**COMMENTS ON THE DRAFT EIS OF THE WESTERN OREGON PLAN REVISION**

The Western Oregon Plan Revision (WOPR) states that "In selecting among
the alternatives in this plan revision, BLM will evaluate which
alternative or combination of alternatives best meets the Purpose and
Need...The purpose and need for this proposed action is to manage the
BLM-administered lands for permanent forest production in conformity
with the principles of sustained yield, consistent with the O&C Act. The
plans will also comply with all other applicable federal laws including,
but not limited to, the Endangered Species Act..."

THE ESA

Section 7(a)(2) of the Endangered Species Act, specifies that "Each
Federal agency shall, in consultation with and with the assistance of
the Secretary, insure that any action authorized, funded, or carried out
by such agency, *is* *not likely to* jeopardize the continued existence
of any endangered species or threatened species *or result in the
destruction or adverse modification of habitat of such species which is
determined by the Secretary, after consultation as appropriate with
affected States, to be critical* ... In fulfilling the requirements of
this paragraph each agency shall use the best scientific and commercial
data available."

THE SCIENCE

The most comprehensive and recent review of the scientific data
available for the murrelet, the Evaluation Report for the 5-Year Status
Review of the Marbled Murrelet in Washington, Oregon, and California,
prepared for the USFWS, Region 1, and published on March 2004, states in
its Final Conclusion that "Results of this scientific review indicate
that marbled murrelet populations in Washington, Oregon, and California
continue to decline (especially in California) and continue to be at
risk from the same threats identified at Listing..." (p 6-34).

What are those threats? "Terrestrial threats to the marbled murrelet are
primarily the loss and fragmentation of nesting habitat." (p. 4-106)

How badly is the marbled murrelet population declining? From Chapter 3
of the WOPR we read "McShane et al. (2004) produced a demographic model
of marbled murrelet populations in Washington, Oregon, and California by
each of the six conservation zones. Similar to previous studies, they
found that populations in all conservation zones are in decline with
**mean annual rates of decline between 2.1% and 6.2%.** The highest
rates of decline were in Zone 6 at the southern extent of the range.
Furthermore, they conclude it is likely that populations in Zone 5 and 6
could become nonviable in the near future."

The population trend across all zones could be worse than this though.
From the 5-Year Status Review: "...demographic modeling with the most
recent biological information indicates that the murrelet population is
still declining in all 6 Conservation Zones...In central Oregon (Zone
3), **an overall population decline of \>50%** was reported from
standardized surveys conducted between 1992 and 1999. This decrease is
the strongest direct evidence of large-scale population decline in the
3-state range." (p. 6-27, 28)

The concluding paragraph of the 5-Year Status Review sums it up with
these words: "Population declines appear to be related to the loss of
nesting habitats due to logging and urbanization over the past 150
years. In most areas within the listed range, murrelets are left with
small, isolated stands of older trees for nesting. At present and for
the foreseeable future, these remnant populations are struggling to be
self-sustaining and may soon become non-viable in Zones 5 and 6 and face
potential extinction during the next century. *It is unrealistic to
expect that the species will recover before there is significant
improvement in the amount and distribution of suitable nesting
habitat."* (p. 6-34)

THE WOPR

In the Summary of Environmental Consequences portion of the WOPR, it
states that "The nesting habitat for the marbled murrelet on
BLM-administered lands would increase under all four alternatives within
100 years."

