**To Whom It May Concern:**

**From:** Sha Spady

**Date:** January 10, 2008

**RE: WOPR Alternative 2 Recommendation**.

Following are the comments I submitted to the Clackamas County Board of
Commissioners in December regarding their recommendation of WOPR
Alternative 2.

Simply put, I find this alternative deeply troubling considering the
situation of our planet and our resources in the 21^st^ Century.

I suggest that the BLM consider and seek out methods of managing our
public lands that do not require clear cutting -- especially of the few
remaining ancient and mature growth forests under BLM management. I
suggest the BLM consider and seek out methods for managing our water
sheds that retain maximum riparian protection on all intermittent and
year round streams regardless of whether they are fish bearing or not.
Clean water, good top soil retention, minimal chemical spraying and the
maintainance of irreplaceable eco systems should be your main focus and
concern.

Why not focus your energy, knowledge and political power toward creating
a system where you gain constant, dependable sources of revenue from our
forests left standing? Work to have carbon offsets paid by American
corporations and entities that currently are sent to foreign countries
stay in our country to leave our rain forests standing rather than
sending our dollars out of this country to other continents?

This is the 21^st^ century. Old ways of viewing, valuing and using our
planet and her resources are destroying the living system that keeps us
all alive.

I would appreciate it if you would take the time to read my testimony to
the County. Perhaps it would open you to another thought process and
more sustainable solutions.

Thank you.

Sha Spady

***[1937 O & C Ruling]{.underline}**: Timberlands shall be managed for
permanent forest production and the timber thereon shall be sold, cut
and removed in conformity with the principal of sustained yield for the
purpose of providing a permanent source of timber supply, protecting
watersheds, regulating stream flow, and contributing to the economic
stability of local communities and industries...*

*[**2007 Conditions**:]{.underline} For the first time in our history,
the fate of our species -- our entire species rests upon the choices of
a single generation. And what we're doing is talking about what some of
those choices are.*

**To**: Clackamas County Commission

2051 Kaen Road

Oregon City, OR 97045

**From**: Sha Spady

17855 Alden Street

Oregon City, OR 97045

**Date**: December 9, 2007

**[RE: O & C Recommendation WOPR -- Alternative 2]{.underline}**

Dear Commissioners,

Thank you for the opportunity to comment on the proposed WOPR
Alternative 2 recommendation. Review of the WOPR and related documents
leads me to the conclusion that Alternative 2 does not reflect Clackamas
County's proactive commitment to sustainable forest practices and models
for 21^st^ century living. A plan that is based on faulty science, that
calls for tripling current levels of cut, clear cutting over 200 square
miles of mature and ancient old-growth forests, logging in riparian
reserves, disregarding the value and function of intermittent streams by
offering them pittance protection, while ignoring the potential impacts
of climate change and 100 year storm events is not a "sustainable" plan.

**[WOPR - Alternative 2 is extreme and will:]{.underline}**

-   Increase logging by 2.9 times -- from 268 mmbf/year to 769
    mmbf/year.

-   Reduce late-succession reserve system by 47% - from approximately
    936,000 acres to 494,000 acres.

-   Clear-cut over 109,600 acres of mature forests greater than 120
    years old.

-   Clear-cut 34,800 acres of old-growth forests greater than 200 years
    old.

-   Reduce the Riparian Reserve System by 57% from approximately 364,000
    acres to 156,000 acres.

-   Reduce riparian buffers on perennial fish-bearing streams and rivers
    to 100' and allow logging is within 25 of the bank.

-   Allow yarding corridors and other operational activities associated
    with logging in the Riparian Management Zone "if needed" to access
    nearby areas.

-   Allow intermittent streams no protection unless they are in
    landslide-prone areas -- then they are given a 25' buffer.

-   Allow for the building of over 600 miles of new road and over 1000
    miles of all road types.

-   Call for the extraction of 1.72 billion board feet of timber in the
    Salem District alone.

