Summer 2011

Click for original Winter/Spring 2011 article

MOUNT SHASTA BIOREGIONAL ECOLOGY CENTER
P. O. Box 1143 • Mount Shasta, CA 96067 • Phone & Fax 530.926.5655 • email shastamedicine@snowcrest.net
Honoring and Protecting Our Mountain Environment since 1988


Via Electronic Transmission

May 27, 2011

Siskiyou County Public Health & Community Development — Planning Division
Attention: Ms Vurl Trytten <vtrytten@co.siskiyou.ca.us>
cc: Greg Plucker <gplucker@co.siskiyou.ca.us>
806 South Main Street
Yreka, CA 96097

Re: Roseburg application for rezoning of about 770 acres of TPZ lands in Sections 5 and 32

Dear Ms. Trytten:

We are writing in order to address the rezoning request by Roseburg Forest Products (RFP) to change the status of approximately 770 acres of Timber Production (TPZ) lands to Rural Residential Agricultural 40-acre (RRB40) high on the slopes of Mount Shasta. We have only recently learned of this proposed action, and are surprised that the public hasn’t been notified since this proposal has been in the works for at least several months.

The Mount Shasta Bioregional Ecology Center is a grassroots nonprofit organization founded in 1988. Our constituency is broad based because the large pristine landscapes we work to protect are vitally important to people near and far, as well as to Native American cultures, as places of renewal, sources of pure water, and rich biodiversity. Over 4,000 people over the past two decades have expressed to us their deep caring about the preservation of Mount Shasta. We have been involved with matters concerning Mount Shasta and its environs since 1988. Preserving the Mountain in its natural grandeur is of paramount importance to our local
communities, to Native Americans, and to people from all over the world.

We stand in strong opposition to the rezoning of these timberlands and urge Siskiyou County to deny this proposal. We encourage RFP, the Forest Service and the County to look at other options that are consistent with the pristine beauty that distinguishes Mount Shasta as a sacred mountain and world-class destination. We want to work in cooperation with all concerned toward a solution, and we are therefore giving our input now so that there can be a meaningful discussion in which the overall good is considered before commitments are made.

While we understand that no Notice has been sent out to the public about this proposed action, we are sending comments on behalf of the public interest that our organization represents. We strongly affirm that the public is a stakeholder in this matter. We are concerned that deals and promises are perhaps being made behind closed doors without the benefit of input from the affected public, and that this could foreclose a more cooperative solution. Therefore we are sending these comments and are asking for a transparent and cooperative process that takes into account the full impacts of the proposed action.

THE SUPERLATIVE VALUE OF MOUNT SHASTA TO VISITORS FROM ALL OVER THE WORLD

Mount Shasta is a world-class destination for visitors from around the world, as well as a recognized major sacred site for Native Americans near and far. Travelers, nature lovers, spiritual seekers, backcountry skiers and hikers visit the Mountain because of its pristine beauty and grandeur. The fact that it rises high above the encroachments of civilization gives visitors a timeless and unique experience that is healing, inspiring and unforgettable.

There are many reasons why high elevation residential or commercial development would not be a good idea especially on this side of the Mountain that is known as a major spiritual, cultural and backcountry recreational attraction.

IMPACTS TO MOUNT SHASTA AND ITS RESOURCES REQUIRE AN EIR/EIS

The proposed action has many potential impacts and unknowns, and all eventualities need to be considered. Dividing the Roseburg timberland into as much as 20 parcels (with a potential for 40 houses and guest houses) could result in multiple ownerships and would invite conflicting uses to this side of the Mountain. Under the California Environmental Quality Act (CEQA), an action that is controversial and has the potential for significant impacts must undergo environment review leading to an Environmental Impact Report (EIR). Because the proposed action could also affect public lands, the National Environmental Policy Act (NEPA) will come into play in the form of an Environmental Impact Statement (EIS), and the requirement would be for a combined EIR/EIS.

The impacts of rezoning this remote environmentally sensitive area from a zone that limited development to a zone that would encourage development would be very controversial and bring potentially significant impacts, which are enumerated below.

IMPACTS ON CULTURAL AND HISTORIC SITE AND DISTRICT

Panther Meadows, the feature adjacent to which the rezoning is being considered, is particularly sacred to Native Americans and visitors from around the world, and is made especially vulnerable by the proposed rezoning. The Mount Shasta Cosmological District and Panther Meadows Native American Ceremonial Site—designated by the National Register of Historic Places—could potentially be greatly affected by the proposed rezoning.

