Dear Eldorado National Forest Supervisor,

We, the undersigned individuals, write to express our deep concern with the Draft Environmental Assessment (Draft EA) for the proposed Caldor Fire Restoration Project on the Eldorado National Forest. Given the scale and potential impacts of this project, we strongly urge the Forest Service to prepare a full Environmental Impact Statement (EIS) rather than proceeding with an inadequate EA. We also call on you to fully protect all post-fire habitats from logging and to allow for natural regeneration processes. The Draft EA does not comply with the best available science on post-fire forest ecology, does not adequately address significant public safety concerns, and does not provide a reasonable range of alternatives, as follows:

Climate Change Considerations: The Caldor Fire Restoration Project must carefully consider the climate implications of proposed salvage logging activities. Hudiburg et al. (2019) revealed that logging-related emissions in California, Oregon, and Washington were approximately five times greater than emissions from wildfires. Harris et al. (2016) found that 85% of carbon emissions from U.S. forests were attributed to logging, while only 12% resulted from the combined effects of wildfire, insect outbreaks, wind damage, and drought. A letter to CARB (CBD et al., 2019) highlighted that current models assume unrealistically high percentages of incineration during wildfires, leading to overestimated emission figures. Stenzel et al. (2019) demonstrated that model-based calculations often significantly overstate actual wildfire emissions.

Black-backed Woodpecker Impacts: The proposed salvage logging poses significant threats to the Black-backed Woodpecker, a species highly dependent on post-fire habitats. Hanson and Chi (2020) found that Black-backed Woodpeckers strongly prefer areas with at least 270 medium and large snags per hectare (about 109 per acre) and larger high-severity fire patches exceeding 100 hectares. This density is far higher than what typically remains after salvage logging operations. DellaSala et al. (2017) emphasized the importance of woodpeckers in creating nest cavities for other species.

California Spotted Owl Impacts: The Caldor Fire Restoration Project poses significant threats to the California Spotted Owl, a species recently proposed for listing as threatened under the Endangered Species Act. The project proposes extensive salvage logging across approximately 76,000 acres within a larger 227,981-acre project area, which could severely impact this species' habitat.
Recent research challenges long-held assumptions about post-fire habitat suitability for spotted owls:
Hanson et al. (2018) found neutral or positive effects on Spotted Owls from large wildfires without post-fire logging, while post-fire logging had adverse impacts.
Lee (2018) observed that Spotted Owls continue to occupy and reproduce in territories affected by high-severity fire.
Jones et al. (2016) described the "bed and breakfast effect," where owls nest in low/moderate-severity burned areas but forage in high-severity burned areas.
The project's reliance on the outdated 2004 Framework is inadequate for protecting this species, especially considering its proposed ESA listing. The U.S. Fish and Wildlife Service has concluded that post-fire logging negatively impacts Spotted Owls. The scale of the proposed salvage logging operation could lead to habitat fragmentation and isolation of Spotted Owl populations.

Furthermore, Bond et al. (2009) found that California Spotted Owls preferentially selected high-severity burn areas for foraging. The proposed salvage logging would significantly degrade this important habitat, potentially leading to population declines and disrupting the complex post-fire ecosystem that these owls depend on.
Given these findings and the species' proposed threatened status, it is imperative that the Forest Service conduct a comprehensive Environmental Impact Statement to fully assess these impacts and explore alternatives that better protect California Spotted Owl habitat within the Caldor Fire area.

