Comments on the Western Oregon Plan Revision

United States Bureau of Land Management

Eric Geyer

Forester, Roseburg Forest Products

Roseburg, Oregon

**My Preferred Alternative**: 2 (with different targets)

**Target Volume**: 1 billion to 1.2 billion board feet annually

**Issue -- Sustainability**

Sustainability does not only mean harvest not to exceed that which can
provide a permanent supply of timber. It also must maintain acceptable
habitat sufficient for healthy wildlife populations. As natural fire
events have been nearly excluded from these lands, a necessary component
of the dynamic ecosystem has been severely limited: stand replacement
and regeneration of new stands. [Management such as that proposed in
Alternative 2 can restore this dynamic function, but harvest must at
least approach the annual growth of these stands.]{.underline}
Currently, Alternative 2 would harvest approximately 700 million board
feet per year, while growth is nearly double that. [Harvest targets
should be increased in an effort to restore and maintain the natural
functions of this ecosystem.]{.underline}

**Issue -- Old Growth Reserves**

The complex habitat functions provided by the characteristics of true
old-growth forests are an essential component of a healthy ecosystem.
Records from books written prior to significant pioneer logging suggest
that roughly one-third of western Oregon's forestland was comprised of
old-growth characteristics (one-third was merchantable pole stands and
one-third was in regeneration, meaning two-thirds of the forestland had
experienced stand replacement events in historically recent time).
[Alternative 2 addresses the old-growth component in a logical fashion,
recognizing that stands can be managed to accelerate old-growth
characteristics, thereby retaining the dynamic changes of a healthy
ecosystem.]{.underline}

**Issue -- Riparian Reserves**

The current concept of no-touch reserves around streams is not
scientifically sound. In a natural system, a stand replacement event
would never leave an untouched riparian strip anywhere. It is logical,
therefore, to question the conventional wisdom of strict no-touch
buffers in these areas. There has been significant research over the
past 20 years showing positive responses of both fish density and size
around gaps in riparian areas. Given reasonable water temperatures, gaps
can provide sunlight which fuels primary production and, ultimately,
increase food levels for fish and other animals. On-going research also
suggests that the slight rise in upstream water temperatures does not
automatically translate into downstream increases in temperature. [A
more flexible approach of riparian management that allows buffer areas
to vary in size and shape depending on stream conditions would maximize
the positive objectives of improved fish habitat and controlled stream
temperatures.]{.underline}

**Issue -- O&C Act**

[The clear legal intent of the O&C lands administered by the BLM was
permanent timber production to provide proceeds for county
services.]{.underline} There is virtually no difference between this
objective and that of private forest ownership, which is also held to
strict environmental standards via a variety of federal and state
regulations. The wording of the O&C Act is not contradictory nor
confusing -- timber production is the primary objective.

**Issue -- Active Management**

Active management is the concept of using the best available sound
science to reach the stated objective, potentially in an accelerated
fashion. [Alternative 2 utilizes active management through the harvest
of mature and dense stands and the acceleration of desired ecosystem
characteristics such as those found in structurally-complex
forests.]{.underline}

**Attachment**

Attached is my guest column that was printed in the Roseburg News-Review
on October 14, 2007. Although intended for a general audience, it
provides some context to the fundamental issues related to WOPR.

The BLM's Plan Revision Must Promote Harvest and Wildlife

***By Eric Geyer***

The Bureau of Land Management (BLM) is currently receiving public
comments on its Western Oregon Plan Revision (WOPR). The objective of
this revision is to use the latest science (such as the most recent
spotted owl recovery plan) to effectively manage for timber, wildlife,
water, and other resources while meeting its financial obligations to
the counties. Jay Carlson, Roseburg BLM district manager, has said that
the BLM's mandate is to meet the federal legal requirements of the 1937
O&C Act as well as the Endangered Species Act and the Clean Water Act
which were written into law in the 1970s.

