> January 7, 2008

Bureau of Land Management

Western Oregon Plan Revisions

P.O. Box 2965

Portland, OR 97208

These are comments from the Steamboaters on the Draft Environmental
Impact Statement (DEIS) for the Revision of Resource Management Plans
for Western Oregon BLM Districts.

Steamboaters is a 35 year old, 300 member flyfishing and conservation
organization centered on the North Umpqua River.

1.  The DEIS does not contain a range of reasonable alternatives for
    meeting BLM's management responsibilities in western Oregon. Federal
    agencies must investigate a range or reasonable alternatives,
    particularly when the proposed action has such potentially serious
    environmental consequences.

-   No alternative proposes to increase timber harvest by focusing on
    thinning of second growth plantations. Such an alternative would
    also serve to reduce fire hazard on BLM lands.

-   No alternative proposes to increase timber harvest while protecting
    watersheds and water quality by maintaining riparian protection
    areas or by selective harvest techniques in these areas which
    results in no siltation or temperature increase.

-   No alternative explores a sustained yield model which includes a
    range of timber harvest rotation periods, resulting in each
    watershed or sub-watershed containing tracts of different forest
    stages including late-successional reserves.

2\. The analysis of Environmental Consequences for Fish (Pg 725 et seq)
is

> inadequate and flawed.

-   The analysis assumes a clean slate, and almost completely ignores
    the deteriorated condition of most western Oregon streams. While
    harvesting practices may have changed, the impacts from past
    operations remain with us and cannot be ignored. Current conditions
    include wide, shallow streams, increased temperatures, low levels of
    dissolved oxygen, and increased competition from fish species that
    adapt better to warm water conditions. Timber harvest in the
    riparian reserves can exacerbate all of these factors to the
    detriment of salmonids. The DEIS analysis focuses almost completely
    on the availability of large wood.

-   Riparian protection will be eliminated from intermittent non-fish
    bearing streams. There is no analysis of negative impacts from
    debris flows from these areas as riparian protection is removed.
    These impacts include siltation and stream scouring. In fact debris
    flows are treated as a positive event, delivering additional large
    wood to fish-bearing streams.

-   Fish Productivity (Table 210) is estimated to have minimal increases
    **[in 100 years]{.underline}** compared to existing conditions.
    There is no estimate of short-range or mid-range impacts in the
    proposed alternatives.

-   There is no analysis of overall watershed condition, productivity,
    or impacts from harvest operations on private land.

-   The Peak Flow analysis is inadequate to gauge impacts on fish
    production or habitat. Problematic peak flows are defined as 5-year,
    24-hour flows occurring at 2-year intervals. Damage from peak flow
    increases can also occur from continuous higher-than normal flows
    over the rainy season.

-   There is no analysis of decline in summertime flows and resultant
    increases in temperatures that result from faster runoff of winter
    precipitation.

-   The brief analysis of stream temperatures claims "None of the
    alternatives would contribute to an increase in stream
    temperatures...." This is incorrect and a poor discussion of a
    critical element for fish survival. There is no analysis of existing
    degraded conditions, no discussion of varying impacts from the
    orientation of streams, or the slope of the adjoining ground, or the
    high amount of flat, bedrock streambeds that exist on many North
    Umpqua River tributaries. Even slight increases in stream
    temperature and siltation on degraded streams can push the in-stream
    environment over the edge to a point where they severely impact the
    ability of anadromous fish to survive.

-   The stream temperature analysis doesn't discuss impacts to streams
    which are on the 303(d) list for failing to meet Clean Water Act
    standards, nor is there any discussion of impacts or contributions
    to TMDL's.

-   The DEIS claims that increases in temperature and fine sediment
    delivery would fall within the range of normal variation. However
    the increase would be in addition to the range of normal variation,
    not a part of naturally occurring conditions.

-   The DEIS assumes no siltation from ground disturbances greater than
    200 feet from a stream. This is simply not true and casts doubt on
    the entire analysis of siltation from BLM activities.

> 3\. The DEIS does not contain discussion of, recognition of, or
> separate standards for streams which contribute to the Outstandingly
> Remarkable Values (ORV's) for rivers included in the Wild and Scenic
> River System. The ORV's identified for the North Umpqua River segment
> include water quality and the fishery, particularly the anadromous
> fishery. This plan revision would produce negative impacts to the
> watershed supporting these ORV's. In particular, Canton Creek, the
> major tributary of Steamboat Creek (the major steelehead spawning area
> on the North Umpqua River) and direct tributaries to the North Umpqua
> River including but not limited to Honey Creek, Clay Creek, Bob Creek,
> Hill Creek and Susan Creek are all vital to protection of the ORV's in
> the North Umpqua River system.
>
> 4\. There is no comparison of existing conditions with reference
> (undisturbed) conditions in regards to water temperature. The
> discussion of Past Effects on pages 477/8 essentially dismisses
> negative impacts from previous actions. In the case of fish habitat
> and water quality, these previous actions have resulted in marginal
> conditions; and further deterioration could be lethal to salmonids.
> The impacts from (projected) small increase in temperature and
> siltation should be added to existing impacts and measured against
> undisturbed conditions.
>
> 5\. The existing inventory of fish-bearing streams in incomplete.
> Riparian protection standards cannot be assigned until all stream
> segments have been surveyed.
>
> We request that a new alternative be developed which will accomplish
> the following:

-   Retain the existing Riparian Protection Areas on all streams, both
    perennial and intermittent.

-   Adopt a standard which retains all existing shade on all streams.

-   Prohibits management activities which have any negative impacts on
    tributaries, and consequently the ORV's, of the Recreational segment
    of theWild and Scenic Rivers System on the North Umpqua River.

-   Protects and enhances water quality, particularly stream
    temperature, on all fish bearing streams.

-   Recognizes Canton Creek, especially upper Canton Creek and
    tributaries, for their importance in anadromous fish production.
    This watershed was identified several years ago as a critical
    watershed by the PACFISH work group. Stream surveys have found up to
    37 steelhead redds/mile (Harkleroad, 1991) above Pass Creek. A
    temperature survey of Canton Creek (Bauer & Oliver, 1969) found
    increases in temperature from timber harvest in the upper watershed,
    and temperatures in the mid 70's downstream.

Joseph Ferguson, President J-FergusonPLS@comcast.net

2130 Daphne St.

Springfield, OR 97477