Additional Wildlife Impacts: A total of 39 bird species have been observed in the Caldor Fire area during site visits by John Muir Project volunteers in Summer 2023, demonstrating the rich biodiversity that thrives in post-fire habitats. These species include: Black-backed Woodpecker, Hairy Woodpecker, White-headed Woodpecker, Northern Flicker, Williamson's Sapsucker, Mountain Bluebird, Red-breasted Nuthatch, Brown Creeper, House Wren, Mountain Chickadee, Western Tanager, Black-headed Grosbeak, Lazuli Bunting, Wilson's Warbler, MacGillivray's Warbler, Nashville Warbler, Yellow-rumped Warbler, Orange-crowned Warbler, Olive-sided Flycatcher, Western Wood-Pewee, Cassin's Vireo, Warbling Vireo, Chipping Sparrow, Fox Sparrow (Thick-billed), Dark-eyed Junco, Green-tailed Towhee, Spotted Towhee, American Robin, Townsend's Solitaire, Swainson's Thrush (heard only), Rock Wren, Cassin's Finch, Steller's Jay, American Kestrel, Golden Eagle, Spotted Owl (heard only), Mountain Quail (heard only), Anna's Hummingbird, and Spotted Sandpiper. Many of these species have been photographed, providing valuable evidence of their reliance on post-fire habitats. This visual documentation can be viewed at: https://www.flickr.com/photos/200810020@N03/albums/72177720319889866/

Steel et al. (2022) noted that 13% of native bird species positively select interior spaces of large high-severity fire patches despite these areas comprising less than 1% of Sierra Nevada forests. The proposed logging would eliminate these crucial habitats for these species and many others.

Natural Regeneration and Forest Recovery: Salvage logging operations can significantly hinder true forest recovery. Hanson and Chi (2021) found that even more than 300 meters from the nearest live conifer, post-fire conifer regeneration in high-severity fire patches is abundant several years post-fire. Donato et al. (2006) reported that over 70% of natural post-fire conifer regeneration was killed by ground-based post-fire logging. The Rim Fire Reforestation EIS (USFS, 2016) indicated that salvage logging reduced conifer regeneration density by 72% and oak regeneration by 26%.

Fire Risk and Community Safety Concerns
The proposed Caldor Fire Restoration Project raises significant concerns about increased fire risks to local communities. Contrary to the Forest Service's assertions, extensive scientific evidence suggests that salvage logging and mechanical thinning can exacerbate wildfire behavior and threaten public safety.

A recent study by Baker and Hanson (2023) specifically examined the Caldor Fire and
found that areas with recent thinning and past high-severity fire followed by salvage logging and plantation creation burned at higher severity than areas of mature, never-logged forest. This local evidence directly contradicts the project's assumptions about fire behavior and forest management.

The tragic case of Grizzly Flats, which was largely destroyed by the Caldor Fire, serves as a stark example of the ineffectiveness of extensive logging and thinning in protecting communities. Despite being surrounded by areas that had undergone significant fuel reduction treatments, including mechanical thinning and salvage logging from previous fires, Grizzly Flats suffered catastrophic damage. This outcome mirrors similar failures seen in other California communities like Paradise (Camp Fire, 2018) and Greenville (Dixie Fire, 2021).
Multiple scientific studies support these observations:
1. Fuel treatments have been shown to have only modest effects on fire behavior and can sometimes worsen fire outcomes (Zald and Dunn, 2018).
2. Removing mature trees, as proposed in this project, is particularly likely to have negative effects on fire suppression efforts (DellaSala et al., 2022).
3. Thinning and salvage logging can increase fire severity by leaving behind combustible slash, opening the forest canopy to create more ground-level biomass, and increasing solar radiation that dries out the understory (Bradley et al., 2016).
4. Dense canopy fuels can actually help suppress fire by keeping the forest cool and moist and inhibiting the growth of surface and ladder fuels (Zald and Dunn, 2018).
5. The effectiveness of fuel treatments is limited by their relatively short duration, often becoming ineffective within 10-20 years as vegetation regrows (Kalies and Yocom Kent, 2016).

Given these findings, the proposed extensive salvage logging and thinning in the Caldor Fire area may paradoxically increase, rather than decrease, the fire risk to nearby communities. The Forest Service must thoroughly address this scientific controversy and reassess its approach to truly prioritize community safety.

We urge the Forest Service to focus on proven, science-based methods for protecting communities, such as creating defensible space immediately around homes and structures, rather than pursuing extensive logging in backcountry areas that may ultimately increase fire hazards. An Environmental Impact Statement (EIS) is necessary to fully evaluate these significant potential impacts on public safety and explore alternatives that better align with current scientific understanding of post-fire forest ecology and wildfire behavior.

