**November 2, 2007**

**Western Oregon Plan Revisions Office**

**Bureau of Land Management\
333 SW 1st. Avenue**

**Portland, OR 97204**

RE: Comments on Western Oregon Plan Revisions

The Southern Oregon Small Diameter Stewardship Collaborative (the
Collaborative) is pleased to offer these comments on the Western Oregon
Plan Revisions.

The Collaborative consists of a diverse group of stakeholders who share
a long term goal to remove small diameter trees from
uncharacteristically dense forests in the Rogue Basin. We believe this
is critical in order to improve ecological health and resiliency, reduce
the risk of uncharacteristically severe wildfire, and improve the
region's economy and quality of life.

The Collaborative has developed a set of "Productive Harmony Guidelines"
with consensus support and has signed a formal Declaration of
Cooperation committing us to working together to apply these guidelines
to at least 10,000 acres over the coming year. (Both documents are
attached and incorporated as part of these comments.)

Individuals within our Collaborative will be commenting separately from
their own perspectives. As a group, however, the Collaborative would
like to offer the following specific comments:

1.  We believe collaborative work with stakeholders and communities is
    critical to the long term success of any federal agency strategy. We
    would like to see the selected alternative explicitly encourage and
    provide legal authority for federal agency collaboration with
    community-based and stakeholder groups.

2.  We encourage you to consider the Productive Harmony Guidelines
    produced by this group as you select and implement a final
    alternative. For example, we understand the analysis of Alternative
    1: Subalternative 1 found that a "thinning only" approach could meet
    ASQ targets for less than a decade. However, a broader definition of
    "thinning" and "small diameter," such as that embraced by our
    Collaborative, might yield more promising results and we encourage
    you to evaluate such an approach. For example, our Productive
    Harmony Guidelines include a flexible characterization of "small"
    that generally includes trees up to 20" dbh.

3.  Whatever alternative is chosen, we encourage BLM to continue to
    encourage the harvest and utilization of small diameter material as
    a strategy for improving ecological health, reducing fire risk, and
    improving and diversifying the region's economy. Some members of our
    Collaborative support additional harvest of larger trees, while
    others oppose projects that do not meet these guidelines. However,
    we all believe that small diameter projects that meet our guidelines
    will enjoy broad community support and that the economics of such
    projects will improve over time.

We look forward to continuing our work with BLM and other federal land
management staff. Thank you for this opportunity to comment.

Sincerely,

Jeff Allen, Coordinator

Southern Oregon Small Diameter Stewardship Collaborative

Attachments: Declaration of Cooperation (including signatory members of
the Collaborative)

Productive Harmony Guidelines

**DECLARATION OF COOPERATION**

**Southern Oregon Small Diameter Collaborative**

**[What We Will Accomplish]{.underline}**

Forest ecosystems in southern Oregon have been altered through a long
history of logging practices and fire exclusion, which has lead to
uncharacteristically high densities of small diameter trees and brush.
This results in a greater likelihood and severity of wildfire, and has
altered the function of these fire-adapted ecosystems, often with
negative consequences.

In the last several decades, the communities of the Rogue Basin have
also undergone profound social and economic changes. Most sawmills that
proliferated in the region are gone, along with much of the social and
economic infrastructure that supported the timber industry.

In the midst of these changes, residents in the Rogue Basin continue to
be actively interested in forestry activities that can reduce the risk
of catastrophic fire, promote ecological health, and provide employment
opportunities. Progressive and increasingly accepted methods of
ecosystem restoration are being developed to restore forests to
healthier and more vigorous conditions. However, social, economic and
technical limitations have prevented large scale harvest and utilization
of small diameter trees, both traditionally commercial and
non-commercial.

The Small Diameter Stewardship Collaborative has come together to
encourage landscape level attention to these conditions and to work for
collaborative solutions. We are a diverse group of stakeholders who
share a long term goal to remove small diameter trees from
uncharacteristically dense forests in the Rogue Basin. We believe this
is critical in order to improve ecological health and resiliency, reduce
the risk of severe wildfire, and improve the region's economy and
quality of life.