-   Elimination of 23 existing ACEC's (Area of Critical Environmental
    Concern)

-   Partially eliminates (O&C Lands removed) in 13 existing ACEC's

> These include North Santiam ACEC, Sandy River Gorge ACEC and
> Outstanding Natural Area, Cottage Grove Old Growth ACEC, Umpqua River
> Wildlife Area ACEC, North Umpqua River ACEC, North Fork Coquille River
> ACEC, Jenny Creek ACEC, Rough and Ready ACEC, Upper Klamath River
> ACEC.
>
> (See Exhibit A)

**[WOPR -- Alternative 2 is based on faulty science]{.underline}:**

-   WOPR -- Alternative 2 management plan relies on a draft Spotted Owl
    Recovery Plan that has recently failed scientific peer review and
    the validity of its "science" is currently being investigated by the
    Interior Department's inspector general.

-   Senator Ron Wyden has requested an investigation into the alleged
    manipulation of scientific evidence by a Bush administrative
    appointee, Julie McDonald, who may have "inappropriately influenced"
    rulings on whether to protect imperiled species (such as bull trout,
    northern spotted owl and marbled murrelet) under the Endangered
    Species Act. (See Exhibit B)

-   "The Bush administration scaled back federal safeguards (riparian
    and old growth protections) for some of those species after legal
    agreements with the timber industry, which sees the safeguards as
    obstacles to logging." *[The Oregonian]{.underline} Dec. 1 2007.
    (See Exhibit C)*

**[WOPR Alternative 2 does not provide a stable, sustainable source of
funding for local communities and industries.]{.underline}**

-   Currently the market is flooded with timber. Prices are nearly 50%
    lower than in 2004. (See Exhibit D)

-   The USFS Region 6 has been "unable to sell some sales" because no
    one bid for them. It is currently more costly to log than to let the
    public forests stand.

-   Tripling the cut of public forest on BLM managed land would only
    exacerbate the problem in an already-flooded market lowering the
    price of timber still further.

-   Relying on market-driven revenue sources provides a sketchy and
    uncertain revenue stream. Counties are only assured 50% of the
    timber receipts from cuts on O&C BLM Managed lands. Surely our
    mature and old growth forests are worth much, much more than 50% of
    very little.

-   Implementation of WOPR Alternative 2 does not [insure]{.underline} a
    stable, sustainable supply of dollars to O&C Counties to fund
    services even if timber cuts are tripled.

-   If timber sales on O&C lands are managed through Stewardship
    Contracts rather than Traditional Timber Sales,
    **[\$0]{.underline}** will go to the O&C Counties from these timber
    sales.

**[Analysis, Questions, Recommendations, Conclusions]{.underline}**

Alternative 2 of the WOPR recommendation is not only an unimaginative,
out-dated and inappropriate plan for managing our public forests in 2007
but does not address or comply with the portion of the 1937 O & C Ruling
that calls for the "protection of watersheds and regulation of stream
flow" and it is arguable whether the harvest of our public O & C lands
under this alternative will significantly "contribute to the economic
stability of local communities and industries." If the O & C Counties
are seeking a stable, [sustainable]{.underline} source of funding for
local programs and services, recommending WOPR Alternative 2 as a
solution is short-sighted and fraught with environmental, social and
economic landmines.

We are currently living in the 21^st^ century faced with challenges that
the authors of the 1937 O & C Lands Act could not begin to imagine. We
currently have approximately 6.5 billion people on the planet vying for
living space and resources. In 1937 there were approximately 2 billion
people living on the planet. In 1937, magnificent stands of old growth
forests blanketed the west and "the rain forests of the pacific
northwest" were mighty, grand and stretched uninterrupted as far as the
eye could see. Those mighty rain forests are something we will never
know again. The twentieth century litany that "our forests are a
renewable resource" failed to include the disclaimer (if allowed to grow
for five or six hundred years between cuttings).

Today in the U.S. only 5% of our native forests are still standing,
scattered in fragmented pockets across our public lands. Only a few
remnant stands of the once mighty old-growth forests of the Northwest
remain and those are under constant pressure to be logged. Yet we are
spending millions of dollars each year attempting to save endangered
fish runs, which continue to falter in spite of our best "science,"
decades of restoration efforts, and millions upon millions of dollars
spent attempting to "fix" the problems. Currently even the upper
Clackamas, Santiam and McKenzie rivers run brown and muddy during even
moderate rain events while historically they ran blue and crystal clear
most of the year. Meanwhile we continue to denude our forests for
profit. But who is profiting and what is being gained?