IMPACTS ON THE FOREST

In view of the critical role forests play in enhancing watershed and habitat health, it does not make any sense to convert forested lands to development. Introducing incompatible uses could alter the forest structure, interrupt ecological processes, increase the potential for invasive species, disease and insect infestations, increase fire danger, and promote rural sprawl.

IMPACTS ON THE WATER AND WATERSHED

Mount Shasta is a major source of waters for all of California, and it is vitally important to keep our water sources pure. There needs to be disclosure of potential water use and wastewater discharges. The volcanic structure of the underlying aquifer is extremely unpredictable, and elsewhere water sources have been known to disappear into lava tubes as a result of drilling (Grass Lake in our region may be such an example). We believe that insufficient hydrogeologic mapping has been done to adequately evaluate the effects of the project and other draws on the hydrology of Mount Shasta, and such mapping would need to be done as part of the EIS/EIR process.

An OTT Report (located at the College of the Siskiyous Library’s Mount Shasta Collection) shows that the soils in this area do not have the capability to properly percolate sewage due to their porosity. The sections below Panther Meadows are vital to the water systems of a large area of Mount Shasta. Any disturbance or contamination could have significant impacts both to the underlying aquifer, which to our knowledge has not been mapped or studied, and also to community water supplies.

VISUAL IMPACTS

Views from the high slopes of Mount Shasta, from the Mount Shasta Wilderness, National Landmark, Native American Cosmological District, from Panther Meadows, Bunny Flat, Grey Butte, Sargent’s Ridge, Shastarama Point, Green Butte, and many other well-loved places could be impacted by the proposed rezoning. Development would change the scenic quality of the Mountain by changing the vegetation, the colors, the forests and character of the area.

We are also concerned about the view shed and its potential impacts on the Volcanic Legacy Scenic Byway.

ECONOMIC IMPACTS

The South County communities surrounding Mount Shasta rely on the Mountain as the prime attraction of the area, drawing people from all over the world. Visitors stay in the inns and motels of these communities, eat in their restaurants, purchase hiking, skiing and snowboarding equipment, shop in local stores...just to mention a few economic benefits of the Mountain’s value in its natural state. High elevation development could impact the Mountain’s attractiveness to the many visitors who seek untrammeled views and an absence of manmade intrusions.

ECONOMIC DEVELOPMENT AND GROWTH ARE MISPLACED IN AREAS REMOTE FROM EXISTING SERVICES

The rezoning could encourage land speculation along the Everett Memorial corridor and would promote random development. It is doubtful that insurance could be obtained in an area prone to avalanches.

Furthermore it could have considerable financial impact and place additional burdens on county and city infrastructures, taxes and equipment that could include additional snow removal, fire protection, and rescues during intense storms.

SIGNIFICANT RISK OF REPEATED AVALANCHES

It is an historically documented fact that a major massive avalanche swept through the northeast corner of the Roseburg land, destroying 300 year old trees and closing Everett Memorial Highway for months.

PUBLIC RECREATIONAL EASEMENTS IN SECTIONS 5 AND 32

In Roseburg’s application, it is stated, "RFP experiences heavy public use that is inconsistent with our long term timber management, thus it will be a likely candidate for HBU sale in the near future." This means that the public in all seasons has used and continues to use roads and trails for recreational purposes. These uses have extended for at least 50 years. If the public uses RFP’s land heavily, then by law it has acquired a public recreational easement across it and the right to continue using it forever. The trails and areas so used should be mapped out in the environmental study.

CUMULATIVE IMPACTS

While the rezoning may look innocuous at first glance, it potentially could open doors, not only to residential, but also to commercial development. The process may not be piecemealed under CEQA or NEPA, and the full scope of possibilities to which the action could lead must be evaluated.

A RANGE OF ALTERNATIVES

Alternatives to the proposed rezoning must be considered. These could comprise various possibilities for land exchanges, including exchanges with parcels not on Mount Shasta, through a cooperative effort with the Forest Service, land trusts, and local nonprofits.

Thank you for your consideration of our input. We request to be notified in writing of any decision on the proposal and of any environmental review that may be initiated. We want to reiterate our hopes for a cooperative process that will bring this issue to a harmonious solution.

Respectfully submitted,
Michelle Berditschevsky
Michelle Berditschevsky
Conservation Director

cc: Sharon Heywood, Forest Supervisor, Shasta-Trinity National Forests
Dwight Dutschke, California State Historic Preservation Office
Winnemem Wintu Tribe
Pit River Tribe
Karuk Tribe
Native Coalition for Cultural Preservation of Mount Shasta

For original Winter/Spring 2011 article: