Stanislaus National Forest
Groveland and Mi-Wok Ranger Districts, Tuolumne and Mariposa Counties
January 11, 2016
Today we provided recommendations to the Stanislaus NF in response to the DEIS released in November. We recommended that the agency select Alternative 4, the only alternative of the five offered that is based on current ecological science. In addition, we asked that the following changes be incorporated into the chosen alternative:
- Lower the maximum number of trees planted on any site to 150 trees per acre.
- Lower the required stocking levels for naturally regenerating stands to 50 conifer trees per acre or more of any species or mixture of conifer species.
- Remove the individual tree spacing requirement when thinning existing plantations and develop a prescription that allows for variable spacing and a true ICO approach.
- Minimize the use of herbicides for controlling native vegetation to the maximum extent practicable.
Download and read our coalition comment letter here.
November 27, 2015
The Stanislaus National Forest released the draft EIS for Rim Fire activities today. The proposal includes "about 48,000 acres of treatments on NFS lands within the 2013 Rim Fire including: deer habitat enhancement; natural regeneration; noxious weed eradication; reforestation; and, thin existing plantations. The DEIS discloses the direct, indirect and cumulative environmental effects that would result from the proposed action, a no action alternative and three additional action alternatives."
April 13, 2015
With stunning lack of regard for the lessons of the past, for scientific credibility, or for accountability to the American taxpayer, the Stanislaus NF has prepared a reforestation proposal that threatens to repeat the exact type of failed silvicultural practices that facilitated the Rim Fire destruction. The agency proposes re-planting the failed plantations, at a likely cost of millions of dollars, and to use intensive toxic herbicide applications to kill the natural forest re-growth on the premise that a natural forest can't grow back on its own without an intervention; and despite the evidence from multiple scientific sources that such unnatural intrusions are not necessary. Download and read our comments on the proposal here.
August 28, 2014
Today the Forest Service released the Record of Decision for their plan to log the Rim Fire region on the Stanislaus National Forest adjacent to Yosemite National Park. The final environmental impact statement was also released at the same time. This is the culmination of many months of negotiations with the agency and industry leaders, multiple collaborative workshops, and planning sessions. Despite all the efforts and money that was spent to effect a sensible, science-based decision, the agency's final decision suggests that agency commitments to the "best available science" and ecological integrity continue to be largely lip service.
The agency proposes to log approximately 33,081 acres of the 154,000 acres that burned. An additional 27,000 acres of burned forest cover will be removed through various other means besides whole log removal. This means that approximately 60,000 acres will be cleared, settting the stage for the identical reforestation tree planting regime that followed previous fires in the region, and which scientists have cautioned against because of the heavy fuels hazards that such plantations present, and adverse effects on natural succession and species composition.
We are gratified that the amount of Black-backed woodpecker habitat that will be logged was reduced in the decision, preserving 10,437 acres of high value habitat. However, research scientists recommended retention of much more acreage--75% of the approximately 30,000 acres of habitat needed to support the 42 pairs predicted to occupy the burned forest. Implementation of the project based on the final decision will eliminate approximately 50% of those birds.
The decision also did not address "early seral" or "early successional" forest habitat in the entire document, a testament to the fact that the agency has not integrated the latest scientific research regarding the importance of post-fire forest habitats that have not been logged or planted.
As proposed, this project cannot pretend to contribute to restoration of the natural composition and ecological processes that result in healthy, biologically diverse forests over time. As we have quoted time and again, "Salvage logging will rarely, if ever, contribute in a direct or positive way to ecological recovery; generally it can be viewed as a tax on ecological recovery" (Lindenmayer, Burton, and Franklin 2008). To pretend otherwise is irresponsible, with serious consequences for future fire resiliency and the impact of climate change in the region. Rather than restoring anything, the project will result in erecting roadblocks to successful evolutionary adaptive processes and the survival of species.
June 16, 2014
Today we submitted our comments on the Draft Environmental Impact Statement for the proposal to "salvage log" approximately 30,000 acres of the burned forest.
As discussed in our earlier scoping comments, we seek the adoption of a science-based alternative for the Rim Recovery Project that is congruent with the current state of the science regarding the adverse impacts of salvage logging upon post-fire habitats with high ecological value. We also expect alignment with the Regional Forester’s leadership intent on ecological restoration, and national policy goals for ecological integrity, restoration, and commitment to use of the best available science. We find that the Proposed Action (Alternative 1) is overly focused on the recovery of economic value from burned timber with an insufficient focus on actions that are of ecological benefit.
The high value that post-fire landscapes contribute to biological and ecological diversity prompted us to promote and co-host a series of technical field trips and a workshop to develop recommendations for accomplishing ecological restoration in this post-fire landscape. We are disappointed that recommendations developed at the workshop were not included in the DEIS or were dismissed out of hand.
Ecological recovery goals embrace biological diversity, represented in the Rim Fire landscape by early-seral habitat, legacy trees, healthy wildlife populations, and resilience to a changing climate and fire regimes.
May 16, 2014
The Forest Service announced today that the draft EIS is now available and the agency will accept comments from the public on the document until June 16, 2014. The agency cut the time for comments to 30 days instead of the normal 45 days. The draft environmental impact statement and all associated documents and announcements are available here.
December 6, 2013
Updated on January 12, 2014. Read Sierra Forest Legacy and coalition comments on the scoping proposal here. Comments were due on January 6, 2014.
The Rim Fire began on August 17, 2013 in a remote area of the Stanislaus National Forest near the confluence of the Clavey and Tuolumne Rivers about 20 miles east of Sonora, California.
Photo above: Rim Fire as seen from near
Crane Flat, Yosemite National Park, June 2014. Photo by Craig Thomas
The fire burned with mixed severity across 257,314 acres including portions of Yosemite National Park, privately owned land, and 154,430 acres of National Forest System (NFS) lands in Tuolumne and Mariposa Counties. It is considered the third largest wildfire in California history. The cause of the fire, as determined by an investigation by the U.S. Forest Service, was an illegal campfire started by a hunter. The extent of the harm to native wildlife and native plant populations is currently unknown, but devastating impacts are obvious due to the extent of the acres burned. Many of the previously installed tree plantations in the area were completely consumed.
The Forest Service has prohibited public access to the burned areas until November 18, 2014.
On December 6, 2013, the agency released a notice of a proposal to "salvage" log approximately 30,000 acres of the Rim Fire's burned forests, including logging in remnant stands of old forest. The agency also plans to improve 327 miles of roads, install 6 miles of new permanent roads, and 22 miles of temporary roads, actions that are necessary to facilitate the logging project. Logging is due to commence in the summer of 2014.
Salvage logging is the term used by the Forest Service in the Rim Fire EIS to describe the expedited harvest of trees after wildfire, in order to recover the commercial value of the burned trees. Many forest ecologists today object to the use of the term, because it implies that the only value of the forest is economic — a view that may apply to corporate owned timberlands, but is not appropriate for publicly owned national forest lands. A less value-laden terminology recommended by modern forest ecologists is "post-fire logging" or "post-disturbance logging."
The Forest Service also uses the term "recovery" to imply not only recovery of lost economic value, but to suggest that post-fire logging promotes recovery of the forest ecology. But in the view of scientists, this is not the case. A recent literature review and summary of the science and policy issues surrounding post-fire logging found that such logging is actually a net "tax" on recovery of forest ecosystems, and may have long lasting, irreversible consequences for forest health and ecological processes (see Lindenmayer et al 2008). This may be especially true for California's unique, dry interior forests of the Sierra Nevada, where forests do not grow back quickly and drought is expected to increase. Whatever benefits may accrue from fire, such as the creation of snags that many species require in their life history (for example, the black-backed woodpecker) they are effectively erased by logging activities and the subsequent reforestation that inevitably follows.
If fire is the re-set button for forest development, then the Rim Fire is an opportunity to permit the forces of natural processes to rebuild the forest. There are many benefits from fire: the reduction in dense forest fuels that give rise to fires like this one, the creation of valuable snags and down logs that are necessary for the survival of hundreds of species of plants and animals, and the release of nutrients that will nurture the next forest for decades. And while the loss of hundreds of acres of monoculture pine tree plantations is a loss of investment and labor for many, their erasure may be a plus for forest ecology, fire resiliency, and the many forest species that are dependent upon the early successional forest structure that was eliminated during the installation of pine plantations (for example, the shrubs and hardwoods).
Sierra Forest Legacy has advocated for a science-based forest and fire management policy for over two decades, and with the growing threat of climate change, the need has never been more urgent. Scientists have known for over half a century that, in forest ecosystems that have evolved with regular and frequent fire return (5 - 30 years), industrial scale logging has resulted in forests that are overly dense with young forest regrowth, a structure that is abnormally preserved with the use of modern fire suppression forces. While we cannot get back the vast tracts of fire-resilient old-growth forests in our lifetimes, we can put into place policies that can insure that the possibility of their return exists, along with all the other biologially rich forest stages and species that should normally occur. And that is exactly what is required by the laws and current policies of our nation.
Young regrowing forests would normally be modified by regular fire return. In a natural system, clumps of old growth trees survive fire in mosaic patches, and the forests contain a rich variety of age classes and species composition — including young forest (early succession) shrub and hardwood communities. Cumulatively, the loss of fire-resistant old growth forests, industrial logging and plantation forestry, along with fire suppression have created forests that are unnaturally dense and ripe for catastrophic fires like the Rim Fire. We hope that the Forest Service will not repeat the unprecedented logging and tree planting that followed the 1987-Complex Fires in the same region. The current Rim Fire Recovery Project suggests that is exactly what the agency is planning to do, with some moderation.
As the preeminent fire ecologist Jerry Franklin stated, in testimony to Congress in 2005,
"Rapid re-establishment of extensive tracts of dense coniferous forests is not appropriate for many other ecological values, however. First of all, it is clearly inappropriate to establish dense plantations of conifers on sites that have been subjected to uncharacteristic stand replacement fire as a result of uncharacteristic fuel accumulations—many of our pine and dry mixed conifer forests, for example. By creating such plantations we are simply creating the conditions—the fuel--for the next uncharacteristic stand-replacement fire!"
Read more about the effects of post-fire logging and salvage logging here.
Link to Forest Service website for the project.
DellaSalla, D. et al. 2013. Conservation science perspective on complex early seral forests: what are they and how to manage them in the Sierra Nevada ecoregion. Comments submitted to the Forest Service for early adopter forest plan revisions.
Lindenmayer, D.B., P. Burton, and J. Franklin. 2008. Salvage Logging and Its Ecological Consequences. Island Press.
North, M. et al. 2009. An Ecosystem Management Strategy for Sierran Mixed-Conifer Forests. Gen. Tech. Rep. PSW-GTR-220. Albany, CA: U.S. Department of Agriculture, Forest Service, Pacific Southwest Research Station. 49 p.
U.S. Forest Service Documents