Our specific goals and objectives are spelled out in our strategic plan.
Our success will be measured by an increased supply of small diameter
material removed, reduced risk of unusually severe fires, improved
ecological health, and an increase in jobs and economic activity.

**[Who We Are]{.underline}**

The Collaborative welcomes participation from any interested person or
organization who shares our goals, objectives, and approach.
Participants in the Collaborative can choose one of the following
levels, which can be seen as a series of concentric circles.

**Core Participants.** These core participants are the only ones who
have a formal voice in the consensus decision making process, as
outlined below. (However, core participants can and generally will
invite others to participate in discussions leading up to decisions.)
Core participants are expected to attend general meetings on a regular
basis (at least 75% attendance) or designate an alternate. There may
only be one core participant from any single organization. Initially,
core participants will be those signing this document and choosing to
participate at this level. Future core participants must sign and agree
to this declaration, and be approved by consensus of the existing core
participants. They will generally work first as non-voting core. A core
participant may be removed with a consensus agreement of all other core
participants attending a meeting where this removal has been placed on
the agenda in advance.

**Non-Voting Core Participants**. These are integral members of our
effort, providing key information and support, but who for whatever
reason choose not to participate in the decision-making process. For
example, federal employees will generally need to serve as non-voting
core participants due to regulatory restrictions regarding participation
in advisory committees. Anyone may become a non-voting core participant
by stating their support of this document outlining the Collaborative's
purpose and plans.

**Friends.** This category is open to anyone who would like to be kept
abreast of our progress, or who can help inform our work, or support it
financially. Friends may join our listserve and review and comment on
documents and in work groups and committees as they wish. Our process,
documents, and meetings will be open and transparent.

**[How We Will Work Together]{.underline}**

**Consensus.** Core Participants will guide our work using a consensus
decision making process, which we define as "a group decision process
which actively seeks and considers the opinions of all members in an
open atmosphere and arrives at a decision that best satisfies everyone's
preferences and feelings without anyone feeling an unacceptable level of
conflict." Core participants will follow the specific procedures
outlined in this section, although these procedures may themselves be
changed by consensus of the Core participants.

**Quorum.** If a meeting has been called, with the meeting time, place,
and agenda circulated at least one week prior to the meeting, then those
Core Participants attending are deemed to constitute a quorum.

**Blocking.** Core Participants have the right to "block" a decision,
which means the decision does not move forward to implementation.
Blocking should not be done lightly, but should be a well thought-out
conclusion. One should withhold consent or block a proposal only based
on some concern, truth or understanding that in the best interests of
the group, one cannot, in good conscience, let the decision go forward.
The underlying concern should be based upon the group's principles or
foundation, rather than a personal preference. After a full discussion
and call for consensus that results in a block, either the full group or
a committee will:

1.  Clarify the concern by respectfully asking questions of the
    person(s) blocking to understand the underlying needs, reasons and
    issues;

2.  Ascertain if the reason for blocking is indeed based on a concern
    for the greater good of the group;

3.  Bring back new creative options to the group.

    **Standing Aside.** It is also possible to Stand Aside, which is
    where the individual disagrees with the proposal from his or her own
    personal values or experiences, but will allow the group to make the
    decision. This is, in effect, a decision by that individual to
    release his or her concern in favor of the group's interests, and to
    consent to the proposal. The person standing aside is bound by and
    required to help implement the consensus decision (just as any other
    member, present or not), unless an individual exception is approved.

    **Absent Members.** People who cannot attend a meeting are
    encouraged to make their opinions known through others who will be
    attending the meeting. Individuals may send a different
    representative from their organization if they are not able to
    attend a meeting, but this is encouraged only as a last resort.
    Under no circumstances will people who are not at a meeting be
    allowed to block consensus. If someone is absent from a meeting and
    disagrees with a decision that was made at the meeting, s/he cannot
    challenge the decision if the item was clearly listed as one of the
    agenda items to be discussed and circulated in advance of the
    meeting.

