Friends of the Bitterroot challenges the Mud Creek Project

We have jointed Alliance for the Wild Rockies, Nature Ecosystem Council, and Yellowstone to the Uintas to file  a complaint with the US Forest Service, The Bitterroot National Forest (BNF), and the US Fish and Wildlife Service to stop the Mud Creek Project. It will clearcut 4800 acres, it redifines old growth to allow for commercial logging that could reduce large trees in the stand by half and destroy the functionality of old growth. This will reduce biodiversity and reduce carbon storage on the forest, vital to mitigate climate change.

See it in the Daily Montanan

See it in the Ravalli Republic

See it in the Missoulian

 

Mud Creek Comments Due April 7

The West Fork Ranger District is asking for comments on the actual logging plan for the NezMud portion of the Mud Creek project. This is the first of four action areas within the 48,000 acre project.

Comments can be sent electronically to District Ranger Dan Pliley daniel.pliley@usda.gov

Mailed to: West Fork Ranger Station, attn Dan Pliley, 6735 West Fork Road, Darby, MT 59829

Or in person at the West Fork Ranger District Office, 8:00-4:30 Monday through Friday

Suggested talking points:

We suggest using any or all of our talking points and putting them in your own words. Also let Ranger Pliley know how important the area is to you. What do old growth and intact forest habitat mean to you?

  1. Comments on the Mud Creek implementation plan are due April 7, but the area involved will not be accessible until mid June. The public should be given a chance to see the existing conditions before commenting on the proposed plan.
  2. Remove the excessive clearcuts from the project. The NezMud implementation plan includes 813 acres of clearcuts. NezMud is only 1 of 4 areas within the Mud Creek project. Clearcuts destroy habitat and promote invasive weeds. They should be removed from the implementation plan.
  3. The Final Decision Memo promised there would be no clearcuts over 40 acres. However, units NM121, NM120, NM122 are neighboring clearcuts equaling 42 acres. They are separated by two open roads, so the entire open area might be even larger. Many of the clearcuts are separated only by open roads. These roads should be included in total acreage of open areas.
  4. The implementation plan includes no mention of old growth. Many public comments expressed concern about old growth. The Final EA promised that that all areas proposed for treatment would include a stand diagnosis including old growth criteria. This information should be mapped with proposed logging methods and shared with the public. The public must be informed of existing old growth and how it will be cut.  Any stands initially identified as old growth with modelling that were removed from old growth status after the stand analysis should be shared with the public.
  5. Thank you for eliminating some of the commercial logging in the Riparian Habitat Conservation Area (RHCA). Please remove the remaining commercial logging in RHCAs from the plan. These areas are important corridors for wildlife that also protect rivers and streams.
  6. Whitebark pine has recently been listed as threatened under the Endangered Species Act. Extinction is forever; prudence is called for. The implementation plan includes thinning in white bark pine stands, but a Biological Opinion from re-consultation has not been received from the USFWS. This plan should not have been completed until after the USFWS has a chance to look at the effects of project activities on threatened whitebark pine.
  7. The project area is heavily roaded. Decommissioning of temporary roads and the promised decommissioning of extraneous roads will only happen if funding is acquired in the future. The excessive number of temporary roads and roads promised to be decommissioned will not balance out the new road construction if the work is never completed. There should be funds earmarked for all promised decommissioning before implementation.
  8. If the promised decommissioning of roads is not guaranteed, lack of decommissioning will increase illegal road use and off-road infractions. This will create user conflict and harm wildlife.
  9. The implementation plan includes thousands of acres of pile burning and prescribed fire. The EA suggests 1,000 to 5,000 acres per year. This will greatly affect the human environment, especially when compounded with concurrent nearby burning projects for the next 20 years.

 

MUD CREEK UPDATE Nov 29 2021

The Forest Wide Amendment for EHE objectives had been virtually abandoned and site specific amendments used. This seems to be a problem for Region 1 and the objection review process. The only changes on the website is a change in title for the EHE amendment to include Old Growth, CWD and Snag retention. And a proposed comment period beginning 12 1 2021. Yet another dump over the holidays.

Here is the new project page. The only thing that has changed is the title.

We received the objection review response. The Bitterroot National Forest must address a number of issues before moving forward. As you can see from the letter, they think the BNF must clarify whether it is in compliance with the forest plan. Instead it seems they will change the forest plan to support their broad commercial logging plan.

Objection Review Letter link

Mud Creek update:

Read Our Objection signed by Friends of the Bitterroot, Wild Earth Guardians, Sierra Club, Friends of the Clearwater, Alliance for the Wild Rockies, and Native Ecosystems Council.

The objection meeting occured last week. The Forest Service plans to go full speed ahead with conditions based project planning that asks the public to accept text book analysis without revealing specific plans and without on the ground research. The first attempt at using this process was deemed illegal in court.

Plan includes:

  • Commercial thinning in Old Growth to as low as 8 trees per acre
  • Treating the Wilderness Study Areas and Inventoried Roadless Areas including bulldozing fire lines
  • 22 or more openings (clearcuts) each up to 200 acres,
  • Destroying important wildlife movement zones for lynx, wolverine, grizzly and elk
  • Degrading bull trout habitat
  • and more

Stay tuned: Decision notice is due on October 7th or November 7th if they choose to extend.

Mud Creek Objection Due August 23

If you have written comments, you have standing to object to the project.

Don’t forget to e-mail your objections to appeals-northern-regional-office@usda.gov

Or mail them to Objection Reviewing Officer: USDA Forest Service . Northern Region 26 Fort Missoula Road , Missoula, MT 59804

Don’t forget to put Mud Creek Objection in the subject line or on the envelope.

Remember you must have commented to object. The talking points we sent were as follows:

  1. For such a large project that affects bull trout, the forest service should prepare an EIS that includes on the ground, site specific analysis.
  2. An official 60 day comment period should be announced for the 22 openings (clearcuts) from 40-200 acres. It should not start until June 1st when the public can access the focal areas specified for large openings.
  3. Protect Old Growth Standards as specified in the Forest Plan
  4. Preserve Elk Habitat Standards as specified in the Forest Plan. These standards limit roads that affect elk security. The area is already heavily roaded and elk in the area are below population objectives.
  5. Protect wildlife by not amending thermal cover and Coarse Woody Debris standards.
  6. Protect endangered and sensitive species like bull trout and lynx.
  7. Do not build new roads, reconstruct naturally decommissioned roads or build temporary roads in the already heavily roaded project area.

