Ed Shepard

Western Oregon Plan Revisions

P.O. Box 2965

Portland, OR 97208

Representative Greg Walden

843 East Main Street, Ste 400

Medford, OR 97504

Senator Gordon Smith

Security Plaza

1175 East Main, Suite 2D

Medford, OR 97504

Senator Ron Wyden

Federal Courthouse

310 West 6th St

Room 118

Medford, OR 97501

January 10, 2008

Re: Comments on the Western Oregon Plan Revision DEIS

Dear Sirs,

Thank you for accepting these comments on the WOPR DEIS. I have been
following this issue with some degree of passion and while my comments
are generally reflected by those of the Klamath-Siskiyou Wildlands
Center as submitted by Joseph Vaille, I feel compelled to comment on my
own behalf on what I believe is a tragically misguided exercise by the
BLM.

My specific concern, which was made clear to me when I attended the
Medford BLM's WOPR presentation on October 16, 2007, is that the BLM
intends to "increase" old growth stands over the next 100 years through
management. As was made clear to me at the 10/16 presentation, this plan
means that BLM intends to achieve late successional style canopy
structure by selective cutting. I asked at the time what scientific
support the BLM had for the contention that the ecological functions of
an old plantation, however carefully managed, would replicate those of a
natural forest. The answer was that the BLM had no such evidence.

The assumption is that a forest that is frequently cut, if its done in
such a way as to reproduce the canopy structure of a natural forest, can
replicate the ecological function of a natural forest. This assumption
is a rather bold one, and that the BLM is making it without extensive
study in support of it seems to me to be a clear violation of the
National Environmental Policy Act's requirement to carefully analyze the
impacts of federal actions that could adversely affect the human
environment.

This assumption seems unfounded to me and counterintuitive for any
number of reasons. For example, the BLM will be cutting out all the
damaged, dead and dying trees. When standing, dead and dying trees are
important habitat to owls[^1] and woodpeckers[^2] and fishers[^3] and
nuthatches[^4] etc.; important habitat for numerous ground species[^5]
and trout[^6] and salmon[^7] when they fall; and important to soil
health as they decompose.[^8] Indeed, "the impact of the individual tree
gradually fades as it is decomposed and its resources dispersed, but the
woody structure may remain for centuries and influence habitat
conditions for millennia."[^9] By removing damaged, dying and decaying
trees from its managed forests, the BLM is unavoidably producing a very
different ecosystem; one that cannot hope to replace true old growth.

The continuing presence of damaged, dead and dying trees in the forest
is but one of many obvious differences that could potentially result in
dramatic differences between managed and natural old growth forests.
What about soil quality? Disturbance from actual cutting activities?
Fragmentation of habitat from continued and expanded logging roads?

Two things seem clear: first, the assumption that a managed forest can
replicate the characteristics of a natural late successional forest is
neither intuitively nor scientifically well supported; second, the
assumption that a managed forest *cannot* replicate the characteristics
of a natural late successional forest is supported both intuitively and
scientifically. Indeed, federal agencies have so concluded on at least
two separate occasions.

The Forest Ecosystem Management Assessment Team, a joint study conducted
by the Forest Service, NMFS, BLM, Fish and Wildlife, National Park
Service and the EPA noted \"Late-successional forest communities are the
result of a unique interaction of disturbance, regeneration, succession
and climate *that probably can never be created with management*. At
present, we do not even fully understand the structure, species
composition, and function of these forests. The best we can hope to
accomplish through silviculture is to at least partially restore or
accelerate the development of some of the structural and compositional
features of such forests. *Because they will be regenerated by different
processes during a different period from that of the existing
late-successional forests, it is highly likely that silviculturally
created stand will look and function differently from current old stands
that developed over the last 1,000 years*. Consequently, conserving a
network of natural old-growth stands is imperative for preserving
biodiversity into the future.\"[^10]

The Northwest Forest Plan notes \"Late-successional forest communities
are the result of a unique interaction of disturbance, regeneration,
succession, and climate that can *never be recreated in their entirety
through management*. The structure, species composition, and function of
these forests are, in their entirety, not fully understood.\"[^11] Given
the clear and consistent conclusion by the federal agencies that one
cannot cut one's way to old growth, the Bureau's contrary contention
seems, to use a frightening legal phrase, arbitrary and capricious.