**[Enter the WOPR]{.underline}**

**\...*providing a permanent source of timber supply...***

Alternative 2 of the WOPR provides for clear cutting (allowing for NO
green tree retention) and extraction of **1.72** **billion** board feet
of timber in the Salem District alone under the "Harvest Land Base"
category during the next 10 years. How much of this will come from clear
cutting the remnant stands of old-growth on BLM managed lands in the
County? Do you have maps showing how much of the O&C land in Clackamas
County is designated mature and/or Old Growth?

WOPR Alternative 2 also allows for the "thinning" of an additional **120
million** board feet of timber from the "Non-Harvest Land Base" in the
Salem District. Combined, this is a huge amount of timber extraction
within just one district within just 10 years. How can this possibly be
sustainable? (Especially if some of it is mature and old growth
forests).

Within the framework of true sustainability, as much (equal)
consideration would given to the impact that this level and manner of
deforestation would have upon all aspects of the environment including,
for example, oceanic conditions off the coast, global warming, carbon
sequestration etc. not to mention the impact on local wildlife,
hydrological systems and plant communities. Instead of focusing on
tripling the cut and further limiting protection to creeks and streams,
a more comprehensive goal would be *to provide a permanent source of
revenue for the counties from all sources* (not just timber management.)

**...*protecting watersheds, regulating stream flows...***

For those of us who live in urban areas, we may not fully understand the
complexities of living forests and how they are able to filter and
purify water, regulate stream flows and maintain temperatures compatible
with fish life cycles. We do, however, understand that when we cut down
our urban forests, water enters our streams muddy, it enters our streams
rapidly and cyclically and, over a period of years, cool, forested
streams once abundant with native fish and clean redds for spawning
become compromised, silt-laden and incompatible to fish habitation. The
role of a healthy network of intermittent streams is especially
important for watershed health.

WOPR Alternative 2 dramatically decreases current levels of riparian
protection. These dramatic decreases in riparian area protection
proposed under Alternative 2 were determined not only by "bad science"
(See Exhibit A) but were heavily lobbied by timber industry interests
whose value system is reflected in the philosophy "maximum cut equals
maximum dollars." Considering the enormous value of healthy watersheds
and the fragility of these salmonid-producing streams, the prudence of
further decreasing riparian protection for the few extra dollars logging
them will bring to County coffers on a one-shot basis is highly
questionable.

**Issues with Alternative 2:**

-   Protection would be lifted from all seasonal/intermittent streams
    except "landslide prone" seasonal streams, which would retain a 25
    foot buffer of non-commercial vegetation. In other words,
    clear-cutting would be done across non-slide-prone, non-fish bearing
    intermittent streams.

-   Levels of logging in the few remaining old growth stands would more
    than double under the preferred alternative. (Clear-cut -- no green
    tree retention).

-   It is the BLM's [opinion]{.underline} that there would be minimal or
    no effect on peak flows, fish, wildlife and sediment in spite of an
    overall 3-fold increase in logging, essentially an abolition of
    intermittent stream buffers and massive reductions in buffers next
    to fish bearing streams.

-   The best science available does not back this up.

> In addition, the WOPR Alternative 2 no longer requires the protections
> of

The Northwest Forest Plan. Protections would instead be administered
under the same faulty science as the proposed for the new Spotted Owl
Recovery Plan. The new Spotted Owl Recovery Plan recently failed peer
review and the Interior Department's inspector general is investigating
the activities of Julie McDonald, a former deputy assistant secretary of
fish, wildlife and parks who was found to have bullied biologists and
altered scientific findings\...that provided the framework of the
"Spotted Owl Recovery Plan." (See Exhibits A, B & C). Also missing from
the WOPR is any mention of the value of the forests as they relate to
global warming or the benefits these forests provide in sequestering
carbon.

***...contributing to the economic stability of local communities and
industries...***

Unlike the logging cultures and working condition of 1937, extraction of
timber today is almost entirely automated. What once took a crew of
loggers many days can now be done expeditiously in one day by two or
three men. Today, timber is often harvested by one man from the cab of a
processor. The processor cuts a tree, de-limbs it, bucks it to length,
bunches it and prepares it for hauling. The timber is then loaded on to
a truck and driven away -- usually far from the extraction site - for
processing.

