction can finally begin!
ATA will be conducting volunteer trail building days where community members can come get their hands in the dirt and be a part of building this beautiful non-motorized trail.
The East Applegate Ridge Trail is the first section of trail intended to connect the cities of Jacksonville and Grants Pass, Oregon. The trail will traverse the ridgeline dividing the Applegate from the Rogue Valley, including areas above Ruch, Applegqte and North Applegate Road. The East Applegate Ridge Trail will extend from just above Sterling Creek Road 5.6 miles to Highway 238 near Forest Creek Road.
Come see a film that features the East Applegate Ridge Trail this weekend! The Siskiyou Film Festival will be featuring Hiking the Wild Applegate, a film created by the Applegate Trails Association. Hiking the Wild Applegate documents the first (mostly) off-trail thru-hike of the Jack-Ash and Applegate Ridge Trails. If you love the Applegate Valley you will surely be moved by this touching adventure film full of beautiful Applegate scenery.
The East Applegate Ridge Trail is sure to become a favorite hike in the Applegate Valley. The trail will offer hikers spectacular vistas, beautiful oak woodlands, sunlit grasslands and shady conifer forests. Please consider attending ATA sponsored trail building parties this spring!
When: April 1, 2017 8:30 AM-1:30 PM
Where: Meet at the East Applegate Ridge Trailhead on BLM road 38-2-29.1. This road is accessed from Sterling Creek Rd. 0.4 miles north of the Woodrat Mountain Access Road. Signs will point the way to the trailhead.
For folks unfamiliar with what ANN does week to week on behalf of the forests and wildlands of the Applegate, check out our schedule for just this coming week alone! Every week ANN works hard to defend the places we live near and care deeply about in the Applegate.
Monday, December 5, 2016
Grant deadline coming soon! ANN is constantly working to secure grant funding to keep our work going. Grant writing is time consuming and not always rewarding — the competition for limited environmental foundations and funders is fierce.
Work on scoping comments for the Gap Fire Salvage on the Siskiyou Crest. The Klamath National Forest wants to log high elevation forests burned in the 2016 Gap Fire. Red fir, white fir and hemlock forests are at risk on the Siskiyou Crest near Condrey Mountain!
Work on scoping comments for the East Applegate Ridge Trail EA. Our member organization, the Applegate Trails Association, has proposed this six-mile trail section from Sterling Creek Rd. to Highway 238 near Ruch. Once completed it will be the first section in the much-anticipated Applegate Ridge Trail that will extend from Sterling Creek to Grants Pass along the Applegate foothills.
Tuesday, December 6, 2016
Meeting with the BLM regarding Nedsbar. The Nedsbar Timber Sale is not over yet! The BLM is promising to restructure and resell the Nedsbar Timber Sale, and it is likely that much of the same proposed environmental impacts will be included in the “repackaged” sale. ANN requested a meeting with the BLM in order to keep the ecological concerns of the Applegate community at the forefront. ANN will advocate for implementation of the Nedsbar Community Alternative or we will keep working to cancel the sale.
Wednesday, December 7, 2016
Continue working on scoping comments for the Gap Fire Salvage Timber Sale and the East Applegate Ridge Trail EA.
Field work: Ground-truth the Pickett West Timber Sale. This massive timber sale includes many units in the western part of the Applegate Valley. The Grants Pass Resource Area has been unwilling to engage the Applegate Community through the AMA process for this timber sale and is ignoring the AMA mandates laid out in their 1994 RMP (Resource Management Plan), the RMP that they are planning the sale under.
Monthly ANN steering committee meeting at 6pm. Monthly ANN general meeting at 7pm at the Applegate Library. There’s always lots to talk about! The many environmental threats facing the Applegate Valley provide plenty of topics for conversation.
Thursday, December 8, 2016
Morning phone call with an environmental attorney regarding issues in the Applegate.
Midday meeting in Ashland with the Rogue River-Siskiyou National Forest and the Klamath National Forest regarding OHV issues and trail management on the Siskiyou Crest to address long-standing ecological damage. Many of the areas experiencing major OHV damage on the Siskiyou Crest are at the headwaters of the Applegate Valley, and within the Applegate River watershed.
Evening Applegate Trails Association board meeting. ATA is a member organization of ANN currently working on the Applegate Ridge Trail.
Friday, December 9, 2016
Public field trip hosted by the Forest Service to look at proposed commercial logging units in the “Demo Projects” approved under the Upper Applegate Roads Project. From 9am-1pm the Forest Service and community members will walk the units and discuss the different “treatments” proposed for these demonstration logging units. The Forest Service is proposing four different “treatments” in order to demonstrate the pros and cons of different techniques, including a “no action” control unit. ANN will be there to push for more ecologically appropriate action.
6 PM film showing presented by the Applegate Trails Association: Walking the Wild Applegate. This documentary film highlights the proposed Applegate Ridge Trail and Jack-Ash Trail connecting the towns of Ashland, Jacksonville and Grants Pass, Oregon. The film follows the first thru-hike of the trail corridor, beautifully depicting the diversity and scenery of the Applegate Valley and the vibrancy of our community. This casual event will be at the Ruch Fire Station Public Meeting Room.