There are many more specific problems with the WOPR that I will rely on
my better educated colleagues to illuminate, but this basic assumption
underlies so much of the WOPR that I feel that my specific comment was
necessary. Thank you for taking the time to consider them. I ask you,
Mr. Shepard, to create a new EIS that addresses my specific complaint,
as well as the many others expressed by KS Wild and allied
organizations; and I ask you, Mr. Walden, Mr. Smith and Mr. Wyden, to
consider the overwhelming voice of your constituency and enact
legislation that will genuinely protect our public lands.

Sincerely,

Christopher Len

Legal Director,

Klamath-Siskiyou Wildlands Center

[^1]: *Characteristics of Forests at Spotted Owl Nest Sites in the
    Pacific Northwest*, Katherine T. Hershey, E. Charles Meslow, Fred L.
    Ramsey, The Journal of Wildlife Management, Vol. 62, No. 4 (Oct.,
    1998), pp. 1398-1410

[^2]: *Snag Abundance for Primary Cavity-Nesting Birds on Nonfederal
    Forest Lands in Oregon and Washington*, Janet L. Ohmann, William C.
    McComb, Abdel Azim Zumrawi, Wildlife Society Bulletin, Vol. 22, No.
    4 (Winter, 1994), pp. 607-620

[^3]: *Distribution and Status of the Fisher* (Martes pennanti) *in
    Washington*, Keith B. Aubry, Douglas B. Houston, Northwestern
    Naturalist, Vol. 73, No. 3 (Winter, 1992), pp. 69-79

[^4]: *Use of Snags by Birds in Douglas-Fir Forests, Western Oregon*, R.
    William Mannan, E. Charles Meslow, Howard M. Wight, The Journal of
    Wildlife Management, Vol. 44, No. 4 (Oct., 1980), pp. 787-797

[^5]: Downed logs as habitat for forest-dwelling ants\--the primary prey
    of pileated woodpeckers in northeastern Oregon, Torgersen, TR; Bull,
    EL; Northwest Science \[NORTHWEST SCI.\]. Vol. 69, no. 4, pp.
    294-303. 1995.

[^6]: *Response of Juvenile Coho Salmon and Steelhead to Placement of
    Large Woody Debris in a Coastal Washington Stream*, C. J. Cederholm,
    R. E. Bilby, P. A. Bisson, T. W. Bumstead, B. R. Fransen, W. J.
    Scarlett, and J. W. Ward, North American Journal of Fisheries
    Management, Volume 17, Issue 4 (November 1997)

[^7]: *Changes in Instream Habitat, Large Woody Debris, and Salmon
    Habitat after the Restructuring of a Coastal Oregon Stream;*
    Crispin, Val, House, Robert and Roberts, Dave; North American
    Journal of Fisheries Management; Volume 13, Issue 1 (February 1993)

[^8]: *Coarse Woody Debris in Douglas-Fir Forests of Western Oregon and
    Washington*; Thomas A. Spies, Jerry F. Franklin, Ted B. Thomas;
    Ecology, Vol. 69, No. 6 (Dec., 1988), pp. 1689-1702

[^9]: *Tree Death as an Ecological Process*, Jerry F. Franklin, H. H.
    Shugart, Mark E. Harmon, BioScience, Vol. 37, No. 8, Tree Death:
    Cause and Consequence (Sep., 1987), pp. 550-556

[^10]: -Forest Ecosystem Management: An Ecological, Economic, and Social
    Assessment, Report of the Forest Ecosystem Management Assessment
    Team July 1993; IV-31,32. Emphasis added.

[^11]: Northwest Forest Plan at B-6. Emphasis added.