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.

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
15 November 2021
Hume 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.
23 October 2020
Comment letter from SFK regarding Forest Service’s proposed addition of e-bikes to its travel management directives.
Issue #1 – The new directives in the FSM should not “establish promotion of ebike use on NFS lands as an objective.” 85 Fed. Reg. 60129 (Sept. 24, 2020).
Issue #2 – The new directive properly categorizes e-bikes as motorized vehicles.
Issue #3 – E-bikes on trails will likely increase the displacement of other trail user that do not want the conflict or disruption of their experience of hiking or riding horses on trails without fear of conflict or potential collisions.
Issue #4 – All bicycles uses on trails should be subject to the same requirements for public involvement and environmental review as e-bikes, and this review should be done retroactively.
Issue #5 – E-bikes pose additional hazards that regular bicycles do not because they all have flammable and potentially explosive lithium-ion batteries, leading to increases in fire risk.

8 July 2020
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.
One 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 emergency
relief directly to the people and communities who need it.
2. There must be absolutely no funding for fossil fuel executives and shareholders or that
would promote fossil fuel production or infrastructure.
3. Funds should be provided for investment in zero emissions, sustainable energy technologies
and equitable programs that will support healthy communities free of pollution.
4. Recovery funds should provide long-term security in the just and equitable energy
transition for fossil fuel workers and communities economically dependent on fossil fuel
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.
CalFire's Vegetation treatment Plan (VTP) fails to address the real need to make homes the first line of defense in preventing catastrophic wildfire. This comment from SFK, California Chaparral Institute, and Los Padres Forest Watch addresses the insufficiencies. The State needs to embrace the goal of eliminating wildfire catastrophes and reject the fatalistic approach that we cannot address the devastating power of wind-driven fire.
5 June 2019
30 April 2019
Attachment 1. Tufted Hairgrass Meadow (Deschampsia cespitosa)
Western Watersheds Project, February 22, 2019
7 September 2018
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
Attachment B. Nowicki, 2018. Rethinking Forest Carbon and Energy
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
26 October 2017
Comments to the Bureau of Land Management from Sequoia Forest Keeper and the Kern-Kaweah Chapter Sierra Club regarding our opposition to a drilling project at Conglomerate Mesa. We asked them to protect the ecological and historical resources found in the area. We opposed the drilling project because of the presence of multiple special status and rare plant species, impacts to the historic Keeler-Death Valley trail, and to support local tribes in their opposition to this project because of the potential to limit and degrade their access to traditional gathering sites.
31 July 2017
31 July 2017
Comment letter from the Center for Biological Diversity, the Environmental Protection Information Center (EPIC), Sequoia ForestKeeper, and Preserve Wild Santee response to the California Department of Food and Agriculture’s CalCannabis Cultivation Licensing Draft Program Environmental Impact Report (“PEIR”). The commenting organizations support the successful implementation of the Medical Cannabis Regulation and Safety Act (“MCRSA”) and Proposition 64 (the Adult Use of Marijuana Act [“AUMA”]). Recognizing that other states will look to California to pave the way in marijuana legalization, this task, properly undertaken, is as complex as it is important. The goal is substantial—to bring a major industry out of the shadows into the scope of modern environmental practice, to address past damage, and to ensure that poor practices are not incorporated into the large and growing legal cannabis industry.
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
5.Producción de energía a partir de los gases rúminales del bovino (Energy production from bovine ruminant gases.)
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 2016
Ara 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
The California Air Resources Board is attempting to regulate carbon emission, yet they don't address the methane contribution of the livestock industry or the carbon emitted by burning biomass. Sequoia ForestKeeper: Ara Marderosian, Wasteful Unreasonable Methane Uprising: Todd Shuman, and Ventura County Climate Hub: Jan Dietrick outline their concerns in this comment letter. 
Climate impact of beef: an analysis considering multiple time scales and production methods without use of global warming potentials. RT Pierrehumbert {Grass fed vs feedlot Eshel Pierrehumbert 2015}
Letter from Center for Biological Diversity and Climate Change Law Foundation to CARB on their Proposed Short-Lived Climate Pollutant Reduction Strategy and Draft
Environmental Analysis, May 26, 2016. {16 05 26 Final CBD SLCP Strategy comments}
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.
A.R. Lauder, et al. {Lauder et al 2012}
Short-Lived Climate Pollution. R.T. Pierrehumbert {Pierrehumbert on SLCPs}

25 May 2016

May 23, 2016
Comment letter 1 on the Tobias Logging Project on the Western Divide District of Sequoia National Forest. The Forest Service is planning on logging green trees from a forest that has suffered a die-off of 90 million trees.

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))

February 1, 2016

SFK discusses in brief 25 species of concern that are missing from the Forest Service draft list.

February 1, 2016
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 25, 2016
Attachment A - March 27, 2014
Attachment B - September 11, 2013
Attachment C - Zielinski e-mail to Voss  
Attachment E1 - Summit & Adjacent Projects 
Attachment E2 - Cumulative Projects

December 29, 2015


November 23, 2015

November 20, 2015

October 19, 2015

October 16, 2015

July 29, 2015
Please find more information in our letter to SWRCB (State Water Resources Control Board){} and write your comment to SWRCB and email to Rick Satkowski.
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.

June 19, 2015

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.

February 28, 2015

Tobias Project FEIS Scoping Comments for Sequoia ForestKeeper ®, Kern-Kaweah Chapter of the Sierra Club, & Western Watersheds Project

December 1, 2014

December 16, 2013

SFK Comments to USDA about USFS Ski Area Recreation Areas not becoming Amusement Parks

July 29, 2013

May 24, 2013

April 15, 2013

April 5, 2013

Mar. 22, 2013

Mar. 22, 2013

Feb. 28, 2013

Nov. 10, 2012

Sept. 17, 2012

Aug. 30, 2012

Aug. 8, 2012

May 21, 2012

May 21, 2012

May 11, 2012

Jan. 30, 2012

Nov. 18, 2011

Nov. 17, 2011

Oct. 27, 2011

Sept. 6, 2011

Aug. 11, 2011

Aug. 5, 2011

Apr. 28, 2011

Mar. 9, 2011

Aug. 2, 2010