Comments and Appeals to Sequoia National Forest and other Agencies about Projects that Affect the Southern Sierra Nevada
Sequoia ForestKeeper assures environmentally sound compliance with the laws through participation in project-level planning, commenting, appealing, and when necessary litigating proposed projects that could negatively affect the ecosystems of the southern Sierra Nevada, including the Giant Sequoia National Monument and Forest (GSNM). Comments specifically about GSNM projects are found here. http://www.sequoiaforestkeeper.org/comments_and_appeals.aspx
Click on any of the links below to view our latest comments and appeals about projects in Sequoia National Forest and Southern Sierra Nevada lands.
Comments and Appeals 11 May 2022 25 March 2022 15 November 2021Hume Basin Restoration Project Scoping Comments from Sequoia ForestKeeper (SFK) and the Kern-Kaweah Chapter of the Sierra Club.22
October 2021
Hume
Basin Restoration Project Scoping Comments from Sequoia ForestKeeper (SFK) and
the Kern-Kaweah Chapter of the Sierra Club. 2
July 2021
SFK
Executive Director comments to the California Air Resources Board (CARB) 2022
Scoping Plan on Natural and Working Lands (NWL) specifically addressing the
carbon sequestration of intact forests and the exacerbation of climate impacts
caused by logging. 24
February 2021
Sequoia ForestKeeper responded with comments on the
"Salvage and Hazard" tree logging for the Castle (SQF Complex) Fire.
19
February 2021
Many
organizations wrote this letter to the Acting Secretary of Agriculture
regarding Forest Service Decisions Finalized Between January 20, 2017, and
January 20, 2021 for Review under Executive Order 13990.
We requested the United States Forest Service (USFS) modify or withdraw
environmentally damaging actions pursuant to Executive Order (EO) 13990. We
request to elevate review of imminent final decisions made during the last four
years.
19
February 2021
SFK and many other
organizations commented on proposed rangeland management directives where
the Forest Service sees a need to increase grazing on its system lands contrary
to science on invasive species and livestock grazing.
The agency bias toward livestock grazing, comes at the expense of the many
other uses of national forest land. Livestock grazing causes immense damage to
native vegetation, soils, and water quality, and frequently helps spread
noxious weeds. Grazing also degrades and fragments wildlife habitat and is a
major contributor to global warming, as livestock, especially cattle, emit much
methane, a greenhouse gas.
2
February 2021
Thirteen
organizations submitted comments on how to be good environmental stewards in
the rewriting of the Forest Products Modernization - Batch 2 #ORMS-2747.
28
January 2021
This
letter from 39 conservation organizations requested that the Department of
Agriculture immediately implement a targeted, 60-day elevation of Forest
Service decisions for the purposes of determining whether imminent decisions
comply with the new administration’s policies for environmental protection,
sound stewardship, climate pollution reduction, and roadless area protection.
This includes the Sequoia Complex/Castle Fire Roadside Hazard Tree Project in
the Giant Sequoia National Monument (CA) that would permit commercial logging
of 9,455 acres of old and large trees along 130 miles of roads, including
within Giant Sequoia Groves, and would destroy essential denning habitat for
the endangered Southern Sierra Nevada Pacific Fisher, of which less than 250 individual
fisher still exist. The Forest Service intends to issue a categorical exclusion
approving the project, which it could do at any time.
8 January 2021 Sequoia ForestKeeper and Sierra Club, Western Watershed, and Basin & Range Watch submitted these comments concerning the Isabella Pumped Storage Project, FERC Project No. P-15035 (Isabella Project or proposed project). We strongly oppose the issuance of this preliminary permit.
We have a number of concerns about the application by Premium Energy Holdings,
LLC, particularly with regard to the potential impact of activities that could
be granted under the preliminary permit on sensitive federal lands, which are
eligible for inclusion in the National Wilderness Preservation System, and
which are currently classified as Inventoried Roadless Areas, Wilderness Study
Areas, and eligible Wild and Scenic Rivers. The proposed project would be
located on public lands with highly sensitive resources managed by the U.S.
Forest Service (Sequoia National Forest) and the Bureau of Land Management
(BLM), state lands managed by the California Department of Fish and Wildlife,
as well as lands owned by Non-Governmental Organizations and other private
lands.
 Sequoia ForestKeeper and others register strong objection to the Bureau of Land Management (BLM) horse herd reduction plan that was proposed on May 8, 2020 by nominee-to-oversee-the-BLM William Perry Pendley. Pendley scapegoats wild horses as the "biggest existential threat" to public lands, even though wild horses and burros live on less than a quarter of lands managed by BLM. Pendley has spent his career trying to privatize public lands, roll back environmental protections, and help extraction industries make more profit. This plan ignores the devastating impacts of commercial livestock grazing, oil and gas by projecting the ills of the desert on its equine inhabitants. There is overwhelming evidence that livestock grazing is the major cause of habitat degradation, elimination of biodiverse native perennial grasslands, sagebrush-steppe, and riparian areas, destruction of carbon-storing biological soil crusts, declines in rare and threatened species, pollution of springs, streams, and rivers, and severe declines in native trout across federal lands where livestock grazing has been authorized by the federal government. Attachment 1. April14, 2020 Sierra Club
Comment letter regarding Notice of Preparation of Environmental Impact
Report for the Delta Conveyance Project and the Scoping Process. 16 April 2020 30 March 2020 24 March 2020One hundred twenty-two organizations including SFK agree on the Five Principles for Just COVID-19 Relief and Stimulus.1. Legislation must focus on combating the coronavirus pandemic and providing emergencyrelief directly to the people and communities who need it.2. There must be absolutely no funding for fossil fuel executives and shareholders or thatwould promote fossil fuel production or infrastructure.3. Funds should be provided for investment in zero emissions, sustainable energy technologiesand equitable programs that will support healthy communities free of pollution.4. Recovery funds should provide long-term security in the just and equitable energytransition for fossil fuel workers and communities economically dependent on fossil fuelproduction.5. Congress must ensure stimulus plans protect the economy from the risks of climate change. 8 March 2020 20 February 2020 27 January 2020 13 Jan 2020 13 Nov 2019
Sequoia ForestKeeper submitted comments to California State Parks on their draft Red Rock Canyon State Park plan. 30 April 2019 Attachment 1. Tufted Hairgrass Meadow (Deschampsia cespitosa)
Western Watersheds Project, February 22, 2019 31 August 2018 13 August 2018 Cleared areas can increase fire risk. Exotic grasses carry flames faster and further grown when native vegetation is cleared. Those same exotic grasses are the ladder fuel that causes total devastation instead of the healthy mosaic pattern of fire movement. Instead of removing woody material, money should be spent finding a way to combat exotic grasses in an ecologically friendly manner. The desert never burned before exotic grasses brought in by grazing animals and their disturbance helped the grasses grow. 8 August 2018
13 June 2018 11 June 2018 20 May 2018 16 May 2018
26 April 2018
Comments to the California Water Commission about the lack of ecological or public trust benefits of Proposition 1 funding of the Water Storage Investment Program (WSIP) and mitigation suggestions.
20 April 2018
23 March 2018
31 July 2017
31 July 2017
21 July 2017
8 May 2017
17 March 2017
15 March 2017
15 March 2017
27 February 2017
14 February 2017 - updated and corrected submission
In the previous January 17, 2017 submission by Wasteful Unreasonable
Methane Uprising, Sequoia ForestKeeper a spreadsheet set concerning
global GHG emissions and global surface temperature change values was
submitted. A few minor errors concerning notes on Sheet 1, lines 57, 58,
and 70 have been corrected, as well as a few other changes have been
incorporated.
1. Recalculated Anthropogenic GHG Emissions Global Surface Temperature Change 1950-2016
Attachments
12 January 2017
CARB Natural Working Lands Modeling comment on the urgent need to increase net carbon sequestration.
Find other comments posted about the CARB lands modeling here.
21 November 2016
19 September 2016
13 September 2016
25 August 2016
17 August 2016
8 August 2016Ara Marderosian comment letter with suggestions to the California Air Resources Board Environmental Justice Advisory Committee.
(1) In answer to the stated
objective of EJAC is to determine how to differently manage forests to reduce
Greenhouse gasses (GHGs) and increase carbon storage, I stated that forests
must be managed as closed canopy forests. Maintaining closed canopy forests,
rather than logging, will increase forest moisture, and decrease forest
temperature and surface winds, which will all reduce severe wildfires and
increase carbon sequestration.
(2) In response to a presenter’s
statement that the California Public Utilities Commission (CPUC) is charged
with considering impacts, of its decisions, to individuals in disadvantaged
communities in order to not create barriers to the use of energy efficiency,
I stated that the CPUC’s decision to allow power companies to charge customers
who generate solar power a grid connect fee that increases the minimum monthly
charge for power to $10, which would be a dis-incentive to invest in solar
panels for individuals in disadvantaged communities.
(3) Written and oral comment on
Short-Lived Climate Pollutant Reduction Strategy were submitted on behalf
of Jan Dietrick, MPH, Steering Committee, Ventura County Climate Hub, Ventura,
CA 805.746.5365, Todd Shuman, Senior Analyst, Wasteful Unreasonable Methane
Uprising, Camarillo, CA 805.987.8203, and Sequoia ForestKeeper, Kernville, CA,
which included three recommended actions for methane emissions reduction to
achieve 80% reduction below current levels by 2030:
(A) A robust fee or fine on unburnt, uncaptured
methane emissions of $4700/CH4 ton (in 2007 US dollars) paid by emitters,
(B) A rapidly decreasing mandatory cap on
allowable methane emissions from all sources, and
(C) Discontinuation of subsidies on
animal products.
26 May 2016
Attachments:
Letter from Center for Biological Diversity and Climate Change Law Foundation to CARB on their Proposed Short-Lived Climate Pollutant Reduction Strategy and Draft
New use of global warming potentials to compare cumulative and short-lived climate pollutants. Myles R. Allen, et al. { Allen et al on SLCP GWP 2016} Offsetting methane emissions — An alternative to emission equivalence metrics.
25 May 2016
The wildlife and habitats of this world cannot take much more assault from humans that refuse to let nature live. Without nature we will all perish.
13 April 2016
March 31, 2016
March 15, 2016
USACE Supplemental Environmental Analysis Borel Canal Comments
March 3, 2016
February 4, 2016
(February first was a very busy day commenting on the Sequoia-Sierra National Forest Plan Revision Species of Concern (or lack of concern as evidenced by the Forest Service paying little heed to the Best Available Science))
SFK discusses in brief 25 species of concern that are missing from the Forest Service draft list.
February 1, 2016
February 1, 2016
Sierra Forest Legacy, Center for Biological Diversity, California Native Plant Society, Bristlecone Chapter, California Native Plant Society, Defenders of Wildlife, Friends of the Inyo, Center for Sierra Nevada Conservation, The Wilderness Society, Forest Issues Group Sierra Club, Range of Light Group (Toiyabe Chapter) Sierra Club, Tehipite Chapter, Sierra Club, Western Watersheds Project, Friends of the River, CalWild/California Wilderness Coalition, and Mono Lake Committee
Submitted general concerns about the approach and documentation for the determination of Species of Conservation Concern and comments related to the determinations for individual species.
February 1, 2016
These comments are submitted in addition to the comments submitted by Sierra Forest Legacy on behalf of multiple organizations on the Draft Proposed SCC lists for the Inyo, Sequoia and Sierra National Forests.
February 1, 2016
January 28, 2016
January 27, 2016
Attach J - Summit Star Tulip Occurrences
Attach K - Summit Species
Attach L - Ice Project CSO PAC Map
Attach O - Summit CE B alta sierrae 2016
Attach P - Summit CE-A gentilis Record
Attachment A - March 27, 2014
Attachment B - September 11, 2013
December 29, 2015
November 23, 2015
November 20, 2015
October 19, 2015
October 16, 2015
July 29, 2015
Please address the petition by including the following subject heading:
RE: June 8, 2015 Temporary Urgency Change Petition Concerning SWP/CVP and Water Deliveries, in relation to the April 6, 2015 TUCO
July 6, 2015
These two pdfs contain the SFK and WURU objections that were submitted
as an addendum to our previous complaints that current SWRCB orders,
which enable water diversions to commercial industry, damage the
environment without regard to impacts to wildlife or the public trust.
The
use of irrigated water for livestock feed crop production is both
wasteful and unreasonable during this time of drought in California;
such use also conflicts with the “waste or unreasonable use” section of
the California Constitution.
May 12, 2015
April 1, 2015
Tobias Project FEIS
Scoping Comments for Sequoia ForestKeeper ®, Kern-Kaweah Chapter of the Sierra
Club, & Western Watersheds Project
December 1, 2014
October 17, 2014
September 30, 2014
Travel Analysis Process Comments for Sequoia ForestKeeper
& Sierra Club
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