05/01 Update: This sale has been stopped by the Rothstein ruling upheld by the 9th Circuit Court.
03/00 Update: Christopher Folly returned to BLM by IBLA. Umpqua Watersheds wins appeal.
10/99 Update: This was found to be illegal by federal court on 9/30/99.

Christopher Folly Timber Sale
Clearcutting in the Key Watershed of Canton Creek

BLM is proposing to clearcut 215 acres in the watershed of Canton Creek, selling over 2,500 logging trucks (12.7 mmbf) of irreplaceable ancient forests. (Unit 8 pictured on right.)

This could be one of BLM's worst timber sales of 1998. It is all "regeneration harvests," the federal government's Orwellian term for Clearcuts. It proposes to wipe out rare plants and threaten rare animal species and a popular recreation area. All this is on unstable soils, in an already degraded watershed classified a Key Watershed for saving our imperiled fish.

Key Watersheds, as defined by the Northwest Forest Plan, are supposed to be top priority for restoration of watersheds feeding endangered fish habitat. Steamboat creek, along with its tributary, Canton Creek, was selected as a "Key Watershed." Even though huge clearcuts degrade the watershed by allowing faster runoff of water and greater erosion, in an incredible twist of logic, BLM claims that if they can’t clearcut, they simply won’t maintain the logging roads currently in the area.

It is a form of blackmail. The clearcutting project includes relatively insignificant road repair projects. BLM writes that if they don’t clearcut, "drainage improvements on existing roads ... would not occur." (EA, pg. 11). This will cause "gradual increase of sediment transport and delivery into the streams; primarily due to plugged and collapsed culverts, and also due to rutting of the road surfaces." The no-logging threats continue: "The sediment would be carried via ditches and ruts in larger quantities and longer distances, significantly increasing sediment delivery, especially during rainy periods." This amazing logic has BLM concluding that Not Logging will result in "significant amount of sediment into the streams over time, resulting in negative environmental effects and would degrade stream conditions." (Geotech report, pp. 3-4)

In addition, BLM states that if they did not clearcut this portion of the watershed, "natural processes" such as "fire, windthrow, disease and insects, and landslides" would take it anyway (EA pg. 11). The timber industry expects to be able to clearcut public forests. They’ve been doing it for so long, they feel they have a right to it. Thus, the old logic is still pervasive in BLM - why let a bug have it, if we could sell it instead? And if we sell it, we must clearcut. BLM states that "Single tree or group selection, partial cutting or thinning were considered," but were rejected because it "retains a substantial amount of the original mature stand" and "reduces the wood volume production" (silviculturist report).

Excuses for Clearcutting: "Insignificant" Road Decommissioning

The three sub-basins containing most of the Christopher Folly sale units (Coon, Scardeman, and Camp Creek) have an average of 6.7 miles of road criss-crossing every square mile. Scientific studies have identified anything over 2 miles of roads to be detrimental to the watershed.

BLM will decommission 2.7 miles of roads, and remove another 1.2 miles of roads from the road inventory because they "decommissioned themselves." The Canton Creek watershed has 273.5 miles of logging roads. BLM is removing 2.7 miles of those roads, or about .01%. This is insignificant when compared with the degrading nature of the large regeneration harvest proposed by Christopher Folly.

Protect the best, restore the rest: The number one rule of conservation biology.

In spite of the degraded nature of Canton Creek, other places are in worse shape. Canton Creek is one of our best places left. The Fisheries Report says that most of the streams within the Christopher Folly units "serve as important contributors of cool water and gravel" to Canton Creek. "Canton Creek is an important watershed for both steelhead and cutthroat," especially summer steelhead. During one monitoring period, Canton Creek appeared to have even better fish habitat than either Rock Creek or Little River. Because imperiled fish depend so heavily on Canton Creek, fishing is prohibited.

