Number range CHAPTERDear BLM:

As a botanist subcontractor who surveys for rare plants, lichens, and
bryophytes on BLM lands in southwest Oregon, I am deeply concerned about
the proposed Western Oregon Plan Revision (WOPR). Although the size of
the documents makes it difficult for a citizen such as me to conduct a
thorough review, I will respond to several of the problems with this
plan. Certainly a deeper analysis would find many other reasons why this
plan is unacceptable. On some issues such as the effects of the WOPR on
wildlife, I will defer to my colleagues who have submitted specific
critiques within their areas of expertise.

Southwest Oregon is the most botanically diverse area of North America
west of the Mississippi river. Here where many mountain ranges and
ecosystems come together, we have plant communities and habitats that
are found nowhere else in the world. These places draw plant enthusiasts
from around the world and serve as living laboratories for students who
regularly come from as far as Seattle to study our unique ecosystems.

It is almost unbelievable that in this day in age anyone could think
that causing rare plants and wildlife to become extinct or extirpated
from their historical ranges could be considered as a forest management
strategy---yet this is what the WOPR proposes.

According to the Draft Environmental Impact Statement, "conservation
measures would not be applied to populations of \[bureau assessment
status or bureau sensitive status rare plant\] species in the conifer
habitat group that occur within the O&C harvest land base unless 20 or
fewer populations of a species are known to exist" (quoted from the
Botany section of ch. 4, Environmental Consequences, WOPR DEIS). From a
scientific perspective, this plan makes no sense; allowing a plant to
decrease to 20 populations is like asking for extinction. It would
inevitably allow the loss of interspecies genetic diversity that is
necessary for a plant population to be resilient.

All proposed action alternatives propose eliminating Late Successional
Reserves, but it is not apparent that the effects that such changes will
have on rare organisms have been thoroughly analyzed. Many of our rare
organisms are dependent on old-growth forests and will likely experience
significant population declines as these forests are fragmented and
destroyed. Lichens such as *Chaenotheca furfuracea, Chaenotheca
ferruginea, Nephroma occultum, Pseudocyphellaria rainerensis,* and
*Usnea longissima* are known to be old-growth obligates. Certainly many
of our rare vascular plants would suffer similarly from the elimination
of the LSRs; these issues will be addressed in more detail in letters
submitted by my colleagues. It is clear that the WOPR could cause
widespread extirpation or extinction of a great many organisms.

Noxious weeds are already widespread on BLM land and all three proposed
alternatives would only make their dispersion worse, according to the
DEIS. Noxious weeds compete with rare plants, so their distribution
through the execution of the WOPR would be another nail in the coffin of
many of our rare species. Proposed clearcuts would turn our lands into
weed-ridden desert.

Besides the fact that the WOPR advocates extinction and extirpation of
our rare plants and wildlife, it is unworkable for a number of other
reasons. Contradictions and inaccuracies are found throughout the DEIS;
I will give a few examples below:

According to the DEIS, "All four alternatives would maintain similar
levels of availability and quantity of special forest products" (DEIS
ch.4, environmental consequences, "Special Forest Products" section).
From a scientific viewpoint, this is impossible. Clearcutting, as
proposed in the WOPR, would compact soil, change light levels and
temperatures, and eliminate host trees that micorrhizal fungi depend on.
As mushroom pickers know, all of our most economically valuable fungi
are mycorrhizal. Certainly this kind of management would damage other
special forest products as well, such as shrubs that are used in floral
arrangements.

The BLM claims to favor multiple uses for our public lands, but there\'s
no question that the WOPR would favor timber harvest at the expense of
most other land uses. Many tourists come to western Oregon for the
amazing forests and hiking opportunities. In the DEIS the BLM dodges
this issue by saying that, under the alternatives, "naturalness of BLM
areas would also be little changed overall. The alternatives would
maintain a mix of naturalness settings that provide a variety of
opportunities and experience for visitors."

By "mix of naturalness settings," one can only assume that the BLM is
referring to clearcuts interspersed with a handful of standing trees
here and there, as that would become the increasingly dominant landscape
under the WOPR. Surely the public can not be expected to believe that
clearcuts will have no effect on "naturalness." Anyone who has walked
through the dense, thorny brush that quickly springs up in clearcuts can
tell you about the "variety of opportunities and experience for
visitors" that such landscapes provide.