**Re-opening Decisions Reached by Consensus.** Once a consensus decision
has been reached, a member may request to re-open the discussion only if
new information comes to light that changes the intent or effect of the
decision. The person with the new information will receive 3 minutes on
the agenda of a meeting to explain why the topic should be reopened. The
decision may be reopened only if the entire group chooses by consensus
to re-open the topic, at which point the decision will be made to
consider it on the current agenda or a future one. If there are any
blocks, the issue dies without being referred to committee.

**Voting.** This process does not allow for decisions by vote. We are
seeking areas of broad agreement. Not everyone has to think every
decision is the best one, but everyone involved must agree to support
its implementation for a decision to move forward.

**Behavior.** Collaborative members agree to treat fellow collaborative
members with respect; to seek to understand and creatively address the
needs and concerns of all participants; to honestly express their own
concerns and needs; to actively pursue common ground in search of
consensus; and to support the group's consensus decisions publicly and
proactively.

**[Where We Will Work]{.underline}**

Our long term scope includes all the forested lands of the Rogue River
Watershed. Needless to say, we would only consider facilitating work on
private land if private landowners invite us to help.

**[When We Will Work]{.underline}**

We expect our work to continue for many years. Our strategic plan
includes a vision and outcome goals for the long term (20-30 year) as
well as focused objectives for the coming 3-5 years. Individual
participants in the Collaborative may resign at any time. Core
participants are asked to give as much notice as possible, and to help
recruit a replacement from their organization.

**[Why We Will Work Together]{.underline}**

There is no alternative that will allow us to achieve our shared goal.
We recognize that no single interest group, agency, company, or
organization can make meaningful progress on these problems alone. To
succeed we must work together, leveraging each others' strengths and
knowledge. Furthermore, many different groups hold the power to
effectively block or substantially delay action they do not fully
support, through legal, administrative, or economic means. To succeed,
we have no choice but to address the needs and concerns of all these
groups.

**[Signatories]{.underline}**

By signing below, we commit to participate in and support the Southern
Oregon Small Diameter Stewardship Collaborative, and we pledge that:

1.  We will work together to achieve the goals and objectives of our
    strategic plan, as approved April 2007 and amended from time to
    time.

2.  We will work together to develop and implement an annual work plan
    and funding strategy.

3.  We will work in accordance with the Productive Harmony Guidelines,
    as approved April 2007 and amended from time to time.

4.  Specifically, we will work to design and implement a landscape
    project of at least 10,000 acres using the Productive Harmony
    Guidelines.

5.  We will do this work using the consensus process outlined in this
    Declaration.

  ---------------------- ------------------------ ----------------- -------------- ------------
  **Name**               **Organization or        **Level of                       
                         Affiliation**            Participation**                  

                                                  **Core**          **Non-voting   **Friend**
                                                                    Core**         

  Darren Borgias         The Nature Conservancy   X                                

  Jon Lange              Individual               X                                

  Kevin Preister,        The Center for Social    X                                
                         Ecology and Public                                        
                         Pollicy                                                   

  Victoria Sturtevant    Individual               X                                

  Joseph Vaile           Klamath-Siskiyou         X                                
                         Wildlands Center                                          

  Jude Wait              Lomakatsi Restoration    X                                
                         Project                                                   

  Joan Resnick           Individual               X                                

  David Schott           Southern Oregon Timber   X                                
                         Industry Association                                      

  Oshana Catranides      Siskiyou Project         X                                

  Jack Shipley           Applegate Partnership    X                                

  George McKinley        Individual               X                                

  Marty Main             Individual               X                                

  Gordon Draper          Biomass One                                X              

  Bill Collins           Jackson County Natural                                    X
                         Resources Advisory                                        
                         Committee                                                 

  Jeff Griffin           Economic Revitalization                                   X
                         Team, Office of the                                       
                         Governor                                                  

  Max Bennett            OSU Extension                                             X

  Dan Moore              Rogue Valley Council of                                   X
                         Governments                                               

  Ryan Temple            Sustainable Northwest                                     X

  Chris Chambers         City of Ashland                                           X
  ---------------------- ------------------------ ----------------- -------------- ------------

**PRODUCTIVE HARMONY GUIDELINES**

**Southern Oregon Small Diameter Collaborative**

**[Overview]{.underline}**

We are a diverse group of stakeholders who share a long term goal to
remove small diameter trees from uncharacteristically dense forests in
the Rogue Basin. We believe this is critical in order to improve
ecological health and resiliency, reduce the risk of
uncharacteristically severe wildfire, and improve the region's economy
and quality of life.