In BLM's own assessment of Canton Creek, the watershed analysis, scientists say: "Where canopy has been removed or altered by timber harvesting in Canton Creek, snow pack accumulation is expected to be greater with loss of interception, and heat transfer to the snow would be more efficient, which accelerates melt during a warm rain-on-snow event. This condition has the potential to produce greater water delivery to the soil which could contribute to increased peakflow."

Fish have evolved to bury their eggs to a certain depth in the gravel based on moderate peak flows of the past. But as studies have pointed out, the legacy of past road-building and timber harvest has caused significant and long-term increases in peak storm flow. Higher flows mean higher energy levels, which means greater ability to carry sediment, which means that spawning gravels will be scoured deeper and more often and that sediment will be delivered in different patterns thereby affecting populations of fish and aquatic invertebrates as well as drinking water.

BLM's watershed analysis continues: "Flood peaks, especially the largest floods caused by warm air and rain on melting snow, have accompanied landslides and debris flows in Canton Creek. These large accelerated sediment pulses have impacted the watershed aquatic habitat, water quality, and created chronic winter sediment sources." Christopher Folly will accelerate this even more since 80% of the project is in the transient snow zone which is very sensitive to "warm air and rain on melting snow" events.

In spite of the law, BLM says that clearcutting Christopher Folly "would best meet the land use objectives" that "Cash flows occur now...". BLM never once considered the long-term monetary and ecological benefits of retaining old-growth forests. Instead, BLM puts forth the incredible statement that by clearcutting this forest, "Stand growth and health are maintained." Even more alarming, BLM recommends that "chemical herbicides... will be prescribed at the earliest possible time" in this critically important Key Watershed (Silviculture report).

People use this forest, too.

This timber sale violates the requirement that BLM "visually manage" areas of high recreation use. This is an area (close to Steamboat) that is one of BLM's highest-use recreation areas. Scardeman campground will be surrounded by the proposed clearcuts units within 1/4 mile. In addition to the campground, hunters and other recreationists camp right within one of the most beautiful units to be clearcut (unit 24d, picture at left), where there is a fire ring and parking area. However, BLM says that just a few more clearcuts would go unnoticed by us: "Hunters and other backcountry drivers would notice these cutting units in passing, but since this entire area has a history of logging as evidenced by other cutting units, these additional units would not be remarkable." BLM is wrong. When we return next year to our favorite camping spots, there will be many remarks on their liquidation.


Rare Plants

BLM discovered Nephroma occultum, a very rare lichen, in the units of Christopher Folly. The only other Roseburg BLM location for this truly rare species is in the proposed Cobble Creek timber sale, in the watershed adjacent to Christopher Folly.

The lichen was discovered on a branch that fell out of a very old tree. Even though BLM now knows this area is able to support the lichen, they have decided to still clearcut around the one spot they happen to find. Scientists have determined that saving only the tree the lichen grows on will exterminate it from the area. Since the lichen only grows in trees over 400 years old, it can not continue to live when the forest around it is clearcut every 80 years.

This rare lichen is an important species to save for reasons we aren't even smart enough to know yet. It could be that this lichen feeds nitrogen to tree tops, and contributes to healthy forests and the wildlife that live in them. We have no right to wipe out any species of plant, especially when we have not yet learned it's role in the web of life. Its secrets might be revealed to our children.

Scientists have strongly recommended that for Nephroma occultum, entire areas should be set aside and preserved. The Northwest Forest Plan says that it grows almost exclusively in pristine old-growth forests over 400 years old. This is a very rare lichen, and Christopher Folly marks the extreme south east location of it's known habitat.

Last summer, Roseburg BLM commissioned a team of scientists to study the Cobble Creek lichen site, just six miles west of Christopher Folly. On August 21, 1997, BLM received the results of the study which concludes: "If the goal of management is to maintain N. occultum in the Rock Creek basin over the long term, then Cobble Knob stand should be left intact. This would also help maintain overall lichen and bryophyte diversity in the watershed."