The BLM\'s fundamental assumption that our forests are a renewable
resource is scientifically flawed. Although forests of some sort will
often grow back from clearcuts, albeit very slowly, they will not
necessarily resemble the old growth forests that were lost. Certainly
many plants and animals from ancient forests will not reestablish
themselves after decades of having no habitat. Thus the BLM's assertion
that the WOPR would increase the amount of habitat for rare wildlife
over the long run cannot be correct.

A management strategy of clearcutting makes no sense from an economic
perspective. Clearcutting causes far greater rate of erosion than
selective logging. The soil that is lost through erosion after a
clearcut has a high economic value, since it is essential for the
reestablishment of forest. However, there is no evidence the BLM has
factored the economic value of the soil into its figures.

As an explanation for why more conservation-oriented alternative plans
were not analyzed in depth, the BLM repeatedly sites the "O&C Act's
requirement to manage the O&C lands that are classified as timberlands
for permanent forest production following the principles of sustained
yield." (DEIS ch. 2, Alternatives, "Alternatives Considered but
Eliminated from Detailed Study" section) This law is used to justify
clearcuts in the DEIS, but a realistic, contemporary interpretation of
this mandate would mean practicing truly sustainable harvesting, such as
selective thinning, which over the long run can produce more timber with
far less damage than clearcutting. The WOPR violates the mandate of the
O&C act to provide a permanent timber supply, and it places an
unreasonable burden on our children who would have to deal with its
ecological consequences.

The only case the BLM has made for advancing this destructive plan is
for the economic benefit of rural Oregon counties. But in the long run,
this plan will be seriously detrimental to local economies. It is clear
that the economic analysis provided in the Environmental Impact
Statement neither looks to the long term, nor considers the economic
damages the WOPR would bring---thus offsetting the theoretical benefits.

According to the DEIS, Alternative 2 would net around 7000 jobs as
compared to the no action alternative, but there is no mention of how
long the jobs will last or what the workers are to do once all the trees
are cut. A boom and bust scenario can hardly be considered a benefit to
the local economy. There\'s also no mention of the jobs that would be
lost upon the implementation of the WOPR---such as those of
biologists\--or the waste of the millions of dollars the BLM has spent
surveying for rare organisms on its lands over the years. And what about
devaluation the many private properties that border patchwork BLM lands
where new clearcuts will be happening? In the long run, this kind of
management will decrease the economic stability of western Oregon.

Although the DEIS admits that the WOPR will lead to increased wildfires,
it is not clear that potentially massive losses of ecomically valuable
timber have been factored into this economic scheme. If this plan causes
as many fires as scientists predict, it is very unlikely that the plan
will come anywhere close to meeting its projected economic goals.

The BLM\'s preferred alternative, number 2, is projected to generate a
net value of \$962 million (if everything works out perfectly) over 50
years. In relation to overall federal spending that total, less than
\$20 million per year, is not large, and pales in comparison to the
damage the plan would cause.

I call on the BLM to consider alternatives to the alternatives. Instead
of basing our economy on the destruction of irreplaceable resources, we
could bring about economic development and reach timber quotas through
sustainable logging practices such selective thinning and very small
clearcuts in selected areas. Increased focus on non-timber forest
products and encouragement of ecotourism on BLM land would also build a
truly diverse and much more resilient economy to support western Oregon.

In a time when we have more scientific data and knowledge of sustainable
forestry than ever before, proposing a plan that ignores everything we
have learned over the last decades does not serve the American people
well. Squandering what remaining resources we have, rather than
stewarding them through sustainable harvest, would hurt our children in
the long run. In the meantime, it would have an immediate detrimental
effect on our rare plants and wildlife, on the beauty of the places
where we live, on the water quality of our creeks and rivers where
salmon and other fish live.

The list of consequences just keeps on going

The WOPR is a poorly-planned document that seems to be politically
motivated. Any scientist can see that it is not grounded in modern
forestry science.

Many great civilizations have destroyed themselves through exhaustion of
natural resources---have we learned anything from history, or must we
repeat it?

Sincerely,

Jesse Miller

Botanist, Pacific Crest Consulting, Inc.

1084 Ashland St.

Ashland, OR 97520