> **Birch Creek Arts and Ecology Center**
>
> **P.O. Box 1330 Jacksonville, OR 97530**
>
> **541-899-1696**
>
> I am writing to BLM as president of the Board of Directors for Birch
> Creek Arts and Ecology Center, a public benefit corporation that
> operates a retreat, education, art and nature center and campground in
> the scenic Little Applegate River canyon in Medford District's Ashland
> Resource Area. We are hosted by historic Trillium Farm, a former trout
> hatchery that continues a 60-year tradition as a center for camping
> and outdoor recreation and education.
>
> A large part of our success is the beautiful scenery, quiet
> surroundings, and wilderness quality backcountry of the BLM lands that
> surround us. We draw our guests, students, and interns from all across
> the country and abroad.
>
> Even with the gorgeous scenery, the first thing nearly all guests
> remark about after their arrival is the quiet. "It's so quiet here",
> they'll say. Even though the river sings with white water over the
> rocks, the creek spills over a loud waterfall, wind whistles through
> the trees, and birdsong fills the air, our guests remark about the
> quiet. The lack of mechanized noise. Our experience shows that such
> quiet is truly a valuable natural resource, one that people will pay
> well to experience, especially as quiet places disappear in our
> increasingly noisy cultural landscape.
>
> When writing the final Environmental Impact Statement for the Western
> Oregon Plan Revision, we urge BLM to include quiet as a marketable
> natural resource important to local rural economies and to identify
> actions that would diminish this increasingly valuable natural
> resource. As a specific example, we discuss below a plan in the DEIS
> that would introduce large amounts of disruptive noise into this
> traditionally quiet river canyon.
>
> Our community outreach program includes Threatened and Endangered
> Little Applegate Valley (TELAV), which has been educating and
> involving local citizens in land use planning issues for nearly 3
> decades. TELAV has prepared these comments for the Board of Directors
> of Birch Creek Arts and Ecology Center.

**Off-Highway Vehicle (OHV) Emphasis Areas**

> In its Western Oregon Plan Revision (WOPR) Draft Environmental Impact
> Statement (DIES), BLM has listed Anderson Butte as a potential
> Off-Highway Vehicle (OHV) Emphasis Area of over 11,742 acres. This
> vast area encompasses the entire north half of the river canyon, and
> nearly surrounds our location, including our entire drinking
> watershed. While the criteria for choosing such Emphasis Areas appears
> to have been limited to current OHV use, a high level of important
> natural resource values indicate that Anderson Butte would be a poor
> choice for a destination OHV Emphasis Play Area.
>
> 1\. Critical Deer Winter Range: According to the WOPR DEIS (page 331),
> 11,094 acres of designated Deer Habitat Management Area, also known as
> Critical Deer Winter Range are within the potential 11,742-acre
> Anderson Butte OHV Emphasis Area. The present Resource Management Plan
> (RMP) Record of Decision (ROD) (page 48) directs BLM to "manage (these
> wildlife areas) with an emphasis on providing thermal cover and
> minimizing disturbances"; and to "restrict activities to avoid
> disturbance between approximately November 15 and April 1." Since most
> OHV activity occurs during autumn/winter/spring seasons and by nature
> is an activity that constitutes a major disturbance to wildlife,
> designation of this area as an OHV Emphasis Area would be
> counter-productive to its management as an important wildlife resource
> value.
>
> This deer range constitutes an important traditional hunting ground
> for many local families and hunters from even distant locations who
> desire a wilderness quality hunting experience. Such hunters
> contribute to our local rural economy by patronizing campgrounds,
> stores, gas stations, and inns.
>
> The Izaak Walton League of America recently published *Collision
> Course: Off-Road Vehicle Impacts on Hunting and Fishing.* This study
> contains a survey of State Wildlife and Fisheries Managers in 34
> states conducted in July and August 2007. 61% of the managers agreed
> that "ORV's negatively impact hunting and habitat" in their state.
> Regarding specific impacts to hunting, the managers reported: resource
> damage to habitat (83%), disruption of hunters during hunting season
> (72%), increased accessibility to formerly remote hunting areas (67%),
> disruption of game species during hunting season (61%). Only 47% of
> the resource managers felt that "existing regulations adequately
> protect hunting from harmful ORV impacts."
>
> 60% of the managers agreed that "ORV's negatively impact fishing and
> fishing habitat" in their state. Regarding specific impacts to
> fishing, the managers reported: ORVs driven along stream banks &/or
> lake shores (87%), ORVs driven in streams &/or lakes (80%),
> ORVscausing erosion or siltation into streams &/or lakes (67%). Only
> 37% of the resource managers felt that "existing regulations
> adequately protect fishing from ORV impacts.