Mud Creek Project

Bitterroot Star Article: Mud Creek Project Draws Criticism

Thanks for all your comments: 80% againsts the project

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Mud Creek Talking points 

  1. EIS is required for a 48,486 acre project that affects bull trout, Canada lynx and myriad sensitive species.
    • This project drains into the popular Westfork of the Bitterroot fisheries and includes the Blue Joint Wilderness Study Area. The Blue Joint Recommended Wilderness, and a number of inventoried roadless areas affecting the human environment in both context and intensity.
  1. Conditions based process is a violation of NEPA
    • It is difficult to discern the likely impacts both positive and negative given the lack of site-specific information for the numerous hypothetical proposed management activities over the course a 20-year project duration.
    • Does not provide specific onsite information leaving the public bereft of necessary information to provide meaningful comment.
    • A better understanding of the conditions of an area are gleaned from on-site detailed analysis which is not provided in this EA. Neither the Forest Service or the public has a detailed, ground truthed understanding of the conditions of the project area
  1. A new comment period should begin June 1st when the public can access the project area.
    • Public should have the opportunity to assess the locations of proposed roads recently specified in the EA.
    • Without on the ground analysis, the public cannot submit meaningful comment as specified in NEPA
  1. Open an official 60 day comment period June 1st for the 22 or more “regeneration” clearcuts from 40-200 acres.:
    • Insufficient information was provided to the public at scoping, general locations for the clearcuts revealed in the EA are unreachable due to impassable roads until early June.
  1. Identify the minimum road system and bring identified roads to BMPs as recommended in the 2012 planning rule.
    • Tables in the EA showing current sediment being dumped into nearby streams from roads shows Forest Service inability to maintain the current road system in the project area.
  1. Do not build new roads, reconstruct naturally decomissioned roads or build temporary roads in the already heavily roaded project area.
    • The reconstruction proposed for existing road templates demonstrates past failures to properly decommission temporary road segments,
  2. Retain Old growth as specified in the Forest Plan:
    • No commercial/mechanical actions in old growth stand
    • Retain Old Growth at 15 trees per acre, including snag retention and coarse woody debris standards
    • Retain large trees to recruit old growth Stands: Cut no trees over 16dbh
    • Do not treat old growth until proper monitoring can occur.
      • Old growth treatment monitoring in Como and Gold Butterfly will not supply timely information to infomr old growth treatment decisions on this project.
      • Como project EIS states, “There is risk associated with treating old growth and being able to retain the old growth characteristics. Some research supports treating ponderosa pine old growth and retaining the old growth characteristics and there is a limited record of successful application. However, retaining old growth characteristics in mixed conifer old growth following treatment is more uncertain.”
  • No mechanical action or commercial logging in IRAs or WSAs, RWA
    • Avoid active vegetation manipulations in Inventoried Roadless Areas, the Blue Joint Wilderness Study Area, and the Blue Joint Recommended Wilderness in recognition of the vast body of science (including the FS’s) that indicates unmanaged areas have the highest functioning of natural ecological processes.
  • Project fails to analyze the cumulative effects of climate change.
    • Intact forests are our best and least expensive defense to mitigate the effects of climate change.
    • EA incorrectly states that wildfires are the “largest source of carbon emissions.” Logging has been found to be greater source of carbon emissions than cars in Oregon.
    • It is irresponsible write off the idea of analyzing affects to climate change by stating, “the Mud Creek project area is by far too small to measure global greenhouse gas emissions.” Death by a thousand small carbon cuts. We must all do our part to keep our forests standing and increase not decrease carbon storage capabilities on the Bitterroot National Forest.
  1. Biocontrols and seeding should implemented to reduce invasive weeds over time before mechanical treatments occur.
    • Merely spraying trucks and roadsides is not enough to preserve and encourage native plants and grasses.
    • Active, non chemical treatments should be implemented before commercial logging and road building is considered.
  2. Cutting piling and burning actions should be limited to trees 6 inches in diameter at breast height and under.
  3. No prescribed burning should happen in the spring,
    • Natural fires do not burn in the spring under wet conditions.
    • Native grass forbs and ground nesting birds are killed by low intensity fires in wet conditions.
    • Studies show soil breaks down and degrades after cool temperature fires.
  1. Retain Coarse Woody Debris (CSD) as specified in Forest Plan
    • CWD important for future soil and carbon storage
    • CWD is important for wildlife habitat
  1. Retain Thermal cover standards as specified in the forest plan
    • Thermal cover is essential to wildlife including elk, deer, lynx, fisher, and marten
  2. Retain Elk Habitat Standards as specified in the Forest Plan
    • West Fork Hunting District 250 does not meet FWP elk population objectives.
    • Elk habitat is damaged by roads and the project area contains some of the highest road density on the BNF
    • Roads fragment habitat and increase human/wildlife conflict.
    • Roads enable spread of weeds.
    • Roads disturb soils
    • Roads impede natural water hydrolics
    • Roads are costly to maintain to BMPs

 

  • The three ATV loops proposed will affect wildlife and fire ignitions.
    • Roads in the project area were left disconnected to protect wildlife.
    • Increasing traffic on roads affects fisheries.
    • Increased human access increases the chance of human caused wildfires.
  1. Consider non-motorized trail work.
    • The majority of trails in the area have been neglected for years.
  1. Soils in the area are impaired due to heavy logging, clearcuts and terracing.
    • A thorough, on the ground soil analysis is necessary before proposing a landscape scale project.

Here is the link to the request for comments

Here is the link to the Forest Plan amendments they must make to complete this over the top project: old growth (allowing for commercial treatment leaving only 8 trees per acre on average), elk habitat objectives (allowing more roads in a heavily roaded area), thermal cover(necessary for wildlife), coarse woody debris (future soil), Openings over 40 acres (they are proposing 22 areas of openings from 40-200 acres.)

This is a conditions based analysis which means no specific information or analysis on the ground. We are not sure what all they will do on 44,832 acres treating 21 square miles with many clear cuts up to 200 acres, new roads, ATV loops, and commercial logging in old growth. Watch out bull trout, lynx, wolverine and grizzly bears! The EA reads more like a forest plan. It completely re-writes the forest plan by amending old growth standards, elk habitat effectiveness, coarse woody debris, thermal cover, and common sense.

How is it possible not to do a full EIS analysis of this? How is it possible that 21 square miles of commercial logging will not make a significant impact?

Project info from Bitterroot National Forest

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