If BLM leaves only a 160' radius circle around one tree that happen to drop a branch containing the lichen, and clearcuts everything else every 80 years, the lichen population will quickly die out of the entire area. It will never be able to re-colonize itself in the older forest habitat it needs, and the one tree in the 160' radius circle will eventually die, taking the lichen with it. This management technique is illegal, not ensuring the lichen's viability, as BLM is required to do. Why would BLM spend the public's money to study this lichen, and then not follow it's recommendations?

It is also against the law for BLM to wipe out the lichen locally. The Northwest Forest Plan says BLM must "Manage Known Sites" for Nephroma occultum . This means that "As soon as the information becomes available, it should be used in the design or modification of activities." BLM was required to modify its activities in the Christopher Folly timber sale when this site was discovered, yet BLM is continuing with the clearcutting, as planned. BLM is simply ignoring the best available science for the management of Nephroma occultum, and clearly violating the law.

Wildlife

How much wildlife will die or be stressed due to clearcutting is hard for anyone to quantify. But one animal we do know about is the Northern Spotted Owl, the indicator species for other wildlife that depend on old forests for their home.

This sale will remove 215 acres of habitat that three pairs of owls now using it for eating and nesting (including the beautiful Sugar Pine trees seen on the right). But elsewhere, in the Late Successional Reserves (LSRs), are the places that BLM has set aside for the owls to live in. Unfortunately, the LSRs in the Canton Creek watershed have already been so heavily clearcut that there is not room for these owls to live there for at least another 100 years.

Unstable Soils

Soil concerns were identified as a Key Issue in the Christopher Folly timber sale area. BLM says there are: "Slope stability concerns on 23D, 23C, 25A, 25B, 26B, 27A and 35AB" and "The very steep scarp separating Units 23C and 23D has had relatively recent failures and looks unstable." Unfortunately, BLM thinks they can log anyway because they will leave a few trees on the unstable places -- called "retention trees." Even so, BLM said, "Slope stability concerns were noted that could impact water quality."

Unfortunately, "retention tree placement" is not only an unproven and unsafe technique, it could even cause landslides on unstable slopes. BLM's soils scientists said the use of retention trees for landslide prevention is dangerous: "There are potential pitfalls. The validity of using retention trees for slope protection is largely unproven. Blowdown can eliminate the intended protection and may even trigger a slide....". Additionally, the Oregon Department of Forestry has stated that leaving trees on unstable slopes will not prevent landslides, and could increase landslide risk. "On steep slopes, there is generally an increased risk of landslides for a period of about ten years after timber harvesting. Partial cutting will not eliminate this risk. Leave areas may actually increase risk of landslides in some cases. In several cases, we have observed significant blow-down of trees in SB 1211 harvesting deferral sites. Blow down can cause vibration, local slope oversteepening, loss of root strength, and alteration of drainage. All these factors can increase landslide hazard."

Yet, without any studies or data showing otherwise, BLM claims that logging these unstable slopes will not cause the landslides that they've caused in the past in Canton Creek. Instead, BLM's unlikely conclusion in the Environmental Analysis is that soil productivity "can ultimately be enhanced" by logging, and logging would "have a small favorable effect on site productivity cumulative impacts." This is a extremely radical conclusion that is not backed up with any scientific credible evidence.

Say Something

Public forests such, as Christopher Folly, are the only refuge for imperiled fish and wildlife, as well as the best recreation areas for people. (Unit 8, above Canton Creek, pictured at right). Since private forests can never offer these services, our public forests must be held to a higher standard. BLM cannot continue with large old-growth clearcuts like the Christopher Folly timber sale. The official public comment period for Christopher Folly has ended, but you can tell BLM anything you want, whenever you want. Just click here to send BLM email, or write to them at 777 NW Garden Valley Blvd., Roseburg, OR 97470.




