By Kevin Proescholdt
With a long-standing drought throughout the American West, exacerbated by climate change, some wilderness managers have come under pressure to try to prevent future wildfires in Wilderness from burning, or from burning so hotly. That pressure pushes wilderness managers to consider “presuppression” activities—like tree cutting—in Wilderness, in the mistaken belief that such actions prevent or diminish wildfire and its effects.
Those pressures seem to have reached the Bureau of Land Management (BLM) in its recent new management plan for the Cascade-Siskiyou National Monument in southwestern Oregon, which contains the Soda Mountain Wilderness. And that is why Wilderness Watch filed a formal Protest with the BLM over the language in that new plan allowing so-called presuppression tree cutting in the Soda Mountain Wilderness in violation of the 1964 Wilderness Act.
The Soda Mountain Wilderness, which covers 24,707 acres and was designated by Congress in 2009, is an ecological mosaic where Oregon’s eastern desert meets towering fir forests. The Wilderness is home to a spectacular variety of rare species of plants and animals, including Roosevelt elk, cougars, black bears, golden and bald eagles, goshawks, and falcons. The Wilderness lies entirely within the boundaries of the 114,000-acre Cascade-Siskiyou National Monument, which President Clinton established in 2000 and President Obama expanded in 2017.
The new management plan’s overly-permissive language in question states:
• Limit vegetation management actions in Wilderness Areas to only occur for the purposes of removing non-native vegetation or to reduce wildfire risk to life, property, or wilderness character.
This language goes far beyond what the 1964 Wilderness Act permits. Our Protest seeks to change this language to authorize only activities that the Wilderness Act allows. The specific points of our Protest include:
1. Cutting and thinning for vegetation management are not allowed within the Soda Mountain Wilderness, especially with chainsaws and other motorized equipment. The language envisions allowing vegetation management activities within the Soda Mountain Wilderness “for the purposes of removing non-native vegetation or to reduce wildfire risk to life, property, or wilderness character.” This would most likely be done with chainsaws and other motorized equipment. Such authorizations would violate the Wilderness Act.
2. Language in BLM’s policy guidance cannot override the statutory language of the Wilderness Act. The language that we are protesting mirrors language from the BLM’s Manual:
Fuel treatment is not allowed in wilderness, except in rare circumstances. Due to the controversial nature of fuel treatments and the complexities of analyzing the effects of these on the totality of wilderness character, when they are to be used as a replacement for wildland fire they may require analysis through an EIS. Fuel treatments may be permitted:
A. To remove non-native vegetation (see also section 1.6.C.15); or
B. When prescribed fire without pretreatment in the wilderness will inevitably cause unacceptable risks to life, property, or wilderness character (including cultural resources, as outlined in 1.6.C.5.f); or
C. When any wildland fire will inevitably cause unacceptable risks to life, property, or wilderness character.
BLM Manual 6340(1.6)(C)(7)(d), emphases added
This policy language is far more permissive than the statutory language from the Wilderness Act. There is no language in the Wilderness Act authorizing a suspension of the Act’s protections to deal with “non-native vegetation,” for example. Nor is there any language in the Wilderness Act authorizing “pretreatment in the wilderness.” This overly-permissive agency policy language cannot override or supersede the statutory language of the Wilderness Act.
3. Section 4(d)(1) of the Wilderness Act—a special provision for the control of fire, insects, and disease—does NOT permit pre-suppression landscape manipulations. This section of the Wilderness Act states:
In addition, such measures may be taken as may be necessary in the control of fire, insects, and diseases, subject to such conditions as the Secretary deems desirable.
The special provision on fire, insects, and disease at § 4(d)(1) cannot be applied so broadly that it renders the statute, its terms, and its overarching mandate meaningless. Accordingly, the fire, insects, and disease special provision requires some actual need, such as responding to an existing fire, and some finality so that fire control does not become an ongoing, landscape-scale ecological manipulation project that completely overrides the purpose and goals of the Wilderness Act.
4. The Soda Mountain Wilderness statutory designation does NOT include any special provision for presuppression activities. Congress recognized the differences between suppression of actively burning fires (as authorized by section 4[d][1] of the Wilderness Act), and presuppression activities that actively manipulate landscape conditions in an attempt to ward off potential future fires. In a couple of instances in California, Congress has specifically allowed presuppression activities in individual Wildernesses. Congress did NOT do so for the Soda Mountain Wilderness.
From a wilderness perspective, it is far better to allow natural, lightning-caused fire to play its role in Wilderness, rather than to invade Wilderness to cut down “undesirable” trees and attempt to create conditions based on human wishes and desires, rather than what nature is creating.
