Forestry Program

Cottonwood Project on the Tahoe National Forest

In February, 2005, the Tahoe National Forest released its final decision approving the final  environmental impact statement for the Cottonwood Vegetation Management Project, following a lengthy revision process after a 2001 court-ordered remand of the agency’s initial proposal first released in 2000. The federal court had ruled that the agency had failed to adequately analyze the environmental impacts of the project. (For more information, visit http://www.forestissuesgroup.org.) In spite of widespread public opposition to the project, the agency is again planning to utilize chemical herbicides to kill native plants on 13,500 acres of the naturally regenerating montane chaparral and other native plant communities that have grown since the 1994 Cottonwood Fire. The area is a biologically diverse region containing several rare plants. The agency has not conducted annual monitoring of key indicator species since 1996, as required under the National Forest Management Act. Science based monitoring is essential to determine if the aggregated outcomes and effects of agency actions are sustainable and are achieving the desired conditions.

CNPS appealed the project along with other grassroots conservation groups in the area, including the Sierra Foothills Audubon Society, the Forest Issues Group, South Yuba River Citizens League and the Mother Lode Chapter of the Sierra Club. The Forest Service response was to deny all points of the substantive, science-based appeals. Subsequently, in July 2005, CNPS took the final steps to stop the illegal and harmful proposal, filing suit in federal court to stop the action.

The Cottonwood Project again fails to adequately analyze the environmental impacts of the project, and the purported goal of the project—to accelerate the attainment of “old-growth forest” cannot be met by the installment of uniform, mostly single species commercial conifer crops. The trees would be managed intensively with herbicides to reduce competition from native, naturally occurring shrubs and other native plants. The project fails to meet the requirements of the National Forest Management Act, that requires the agency to follow its forest plan and to protect biological diversity across the landscape. CNPS asserts that an ecology-based analysis would have informed the DEIS with needed information about the natural successional processes associated with the montane chaparral vegetation type and the role of the natural fire regime. Although seven different vegetation communities exist in the planning area, the DEIS does not acknowledge or analyze this diversity and the environmental impacts of habitat conversion to even-aged uniform tree plantations. Furthermore, although the area contains a high diversity of tree species, including Western juniper, Washoe pine, Jeffrey pine, Western white pine, pinyon pine, white fir, red fir, sugar pine, incense cedar, black cottonwood, quaking aspen, willow, and alder, the agency claims it must use herbicides to hasten the growth of thousands of planted yellow pine conifers (Jeffrey or ponderosa), in order to “restore” the area and “increase diversity.”

Research has shown that the thousands of acres of conifer tree plantations already existing in the Sierra Nevada has simplified forest structure, and the pole trees of even-age and size contribute to increased fire hazard. According to the venerable forest ecologist Dr. Jerry Franklin, naturally recovering forests post-wildfire are now the rarest of forest ecosystems. These early-successional post-fire habitats are rich environments for biodiversity, supporting hundreds of different plants and animals and forming the foundation of the forest food web.

Seventeen of the 28 most threatened plant species in the Sierra Nevada occur on the Tahoe National Forest, as identified in the 2001 Sierra Nevada Framework. Habitat for 13 of these rare plants occurs in the Cottonwood Project area, including Ivesia aperta var. aperta, which has already suffered impacts from the on-going grazing permitted in the area. One of the chemicals proposed for use in the area, the butoxyethyl ester form of the chemical triclopyr, has been identified by the EPA as presenting a risk that cannot be mitigated, at all levels of application rates, for endangered plant species. The chemical is also known to be highly toxic to fish and amphibians. Riparian plant communities in the project area are robustly thriving after the 1994 fire. The agency’s plan to now apply herbicides widely to this healthy post-fire environment violates all claims the agency may have to scientific credibility. For more information about the project, contact Vivian Parker, CNPS conservation coordinator for the Sierra Nevada region’s national forests, at vivparkerstarband.net.