Nothing in WOPR Alternative 2 calls for reinvestment of timber dollars
into timber communities to reinvigorate employment opportunities related
to local use for "value added" products or investments within the
community itself. It is unclear that WOPR Alternative 2 will have any
significant positive impact on employment and local business in the
local communities near the timber removal sites and therefore does not
positively reflect opportunities to build a sustainable rural economy
which is a County goal.

**[Other Timber - Related Revenue Sources Leaving County.]{.underline}**

1.  We continue to export over 40% of the raw logs cut from private
    timberlands.

2.  When this occurs, potential jobs and locally-based timber processing
    and value added markets that could financially and socially benefit
    rural Clackamas County (which is a fundamental goal for creating
    sustainable, rural, timber-based communities and economies), is
    being whisked out of the county and the country with nary a cent
    coming to County coffers or local economies.

3.  In addition, other than paying minimal property taxes on their
    private timberland and paying a small severance tax on the cut wood,
    when timber is exported, no further taxes are received inside of the
    U.S. Money paid to the private timber companies for sale overseas
    often goes into offshore accounts and the county, state and federal
    government receive nothing for it.

4.  Property taxes on private timberlands are taxed at an average of .68
    cents per acre in western Oregon. Why is this rate so low? Would not
    doubling that rate add stable revenue to the County? How is the
    County benefiting by giving property tax breaks to private/corporate
    timber interests for decades on end only to watch the revenue float
    out the door -- no strings attached? Meanwhile the rest of the
    County's taxpayers are subsidizing these investments. The logging
    companies mine the soil and export the resource with almost none of
    the money being collected to help pay for infrastructure and
    schools.

5.  Up until 1977, the Severance Tax Rates for logs cut on private lands
    in Western Oregon was approximately 12%. Today it hovers around 1%.
    (See Exhibit E). Since 35% of the collected Severance Taxes go to
    Counties, 60.5% goes to the State School Fund and 4.5% goes to the
    Community College fund, it seems an increase of the Severance Tax
    Rate would insure a much more stable funding source for County
    service and schools than logging the last of our old growth forests
    and sensitive riparian areas will.

For additional issues related to the WOPR Alternative 2, please see
Exhibit F, "The Top Reasons WOPR is a Bad Idea."

**Some [Real]{.underline} Questions to Be Asking:**

**Will tripling the cuts under WOPR Alternative 2 actually bring more
money to the coffers of Clackamas County and stimulate economic growth
in our timber communities? Or will tripling the cuts just mean
increasing the speed with which we unravel the natural systems of our
public forests for the benefit of a few timber companies at the expense
of the taxpayers? Does anybody know?**

**Does anybody know what we will be losing? What percentage (how many
acres) of O & C Lands in Clackamas County are old growth stands? What
percentage (how many acres) are "mature" stands (over 140 years old)?
How many species of plants and animals survive there? What percentage
(how many acres) of these stands are "available" under Alternative 2 for
clear-cutting? For thinning?**

**Do the O&C Counties have any assurance that timber from BLM managed
O&C lands will continue to be managed under "Traditional Timber Sale"
criteria? Do O&C Counties have any legal say if BLM chooses to
administer the timber sales on O&C lands under Stewardship Contracts?
Will O&C Counties receive any direct payments from the U.S. Treasury or
the BLM if Stewardship Contracting is implemented? Do O&C Counties have
any legal say in the matter?**

**Why it Matters: Traditional Timber Sales vs. Stewardship
Contracting:**

**[Enter Stewardship Partners and Stewardship Contracts.]{.underline}**

Stewardship "authorities" were initially put in place in 1998 by the
Clinton administration and then extended by the Bush administration in
2003. They have been weaving their way into the culture of the U.S.F.S.
and BLM ever since. Originally designed to "increase the cuts" on public
lands and **pre-empt litigation**, these authorities were tested in
pilot programs during the late '90's and early 2000's. (See Exhibit G)
Stewardship Contracts are currently being awarded and some have been
completed on the Mt. Hood National Forest in Clackamas County as of this
writing.