Inadequate Data Accessibility: The Forest Service must provide comprehensive GIS data for the Caldor Fire Restoration Project to allow for thorough public review. Without this data, it's impossible for the public to fully understand the project's impacts across the vast project area.

Cumulative Impacts: The Draft EA fails to adequately address the cumulative impacts of the Caldor Fire Restoration Project when considered alongside other past, present, and reasonably foreseeable future actions in the region. This analysis is crucial for understanding the full scope of environmental consequences:

1. The project must consider the cumulative effects of multiple salvage logging operations across the Sierra Nevada region, which collectively impact wildlife habitat, watershed health, and carbon sequestration on a landscape scale.
2. The cumulative loss of post-fire habitat due to this and other salvage logging projects could have significant long-term impacts on species like the Black-backed Woodpecker and California Spotted Owl, potentially leading to population declines across their range.
3. The Draft EA should analyze how this project, combined with other forest management activities in the area, might alter future fire behavior and impact overall forest resilience in the face of climate change.
4. The cumulative effects on water quality and soil erosion from multiple logging operations in burned areas could have far-reaching consequences for downstream ecosystems and communities.
5. The Forest Service must consider how this project, along with other similar projects, contributes to the overall fragmentation of forest ecosystems in the Sierra Nevada, potentially disrupting wildlife corridors and altering species distributions.

Misleading Project Labeling: The disconnect between the stated goals of "restoration" and the likely outcomes as indicated by numerous peer-reviewed studies is stark. The project prioritizes timber harvest over true forest health and short-term economic gains over long-term ecological resilience. This mislabeling is not just semantically incorrect but fundamentally misleading to the public and decision-makers:
1. True ecological restoration would prioritize natural regeneration processes, habitat preservation, and ecosystem recovery, not extensive salvage logging.
2. The project's focus on removing burned trees and replanting ignores the ecological value of post-fire habitats and the natural forest succession that occurs after wildfires.
3. By labeling this as a "restoration" project, the Forest Service is obscuring the potential negative impacts on wildlife, soil health, and long-term forest resilience.
4. We urge the Forest Service to accurately describe this as a "salvage logging" or "timber sale" project to reflect its true nature and intentions.
The misuse of the term "restoration" for what is essentially a commercial logging operation undermines public trust and misrepresents the ecological consequences of the proposed actions. We call on the Forest Service to be transparent about the project's primary objectives and to reconsider whether large-scale salvage logging aligns with true forest restoration principles.

Emergency Action Determination: We strongly oppose the use of an Emergency Action Determination for Phase 1 of the project, which bypasses the objections and administrative review processes. This action undermines public participation and environmental review, both of which are fundamental to our democratic system. The decision to invoke emergency authority in this instance is unjustified and raises significant concerns about government overreach. It disregards the will of the people and sets a troubling precedent that could erode public trust in government processes. The U.S. Forest Service (USFS) has a responsibility to uphold the principles of popular sovereignty and democracy. We urge your agency to reconsider this approach and engage with the public as intended. If the USFS truly claims to serve people, you should actually respect the will of the people and not attempt to bypass the democratic process. Democracy thrives on transparency and accountability, and it is vital that all voices are heard in decisions that affect our environment and communities. We hope to see a commitment from the USFS to uphold these values by:
Rescinding the Emergency Action Determination
Reinstating the standard objections and administrative review processes
Ensuring robust public participation moving forward

Given these significant concerns we urge you to:
Prepare a full Environmental Impact Statement (EIS) instead of the inadequate Environmental Assessment.
Provide a true no-action alternative that allows for natural regeneration and protects burned areas from further disturbance.
Fully protect all post-fire habitats from logging recognizing their ecological importance and role in carbon sequestration.
Prioritize community fire safety measures such as defensible space around homes rather than extensive logging in backcountry areas.
Release comprehensive GIS data for the project to allow for thorough public review.
Reconsider the use of the term "restoration" for a project that the evidence indicates will cause significant ecological harm.
Withdraw the Emergency Action Determination for Phase 1 and allow for full public review and objection processes.
We thank you for considering these comments and urge you to revise the project to align with the best available science on post-fire forest ecology and climate change mitigation.

Sincerely,

We The People: