Sequoia National Forest
September 26, 2019
Read our coalition comments on the draft forest plans and revised draft environmental impact statement for the Sequoia and the Sierra National Forests.
You may also download this additional coalition comment letter that is specific to errors in Alternative E related to Recommended Wilderness Areas (RWA) and Backcountry Management Area (BMA) boundaries.
August 7, 2019
On June 28, 2019, the Sequoia and Sierra National Forests released their draft forest plans and revised draft environmental impact statement, initiating a 90-day public comment period closing on September 26, 2019.
Click here for a printable version of the most recent summary of key issues and recommendations.
Below, we provide a brief analysis regarding key issues in the plans.
Key Issues in the Sequoia and Sierra Revised Draft Forest Plans
The revised draft Sequoia and Sierra Forest Plans are analyzed in the Revised Draft Environmental Impact Statement (RDEIS) as the "Preferred Alternative B." We, the Sierra Forest Legacy coalition, urge the public to support "Alternative C" with the changes noted below. Alternative C recommends far more wilderness protection, proposes more acres of forest restored through prescribed and managed fire, and more riparian and meadow restoration than Alternative B.
What’s Good: The RDEIS identifies more than 800,000 acres of wilderness-quality lands across the two forests. The conservation-oriented Alternative C recommends over 452,000 acres of new wilderness. The new Alternative E also creates a Backcountry Management Area designation for roadless lands not recommended as wilderness. However, the Forest Service’s preferred Alternative B only adds a paltry 4,900 acres of new wilderness on the Sequoia NF and recommends no new wilderness on the Sierra NF despite hundreds of thousands of eligible acres.
Significant Improvements Needed:
• The Forest Service should adopt Alternative C or strengthen Alternative B to include more recommended wilderness areas on both forests, with an emphasis on low-elevation areas not typically protected by the wilderness system (see below for specific areas).
• Both plans should also apply Alternative E’s Backcountry Management Area designation to protect roadless areas not recommended for wilderness protection.
• Sequoia National Forest: Recommended wilderness areas should include the Golden Trout Wilderness Addition, Stormy Canyon, Oat Mountain, Cannell Peak, and the Domeland Wilderness West Addition, using boundaries developed by conservation groups to reduce conflicts with motorized and mountain bike trails (as displayed in Alt. E).
• Sierra National Forest: Recommended wilderness areas should include the Kings River-Monarch Wilderness Addition, Sycamore Springs, San Joaquin River-Ansel Adams Wilderness Addition, Bear Mountain, and Devil Gulch-Ferguson Ridge, using boundaries developed by conservation groups to reduce conflicts with motorized and mountain bike trails (as displayed in Alt. E).
Wild & Scenic Rivers
What’s Good: The Sequoia National Forest’s inventory of eligible rivers and streams was substantially improved in the 2019 draft plan. Eligible river miles increased from 75 miles in the 2016 draft plan to 341 miles in response to public comments. However, the Sierra National Forest’s inventory is a huge step backwards: eligible wild & scenic river (WSR) miles decreased by more than 500% from 640 miles in 2016 to just 35.5 miles in 2019. Public comments should commend the Sequoia NF for their expanded inventory and express concern about the substantially reduced WSR inventory on the Sierra NF. The eligible Wild & Scenic River inventory remains the same throughout all the alternatives.
Significant Improvements Needed:
• The draft plans should take a watershed approach to identifying eligible rivers and streams by identifying full streams as eligible rather than disconnected segments.
• Sequoia National Forest: The Forest Service should recognize additional eligible rivers including the North Fork Middle Fork Tule River and Rattlesnake Creek (North Fork Kern tributary).
• Sierra National Forest: The Forest Service should recognize additional eligible rivers including all 30+ miles of Dinkey Creek, the lower South Fork San Joaquin, the main San Joaquin below Mammoth Pool and Redinger dams, Granite Creek and Iron Creek (South Fork Merced tributary).
What's Good: The draft plans allow for prescribed fire and naturally-ignited wildfire managed for resource benefits, when conditions are right, across the landscape. The plans also recognize the benefits of prescribed fire on long-term smoke emissions and emphasize collaboration with air regulators to increase pace and scale of fire restoration.
• Set objectives for fire restoration that better match the ecological need of the landscape. Triple the amount of ecologically beneficial fire to 279,000 acres over the next 15 years.
• Include a realistic plan to increase prescribed fire capacity by establishing wildland fire crews solely dedicated to supporting prescribed fire rather than fire suppression.
• Increase focus on reducing surface and ladder fuels and using prescribed and managed wildfire as the primary fuels reduction and forest restoration tools.
Old Forests and Complex Early Seral Forests
What's Good: The draft plans recognize the ecological importance of mixed-severity fire in shaping the landscape.
Significant Improvements Needed:
• Adopt plan components in Alternative C that protect trees over 24” in diameter and a focus on removing surface and ladder fuels to across the landscape to better protect old forest habitat and increase resiliency.
• Include restrictions on salvage logging to protect most of the complex early seral habitat that is created by fire and other disturbances.
• Adopt the standards and guidelines in Alternative C for snag recruitment and retention.
Wildlife Species At-Risk
What's Good: Northern goshawk has been added as a Species of Conservation Concern. Protected areas have been added for great gray owl and northern goshawk. The approach to California spotted owl and fisher conservation has been improved but remains inadequate to support population viability. The plans now recognize that logging and grazing are threats to some at-risk species. Protections for Yosemite toad have been very much improved.
Significant Improvements Needed:
• Adopt plan components in Alternative C to protect more high-quality habitat (dense, large structured forests) for old forest dependent species like spotted owl, Pacific fisher, Pacific marten, great gray owl and northern goshawk.
• Add standards and guidelines to increase habitat quality of meadows historically occupied by willow flycatcher
• Adopt plan components in Alternative C to ensure high quality meadow foraging habitat is provided for reproductive great gray owls.
• Add conservation measures for species considered at-risk by experts and wildlife agencies; these include black-backed woodpecker and western pond turtle.
• Adopt Alterantive C that follows all recommendations made by scientists in the Fisher Conservation Strategy, including a 24” diameter limit.
• Add standards and guidelines, especially for logging and grazing, to ensure that habitat quality for at-risk species will maintain population viability or contribute to recovery.
Aquatic and Riparian Ecosystems
What's Good: The draft plans establish five Conservation Watersheds (2 on Sierra NF and 3 on Sequoia NF) to provide for continued high-quality water sources and the long-term persistence of at-risk species. Improvements were made to protections for riparian areas, meadows, and special aquatic features. Riparian areas now not considered part of the timber base.
Significant Improvements Needed:
• Adopt the Critical Aquatic Refuges identified in Alternative C to protect areas of high biodiversity and aquatic/riparian species that are at-risk.
• Adopt a standard that does not allow management actions, e.g., grazing, to impede the recovery of a meadow or other special aquatic feature.
• Adopt Alternative C to eliminate grazing in meadows that are degraded, poorly functioning, or that sustain at-risk species.
• Remove standard that allows 20% of a fen to be disturbed and eliminate grazing and other human-caused disturbance from seeps, springs, fens, and other special aquatic features.
• Adopt Alternative C to increase the number and acreage of meadows improved or restored.
What's Good: The draft plans recognize the importance of high quality forest recreation and the need for sustainable recreation opportunities that can be maintained into the future without harming the land. The draft plans recognize changes in use of recreation on the forests and the need for partnerships to sustainability manage recreation. In an attempt to better address emerging recreational interests, the plans also revise the Recreational Opportunity Spectrum.
Significant Improvements Needed:
• Provide quantifiable visitor use levels for each type of recreation and projections of how these levels would be affected by declining federal budgets.
• Include plan components, beyond desired conditions, to assure adequate protection and maintenance of national forest recreation areas.
• Better integrate recreation to other aspects of the plan such as fire and ecological integrity.
• Provide direction to improve education and interpretation so that all visitors better understand how to enjoy the forest responsibly.
• Commit to more robust partnerships with local communities, conservation groups and others to help achieve desired conditions for recreation.
• Improve Recreational Opportunity Spectrum (ROS) understanding by providing more detailed maps, including standards and guidelines for the management of each ROS allocation, and by adjusting some primitive and non-motorized boundaries to better protect inventoried roadless areas.