March, 2000 Christopher Folly

BLM proposed the Christopher Folly timber sale early in 1998. Umpqua Watersheds appealed it to the Internal Board of Land Appeals (IBLA) who granted us a stay until they could decide examine the issues. On April 29, 1998, the U.S. District Court (Judge Rothstein), ruled that sales like Christopher Folly had not complied with the law. BLM had to withdrew the sale. In August of 1998, BLM re-released the 'new and improved' Christopher Folly proposal. Incredibly, BLM did not make even one change to the sale. Instead, they increased the volume and clearly documented how the watershed would degrade if they didn't clearcut (see "road repair" information above). In BLM's 1998 annual monitoring report, they documented how BLM accidently put part of the sale 100' into an old-growth reserve (riparian reserve). BLM said this is "insignificant", and refuses to fix it. Lucky for the forest, more court rulings plague it.

In February of 1999 we re-appealed the sale. In August of 1999, Judge Dwyer ruled that BLM failed to survey for and protect rare species of wildlife. In September of 1999, Judge Rothstein ruled that Christopher Folley did not comply with the Aquatic Conservation Strategy. BLM can't imagine how to log without degrading the watershed, so they are now appealing the Rothstein ruling -- maybe a year to get through that court mess. In December of 1999, the IBLA granted Umpqua Watersheds another 'stay' on the sale until our appeal could be considered, and in March of 2000 the IBLA remanded the sale, meaning we won our appeal. In May of 2001, the Rothstein ruling in 2000 was upheld by the 9th Circuit Court. For more information about the save, please see the latest about the Rothstein ruling.

What a tangled mess they do weave. Unfortunately, BLM's sole purpose in life is to keep fighting the courts. They have unlimited money and personnel, and they will continue to do their job until they have a quick opportunity to cut the trees down. Christopher Folley will never be safe until all public forests are safe. Below is a fairly recent press release about last year's Christopher Folley victory.

Christopher Folley timber sale returned to BLM. Umpqua Watersheds wins appeal.

Umpqua Watersheds appealed the Roseburg BLM Christopher Folley timber sale in February of 1999 to the Interior Board of Land Appeals (IBLA). This month the judges granted our request and ordered the sale "remanded" back to BLM. In other words, we won.

BLM had attempted to clearcut 215 acres in one of our most important Key Watersheds, Canton Creek. BLM claimed that their logging would restore the watershed because otherwise BLM would not do routine road maintaince. Not logging, BLM said, would degrade the watershed because the unmaintained logging roads would eventually deposite more sediment into the stream system than sediment created by logging.

We told the IBLA this was like blackmail. If BLM builds a logging road they should be able to maintain it. If a road in a Key Watershed is too expensive to maintain, it should be decommissioned. Clearcutting will degrade our watersheds by increasing peak flows and decreasing low flows in creeks. Yarding and hauling the logs will cause fish killing sediment to enter streams. Because Canton Creek is such an important stronghold for Steelhead, it has been closed to all fishing since the 1930’s.

The IBLA cited the two law suits that BLM had recently lost (Dwyer and Rothstein), and stated that to address these law suits, BLM will need to make the necessary changes, and remanded the sale back to them.

Roseburg BLM failed to convince the IBLA not to remand the sale with their argument that if Christopher Folley was found invalid, then "all BLM timber sales which rely on BOs issued by the NMFS would also be invalid. Since, in excess of 90% of sales in Western Oregon rely on these BOs, the effect would be to stop the BLM timber program..."

We hope BLM is right. The IBLA’s response to “BLM’s forebodings” is that “BLM does not explain how this Board can reduce the impact of the court opinion”. The IBLA stated that “BLM’s continuing obligations to consult with NMFS remain and cloud BLM’s ability to more forward to implement this sale”.

Christopher Folly isn’t the only BLM sale the IBLA ruled on this month. In seperate rulings they remanded Sugar Pine, Sweet Pea, Buck Fever, Dream Weaver, Final Curtin, Foghorn Cleghorn, Class of ‘98, Bell Mountain and Happy Summit. Most other BLM sales have been slapped with an injunction (called a ‘stay’) by IBLA, and we expect them to be remanded in the near future. It looks like it’s back to the drawing board for BLM. Maybe they will eventually learn how to not degrade our watersheds.