Richard Brock

892 Gaden Way

Ashland OR 97520

January 11, 2008

re: Western Oregon Plan Revision

A few comments on the Draft EIS For the Revision of the RMP's of the
Western Oregon BLM Districts (WOPR).

I have worked on BLM lands in southwest Oregon since 1978 conducting
surveys for special status species, moitoring, inventorying, as well
stand exams, fuels transects, range inventory, planting trees, thinning,
brushing, and collecting seed cones and native species seed.

In my opinion, the BLM should go with the No Action Alternative.

# Continuous Forest Production

The protection and building of soils is the primary goal of "continuous
forest production" Thus any forestry management which reduces the soil's
potential is a violation of the O&C Act. The changes in management
proposed in this EIS would reduce soil potential by; 1) removing nearly
all Coarse Woody Material through repeated harvesting rotations,
2)maintaining a "rotation" of regeneration cuts that is too short to
permit late successional processes for soil development. By limiting CWM
contributions to the soils, there is a predictable loss of soil
fertility in the long run.

Additional productivity loss is expected from these proposed changes
through increased earth flow events. The main loss of soil productivity
is through earth flow events that occur during maximum rainfall events.
These events can small or large. Evidence as been forthcoming from many
sources in the past 20 years that clearly indicates that intensive
forestry as practiced with short rotation minimum diversity forestry (as
proposed in this EIS) leads to increased earth flow events.

The management approach proposed in this EIS would potential for
increased earth flow events is a violation of the O&C Act. 1) increased
road building; (roads are the number one cause of earthflow, 2)
reduction of riparian buffers for secondary and intermittent streams
(the other obvious source).

Maintain overstory trees in regeneration cuts. The importance of
maintaining adequate overstory canopy cover in all of the forests of
southwest Oregon is a clearly demonstrated fact. Medford District,
Lakeview District and some Roseburg District forests need to maintain 20
trees per acre in the overstory with plantation production working with
the understory. Again in order to maintain "continuous forest
production". The proposed step back to the 1980's is difficult to
understand considering all the evidence available.

**The EIS proposed actions would, by design, reduce abundance of many
species in the tree and shrub layers**. In portions of the Roseburg and
Medford District, high levels of tanoak, madrone, chinquapin, and live
oak are essential to maintain soil stability and productivity. The EIS
seems to ignore this fact.

The EIS appears, in many areas, to ignore the constraints imposed by
insufficient information. One weakness in all the alternatives is a
failure to assess the importance of fungal diversity. It is clearly
demonstrated that short rotation forestry changes the fungal species
complexes. The distribution and function of the forest fungi is only
partially understood. Local patterns have not been studied at all.

In much of Southwest Oregon the goal of "continuous forest production"
will only be attained through two layered stand management by
maintaining a high cover in the overstory, hardwood and shrub diversity
and abundance, and high levels of retained course woody material.

# Endangered Species 

The management changes proposed in the WOPR are de-facto changes to the
Northwest Forest Plan. The Northwest Forest Plan as it is currently
structured, is the minimum needed to attempt recovery of T&E Listed
Species. The BLM ownerships, including the O&C Lands are a key piece in
the management framework. **The removal of a large area of BLM Lands
from the framework of the NWFP is a violation of the ESA**.

The impacts of the proposed alternatives incorrectly assesses the
impacts to **Marbled Murrelets**. A comparison of acres of habitat does
not cut it. Marbled murrelet habitat is one-tree-at-a-time often in
stands which offer several suitable trees. Because suitable tree
structure is not evenly distributed between "suitable habitat" acres,
any cutting which eliminates habitat known to be utilized by murrelets
will have a disproportional impact to the population. Historic use
patterns may be extremely important to the bird's choice of location and
success in finding a suitable nest platform; elimination of historically
used trees and stands will likely reduce nesting success.

**Fritillaria gentneri** is a plant which flowers very infrequently and
irregularly, in any population there are very few if any plants that
flower in any given year (this is well documented). Without flowers it
is impossible to tell from other Fritillaria species. As a result we
know of only a small number of the actual populations. Any Plan Revision
should include multiple-years surveys for this species and provide a way
to keep ground disturbance out of suitable habitat.

# Sensitive Species

The proposed changes would Remove protection for Bureau Sensitive
species. This is an abrogation of policies that have been developed for
the purpose of meeting the goals of the FLPMA to "consider the relative
scarcity of the values included" in an area. Because these "reserves"
have very little actual impact on the goals of the O&C Act, it is
irresponsible to abandon the excellent protection and management
programs currently in place. It is through these programs in wildlife
and botany (and fisheries) that we are learning what Best Management
Practices really are. Inventory and management is a kety to appropriate
management. A responsible action alternative would allow for a system of
implementing flexible management areas in the vicinity of Bureau
Sensitive Species. Without the tools currently available (protection
buffers) there will be population extinctions of many species over the
long term. Some of these populations are widely disjunct or otherwise
genetically important. **The extent and consequences of these local
extinctions cannot be adequately assessed due to a lack of understanding
of these species, including many fungi species. The actual impact of
this is clearly underestimated in the EIS.**

# Noxious Weeds

All evidence indicates that clearcut forestry is increasing Himalayan
Blackberry, Scotch Broom (Cytisus scoparius) and other species. In some
areas on the Roseburg District the BLM land is currently the only part
of the landscape where Scotch Broom is not a co-dominant in the shrub
layer. Himalayan blackberry often becomes a co-dominant in the shrub
layer. **Maintenance of a stable tree overstory component is essential
to keep these noxious weeds under control.**

# ORV's

**There should be no consideration of expanding or encouraging ORV use
in the Anderson Butte or John's Peak areas**. Federal Listed
[Fritillaria gentneri]{.underline} grows in areas that are also used by
ORV's (I.E. ridgeline ecotones). Because of the very small populations
of this species and the highly infrequent flowering, it would take many
years of consistent surveying (perhaps ten years) to be able to
determine abscence. Encouraging ground disturbing user activities in
prime habitat for this species would create clear a conflict with the
ESA.

# Cumulative Impact

The key role of BLM lands, including O&C Lands is to act as a buffer in
areas with high levels of short rotation industrial logging. In many
areas of the Roseburg and Medford Districts the Only remaining low
elevation Old Growth forest is on O&C lands. These older forest types
are supporting many species that are not found on the cutover lands. The
importance of these species over the long term are unknown (particularly
fungal species). The stable older forests often also act as a buffer for
soil movement, particularly in seasonal water courses. These remnant
older stands also act as an essential baseline against which we will
compare the "commercial forest" ecosystem over time. These ecosystem
services have a value exceeding the value as "timber". The current
proposals offer no way to recognize the amplified value of the remnant
old growth forests. In a local landscape where older forest types are
rare, the negative impacts of removing those remaining forests is far
greater then is anticipated in the EIS. **Thus the impact of proposed
cutting of these stands is incorrectly assessed** especially when done
with no overstory retention and minimal CWM retention**.**

# Secondary Effects OF Bad Planning

One last observation: There is certainly room for modifying current
management on BLM forest lands, particularly when it comes to the need
for understory thinning in dry forest ecosystems. Currently, most
Districts are beginning to efficiently implement appropriate small
diameter fuels-focused timber sales. There are problems and legal cases
when converting old forest habitat to young stands (regeneration
cutting) is seen as an essential part the program. This EIS outlines
action alternatives which will all lead to inevitable very-well-founded
legal battles that will create another "stop-work-order" in Oregon's
forests similar to the early 1990's. The economic impact of that should
be clearly stated in the Final EIS.

Thank-you for the opportunity to comment;

Richard Brock