Sierra Forest Legacy Newsletter


In this Issue:

Newly Revised Forest Plans for Sequoia and Sierra National Forests

Comments Needed by September 26, 2019


In the News -- Fire

LA Times: "Forest thinning projects won’t stop the worst wildfires. So why is California spending millions on them?"




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The Sierra Forest Voice Newsletter

The Sierra Forest Voice

Web Edition
Vol. 12, No. 3, September 16, 2019


Newly Revised Forest Plans for Sequoia and Sierra National Forests
Your Comments Needed before September 26, 2019

This is an abbeviated version of The Sierra Voice, as we focus on the new forest plan revisions for the Sequoia and Sierra National Forests. These plans will likely guide management policy for the forests for decades to come. The article below is a recap of the Action Alert we sent out on Tuesday, September 10. We’ve added some links, background, and historical contextual information. If you haven’t ever been through this process, it can seem daunting. We hope you’ve had a chance to review the plans and to craft a letter to the Forest Service that is uniquely shaded by your own experiences and knowledge. If not, there is still time to provide your comments to the agency. 

If you prefer to go straight to the electronic comment submission form, click here. Comments must be posted by Thursday, 9/26/2019.  

You can also submit comments by email to:

Or by regular mail to:
Planning Team Leader, Forest Plan Revision, 1323 Club Drive, Vallejo, CA 94592.

On June 28, 2019, the Sequoia and Sierra National Forests released new draft forest plans and the accompanying joint draft environmental impact statement, initiating a 90-day public comment period that closes on September 26, 2019. 

Planning Process History

In January, 2012, the USDA Forest Service announced that three forests (the Inyo, Sequoia, and Sierra NFs) in California would be among the first nationally to implement the new planning 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). In August, 2014, the agency announced in the Federal Register the notice of intent to prepare an environmental impact statement for the plan revisions for the three forests. This kicked off the scoping process for developing new forest plans for the three national forests. Scoping is a requirement of the National Environmental Policy Act, NEPA. While NFMA describes what forest plans have to cover, NEPA spells out the specifics of how possible environmental impacts that may occur as a result of implementation of the plan are disclosed. NEPA requires that there be an early and open process for determining the scope of the issues to be addressed by a study. This process is commonly known as “NEPA scoping,” during which an agency will solicit input from the public.

For an excellent discussion of the process, download A Citizens Guide to the NEPAHaving Your Voice Heard  published by the Council on Environmental Quality (CEQ) in 2007. There is a flow chart on page 8 that is very helpful to see the process in total. 

You may also want to check out all the links in the Forest Planning Regulations pages on Sierra Forest Legacy’s website.

With the scoping process completed, the first draft planning documents for the Sequoia and Sierra National Forests were released in May, 2016, but the plans were quickly withdrawn due to emergence of a problem that the plans had not even addressed:  the massive numbers of trees dying in the central Sierra from bark beetle infestation. During the re-draft, the agency also responded to additional concerns and input from our coalition, and the new draft reflects this. We have put together a summary of the changes that have been made, highlighting the positive “What’s Good” in the plans, and also pointing to the key issues that need further resolution. We believe these are the issues that are the most important to address during the open comment period.  

Key Issues in the Sequoia and Sierra Revised Draft Forest Plans

In the Revised Draft Environmental Impact Statement (RDEIS), four alternatives (A-D) for management are compared. The new forest plans are referred to as “Alternative B," the agency’s preferred alternative. However, the Sierra Forest Legacy coalition supports and recommends “Alternative C,” which includes recommendations for expanded wilderness protection,  more acres of forest restored through prescribed and managed fire, and more riparian and meadow restoration than Alternative B.

Wilderness Recommendations

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).

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.

Fire Management

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.

Improvements Needed:
• 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.


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 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 or  (828) 403-0418.

Additional information is available on several Forest Service websites. Each site contains unique links to staff contacts, historical documents, FAQs, etc. If you have the time, you can work your way through all of these links:

This is the introductory site with additional links to news items and contacts. On this public outreach page, you can view videos of public meetings and webinars hosted by the Forest Service to inform and receive feedback from the public about the draft plans. From this site you can download the current and past documents, and link to the public comment page. You can also link to the public comment and objection reading room from here.  

If you prefer to go straight to the electronic comment submission form, click here. Comments must be posted by Thursday, 9/26/2019.  
You can also submit comments by email to:
Or by mail to this address: Planning Team Leader, Forest Plan Revision, 1323 Club Drive, Vallejo, CA 94592.

Additional resources: 
Click here for a printable version of the Sierra Forest Legacy coalition’s summary of key issues and recommendations.
To read more about this revision and to read supporting documents from our coalition, click here. Get all the documents going back to scoping in 2014, here
Learn more about the history and background of NFMA and the planning rule change that occurred in 2015.
Go back to 2008, when we announced the start of this cycle eleven years ago in The Sierra Voice, click on this link.  