We have developed these guidelines in order to ensure that ecological,
social, and economic goals are given equal attention and pursued
together in a spirit of productive harmony, or sustainability. We have
defined each of the three "legs" of our sustainability stool at three
levels of detail:

1.  Our **long term goal** is the ideal which we strive to maximize.
    Different projects will come closer to meeting one or another of
    these goals, but we will maximize them all to the extent possible.

2.  Our **minimum standard** is the threshold that any project must meet
    to gain our support. This is our "bottom line" in each category, and
    we will not support any project that fails to meet any of these
    thresholds.

3.  **Specific guidelines** outline the way we will do our work. We
    recognize that every project and situation will be slightly
    different, and it is not possible to write a single set of specific
    guidelines that have universal application. The guidelines will be
    adapted to each specific project, and will also adapt and evolve
    over time as we learn more and grow more comfortable working
    together.

More information about these guidelines, and the Collaborative, is
available online at <http://www.pacrimrcd.org/Page.asp?NavID=313>.

**[Social Goals & Guidelines]{.underline}**

**Long term goal:** Forest lands contribute to a high quality of life
and to strong communities by providing recreation, beauty, and other
important values while being managed in a way that builds trust and
community capacity.

**Minimum standard:** Any work we support must have broad based
community support, providing more social benefits than social costs.

**Specific guidelines:**

1.  *Focus on local priorities.* We will look to local communities to
    help identify priorities, such as plantations, projects within the
    Wildland-Urban Interface, and projects identified via Community
    Wildfire Protection Plans. (See table.)

2.  *Be clear about what "small" means*. Since we are focused on
    reducing forest density by removing small diameter trees, we will
    explicitly and publicly identify the diameters of trees to be cut,
    and the ecological, social, and/or economic reasons for cutting
    them. In general, we will avoid removal of trees over 20 inches dbh
    unless justified on ecological grounds (e.g. larger white firs
    encroaching due to fire exclusion.)

3.  *Be open and transparent.* We will be inclusive, transparent, and
    welcoming to anyone who wants to work together toward our shared
    goals.

4.  *Involve stakeholders early.* We will specifically seek to involve
    communities of interest, as well as local communities of place, as
    early and as fully as possible.

5.  *Value all social benefit*s. Forest lands provide diverse benefits,
    including scenic beauty, outdoor recreation, and a cultural legacy.
    We will seek to understand, value, and protect these many different
    benefits.

6.  *Build community capacity*. We will seek to increase and sustain
    community capacity to harvest and process small diameter timber in
    ways that provide social and economic benefits for people in the
    community.

7.  *Engage residents.* We will engage residents via community processes
    which are respectful, inclusive, comfortable, culturally
    appropriate, and build trust.

**[Economic Goals & Guidelines]{.underline}**

**Long term goal:** Forest lands support a thriving small-diameter
timber industry that provides high quality work in profitable local
businesses and generates revenues for local governments.

**Minimum standard:** Any work we support must generate more revenue
than expenses. Revenue includes subsidies as well as the market value of
the products removed.

**Specific guidelines:**

1.  *Begin with more economically viable projects*. We will tend to
    focus first on projects that have good existing access, and where
    markets can be identified for the material to be removed. (See
    table.)

2.  *Capture all economic benefits.* The benefits from small diameter
    projects include both the market value of the products removed, and
    non-market benefits (e.g. reduced fire risk, improved habitat.) We
    will actively work to establish the economic value of non-market
    benefits and develop strategies that pay for them.