The proposed OHV Emphasis Area centers on Anderson Butte east to Bald
Mountain, a long east-west trending ridge separating the Bear Creek
watershed to the north and the Little Applegate River watershed to the
south. While both the north and south slopes of this ridge contain
Spotted Owl core areas that require seasonal protections, the two sides
of the mountain are dramatically different. The north slopes are
primarily forested and intensively roaded as a result of extensive
timber harvest activities on BLM and private industrial lands. In
contrast, the south slopes of Anderson Butte are characterized by
roadless wildlands composed of a complex mosaic of various ecosystems.
These southern slopes contain multiple natural resource values that must
be examined when considering designation as an OHV Emphasis Area.

a.  Proposed Dakubetede Wilderness: This area comprises an approximately
    6500 acre roadless area that was first nominated for consideration
    as Wilderness in 1980. This area's extensive and popular Sterling
    Mine Trail System, outstanding scenery, wilderness character, and
    unique biodiversity all make it a superlative candidate for the
    unique level of protection afforded by Wilderness designation. The
    Dakubetede is prominently featured in the book *Oregon Wild:
    Endangered Forest Wilderness* and is a unit of the proposed Siskiyou
    Crest Wilderness advocated by several conservation organizations.
    Its trail system is featured in several guidebooks to Oregon hiking
    trails. For some inexplicable reason the Dakubetede was not chosen
    by BLM in the WOPR DEIS process for inclusion in the list of lands
    with Wilderness Characteristics (pages 417-18, and Appendix K), even
    though it has a longer and more intensive level of advocacy for
    wilderness than other areas that were chosen. The issue of
    Wilderness protection for this area has made the Dakubetede Wildland
    a high profile and controversial area for decades. The lack of its
    inclusion as described above will likely be a source of critical
    comments on the WOPR DEIS. Meanwhile, designation of the Anderson
    Butte OHV Emphasis Area would be a most controversial decision, a
    controversy BLM would do well to avoid.

b.  Biodiversity Hot Spot: The proposed Dakubetede Wilderness discussed
    above comprises an unusual concentration of diverse ecosystems and
    biodiversity elements. Located in the rain-shadow of the Siskiyou's
    highest peaks, this area's arid microclimate is possibly the driest
    and sunniest location in western Oregon. As such contains the
    largest, most diverse, northern extent of California chaparral shrub
    communities in Oregon. It is home to the largest groves of
    old-growth juniper stands in western Oregon; contains the second
    largest populations of the listed *Frittilaria gentneri*, and the
    endemic *Sedum oblanceolatum*, and the only known Oregon location of
    a rare birch, *Betula occidetnalis inopina.* The area has extensive
    intact native grasslands (a magnet for OHV traffic), and is
    noteworthy for its lack of yellow star thistle. Many, if not all, of
    these important biodiversity values (and the wildlife that depend on
    them for habitat) would be negatively impacted by increased OHV use.

c.  Sterling Mine Ditch Special Management Area (SMA): The Sterling Mine
    Ditch is an important cultural and historical resource that BLM has
    managed as an SMA in compliance with the Antiquities Act. The
    Sterling Mine Ditch, approximately 20 miles in length on BLM land,
    traverses the south slopes of the Anderson/Bald ridge. According to
    the present RMP ROD (page 60) and the WOPR DEIS (page 142), this SMA
    is closed to OHV use, a closure that would be extremely difficult to
    enforce if the surrounding 11,742 acres was designated an OHV
    Emphasis Area.

d.  Sterling Mine Ditch Trail System: This trail system has always been
    closed to OHV use, and as such, has been very popular with hiking,
    hunting, and horse enthusiasts who desire a wilderness trail
    experience without the user conflicts associated with motorized
    recreation. Because of its location in dry lower elevations, this
    trail system provides year-round access and is especially popular
    during winter months when higher elevation trails are covered with
    snow. The WOPR DEIS (table page 127) is in error regarding the
    extent of the Sterling Mine Ditch Trail system. The mileages in this
    trail system should read: Sterling Mine Ditch Trail (Deming Gulch to
    Little Applegate): 18 miles, Wolf Gap Trail: 2 miles, Bear Gulch
    Trail: 1 mile, Tunnel Ridge Trail: 1 mile (not 41 miles!), and
    Little Applegate Trail: 1 mile. The combined 23 miles of
    historically maintained hiking trails make this trail system second
    only to the Pacific Crest trail in length within the Medford
    District. According to the present RMP ROD (page 60) and the WOPR
    DEIS (page 142), most of the Sterling Mine Ditch Trail system is
    closed to OHV use, a closure that would be extremely difficult to
    enforce if the surrounding 11,742 acres was designated an OHV
    Emphasis Area.

e.  Other Hiking Trails: Hidden Creek and Listening Tree are short
    hiking trails (1 mile each according to WOPR DEIS \[page 127\] that
    have been managed as Environmental Education Areas with OHV use
    restricted to existing roads according to the present RMP ROD (page
    58). Recreation opportunities and OHV related negative impacts are
    similar to those described in the Sterling Mine Trail System
    discussion above.

f.  Dakubetede Wildland ACEC Proposal: The WOPR DEIS (page 127) lists a
    potential 1796-acre Dakubetede Wildland ACEC located on the south
    slopes of Anderson Butte. Designating the surrounding several
    thousand acres as an OHV Emphasis Area would create negative OHV
    impacts to this sensitive area incongruent with adequate protection
    mandated as an ACEC.

g.  Holton Creek Research Natural Area: This is a 423-acre old-growth
    reserve located on the north slopes of Point Mountain. According to
    the present RMP ROD (page 61), this RNA is closed to OHV use, a
    closure that would be extremely difficult to enforce if the
    surrounding 11,742 acres was designated an OHV Emphasis Area.

h.  Bald Mountain Cultural Resource: There is an indigenous sculpture
    (boulder arrangement) in the grassland below the summit of Bald
    Mountain. OHV use is the biggest threat to the continued integrity
    of this important cultural resource.

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1.  Existing OHV Damage on Crests

> OHV damage currently exists along most of the major crests in the
> potential Anderson Butte OHV Emphasis Area, including unauthorized
> trails cleared by OHV users. The damage ranges from an eroded hill
> climb on Goat Cabin Ridge to excessive use on the old crest trail that
> once connected the lookout towers that topped Anderson and Wagner
> Buttes. Unlike the areas hiking trails, the OHV trails are extensively
> littered with beer cans, bottles used for target practice, shotgun
> shells, and other trash. Through personal communication with several
> OHV users in the area over the years, it appears current OHV use is
> limited to relatively small groups of users, some of whom fear that
> designation of the area as an OHV Emphasis Area would bring in
> unwanted new users and further degrade the area. Such designation
> would undoubtedly lead to severe increases in all negative impacts of
> OHV use.

2.  User Group Conflicts

Present BLM guidance under the RMP ROD (page 63) states: "Manage OHV use
on BLM-administered land to protect natural resources, provide visitor
safety, and minimize conflicts among various users." The potential
Anderson Butte OHV Emphasis Area is already a long-established home to
hikers, birders, hunters, horseback riders and others seeking quiet
recreation; increased OHV use should not be added to the mix.