**[So what's the Problem?]{.underline}**

The problem is that not one cent of the millions of dollars of revenue
that came from or will come from the stewardship contracts (that
involved logging on 1350 acres of public forest land in Clackamas
County) flowed into the coffers of Clackamas County...nor were they
intended to. By "law" the proceeds from stewardship contracts "stay with
the agency," in this case the USFS. Under a Traditional Timber Sale, the
County would have received 25% of the revenue from these sales on Mt.
Hood National Forest.

**[So What Does This Have To Do With the WOPR & O& C
Counties?]{.underline}**

The problem arises if the BLM chooses to employ Stewardship Contracting
instead of Traditional Timber Sales as their method of choice in
managing O&C Lands. Instead of receiving 50% of the timber receipts from
a sale as they currently do under Traditional Timber Sales, if
Stewardship Contracting is employed, the Counties will receive
**[\$0]{.underline}**. It "appears" that the Stewardship Authorities
trump the O & C Act of 1937 but, to date, there has not been a court
ruling proving or disproving this. One might seriously question whether
receipts from BLM managed O & C lands will provide a long-term, stable
funding source.

**[So Why Is That a Problem?]{.underline}**

The O&C Counties have no legal authority over the BLM or the U.S. Forest
Service. **\*** The recommendation the O&C Counties are making regarding
WOPR Alternative 2 is just that, a recommendation. If the BLM and/or
USFS continue to forward Stewardship Contracting as their method of
choice, what recourse will the O&C Counties have? The ultimate power to
decide what happens to our public forests and where the money goes lies
solely in the hands of the BLM or USFS and, therefore, the political
group currently in power.

**\***The County receives \$0 from Stewardship Contract sales since 100%
of all receipts (as granted by the Stewardship Authority) remain in the
district (Forest Service or BLM) where they were sold. None of the money
received from "Stewardship" harvests goes to the U.S. Treasury and,
therefore, none comes back to the County*. (Sec.347 (d) (3) Relation to
other laws.---The value of services received by the Secretary under a
stewardship contract project conducted under this section, and any
payments made or resources provided by the contractor or the Secretary
under such a project, shall not be considered to be monies received from
the National Forest System under provision of law.*

It concerns me that in the establishment of Cooperative Conservation,
the federal government remains the sole, legal authority on how our
public lands will be administered and managed while the appearance of
"partnership" is being projected to the community. Though seated at the
table, the recommendations of conservation groups, non-profits and
well-intended citizens are just that, recommendations. We, the people,
(the Counties and the State) have, ultimately no say in what happens to
our resources...just as we have no say when private lands across the
state are condemned by the Federal government to benefit private
industry (for-profit gas lines and LNG terminals).

The stewardship contracts provide the illusion of public participation
by inviting community groups, watershed councils, soil and water
conservation districts, \"green\" groups and industry representatives to
a \"place at the table\". Ultimately however, the final say in
[all]{.underline} decisions lies with the regional administrators of the
managing agency.

By the end of fiscal year 2007 there are expected to be over 300
stewardship contracts either completed or active on the public lands of
this nation. I am concerned that what appears to be a benign and
collaborative process for the intended wellbeing and restoration of our
public lands will become an Orwellian nightmare. (See Exhibit H
Beaverhead Dearlodge Partnerships by George Wuerthner). One of the most
vital questions for the O&C Counties to answer may not be which
Alternative of the WOPR to recommend but how to insure that O&C lands do
not fall into the welcoming arms of stewardship contracting.

**Conclusion:**

To manage our public forests, (the lungs of our planet) based on an
industry-biased interpretation of a 70 year old law is, from my
perspective, archaic and indefensible. Tripling cuts, clear-cutting old-
growth ancient forests, logging in riparian reserves, disregarding the
value and function of intermittent streams and ignoring the potential
impacts climate change and 100 year storm events may have upon these
forests is not a 21^st^ century solution - nor does it lead to
environmental sustainability.

It is clear that within the context of Clackamas County's commitment to
sustainability, "tripling the cut" under WOPR Alternative 2 is not in
alignment with our stated objectives. Signing on to a process that may
encourage the wholesale cutting of our public lands in a manner that
returns next to nothing to the public is troubling. Under these
circumstances, how is signing on to WOPR Alternative 2 a prudent
recommendation?