3.  *Seek maximum economic value-added.* We will strive to have small
    diameter material put to the economic use that adds the greatest
    economic value and generates the greatest level of local economic
    activity. (e.g. a two-by-four has more social and economic value
    than a log that is chipped for market because it adds more jobs and
    income; likewise, wood used in furniture manufacturing has more
    value than a two-by-four.)

4.  *Catalyze economic activity.* We will strive to play a catalytic
    role in fostering the development of new economic ventures that
    utilize small diameter material and engage local workers,
    contractors, and entrepreneurs.

5.  *Support business development.* We will design projects to support
    business development (e.g. via long-term contracts.)

6.  *Spread opportunity*. We will strive to develop projects that spread
    economic opportunities to diverse organizations, businesses, and
    families.

**[Ecological Goals & Guidelines]{.underline}**

**Long term goal:** Forest lands are restored and protected as healthy,
resilient ecosystems with high ecological integrity.

**Minimum standard:** Any work we support must result in a significant
net improvement in ecological health and resiliency.

**Specific guidelines**[^1]**:**

1.  *Focus on the most altered systems*. The priorities for active
    restoration include plantations, dry forests with historically low
    -severity fire regimes, and mixed-severity regimes that currently
    support a disproportionate number of small diameter trees and
    uncharacteristically high probability of crown fire. (See table)

2.  *Seek adaptive improvement*. Reduce uncertainty of forest integrity
    and restoration by employing an adaptive approach based in
    monitoring, research, and scientific review.

3.  *Build ecological integrity and resiliency.*The objective of forest
    restoration is ecological integrity and resiliency by restoring
    within the natural range of variability the functions, processes,
    structure complexity, and the composition of species and their
    interactive networks. Projects we support to remove small diameter
    material will not achieve this objective by themselves, but should
    serve to support it.

4.  *Solve for the context of place*. A spatially explicit
    prioritization that reflects conditions across multiple scales of
    watershed, landscape, and region over time is needed. This
    prioritization should analyze root causes of degradation such that
    specific restoration tools can be matched with those causes.

5.  *Integrate conservation in restoration*. Prioritize and
    strategically integrate treatment and non-treatment areas, each with
    site specific prescriptions\-- fostering regional and landscape
    heterogeneity and habitat connectivity, to preserve rare landscape
    elements, sensitive communities, old growth communities, critical
    terrestrial and aquatic habitats and associated species. Protect
    large contiguous or connected habitat while recognizing that some
    protected areas may require active (or passive) management.

6.  *Use ecological references*. Guide restoration treatments through
    use of specific ecological references for composition and structure
    based in Plant Association Group and historic fire regime accounts.

7.  *Apply "fire-safe" treatments*. Consider mechanical thinning and
    prescribed fire, but in all cases apply fire-safe principles; reduce
    surface fuels, possibly raking fuel away from leave trees, increase
    height to live crown, decrease crown density, thin and remove excess
    trees, etc.

8.  *Retain large and complex woody biomass*. Integrate fire and
    structure by retaining the most fire-resistant, large live trees,
    particularly trees that pre-date Euro-American settlement, large
    snags and down logs, and retain the structural complexity of tree
    clusters while also retaining a component of younger trees for
    recruitment. This will generally mean avoiding removal of trees over
    20 inches dbh unless justified on ecological grounds (e.g. larger
    white firs encroaching due to fire exclusion.)

9.  *Restore understory composition and structure*. Reestablish healthy
    native forest understory, managing both composition and structure
    proactively.

10. *Use minimum tool necessary.* Minimize negative impacts of
    restoration and consider a staged approach. Elevate the priority of
    treatments in roaded areas and avoid construction of new roads;
    protect and maintain watershed and soil integrity. Remove ecological
    stressors where feasible as part of project design. Act
    conservatively in removing biomass materials to maintain soil
    productivity.

**[Opportunity Table]{.underline}**

These guidelines also provide a structure for prioritizing where we work
and what kinds of projects we will support, based on ecological,
economic, and social opportunities. For example, our ecological priority
might be even-aged "plantations," whereas economic opportunities might
be greater in areas with good roads and our social priorities could
include areas near communities. Our challenge in choosing and designing
projects, and working through the necessary details, will be to identify
areas where these multiple priorities overlap. The table below shows
these issues graphically.