• Identify and address different seasons of recreation in the plan, including differentiating between summer and winter ROS. This can help lay the groundwork for winter travel planning.
For more information about Wilderness and Wild & Scenic Rivers, contact Steve Evans at CalWild at firstname.lastname@example.org or (916) 708-3155. For more information about Fire Management, Old and Early Forests, Wildlife Species at Risk, and Aquatic and Riparian Ecosystems, contact Jamie Ervin at Sierra Forest Legacy at email@example.com or (828) 403-0418.
June 28, 2019
The Sequoia and Sierra National Forests have released their draft forest plans and revised draft environmental impact statement, initiating a 90-day public comment period closing on September 26, 2019. Earlier versions of these draft documents were released in 2016. The agency has revised the draft documents to address changed conditions across the landscape, including extensive tree mortality, and other concerns brought up through public participation (see below).
The Forest Service will host a webinar on July 10 from 12-1:30 (Pacific) to provide an orientation to the planning process and draft documents available for review. Register here.
April 9, 2018
Read the SFL coalition's letter to the Sierra and Sequoia National Forests' supervisors, in support for protection of roadless areas and priority Recommended Wilderness Areas. The letter summarizes the culmination of many meetings with a variety of people and groups with an interest in conservation of the Sierra Nevada, and working out possible conflicts with other user groups. It is a refinement of our earlier recommendations, both in 2016 and 2017, and more clearly defines five highest priority areas for recommended wilderness areas as well as areas we suggest for backcountry management areas (BMAs).
June 16, 2017
Read a summary of our coalition comments on forest plan components and content that we think are important to include in the revised draft forest plans for the Sierra and Sequoia National Forests. This is a summary of comments submitted in August, 2016 (see below).
August 25, 2016
At the links below, download and read our coalition comments on the draft EIS and forest plan revisions for the Sequoia, Sierra, and Inyo National Forests. This was a huge effort made possible because of the deep commitment, dedication, and expertise of a crack group of core activists on our team. Thousands of pages of (frequently highly technical) documentation had to be carefully read through, vetted, and analyzed in order to identify the many problem areas in the agency's management plans.
Sadly, the DEIS and plans are a big disappointment, and we know the Forest Service can do--and should have done--better. Because of the many omissions and inaccuracies, we have asked for a revision or supplement to the draft plans. In many instances, the findings of leading scientists in their fields, as well as the agency's own scientists, were ignored or simply left out. Further, the massive tree mortality event now taking place throughout the Sierra Nevada, but most notably in the southern end of the range, due to drought and bark beetle epidemic, was not addressed at all--not even mentioned.
The agency has utterly failed to produce a scientifically credible representation of the environmental conditions of the region.
The first link below takes you to the Sierra Forest Legacy coalition's main comment letter, followed by four attachments containing exhibits I -XII. Part 2 lists the attachments.
Part 1. Main comment letter (4.3 MB)
Part 3. Exhibits VIII - IX (8.7 MB).
Part 4. Exhibit IX - XII (Maps (10.7 MB).
Part 5. Exhibits XII (continued) (4.4 MB)
May 19, 2016
The Forest Service has released the draft forest plan revisions and draft environmental impact statements for the Inyo, Sequoia, and Sierra National Forests. The documents can be accessed at this website. The official 90-day timeline for submitting comments to the agency is determined by the publication date in the Federal Register, May 27, 2016; comments must be received by the agency by August 25, 2016. Instructions for submitting public comments electronically are found on the website, or click here. There will also be several opportunities to participate in discussions with the Forest Service at public meetings, and comments may be submitted directly there.
The meeting places and times are posted here.
The Sierra, Sequoia and Inyo’s plan revisions are being completed with a single environmental impact statement (EIS). The final EIS will result in three separate Record of Decisions and three separate forest plans. Forest Supervisors will remain the responsible official for making decisions on their specific forest plan.
To learn about other on-going forest resource activities, not related to new forest plan revisions in the Sequoia National Forest, follow this link.
Below, you can read the comments and letters we've provided recently to the Forest Service relating to the three early adopter (Inyo, Sequoia, and Sierra National Forests) plan revisions.
