Frequently Asked Questions
On October 4, 2021, the U.S. Forest Service announced its final approval to remove trees and native chaparral from 775 acres of Pine Mountain, between Scenic Highway 33 and Reyes Peak.
Where is Pine Mountain?
Pine Mountain is located in the heart of the Los Padres National Forest, approximately 12 miles north of the City of Ojai in Ventura County. It rises to an elevation of more than 7,500 feet at Reyes Peak, and contains isolated stands of conifer forests and montane chaparral along with two public campgrounds and four trailheads (Boulder Canyon, Chorro Grande, Raspberry Springs, and Reyes Peak). It is also a key access point to the Sespe Wilderness and the Gene Marshall-Piedra Blanca National Recreation Trail.
What exactly does the Forest Service’s decision allow?
The decision authorizes the following activities within a 775-acre project area:
Removal of large living trees and snags up to 24” wide, and up to 64” in some cases
Creation of skid trails and landing areas where timber will be decked and loaded onto trucks
Removal of hundreds of acres of native chaparral habitat
While this is not a clearcut, the project allows for the cutting of thousands of trees, living and dead, of all ages and sizes. It will significantly transform the Pine Mountain area.
Will commercial logging be used?
Probably. The Decision Memo allows for “the sale of timber and other wood by-products.” In a commercial timber sale, the Forest Service offers logging companies an opportunity to bid on the project and remove merchantable timber from the site. Stewardship contracting may also be used, in which the Forest Service signs an agreement with a private company to conduct some or all of the tree and vegetation removal, and pays the company for the work or offers commercially valuable timber in exchange for the work. Earlier this year, the Forest Service signed an agreement with an Oregon-based logging company to remove trees on Tecuya Ridge approximately 22 miles northeast of Pine Mountain. The American Forest Resource Council—a lobbying arm of the logging industry—wrote a formal letter to the Forest Service supporting the project.
Did the Forest Service prepare an environmental assessment to thoroughly study impacts and alternatives?
No. Instead of the usual process to prepare an environmental assessment, the Forest Service opted to invoke a loophole that allows the project to move forward using a much less thorough approach. This loophole—called a categorical exclusion—allows officials to approve the project much more quickly, without a standard environmental assessment, and eliminates the public’s ability to file a formal objection or appeal of the project.
Did the Forest Service evaluate any environmental impacts at all?
Some. While the Forest Service prepared several reports, none met the legal standard of an environmental assessment, and none of them were released to the public before the project was approved. This “behind closed doors” approach does not foster trust among the public, and does not facilitate a helpful exchange of information from independent experts to ensure that the decision is based on the best available science.
Is there strong opposition to the project?
Yes, overwhelmingly so. More than 16,000 people from throughout the region and beyond wrote emails and letters to the Forest Service, asking officials to scale back the project and prepare an environmental assessment. Three Native American tribes and groups expressed opposition to the project, as well as several archaeologists. Two Congressional representatives whose districts cover the project area and surrounding communities urged the Forest Service to prepare an environmental assessment. The Ventura County Board of Supervisors voted to formally oppose the project and submit a letter to the Forest Service. In addition, the California Department of Fish & Wildlife and 66 nonprofit conservation organizations submitted a joint letter expressing serious concerns about the project.
Who supports this project?
The Forest Service received almost no support for the project. We thoroughly searched the project record and found only five comments in support, including one from the American Forest Resource Council, a lobbying arm of the logging industry.
Will this project help protect communities from wildfire?
No. Removing trees and vegetation in our forest backcountry several miles from the nearest town, does not make communities safer. Time and again working from the home out rather than from the forest in, has proven to be the best approach to protecting communities from wildfires. Most homes that burn during wildfires are ignited by wind driven embers that can travel miles ahead of a fire before entering attics, crawlspaces, windows, and other openings in the home, igniting it from the inside. Homes that are hardened to withstand these embers and that have defensible space maintained around them are most often the ones left standing after wildfires.
Vegetation removal on Pine Mountain ranks very low on the Forest Service’s own priority list. Specifically, in a 2015 assessment, officials listed the Reyes Peak project as priority number 118 out of 163 projects. The project received a “Values at Risk” score of 3 out of a possible 28, and a wildland-urban interface (WUI) score of zero.
What is home hardening and defensible space?
In the context of wildfires, home hardening refers to things that can be done to the home directly to reduce chances of it igniting in a wildfire. Defensible space is the area directly adjacent to a home that is maintained in a way that allows firefighters to engage in structure protection activities. Though there are many things one can do to harden homes and maintain defensible space in the WUI in preparation for wildfires, some fire preparedness tactics are simple and can be executed at little or no cost. For example:
Keep the first 5 feet from structures free of anything that could ignite in a fire
Regularly clear leaves and pine needles from roof and rain gutters
Install fine mesh screens over attic and crawl space vents to block embers from entry
Plant fire safe vegetation
Move all combustibles such as lawn furniture, firewood, etc. away from structures
Will this project promote forest health?
No. The forests on Pine Mountain are naturally variable. They are made up of large and small trees, dominated by Jeffrey pine, sugar pine, and white fir (with some incense cedar and canyon live oak scattered throughout). The use of heavy equipment to cut trees on the mountain will cause damage to soil and understory plants, while spreading invasive grasses such as cheatgrass that has already established along the road and in areas that were unnecessarily bulldozed to fight wildfires that never reached the ridge. These non-native grasses will outcompete native grasses and forbs that naturally grow in the forest understory. Cheatgrass is also an annual, short-rooted grass that doesn’t hold the soil in place very well, and it’s much more flammable than native plants in the area.
In addition, the removal of small live trees—particularly young conifers that have grown successfully during recent drought years—may diminish the forest’s long-term ability to deal with rising temperatures. The project will also remove many of the dead trees on Pine Mountain. Dead trees, or snags, are ecologically vital to forests as they provide habitat for countless species from woodpeckers to fungi. Snags eventually fall and become downed woody debris, which not only decomposes over time and recycles nutrients but also provides important habitat for chipmunks and other small rodents, lizards and salamanders, insects, and more.
Will this project help the climate?
No. Most of the aboveground carbon in any forest is found within the trunks (also called boles) of trees. During a wildfire, only a very small proportion of the total carbon in a forest is actually emitted as carbon dioxide, mostly coming from the combustion of leaves, small branches, and understory plants. Nearly all the biomass found in trunks and large branches as well as in root systems is left behind after a fire. In a logging project however, most of the aboveground biomass in a tree is removed and transported to a mill or cut, piled, and burned on site. Large scale tree and vegetation removal also requires use of heavy equipment that itself generates greenhouse gas emissions. In addition, with projects such as these, logs are transported long distances by fossil fuel powered trucks to processing facilities where they are sometimes burned as biofuel to generate electricity in a process that’s less efficient that burning coal.
Is the Forest on Pine Mountain suffering from insect and disease infestation?
In approving this project, the Forest Service relied on a loophole that speeds up approval for activities that address insect and disease infestation. However, the agency failed to provide evidence that the forest is suffering from unnatural insect and disease issues. Jeffrey pine and mixed-conifer forests like those found on Pine Mountain naturally have some level of tree mortality caused by insects and disease. While there has been some bark beetle activity on the mountain, only native beetles have been observed there. These insects have co-evolved with native tree species in the area for the past several million years, and they serve a vital function in our local forests. When drought occurs, weakened trees may be susceptible to bark beetles, which can result in tree death. However, these beetles are an important component of the food web in these ecosystems. They attract woodpeckers, which will forage for the bark beetles and excavate nest cavities in the softened dead trees. Those nest cavities are later used by smaller birds such as nuthatches, bluebirds, and violet-green swallows. These birds in turn are prey for raptors.
The forests on Pine Mountain also naturally have dwarf mistletoe, a native parasitic plant that grows primarily on Jeffrey pine in the area. Studies have found increased bird diversity in forests with significant dwarf mistletoe populations. Like the bark beetles, these native plants have evolved in these forests for millennia and are just one of many critical but misunderstood components of the ecosystem.
You can read more about ecological and other concerns in a 99-page comment letter submitted by ForestWatch and partners.
Did the Forest Service use a “collaborative” process to approve this project?
No, the Forest Service did not collaborate with stakeholders on this project, even though it is a requirement for projects approved using the categorical exclusions that the agency selected to approve the project. By the time the Forest Service announced the project in May 2020, it had already delineated a project boundary, prepared a project description, and determined to proceed with the categorical exclusion loophole. There was no advance consultation or input from stakeholders including conservation groups, tribes, local governments, or forest users. There have been no collaborative field trips or collaborative virtual workshops. Instead, the Forest Service conducted three virtual presentations that were fraught with technical difficulties and were not designed to receive information and feedback from the public to incorporate into the project. Rather, in these workshops, the Forest Service simply told the public what it wanted to do and only selected certain questions from participants that were posted in the chat room.
Will the project protect California spotted owls?
No. ForestWatch commissioned a survey of California spotted owls (CSO), a rare species whose populations are declining throughout southern California. During these surveys, biological technicians with Tanner Environmental Services identified two previously-unknown owls along with three young owlets. These owls may use the project area for foraging, and there is suitable nesting habitat in the project area that would allow these young owls to disperse. ForestWatch contracted with Pax Environmental to synthesize the survey results and analyze project impacts. Their report identified habitat that should be protected for spotted owls (“Protected Activity Center” or PAC) and concluded:
The Project will have at least a short-term effect on the CSO pair which undoubtedly uses the Project area for foraging with the overlap of the PAC and the Project area (Figure 3). The same is likely true for the nesting pair. It is possible that these CSO use more of the Project area outside of the delineated PAC. If this is the case, then Project impacts could extend beyond the overlap of the Project area and the PAC. The Project area is likely also potentially dispersal habitat for the three owl fledglings, as well as habitat for floaters (non-territorial owls).
It is likely that the Project will impact woodrats, the primary food source of CSO, during the mastication of downed materials. Foraging habitat within the Project area will likely take several years to recover and again support woodrats. Additionally, the level of canopy closure within the Project area has the potential to be reduced to a break-point where CSO habitat may be removed or downgraded from suitable roosting/nesting and/or foraging habitat to non-suitable.
Will the project affect wilderness and roadless areas?
Yes. Approximately 34% of the project is located within the Sespe-Frazier Inventoried Roadless area and proposed for permanent wilderness designation in the Central Coast Heritage Protection Act. This bill—introduced by local Congress members Salud Carbajal and Julia Brownley—was passed in the House of Representatives and is currently awaiting action in the Senate.
When will the project begin?
The project can begin immediately, although it may be several weeks or months before we see any activity or heavy equipment in the area. The Forest Service will likely issue a prospectus or timber sale notice, accept bids, and execute a contract to complete some or all of the work. Trees to be removed may be marked with paint or flagging. Work could be halted if a judge issues an injunction.
Will the project be challenged in court?
ForestWatch is working with our legal team to consider our next steps. Because the project was approved using a categorical exclusion, there is no opportunity for the public to file an administrative objection or appeal. The only way to get our concerns addressed at this point is to file a legal action in federal court.