The National Environmental Policy Act (NEPA) is one of our nation’s most important environmental laws, and has successfully been used for decades to infuse the public interest into the public land management process. NEPA encourages public accountability, scientific rigor and collaboration. It requires federal land managers to solicit public input, consider public comments, disclose the impacts of proposed management activities, analyze the cumulative environmental effects and conduct a detailed, site specific scientific review for all major land management activities on public lands.
NEPA has consistently made federal land management projects more thoughtful, innovative, environmentally responsible, scientifically credible and socially acceptable. Yet, under the direction of the Trump administration, many government agencies are being pressured to streamline the NEPA process, eliminate meaningful public comment and reduce scientific review for land management projects. The goal is to eliminate public involvement, expedite resource extraction, reduce regulation, and promote industrial land management activities on public lands.
Locally, the Medford District BLM is implementing these policies through projects like the innocuously named Integrated Vegetation Management for Resilient Lands Project (IVM Project). Although the project purposefully sounds benign, it is far from it. Terms like “integrated vegetation management” and in this case, “resilience,” are euphemisms for commercial logging and serve only to mask the impacts and objectives of timber management with misleading language.
More specifically, the proposal would encourage commercial logging in vast areas outside the existing “harvest land base.” Under the “Adapted Rogue Basin Strategy Alternative,” the BLM has proposed to allow up to 4,000 acres of commercial logging and 10 miles of new road construction per year without additional environmental review or public comment. The IVM Project would authorize up to 25,000 acres of commercial logging and 90 miles of new road construction over a ten year period.
These provisions would apply to the entire Medford District BLM, with the exception of the Cascade-Siskiyou National Monument and Wilderness Areas on BLM land. This would include Late Successional Reserve forests intended to protect habitat for the Northern spotted owl, Areas of Critical Environmental Concern (ACEC), Research Natural Areas, Lands with Wilderness Characteristics (LWC) and other areas outside the BLM’s “harvest land base." These areas are currently “reserved” for conservation purposes. According to the BLM, these authorizations would have “no sunset” date and could theoretically be used to build hundreds of miles of new roads and to log many tens of thousands of acres across southwestern Oregon over the next few decades.
To make matters worse, the BLM has proposed a programmatic planning approach, meaning that the agency will not be implementing existing public involvement or scientific analysis requirements for future timber sale and road building activities “tiered” to (agency-speak for tied to) the IVM Project. This would allow the agency to avoid both scientific and public scrutiny, while implementing industrial logging projects on public lands.
The Medford District BLM is working to remove both the public involvement process and public accountability in federal land management planning, while reducing or eliminating scientific analysis. The goal is to increase timber production on public lands, not to “restore resilience” as the BLM might suggest. Our coalition strongly opposes this approach and believes we should keep the public, in public lands.
Although not currently approved or even scientifically analyzed, the BLM is assuming that they will be authorizing and implementing the IVM Project. In fact, they have even begun planning projects “tiered” to the still unauthorized provisions of the proposed IVM Project.
The BLM has announced that one of the first projects to be implemented under the IVM framework will be the Late Mungers Project and despite having no official authorization, project planning has already begun.
Located in a large Late Successional Reserve (LSR) designated to protect important habitat for the Northern spotted owl, the forests of the Late Mungers Planning Area sprawl across a prominent ridgeline dividing Williams Creek in the Applegate Valley from Deer Creek in the Illinois Valley. This ridgeline, (known as Willdeer Ridge) is highly important for connectivity within the LSR network and as a habitat linkage between the Siskiyou Crest, the eastern Siskiyou Mountains in the Applegate River watershed and the more mesic habitat of the western Siskiyou Mountains, including the Wild and Scenic Rogue River, the Illinois River watershed and the vast Kalmiopsis Wildlands.
The Late Munger "planning area" contains a patchwork of logged off plantation stands, beautiful wildlands, lush, old-growth conifer forests, and unique habitats shaped by the region’s unusual serpentine soils. Although portions of the LSR have been heavily fragmented, other portions contain beautiful uncut forests and important habitat for species such as the Northern spotted owl. Far ranging carnivores such as the Pacific fisher, cougar, bobcat, and black bear also inhabit the area, along with goshawk, large populations of black-tailed deer, and a multitude of other wildlife species.
Currently little information is available about the Late Mungers Project, but a draft map has been released showing significant commercial logging units in some of the last old forest habitats on Mungers Butte, Powell Creek, Murphy Creek, Mungers Creek and numerous smaller tributary streams in the Williams Creek and Applegate River Watershed.
Our initial field monitoring demonstrates that BLM is targeting old, fire resistant forest for commercial logging in the Late Mungers Planning Area. According to the prescriptions described in the IVM Project, this logging will dramatically reduce canopy cover and remove large, fire resistant trees; degrading habitat values, increasing fuel loads, damaging scenic and recreational values, and impacting regional connectivity.