3.  ANN MOU

Many residents of the Little and Upper Applegate areas who are concerned
about BLM management have entered into a cooperative Memorandum Of
Understanding (MOU) agreement with BLM to better explore possible
solutions to management conflicts. This process has thus far been
beneficial in addressing timber, wildlife, water quality and other
issues. Designation of an Anderson Butte OHV Emphasis Area would be a
big step backward in what has been a hopeful exercise for both residents
and Ashland Resource Area management and staff.

4.  OHV Summary

On behalf of my neighbors in the Applegate, and my colleagues in the
natural resource utilization and conservation communities, I urge you to
use the discussions above as rationale for your internal BLM
recommendation that the Anderson Butte area be removed from further
consideration as potential OHV Emphasis Area in the Final EIS for WOPR.
While much focus has been placed on providing OHV areas, where is the
balanced focus on providing quality areas for non-motorized recreation?
This is inconsistent with your DEIS, which predicts a 27% increase in
non-motorized recreation vs. only a 5% increase in motorized recreation.
Additionally, the 2004 Oregon Statewide Trail User Survey (used to
create the *Oregon Trails 2005-2014: A Statewide Action Plan*;
(see: [[http://www.oregon.gov/OPRD/PLANS/docs/trails/StatewideTrailsPlanFinal.pdf]{.underline}](http://www.oregon.gov/OPRD/PLANS/docs/trails/StatewideTrailsPlanFinal.pdf))
indicates 438,000 Oregon households engage in non-motorized trail
recreation, while only 98,000 Oregon households engage in motorized
trail recreation. Why isn't the amount of recreation planning balanced
with predicted & actual uses? Please explain in the FEIS how your OHV
proposals are linked to funding (provide figures) from Oregon State fuel
taxes, and how that funding might continue if contemplated changes are
made to the existing motorized recreational tax funding programs.

**Forestry Planning**

> The DEIS proposes vast acceleration of converting native forest stands
> to intensively managed plantations. This proposal triggers questions
> more than comments. Please answer these questions in the FEIS.

a)  Any long-range forestry plan must justify anticipated growth of
    plantations. Previous research in the Medford District (on file at
    Medford BLM) indicates that the ORGANON modeling program used by BLM
    to estimate future growth of plantations grossly overestimated tree
    growth while underestimating negative impacts such as clumpiness,
    non-stocked openings, and animal damage. What surveys and modeling
    is BLM using for these WOPR proposals? Please indicate how which
    data were utilized to obtain results displayed in the FEIS.

b)  Even adequately growing plantations must survive to maturity to
    provide the economic values described in the DEIS. Review of
    plantations in the Medford District indicate that compared to native
    forest stands, plantations are more susceptible to damaging, and
    often fatal, impacts from several sources. Even-aged plantations are
    more susceptible to animal damage, pathogens, and environmental
    damage (windthrow, solar insolation, drought, vegetative
    competition) than native forests. Fire history also indicates that
    plantations are more likely to burn catastrophically than native
    forest stands. How has BLM computed these risks into the predictions
    of plantation growth?

c)  BLM admits in the DEIS that the thinned forests and native forests
    converted to fiber plantations will significantly increase fire
    danger at the landscape scale while reducing the resiliency of the
    forest stands to survive fire. Please indicate quantified rationales
    for increasing such fire danger, and include amount of increased
    funding required for more firefighting, slash management, impacts on
    local communities.

**Forests and Economics**

The WOPR combines forestry and economics toward a specific set of goals.
The entire plan is based on the assumption that there is a hungry timber
industry waiting anxiously to bid on every timber sale the federal
agencies can design and offer. However, such has not been the case. Even
prior to the current housing market slump and mortgage crisis, many BLM
timber sales in the Medford District did not attract bids. Now, as any
investment analyst will declare, the housing market and related
industries are not looking good these days. How does BLM plan to meet
its WOPR goals if a reduced demand for wood products even further
reduces demand for BLM timber sales?

The WOPR proposals would result in a drastic change in the scenic and
environmental amenities on our area. We fear that tourist related
business would suffer in any of the action proposals are implemented.
Research indicates that economic growth in rural Oregon counties is
associated with protected areas on federal land. To quote from
*Environmental Protection, Population Change and Economic Development in
the Western United States*:

> "This analysis shows that the presence of protected federal lands is
> associated with population growth, income growth and employment
> growth. While it does not prove that protected lands cause this
> growth, it does provide support for the argument that, in the rural
> West, economic security is associated with counties that no longer
> rely on the environment as a source of raw materials for export, but
> instead use the environment as a magnet to attract tourism, retirees,
> and small businesses."

We would appreciate any answers you can provide in the following
questions to help us address our concerns.

Has BLM conducted research on the possible impacts that the WOPR will
have on individual Oregon residents and the economic future of
non-timber businesses in rural Oregon communities?

How will the WOPR impact the value of Oregon residential, agricultural,
and business property in the O&C corridor?

We are concerned that the WOPR will make our property investments more
difficult to market for the highest dollar value.

Has BLM conducted any research that explains the potential loss of
property value and property marketability the WOPR might inflict on land
owners in the O&C corridor? What research have you done to clarify how
the loss in property value will be off-set by a higher or equal value in
the reduction of property taxes?

How will the WOPR impact the economic viability, sustainability, and
future of tourism dependent businesses in the O&C corridor? The reason
for our concern is the severity of the impacts the logging in
Alternative 2 will have on visual resources, which the BLM describes in
their visual resource index (VRI) as visually obvious and distracting to
the casual observer.

Research on tourism indicates the majority of Americans travel to see
scenery while other studies indicate the majority of travelers choose
destinations where the community has preserved is natural and cultural
heritage. How are we supposed to market ourselves in a landscape of
clear-cut logging? Has BLM done any research on marketing strategies for
O&C communities who must readjust their current economic planning to
survive under the force of these impacts?

We are also concerned about the perception that the traveling public
will have when they see clear-cuts. Most people who have never seen a
clear-cut describe their first experience as if they had just seen an
area ravaged by an atomic blast. This is going to make it difficult to
market ourselves as place that preserves its natural and cultural
heritage! Has BLM done any research on how tourism businesses are going
to market the O&C corridor as a travel destination with the loss of this
strategic marketing value? What will be the net loss of this
marketability and how are you proposing to assure tourism businesses
will survive and grow after the WOPR destroys Oregon's strategic tourism
industry marketing values?

We have read that tourism is predicted to be the number one industry in
America within the next decade. How will the WOPR impact the ability of
communities in the O&C corridor to expand and grow in a direction that
will enable them to capture these dollars for their economy? Do you have
any information to assure us and owners of tourism-based businesses that
the WOPR is not going to cause a gradual decline and annihilation of
tourism dependent businesses and hence the annihilation of the
community's ability to capture tourism dollars?

Can you explain how the economic value we gain from logging will provide
an equal or greater economic return to the communities that have lost
their tourism industry? Will there be new jobs for the tourism
businesses that may go out of business as a result of the WOPR?

Considering that the American dollar is weakening against other
currencies around the world, have you done any research to help O&C
counties understand how the WOPR might impact their ability to compete
in the global tourism market and help get our money back into this
country?

Tourism is a non-outsource-able resource. No one can take our tourism
resources away from us and move them to another country. For that
reason, we feel it is foolish to support a forest management plan that
risks destroying tourism resources that could bring hundreds of millions
of dollars to the O&C corridor *every year*. We are extremely concerned
about the economic future of Oregon under a plan that destroys tourism
for the purpose of committing our O&C lands to timber production that
contributes to Oregon's economy at an agonizingly stale cycle of once
every 80-100 years.

Has BLM done any research on the impacts the WOPR will have on the
quality of life in the O&C corridor and how this might impair the
ability of communities to attract business development or attract
home-based entrepreneurs and service providers who create their own
jobs?

We are concerned that the intense logging proposed in the WOPR is going
to detract from our quality of life by making O&C lands unusable to the
public and that this in turn will reduce or limit the ability of a
community to expand or diversify its quality of life resources.