The BLM has recently ruled against our Protest. The language we have protested could set a troubling precedent for the entire National Wilderness Preservation System, and we hope to eventually succeed with our Protest to both protect the wilderness character of the Soda Mountain Wilderness and avoid that precedent. We and our allies are considering our options.
Click here to read Wilderness Watch’s full Protest.
Photo: Soda Mountain Wilderness by Kyle Sullivan/BLM
Kevin Proescholdt is Wilderness Watch’s conservation director.
391 Comments
The Wilderness Act must be strictly followed. This foundational law clearly prohibits the use of mechanized equipment—including power tools—and forbids vegetation removal intended for fire prevention in designated wilderness areas. The Bureau of Land Management (BLM) has a legal and moral obligation to honor the intent and integrity of the Wilderness Act, which was established to preserve the natural character of these lands for present and future generations.
Unfortunately, BLM has once again demonstrated its inability—or unwillingness—to uphold what is best for these uniquely protected public lands. Wilderness areas are designated for their untrammeled, pristine nature, where natural processes are allowed to occur without human interference. These lands are not just scenic landscapes; they are vital ecosystems, cultural touchstones, and places of solitude and reflection. BLM’s recent actions suggest it has lost sight of the very purpose of wilderness preservation.
Therefore, we strongly urge the BLM to refrain from including any authorizations for fire pre-suppression activities within the boundaries of the Soda Mountain Wilderness in the Final Environmental Impact Statement (EIS), Record of Decision (ROD), and Resource Management Plan (RMP) for the Cascade-Siskiyou National Monument. Introducing such activities would violate the Wilderness Act and compromise the ecological integrity of this irreplaceable landscape.
As a concerned citizen, I echo the growing public sentiment: just stay out! We instead advocate for the adoption of the language in Alternative D, which clearly states: “Prohibit all vegetation management activities in Wilderness Areas” (Volume 2, E-3). This is the only path consistent with federal law, conservation ethics, and the long-term protection of America’s most treasured wild lands.
It’s well past time to learn to live in harmony with the planet we inhabit. This is a good place to follow the law and begin that practice. Thank You.
Please leave nature alone! Fires are caused by habitat destruction and careless people.
Healthy, intact forests prevent soil erosion and flash floods!
Trees are a critical line of defense against pollution, flooding, and carbon dioxide. Do not cut them down!
Because of this incontrovertible truth – “Language in the BLM policy guidance is far more permissive than the statutory language from the Wilderness Act. There is no language in the Wilderness Act authorizing a suspension of the Act’s protections to deal with “non-native vegetation,” for example. Nor is there any language in the Wilderness Act authorizing “pretreatment in the wilderness.” This overly-permissive agency policy language cannot override or supersede the statutory language of the Wilderness Act.” – the BLM needs to be STOPPED immediately from any forward action.
Many things at play here. One is certainly to follow the law. Wilderness has specific definitions. Adding vague requirements or negating these definitions is against the laws.
Another thing is that when ancient trees are removed, the wilderness suffers, the people suffer and the world suffers. Those trees will be forever lost.
Also important is that people (and corporations) know little about Wild lands. As we designate them protected we learn more about them. The forests have been managing themselves for as long as there have been forests. Their main problems now hinge on change and destruction caused by Man–even if only for recreation.
Knowing Wilderness is finite and will never return must be in the forefront of our thinking and actions.
The Soda Mountain Wilderness statutory designation does NOT include any special provision for pre-suppression activities. Thus, no individual exemption has been made for SMW and that type of activity is not permitted nor appropriate.
No cutting trees, please.
The BLM must follow the rule of law (Wilderness Act), and cease to manipulate its decree and purpose through vaguely worded “management plans.” Wildfire is a very complex issue that requires thoughtful, interdisciplinary dialog and sustainable solutions that remain within the confines of existing laws, requiring management plans to use very specific language. It matters to everything living; now, and for generations to come.
we must act to maintain biodiversity, the unnecessary removal of one tree impacts 1000’s+ microorganisms, insects, birds, mammals & more life that depends on that ecosystem & surrounding biosphere for survival…
The Bureau of Land Management’s mission is supposed to be to sustain the health, diversity, and productivity of public lands not destroy it.
Here are a few lines from the beginning of The Light Eaters by Zoe Schlange that speak well for the Wilderness
I am in the Hoh Rain Forest in the Pacific Northwest, and everywhere is a sense of secrets. And for good reason. For everything that science does know about what, biologically, is going on here, there is so much more that it cannot explain. All around me are complex adaptive systems. Each creature is folded into layers of interrelationship with surrounding creatures that cascade from the largest to the smallest scale. The plants with the soil, the soil with the microbes, the microbes with the plants, the plants with the fungi, the fungi with the soil. The plants with the animals that gaze on them and pollinate them. The plants with each other. The whole beautiful mess defies categorization. …Understanding plants will unlock a new horizon of understanding for humans: that we share our planet with and owe our lives to a form of life cunning in its own right, at once alien and familiar….I am lost in their world, taken into it. Then again, we’ve all been lost in it a long time, unaware of its true machinations. This seems imprudent. I wanted to know, so I went out and looked.
If the Trump admin. is looking for places to cut, Cut the BLM. I have not seen anything positive about any of the plans they have had for the lands or animals that need those lands. Not farm animals.
Leave Wilderness as is. It’s only for humans as real wilderness. Human interference cuts into it being wilderness.
These plans certainly cry for some other motives than tree care and fire worries.
There are few pristine places remaining in the US, keep the wilderess wild. Allow the plants and animals to live in peaceful harmony.
It never fails to amaze me how the BLM and other land management agencies conveniently ignore the Wilderness Act provisions when they propose certain land use actions. Either the BLM is staffed by incompetent employees or is being directed to take actions they should know are not in accordance with the law. This is a successful lawsuit waiting to happen. What a waste of government money!
Protect Soda Mountain and follow the Wilderness Act, for goodness sake! End logging of old-growth trees and all trees in Wilderness Areas protected by law. Protect our forests, wildlife, and plants, living in an interconnected web of life. What you do to nature, you do to yourself. Rather than dominion over, we are bound by stewardship over. Think!!! Thank you for reading this.
Hello,
PLEASE do not cut the trees!
All of creation is intimately connected. We must protect our forests because they protect us and all the creatures of our planet.
Congress considered the Soda Mountain Wilderness and deliberately chose to exclude it from the California exception. BLM should not circumvent Congress to execute their own presuppression plan.
It is imperative that we put an end to logging of old growth trees and slow down on newer trees to prevent the loss of our forests, wildlife and plants.
Leave nature alone! BLM needs to adhere to the Wilderness Act and leave this ecosystem alone.
The Soda Mountain Wilderness statutory designation does NOT include any special provision for presuppression activities.
This mandate must be followed and do not interfere with nature.
Wildlife will be harmed if you destroy their homes and the environment in general will be very negatively affected.
From a wilderness perspective, it is far better to allow natural, lightning-caused fire to play its role in Wilderness, rather than to invade Wilderness to cut down “undesirable” trees and attempt to create conditions based on human wishes and desires, rather than what nature is creating.
No to Logging for any purpose in the Soda Mountains Area: Forever Wild Means exactly that, Not Roads Cut for BS Reasons !
Follow the rule of law and do not cut trees in the Soda Mountain forest.
I want to comment on the proposed management plan for the Soda Mountain Wilderness. I am a frequent visitor to the Ashland, OR, area, and have hiked the Soda Mountains Wilderness several times. Generally I feel the management plan is overly permissive of human management of the area. Specificaly, I would say that:
Cutting and thinning for vegetation management are not allowed in wilderness areas unless specified by the designating legislation.
Language in BLM’s policy guidance cannot override the statutory language of the Wilderness Act.
Fuel treatment in designated wilderness is only allowed in limited circumstances, such as when wildland fire will inevitably cause unacceptable risks to life, property, or wilderness character.
Section 4(d)(1) of the Wilderness Act—a special provision for the control of fire, insects, and disease—does NOT permit pre-suppression landscape manipulations. The Soda Mountain Wilderness statutory designation does NOT include any provision for presuppression activities.
Thanks for the opportunity to provide these comments, and I appreciate your efforts to maintain the wilderness qualities of the Soda Mountain Wilderness.
Patrick Carr
1704 Virginia Way
Arcata CA 95521
We need the trees. Keep wilderness wild.
I agree with this comment. Leave our remaining forests in their natural state. Mother Nature knows best. Let her be.
Designated wilderness comprises the only places on Earth where humans are NOT ALLOWED to try to control nature. Adhere to the Wilderness Act! Let the natural world continue to have a place of its own.
As a very concerned constituent, I am alarmed of the plans to destroy such important areas to our ecosystem. Destruction of protected areas would be devastating to not only the area, but also to wildlife, the environment, our future, and contribute to climate change. We must act responsibly in order to protect our future and the future of our children. Please, I urge you to make the right decision to continue to protect these important areas. Thank you for your consideration
I respectfully ask that you be environmentally conscious.
Follow the rule of law and do not cut trees in the Soda Mountain forest.