+---------+-------------+--------------+--------------+--------------+
| **      |             |              |              |              |
| PROJECT |             |              |              |              |
| OPPORT  |             |              |              |              |
| UNITY** |             |              |              |              |
+---------+-------------+--------------+--------------+--------------+
|         | **HIGH**    | **MEDIUM**   | **LOW**      | **SPECIAL    |
|         |             |              |              | CASES ONLY** |
+---------+-------------+--------------+--------------+--------------+
| **S     | Directly    | Indirectly   | No           | Significant  |
| ocial** | supports    | supports     | substantial  | negative     |
|         | identified  | identified   | impact on    | impacts on   |
|         | social      | social       | identified   | identified   |
|         | benefits    | benefits     | social       | social       |
|         |             |              | benefits     | benefits     |
+---------+-------------+--------------+--------------+--------------+
|         | Highest     | Medium       | Lower hazard |              |
|         | hazard      | hazard       | priorities   |              |
|         | priorities  | priorities   | in CWPPs or  |              |
|         | identified  | in CWPPs or  | other plans  |              |
|         | via county  | other plans  |              |              |
|         | or local    |              |              |              |
|         | Community   |              |              |              |
|         | Wildfire    |              |              |              |
|         | Protection  |              |              |              |
|         | Plans       |              |              |              |
|         | (CWPPs) or  |              |              |              |
|         | other       |              |              |              |
|         | planning    |              |              |              |
|         | efforts     |              |              |              |
+---------+-------------+--------------+--------------+--------------+
|         |             |              | Critical     | Roadless or  |
|         |             |              | habitats for | Inventoried  |
|         |             |              | endangered   | Roadless     |
|         |             |              | species      | Areas        |
+---------+-------------+--------------+--------------+--------------+
| **Eco   | Great road  | Adequate     | Some         | Areas where  |
| nomic** | access      | roads, some  | helicopters  | significant  |
|         |             | skid paths   | required     | new roads or |
|         |             | may be       |              | helicopter   |
|         |             | required     |              | logging      |
|         |             |              |              | required     |
+---------+-------------+--------------+--------------+--------------+
|         | Guaranteed  | Near         | In           |              |
|         | end user    | inf          | frastructure |              |
|         |             | rastructure, | lacking,     |              |
|         |             | markets      | markets      |              |
|         |             |              | distant      |              |
+---------+-------------+--------------+--------------+--------------+
|         | End use is  | End us is    | End use is   | No           |
|         | high value  | medium value | low value    | identified   |
|         |             |              |              | end use      |
+---------+-------------+--------------+--------------+--------------+
| **Ecolo | Plantations | Matrix Lands | Steep        | Wilderness   |
| gical** | in Matrix   | or LSR (non  | slopes,      | areas,       |
|         | or Late     | plantation)  |              | roadless     |
|         | S           |              | fragile      | /inventoried |
|         | uccessional |              | soils, and   | roadless     |
|         | Reserve     |              |              | areas,       |
|         | (LSR)       |              | critical     | Riparian     |
|         | locations   |              | habitats for | Reserves,    |
|         |             |              | endangered   | Wild &       |
|         |             |              | species      | Scenic River |
|         |             |              |              | Corridors    |
+---------+-------------+--------------+--------------+--------------+
|         | Historical  | Historical   | Historical   | Historical   |
|         | low         | mixed        | mixed        | high         |
|         | severity    | severity     | severity     | severity     |
|         | fire        | fire regimes | fire regimes | fire regimes |
|         | regimes     | outside      | within NRV   |              |
|         |             | Natural      |              |              |
|         |             | Range of     |              |              |
|         |             | Variation    |              |              |
|         |             | (NRV)        |              |              |
+---------+-------------+--------------+--------------+--------------+

[^1]: Literature review and citations available from the Collaborative
    upon request.