WOPR Alternative 2 does not allow the forests and watersheds time to
heal and regenerate. WOPR Alternative 2 will not solve the financial
problems facing our rural communities and county coffers rather, **it
insures a long-term outflow of timber from the County, not a steady
income to support County services.** WOPR Alternative 2 does not reflect
the opportunities we have to create some truly innovative solutions to
support life-sustaining forest practices on the planet in 2007.

One powerful definition of insanity is doing the same thing over and
over and over expecting different results. How many more times can we
damage our northwest rain forests before they are unable to heal? A
21^st^ century model for sustainable living cannot be based upon "human
entitlement" and "profits" alone. That model of living has brought us to
the verge of extinction. Let us create a different future. Let us move
forward in a truly conscious and sustainable manner balancing the needs
of our local environment, our local communities and our local economy in
the face of this industry-driven plan.

**[Recommendations]{.underline}**

I invite you, the Commissioners of Clackamas County, to take this
opportunity to show courage and vote against the recommendation of WOPR
Alternative 2. Instead, please consider recommending the following:

1.  **[No]{.underline}** harvest of mature (140 years or older) or old
    growth (200 years or older) forests be considered under any WOPR
    Alternative.

2.  Request the BLM subject the WOPR to peer review and that the agency
    consider other alternatives that rely on logging of smaller trees
    rather than further liquidation of old-growth forests and riparian
    areas that represent irreplaceable resources to Oregonians and the
    nation.

3.  Make recommendation to the O & C Counties and BLM that all current
    protections governing riparian buffer protection remain constant or
    increase.

4.  Instead of valuing public forests [only]{.underline} as a source of
    timber, encourage the BLM to sell carbon offsets on these O & C
    mature and old-growth stands as a source of revenue on our public
    lands; leave the trees and the watersheds intact and still receive
    revenue. Currently, we in the United States are paying many dollars
    for carbon offsets in other part of the world. Why not pay here? Why
    not let the money currently being paid for carbon offsets in other
    countries go to protect our own ecosystems here in the United
    States? In Clackamas County? On O & C Lands?

5.  Instead of relying on WOPR Alternative 2 to solve County financial
    woes, seek consideration among the O&C Counties of implementing and
    lobbying for alternative, more sustainable revenue sources such as
    Service Development Charges on new construction, timber export
    taxes, increases in STF Severance Tax Rates, and/or increase
    property tax rates for timber deferred lands. A doubling of the
    property tax rate on private/corporate timberlands would still be
    well under \$2 per acre per year.

6.  Negotiate an agreement between the O & C Counties and the BLM that
    insures all timber sales on BLM managed O & C public lands be
    managed via Traditional Timber Sales not via Stewardship
    Contracting.

7.  Encourage the AOC to look for methods and mechanisms for funding
    community services other than with timber dollars as a more stable,
    sustainable approach to meeting long-term, fiscal needs.

The Clackamas County Commission has embraced sustainability and proven
their commitment through actions (gaining National recognition for the
County's new LEED building, establishing a Department of Sustainability
and funding and supporting the work of the Green Ribbon Committee) as
well as with words. By embracing sustainability, you have committed to
being conscious of and responsible for the impacts our choices and
actions have not only on the health of our economy but on the health of
our social and our natural systems as well.

The stand that you, as Clackamas County Commissioners, take in your
recommendations regarding O&C Lands WOPR -- Alternative 2 is an
opportunity to provide strong and thoughtful leadership in a
highly-contentious dialogue. Please consider adopting and forwarding the
above recommendations to the O & C Counties. We have much to lose under
WOPR Alternative 2 (irreplaceable old growth forests) and little to gain
(50% of a little is a little less).

And, remember when considering whether or not to support a plan that
calls for doubling or tripling the cut...

**Twice as much**

**Aint twice as good**

**And can't sustain**

**Like one half could**

**It's wanting more**

**That's going to send us to our knees.**

Thank you for your time and consideration of these issues.

Sincerely,

Sha Spady

Oregon City, OR 97045