A Partial History
We’ve compiled a sampling of historical links relative to these plan revisions. 
2012 Final Programmative EIS for New Planning Rule 2012
2012 National Forests in the Sierra Nevada: A Conservation Strategy. Sierra Forest Legacy releases a science-based Conservation Strategy to help inform Forest Service planning for the SN forest plan revisions. Link here for more information. .
2013 First Phase of the Forest Planning Process Announced March 2013
2014 Lawsuit Settlement Agreement Includes Key Requirements for Inclusion in New Forest Plans October 2014   Also see FS Press Release here, and The Sierra Voice here.  The settlement agreement required the FS to create conservation strategies for the Pacific fisher and the California Spotted owl, create a Fire Partnership MOU for the increased use of managed fire for ecological benefit, and include forest plan components addressing post-fire, complex early-seral habitat.
2014. Notice of Intent to file an EIS for forest plan revisions. Federal Register, August 29, 2014. Further details of proposed action here.
2014 Inyo, Sequoia and Sierra Forest Plans: The Forest Service is Proposing Changes  The Sierra Voice September 2014.
2016 Vulnerable Species Not Considered in Forest Plan Revisions The Sierra Voice, March 2016
2016  Forest Plan Revisions – They’re Here. First draft released for forest plan revisions for the three early adopter forests (Inyo, Sequoia, and Sierra National Forests. The Sierra Voice, June 2016.
2018 Southern Sierra Roadless Proposal. The Sierra Voice, June 2018. 

In the News – Fire

The LA Times recently published an article "Forest thinning projects won’t stop the worst wildfires. So why is California spending millions on them?" by Bettina Boxall and Jon Schleuss. The article was well presented graphically and while the story is factually correct, the take home message--extrapolating from recent extreme fire events that fuel thinning in forests is not effective and not worth the expense--is simply not supported by the science.

This issue continues to be contentious even in the face of overwhelming data collected over decades, supporting the value of forest thinning, when  followed by prescribed fire to restore resiliency and reduce  fire intensity and destruction, in the fire-adapted forests of the Sierra Nevada. At the same time, under extreme “perfect storm” conditions of drought, weather, wind, and location, fires can be unstoppable regardless of the fuel treatments. Fire science and fire ecology are complex topics, and it should be stated up front that there is no either/or, black and white solution or answer to the issue of how best to ameliorate the effects of the increased fire hazards in the state. Innumerable variables are at play during a wildfire event. It would seem that  acknowledging this is a better place to begin the conversation, rather than pointing fingers.

At the same time, actions taken to protect private lands and homeowners require a different set of assumptions and solutions than actions proposed in wildlands, far from homes, where fire resiliency is the goal to protect the integrity of the forest ecology and to conserve biodiversity. These two issues of location (Sierra Nevada forests, versus Southern California chaparral communities; and National Forest locations far removed from homes, versus homeowners’ and other private lands and WUI locations) are frequently conflated in news coverage.

Perhaps this is partially due to some in our conservation community who would like to find justification for hands-off management in our National Forests; but whatever the case, the issue continues to fuel the fire of controversy both inside our conservation community and among policy makers. 

Savvy readers must become familiar with a host of new concepts and vocabulary—a difficult task  for the media as well, but necessary to accurately present conflicting ideas. This issue is not that different from climate change: deniers want to embrace science when it improves their daily lives, but reject science when it doesn’t suit their agenda.

For some perspective, we offer this blog from the Fire Learning Network website, “Fuels Treatments Aren’t a Guarantee, but They Still Matter: Gaining Perspective from the Carr Fire,” by Eamon Engbar, National Park Service. 

And to follow up, check out this slide presentation from the fall meeting of the Northern California Prescribed Fire Council, “Fuels Treatments Effectiveness:  Gaining Perspective from the Carr Fire in an Era of Megafires.” Presentation by Eamon Engbar, National Park Service and Forest Service; and Jennifer Gibson, Whiskeytown National Recreation Area.

From the homeowner's perspective, you may also want to read Why the Ferguson Fire Didn’t Destroy Yosemite West: 15 Years of Wildfire Mitigation Generates a California Wildfire Success by John Mock and Kimberly O’Neil.

In addition, the Sierra Forest Legacy fire science webpages have many published, peer-reviewed science papers you can download. You will not find anything that claims a perfect solution to the dilemmas facing us; but overall, the data support the use of thinning and prescribed fire as valuable tools to protect and conserve forest integrity in the hands of knowledgeable practitioners. Home hardening is also necessary for private lands, and we have been highlighting the research science of Jack Cohen and others for over a decade.

Read Forest thinning projects won’t stop the worst wildfires. So why is California spending millions on them? by Bettina Boxall and Jon Schleuss, LA Times, September 11, 2019.



Symposium: Climate Change and the Ecology of Sierra Nevada Forests Friday Sept 20 and Saturday Sept 21, 2019

University of California,  Merced
Co-Sponsored by The Sierra Nevada Research Institute and Western North American Naturalist. This symposium will focus on the responses of Sierra Nevada forest organisms and ecosystems to increasing climate stresses. Session topics include:
- Fire
- Wetlands
- Fauna
- Conservation and Management
- Climate Change and Tree Mortality
- Seedlings and Herbaceous Plants
- Soils and Nutrient Cycling
For more information and to register, click here


Annual Meeting of the Southern Sierra Prescribed Fire Council, November 6-7, 2019

SAVE THE DATE! Annual meeting of the Southern Sierra Prescribed Fire Council. The meeting on November 6 will be held at the Central Sierra Historical Museum in Shaver Lake. November 7 will be a field trip to see prescribed burning on Southern California Edison forest lands. Download a flyer at the SSPFC website. There will be a prescribed fire workshop on November 5th and 6th, see note below, and register here.


Five Upcoming Prescribed Fire on Private Lands Workshops this Fall

All the information you need including the links for registration can be found at the University of California Forest Research and Outreach prescribed fire workshop website. Sign up soon as space is limited. Cost for each workshop is $30 for the one day workshops, and $60 for the two day ones.

October 8th, 2019: Ambulance, Fire and EOC Facility, 18440 Striker Court, Sonora, CA
October 10th, 2019: American Legion Hall, 11401 American Legion Drive, Sutter Creek, CA
October 18th and 19th, 2019: UC Berkeley Forestry Camp, 8091 Schneider Creek Rd, Meadow Valley, CA 95956.
November 5th and 6th, 2019: Central Sierra Historical Museum, 42642 Tollhouse Road, Shaver Lake, CA 93664.
December 13th, 2019: Chico State University’s Big Chico Creek Reserve, 3521 14 Mile House Rd, Forest Ranch, CA


TREX Fire Training Workshops Sponsored by Terra Fuego

TREX (TRaining EXchange) fire workshops are for fire professionals, or those just entering into the profession, and are designed to build capacity for prescribed fire and landscape management for fire resilience. These dates are for TREX in the Yuba-Nevada Counties area. For further information, contact Stephen Graydon, You must register before September 27, 2019 to ensure a space, participation is limited.
October 12-14: NWCG training 0800-1630
October 19-20: Field days 0800-1700
November 1 – 27: Estimated date range of prescribed burn.

Learn more about TREX at The Nature Conservancy's Conservation Gateway for TREX.


Wildland Fire Book List for Young Readers

Just in time for the end of year holiday season, the Fire Adapted Communities Learning Network has a created a “wildland fire book list” for kids. It's a great list of books for young readers from pre-school to young adults--and beyond.

The list includes one of our favorites, The Charcoal Forest by Beth Peluso, that we reviewed here in The Sierra Voice in 2012. The story is based on the fire ecology of the Rocky Mountains. We posed the question then:   If the book was based in the Sierra Nevada, what species would you include?  Wouldn’t it be great if someone created a similar book for children for our region? Hopefully it would not spark the kind of controversy that discussions about our fire regimes here seem to engender! Of course we are hoping that some creative individuals out there will be inspired to write this book....


National Environmental Policy Act Regulations Rewrite Redux

August 26, 2019 was the deadline for the public to weigh in on a controversial proposal by the U.S. Forest Service to re-write the regulations implementing the National Environmental Policy Act (NEPA) for our national forests. Across the U.S., citizens had much to say on the subject. Read a sampling of the letters submitted to the agency, and our coalition letter here.


New Science: Red Fir and Subalpine  Ecology in the Sierra Nevada

A new technical publication released by the U.S. Forest Service concludes that “fire frequency and severity, moisture stress, the incidence of pathogens and insects, and tree mortality rates are projected to increase and likely exceed the NRV with climate change” in both red fir forests and subalpine forests in the Sierra Nevada. The authors concluded that there is likely to be a substantial loss in suitable habitat in red fir and subalpine forests in the Sierra Nevada bioregion by the end of the 21st century, as a consequence of climate change.
Download the report here.

Citation: Meyer, Marc D.; North, Malcolm P. 2019. Natural range of variation of red fir and subalpine forests in the Sierra Nevada bioregion. Gen Tech. Rep. PSW-GTR-263. Albany, CA: U.S. Department of Agriculture, Forest Service, Pacific Southwest Research Station. 135 p.




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Help Protect Our Sierra Nevada Forests

The work we do to protect the forests, with all of their unique and rare plants and animals, and the many wild places of the Range of Light cannot be done without the generosity of our supporters. Please help us to keep up our efforts. You can make a safe and secure donation from this website. Thanks to all who have so generously supported our work - together we form a multitude of voices. Join us in saying, "Si, se puede" on behalf of the wild forests of the Sierra Nevada.   

"A thing is right when it tends to preserve the integrity, stability, and beauty of the biotic community. It is wrong when it does otherwise."
~Aldo Leopold

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