The loss of quality of life resources will have extended impacts. For
example, if we were able to expand the number of equestrian trails on
O&C lands, we might attract more people to move into the area who own
horses. This will benefit local feed and tack stores and increase the
opportunity of selling agricultural products such as locally grown hay.
Equestrian trails on O&C lands would increase the opportunity for
attracting riding clubs or holding annual riding events, which increases
tourism spending. Has BLM done any research on how the exclusion of
quality of life from WOPR planning is going to impact significant
economic opportunities for the community?

Has BLM done any research on the role quality of life plays in
attracting business development or recruiting the development of
non-timber industries in a community?

Has BLM created a list of potential quality of life alternatives and
researched the potential economic contribution they could make to a
community and estimated what will be lost if they are displaced by
timber practices that minimize quality of life values? For example:

[Equestrian trails]{.underline}: Increases property value, benefits
local shops, increases tourism opportunities.

[Walking trails]{.underline}: Walking is the number one recreation in
America. Healthy lifestyles are a strongly marketable attribute.
Increases property value, increases tourism opportunities, increases
community health.

[Biking trails]{.underline}: Mountain biking is a popular sport with Gen
X. Increased mountain biking would benefit local shops, increase tourism
opportunities, and make the community a more diversified living
experience which contributes to the value of property.

[Wildlife habitat]{.underline}: Birding is the fastest growing activity
in America. Forest attributes that create a diversity of bird habitats
increases the opportunity for marketing the area as a place for a
diversified living experience. Property value increases, increases
opportunities for tourism marketing.

[Quality of life values]{.underline}: QOL values attract home-based
entrepreneurs and internet-based service providers. Increases the number
of jobs in the community, their income is able to purchase other
services in the community such as construction, landscape maintenance,
house cleaning, etc.. QOL may also play a role in attracting business
and clean industry.

[Unique logging practices such as the Natural Selection
Alternative]{.underline} (Page 108 Vol. 1 of the Draft WOPR): This
proposed alternative was rejected by the BLM but should have been given
more consideration because it creates a unique cultural marketing
opportunity with a forest management practice that harvests timber in a
way that creates recreational and tourism resources. A unique forest
management practice give us powerful publicity marketing values, long
term local forest jobs, increased opportunities for tourism, walking
trails, equestrian trails, mountain biking trails, birding, and
interpretive trails.

Does timber harvesting on O&C lands create an equal or greater economic
return than these six alternative economic strategies?

Has BLM given any thought as to how we can use timber management to
obtain wood fiber AND create quality of life values that enable each
acres of O&C land to contribute to the local economy every year rather
than once every 80-100 years? We are very concerned about how the WOPR
will impact Oregon's future economy with its strategy that commits each
acre of O&C land to a cycle contributing to the economy at an extremely
stale rate of once every 80-100 years. Has BLM done any research on how
we can make these lands productive every year rather than once every
80-100 years?

**Forests and Politics**

The WOPR is based on the antiquated 1937 O&C Act. Politics, while
sometimes painfully slow, does eventually respond to current conditions.
With political change in the air in this election year, has BLM
developed an option to deal with a possible re-interpretation or
replacement of the O&C Act?

**Forests and Science**

The WOPR is based on faulty science regarding the viability of the
spotted owl and salmon and inadequate measures to protect them under the
Endangered Species Act. WOPR should stop now and wait for the issues and
scandals surrounding endangered species to be investigated and
rectified. Otherwise, this process will be a huge waste of time and
taxpayer dollars. Should that happen, who is responsible and accountable
for deciding to continue pushing the process forward?

**Conclusion**

We are very alarmed that the WOPR is sending Oregon in a direction of
economic stagnation, reduction of property value, increased tax
liabilities, lower quality of life, impairment of our ability to recruit
business and industry, and loss of tourism and tourism dependent
businesses. The questions above must be answered during the preparation
of the FEIS. We recommend that the WOPR process be halted while the
questions are answered and the answers are presented as an amendment to
the DEIS.

Respectfully submitted,

Chant Thomas, President

Birch Creek Arts and Ecology Center

Jacksonville, OR 97530