February 1, 2016 Comments on draft list of Species of Conservation Concern
February 1, 2016 Wilderness Evaluation Process and Areas Identified for DEIS Analysis
February 1, 2016 Comments on Wild and Scenic River Evaluation
October 30, 2014: Comments on Wilderness Evaluation Process
September 29, 2014
Today Sierra Forest Legacy and our coalition partners submitted scoping comments on the NOI for forest plan revisions for the Inyo, Sequoia, and Sierra National Forests. Coalition partners included American Rivers, California Native Plant Society, California Wilderness Coalition, Defenders of Wildlife, Friends of the River, Mono Lake Committee, Pacific Rivers Council, Sierra Club, Western Watersheds Project, and the Wilderness Society.
The following five files were part of the comment package and can be downloaded here:
August 29th, 2014
Today the Federal Register published the Forest Service's Notice of Intent to prepare an environmental impact statement for the joint forest plan revisions for the Inyo, Sequoia, and Sierra National Forests. Download the NOI here, and review all of the scoping materials and maps at this FS planning website for the three early adopter Sierra Nevada forests. The draft EIS and plan is expected to be completed in the Spring of 2015; the revision is expected to be completed in the Spring of 2016. Comments from the public will be accepted until September 29, 2014.
Click here to go to the FS planning website to download all the documents.
May 20, 2014
The Forest Service announced today that they have completed a revised Need for Change document. They will be now be hosting public workshops to mark the beginning of National Environmental Policy Act (NEPA) process of forest plan revisions for the Sierra, Sequoia and Inyo National Forests. Additional information about the meetings is available at this Forest Service planning website.
Meetings in January focused on the emphasis areas outlined in the Preliminary Need to Change document from each Forest's Assessments that will inform the Land Management Plan revision.
The Sierra, Sequoia and Inyo forest plan revisions will be completed through the development of one environmental impact statement. The final EIS will result in three separate Records of Decision and three separate forest plans. Forest Supervisors will remain the responsible officials for making decisions on their specific forest plans.
December 30, 2013
The final Forest Assessment has been completed for the Sequoia National Forest. A workshop for the public to discuss the assessment, forest plan revision, and the "Preliminary Need for Change" document will be held on Tuesday, January 28, 2014, from 5 to 9 pm, at the Double Tree Hotel, 3100 Camino del Rio Ct., Bakersfield, CA 93308. For more information, contact Cody Norris at 760-376-3781 or firstname.lastname@example.org.
October 16, 2013
Download and read our coalition's comments on the Draft Sequoia National Forest Assessment.
September 10, 2013
The Sequoia National Forest has completed the draft forest assessment that will be used to inform the forest plan revision. Comments from the public will be accepted until October 16, 2013. Download the draft assessment at the agency website.
Contact Maria Ulloa-Cruz for any questions or comments concerning the forest plan revision process for the Sequoia NF, at 559-784-110, ext. 1160, or at mtulloa<AT>fs.fed.us.
A fundamental principle in the planning rule is a commitment to utilizing the latest science. In Region 5, a Science Synthesis team was convened to summarize the most relevant new findings from recent (last 10-12 years) scientific literature on social, economic, and ecological issues across the Sierra Nevada. The Science Synthesis is now available, download it here.
The Draft Sierra Nevada Bioregional Assessment is now available. The purpose of the assessment is to provide broad, landscape-level information that will inform all forest plans throughout the region. Comments and information can be added directly to the document at the Living Assessment interactive website. The Bioregional Assessment addresses the 15 topic areas that the planning rule requires each forest to address and incorporated information from the agency, the public, and the Science Synthesis.
