July 3, 2024 | By:

Wilderness at Risk with BLM’s Cascade-Siskiyou Plan: Send Public Comments by July 5!

Hyatt Lake, within the Cascade-Siskiyou National Monument, June 21, 2020. (Photo © BLM, Kyle Sullivan)

Hyatt Lake, within the Cascade-Siskiyou National Monument, June 21, 2020. (Photo © BLM, Kyle Sullivan)

We hope you don’t, but…

The Bureau of Land Management (BLM) is revising its management plan for the Cascade-Siskiyou National Monument. Public comments on BLM’s Draft Environmental Impact Statement (DEIS) are due by Friday, July 5. BLM’s Draft Plan is over 600 pages and its numerous links are online at: https://eplanning.blm.gov/eplanning-ui/project/2023675/570 Most of you probably haven’t and won’t read much of BLM’s Draft Plan, if you read any of it. We hope this very brief overview and “comment guide” will help you cut to the chase.

A group of us have been working through BLM’s Draft Plan. It’s tricky. And, despite some decorative decoys, it’s worrisome. The Draft Plan presents one “No Action Alternative” (“A”) and three “Action Alternatives” (“B” and “C” and “D”), each proposing various management scenarios – with “Alternative C” as BLM’s allegedly moderate “Preferred Alternative.” (Who could argue with moderation?) And though Alternative B is ostensibly and generally the most heavy-handed and Alternative D generally the most light-touch, the alternatives are not uniformly as advertised. (BLM will likely combine parts of each alternative in their Final Plan.)

For example, the more heavy-handed Alternative B includes Areas of Critical Environmental Concern and Research Natural Areas – but the generally lighter-touch Alternative D does not. Alternatives B (heavy), C (“moderate”), and D (“light”) all include logging inside the congressionally designated Soda Mountain Wilderness boundaries (Vol. 2: Maps 2-35, 2-36, 2-37). Elsewhere in the Monument outside the Wilderness, Alternative B allows for 4-acre forest “openings” – aka clearcuts – (Volume 1, page 198). And in the “moderate” and “preferred” Alternative C, “opening would be limited to 2 acres” (Volume 1, page 204). Re: “limited” – an acre is about the size of a football field. All this based on questionable science and whistling-in-the-dark fuels reduction assumptions that seem to ignore the precautionary principle re: the Monument’s primary purpose of protecting native species and natural ecosystem dynamics.

Most – though not all – of BLM’s Draft Plan belies BLM’s chronic, predominant, two-dozen-year reluctance (often refusal) to take the Cascade-Siskiyou National Monument’s Proclamation protection mandates seriously. BLM seems institutionally incapable – which is why BLM’s Monument ecologist resigned from the planning team in protest. He’s now on our comment team. Would the National Park Service ever write such a flawed Draft Plan? We doubt it.

Oregon Wild’s Conservation Director, Doug Heiken, nails it: “Much of the DEIS analysis is based on an outdated agricultural model of forestry that treats natural processes like succession and mortality as problems that can be fixed with logging. …BLM’s criteria for…forest health reveals an unjustified bias against natural processes which have helped create the biodiversity that the Monument is known for. It is past time for BLM to adopt a meaningful ecosystem-based approach to land management that works with instead of against natural processes.”


BLM usually only listens to you if they think you might sue them. But if they get a lot of comments asking them to do something they don’t want to do, they say, “Hey, it’s not a vote!” And if they get comments asking them to do what they already want to do, they say, “People want this!” Here’s some of what we are recommending to BLM in long, technical letters. We welcome you to make any/all of these recommendations, too, in your own words and/or by copying/pasting.

Soda Mountain Wilderness: Keep chainsaws and motor vehicles out. Respect the Wilderness. Parts of Alternatives B, C, and D propose “thinning” in the Soda Mountain Wilderness. No!

Lands with Wilderness Characteristics (LWCs): Support all LWCs in Alternative D plus LWC status for the proposed Green Springs Mountain and Grizzly Peak wild areas. All LWCs should receive full LWC protection and be upgraded to Wilderness Study Area (WSA) status.

Northwest Forest Plan: Continue and improve Alternative A’s “Aquatic Conservation Strategy” and “Survey & Manage” (aka “Look before you log”) elements of the Northwest Forest Plan. The Northwest Forest Plan was developed to protect biodiversity. It’s part of BLM’s original 2008 Monument Management Plan. BLM should carry it forward in their Revised Plan.

Livestock Grazing: Cows don’t protect land and water. End BLM grazing leases for private cattle on Monument lands when leases expire as in Alternative D. Cancel leases when terms/conditions are chronically violated, including for trespass grazing where cattle aren’t authorized.

Roads: Institute all closures/limits/restrictions in Alternatives A, B, C, & D with no exceptions.

Areas of Critical Environmental Concern (ACECs) & Research Natural Areas (RNAs): Maintain existing ACECs/RNAs (Alternative B) and also designate the proposed Mariposa Preserve ACEC and Cottonwood Glades ACEC.

Reducing Wildfire Risk: No BLM Draft Plan alternatives are acceptable as written. We recommend: 1) Expand riparian areas, wetlands, and wet meadows – including beaver reintroduction and prohibition of human beaver predation; 2) Ecological treatments of plantations – closest to homes first and weigh tradeoffs (roading, etc.) when considering treatments further out; 3) More ecologically informed Wildland Urban Interface (WUI) treatments. Best science says only treatments within 200 feet of structures have best chance of effectiveness; 4) Traditional practice prescribed fire; 5) Close roads. Roads are vectors for human-caused fire; 6) Remove/bury powerlines; 7) Remove cattle and feral horses. They replace native grasses with more flammable exotics; 8) Acquire private inholdings from willing sellers. More fires – some during “fuels reduction” – start on inholdings than from lightning.

Vegetation and Forest Management: BLM’s Preferred Alternative C emphasizes logging as a preferred tool for fuel reduction, even in riparian areas and mature and old-growth forests. BLM would significantly reduce the forest canopy across thousands of acres. All BLM’s logging plans are contrary to the Monument Proclamations and contrary to the best science which recommends focusing fuel reduction on small surface and ladder fuels near homes and conserving intact forests for biodiversity, spotted owl habitat, carbon storage, and future recruitment of snag habitat. BLM should develop a New Alternative that blends the more enlightened parts of Alternatives C and D to create a scientifically and ecologically sound vegetation plan that works with – instead of against – natural processes to protect Monument objects and values.


Send via email to: bl**********@bl*.gov (that’s an underscore on each side of “csnm”) Or… ATTN: CSNM RMP Project Mgr, BLM Medford District, 3040 Biddle Road, Medford, OR 97504. Or you can visit the BLM  website and follow their instructions for submitting comments online.

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Jason Lucas Kahn
10 days ago

The BLM has the worst scientific literacy of any federal agency. Proponents of intelligent falling and a flat Earth seem to have found a home there.

Jeff Hoffman
8 days ago

It would be illegal to build roads or kill trees in a designated Wilderness, so that wouldn’t stand up in court if so challenged.

This is what we can expect from the Bureau of Livestock & Mining. Worst federal agency that manages land in the U.S. This agency should be abolished and the land that it manages put under the National Park Service, with all qualifying land designated as wilderness.

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