One county resident has attempted to satisfy environmental, county, and
industry concerns by proposing a 30-year commercial thinning program
without regeneration harvests (clearcuts) and only in previously logged
areas. According to the BLM, that 30-year plan would only generate
roughly 10% of the annual county receipts currently received from the
federal government. Consequently, the remaining 90% would necessarily be
collected from taxes and fees assessed to county residents. Otherwise,
valuable services would be lost.

If thinning without regeneration harvests was accelerated to meet
current county receipts, the backlog of dense forest stands in the
Roseburg district would be exhausted within three years. Under this
plan, the vast majority of timber harvest and subsequent county payments
would end once the backlog was complete unless regeneration harvests
began by year four. In contrast, Congress in 1937 directed that the O&C
lands "shall be managed for permanent forest production under the
principles of sustained yield management."

A few community members believe that forests should not be managed at
all. The assumption that "quality" habitat only exists in untouched or
"protected" forests is a myth. Our scientific understanding of the
environment around us is constantly improving. We must strive to manage
it responsibly and to the height of our current knowledge while
providing an important renewable resource to society.

Forests are neither irreplaceable nor static. They are dynamic, which
means there is a natural cycle of birth, growth, and death, just like
all living things. Because forests are constantly changing, wildlife
species -- including the spotted owl and salmon -- have learned to
survive disturbances. In fact, many animals depend on occasional,
large-scale disturbances, whether by fire or by clearcut. Species such
as deer and elk are classic examples of animals that use forest for
cover and open areas to forage for food. In general, forests adjacent to
distinct openings attract more wildlife species because there is more
habitat diversity.

The fact is that large-scale disturbances, especially fires initiated by
lightning, naturally restarted wide swaths of forests. One of the best
examples of large-scale disturbance is in the Tillamook State Forest.
The Tillamook fires "clearcut" 355,000 acres during four large fires
between 1933 and 1951. One of the world's largest reforestation efforts
a half-century ago resulted in a forest with so much habitat that a
group placed Measure 34 on the ballot three years ago asking voters to
severely restrict logging in this premier habitat which they dubbed the
"Tillamook Rain Forest." The measure was soundly defeated because the
public understood that our productive Oregon forests can be managed to
accommodate wildlife and clean water while providing an important
resource and critical funding for public services.

Some of the comments submitted to the News-Review recently have
expressed concern over the harvest of old-growth forests. Old-growth is
a forestry term used to describe a particular type of forest structure
(which can be created through management), not an emotional state of
mind. All of the possible alternatives in the WOPR retain this important
old-growth structure as a significant component of O&C forests. Many
stands are designated to be managed with the objective of creating
old-growth habitat while other stands are left to grow without active
management. Overall, this appreciation of forests moving through time
should result in a continuous cycle of mixed old-growth structure across
the landscape.

The BLM's preferred Alternative 2 in the WOPR is the most responsible of
the presented alternatives to manage the O&C lands. It recognizes, at
least in part, the value of dynamic forests and the need for active,
science-based management to achieve the ultimate objective --
sustainable ecosystem functions and sustainable returns for the county.
The basic structure of Alternative 2 would promote a mix of old-growth,
mature, and young forests. In fact, under Alternative 2, nearly 50% of
the forest would be set aside for stream protection, old-growth, and
other withdrawn areas.

Alternative 2, however, only harvests one-half of the annual volume
growth, allowing the forest to increase in size substantially over time.
As these forests age and increase in density, harvest rates must
increase if the O&C lands are to maintain a sufficient amount of quality
wildlife habitat and minimize the threat of catastrophic wildfires.

The BLM is urging the public to provide comments. Please tell them that
you want responsible, active management of our bountiful timber
resource. Your forest and your county are depending on it.

*Eric Geyer is past chair of the Umpqua Chapter of the Society of
American Foresters, the national society of professional foresters
representing over 1,000 foresters in Oregon. He holds an M.S. degree in
forest management from Oregon State University.*