Draft topic papers for the Sequoia NF are currently available for public review until July 31, 2013. The planning rule requires assessment of the following fifteen components:
1. Terrestrial & aquatic ecosystems, and watersheds
2. Air, soil, water
3. Systems drivers (e.g. ecological processes, disturbance regimes and stressors)
4. Baseline assessment of carbon stocks
5. T & E, proposed & candidate species, & potential species of conservation concern in the plan area
6. Social, cultural, and economic conditions
7. Ecosystem services
8. Multiple uses
10. Renewable & nonrenewable energy and mineral resources
12. Areas of tribal importance
13. Cultural and historic resources and uses
14. Land status and ownership, use, and access patterns
15. Existing designated areas within the plan area (e.g. Wilderness , etc.)
In addition, the new forest plan will also contain these required components:
- Desired Conditions
- Suitability of Uses
- Other plan content such as:
- Distinctive Roles and Contributions
- Management Areas - Zones - Geographic Areas
- Recommended Areas (e.g., Wilderness, Wild & Scenic Rivers)
- Priority Watersheds
- Monitoring Program
March 23, 2012
The Forest Service announced today the finalizing of the new forest planning rule. According to the agency, no significant changes were made from the draft rule published in May, 2011, however, clarifications were made for important issues, such as the use of the best available science. You can read the rule here, or at the Forest Service planning rule website, where you will also find a summary, FAQs, and additional information and documents pertaining to the rule.
Read the Forest Service press release announcing the final rule here.
Although there was widespread support for retention of the strong viability rule language from the 1982 version of the rule, no such viability rule now exists for wildlife. However, because of the strong commitment to utilizing the best available science, we believe that the new rule can be equally as protective for wildlife viability and biological diversity, if commitments for monitoring and adaptive management are kept. Public participation in new forest management plan development will be essential to ensure that these commitments are met, and that national forest management continues to evolve along with our increased scientific knowledge.
If we are to sustain the biological treasure that is the Sierra Nevada for posterity, we must take seriously the threats of climage change and loss of habitat and ecological processes that face the national forests of our mountain range. Sierra Forest Legacy's Conservation Strategy, along with GTR-220, An Ecosystem Management Strategy for Sierran Mixed-Conifer Forests, and the latest companion technical report, GTR-237, Managing Sierra Nevada Forests, are the right tools we will need to get off to a good start for forest planning in California.
January 26, 2012
Today the USDA Forest Service announced the release of the Final Programmatic Environmental Impact Statement (FPEIS) for the 2011 Planning Rule. In addition, the agency announced that three forests (the Inyo, Sequoia, and Sierra NFs) in California will be among the first nationally to implement the new rule in the process of revising their current forest plans as required under the National Forest Management Act, NFMA (forest plans must be revised every 15 years). Read more about this history and the current planning rule on the NFMA section of this website.
It is likely that all of the forest plans currently due for revision in California will be revised in accordance with the new rule, which will be finalized in early 2012. We are fully engaged in leading a coalition of conservation groups throughout California in developing a conservation strategy for the 11 national forests of the Sierra Nevada that will ensure long term protection and conservation of the Sierra Nevada's unique and priceless biological heritage, and we will continue to be actively engaged with the Forest Service throughout the collaborative process set out in the new rule.
Due to the efforts of the Bush Administration in dismantling the 1982 forest planning regulations and replacing them with a watered down 2005 planning rule revision, National Forests throughout the Sierra Nevada came under serious threat of losing the key conservation provisions of the National Forest Management Act. The Forest Service sought to advance the plan revision process under a categorical exclusion from NEPA, or environmental analysis of possible significant impacts from new management directions. That would virtually eliminate public oversight of management of our public lands, and greatly erodes the long-standing NEPA process of environmental review. This, along with the administration's decimation of the conservation-focused 2001 Sierra Nevada Framework with its 2004 Framework revision, could leave the National Forests of the Sierra Nevada at risk of losing the amazing attributes that make them such unique global watersheds, recreation destinations, and significantly important ecosystems -- or at the least, leaving them significantly diminished.
In March, 2007, a court decision reversed the Bush administration's 2005 planning rule. In April 2008, however, the Planning Rule was released virtually unchanged, in spite of tens of thousands of comment letters opposing the revisions. Subsequently, the rule was found to be unlawful and overturned in federal court in June of 2009. Since then, the Forest Service has been developing a new rule and the accompanying environmental impact statement.
Today we are working with a coalition of national conservation groups to provide the agency with a unified, comprehensive vision for science-based management of our national forests that will ensure their long term stability in the face of global climate change, and protection for rare and imperiled plants and wildlife. Click on this link to go the Conservation Strategy website.