And until then? It depends on the Alternative. The No-Action alternative
keeps intact the Late Successional Reserve system put in place by the
Northwest Forest Plan and is the *only* alternative that does not reduce
murrelet nesting habitat for all of the BLM districts throughout the
next one hundred years. For Alternative 1, "The Coos Bay District would
be the only district with a short-term decline in marbled murrelet
nesting habitat. The decline would be 3.3% over the next 10 years." And
if either Alternative 2 or 3 is chosen, the expectation is that "In the
short term (50 years), there would be a **16% decrease from the current
condition in the quantity of marbled murrelet nesting habitat under
Alternative 2 and a 14% decrease under Alternative 3."** More
specifically, Appendix G of the WOPR states that out of the 29 critical
habitat units (CHUs) listed, under Alternative 2 "from 2006 to 2016...20
critical habitat units would decrease in habitat during this time
period. Nine of these 20 units would decrease in habitat by more than 10
percent. Nesting habitat would decrease between 2016 and 2026 in 20
critical habitat units. Two of these 20 critical habitat units would
decrease more than 10 percent." And under Alternative 3 "habitat would
decrease in 14 critical habitat units in the first decade. Three of
these 14 units would decrease more than 10 percent. Nesting habitat
would decrease between 2016 and 2026 in 23 critical habitat units. One
of these 23 units would decrease more than 10 percent."

As well as this, "the mean patch size of mature and structurally complex
forest on BLM-administered lands in the planning area would...decrease
to 101 acres under Alternative 2, and decrease to 37 acres under
Alternative 3 \[from a current patch size of 111 acres\]." As pointed
out in Chapter 4, "Potential nest predation increases with increased
forest fragmentation and the amount of edge (Raphael et al. 2002a and
2002b, Meyer et al. 2002)," and so Alternatives 2 or 3, if chosen, will
effectively result in an increase in potential nest predation, further
reducing the viability of the species.

Furthermore, under Alternative 3, as stated in Appendix G, "with the
exception of Congressionally-withdrawn lands and riparian management
area, almost all marbled murrelet critical habitat units would be
subject to regeneration harvests \[i.e. clearcuts\] and partial harvests
that would remove marbled murrelet nesting habitat."

In addition to this, "Analysis of Alternative 2 assumes that surveys
\[for the murrelet\] would not occur. Because of the hidden nature of
nesting marbled murrelets, it is not reasonably foreseeable that
additional sites would be found without surveys. Therefore, the analysis
of Alternative 2 does not project protection of additional sites beyond
the currently known, occupied sites." As a result, it is likely that
occupied nesting habitat may be destroyed throughout the years of its
implementation.

CONCLUSION AND FURTHER COMMENTS

It is clear that all of the Action Alternatives to some degree fail to
meet the legal requirement of the Endangered Species Act which
stipulates that "Each Federal agency shall...insure that any action
authorized, funded, or carried out by such agency, is not likely
to*...result in the destruction or adverse modification of habitat of
such species* which is determined by the Secretary, after consultation
as appropriate with affected States, to be critical."

Alternatives 2 and 3 are especially flagrant regarding this. To repeat,
Appendix G of the WOPR states that out of the 29 critical habitat units
(CHUs) listed, under Alternative 2 "from 2006 to 2016...20 critical
habitat units would decrease in habitat during this time period. Nine of
these 20 units would decrease in habitat by more than 10 percent.
Nesting habitat would decrease between 2016 and 2026 in 20 critical
habitat units. Two of these 20 critical habitat units would decrease
more than 10 percent." And under Alternative 3 "habitat would decrease
in 14 critical habitat units in the first decade. Three of these 14
units would decrease more than 10 percent. Nesting habitat would
decrease between 2016 and 2026 in 23 critical habitat units. One of
these 23 units would decrease more than 10 percent."

So let's be clear about this---the Action Alternatives as proposed
(especially Alternatives 2 and 3) significantly reduce the habitat
designated as 'critical' to the recovery and survival of this federally
threatened species, whose main threat has been and remains the loss and
fragmentation of its old growth nesting habitat. Moreover, to reduce
this amount of habitat from the remnant patches that remain will
increase the risk of both nestling and adult mortality due to predation,
further reducing the likelihood of recovery of the murrelet. Finally, to
a species already federally designated as threatened with extinction and
whose population is in decline throughout its range, this could be the
final push over the edge. With this in mind, I strongly urge you to
adopt the No Action Alternative in the Western Oregon Plan Revision.

Sincerely,

Erich Reeder

41 Eastwood Drive

Medford, OR 97504