January 11, 2008

To The Bureau of Land Management re: Western Oregon Plan Revision

After reviewing the drastic changes proposed in your Western Oregon
Resource Management Plan Revisions, I find that each of the three
alternatives would violate the language of The O&C Lands Act of 1937
(a.k.a. "The Oregon and California Railroads Grant Act" and "The McNary
Act"). The Act states:

> "...timberlands, and power-site lands valuable for timber, shall be
> managed...for permanent forest production, and the timber thereon
> shall be sold, cut, and removed in conformity with the principal
> \[sic\] of sustained yield for the purpose of providing a permanent
> source of timber supply, protecting watersheds, regulating stream
> flow, and [contributing to the economic stability of local
> communities]{.underline} and [industries]{.underline}, and providing
> recreational facilities \[sic\]."

The O&C Act directs the Department of Interior (DOI) to manage the O&C
lands for [permanent forest production]{.underline}, as opposed to
[permanent timber productio]{.underline}*n*. Seven decades later,
Americans have come to recognize that intact forests
[produce]{.underline} much more than just timber, and, indeed, intact
forest ecosystems figure prominently in the impending climate crises.
The United Nations Report on Global Warming explains that fully
functioning natural forests are invaluable resources that must be
protected for human survival.

The O&C Act recognizes certain essential components of --- and charges
the DOI with specific responsibilities in --- maintaining productive
forests: "protecting watersheds, regulating stream flow, and providing
recreational facilities." Although perhaps less obvious, these three
"forest-related," as opposed to "timber-related," purposes provide
substantial tourism funds every year for O&C counties, and, indeed, they
satisfy the criterion of "contributing to the economic stability of
local communities and industries."

With regard to the Act's one commercial component, a sustainable amount
of timber is to be "sold, cut, and removed...for the purpose
of...contributing to the economic stability of local communities and
\[local\] industries." Note that the O&C Act only requires the timber
proceeds to [contribute to the economic stability of]{.underline} ---
not to fully fund --- local communities and local industries. The Act
was written to help stabilize the financial conditions of local
residents and businesses --- not to provide a timber supply and, thus,
profits to non-local people and businesses. The Act never intended to
advance or satisfy the objectives of The American Forest Resource
Council.

The practices of clearcutting and reforestation destroy fully
functioning natural forests and bring about the extinction of many of
their associated species. As explained in Orville Camp's essay "Critical
Elements of Forest Sustainability" \[Chap. 1, "*Ecoforestry: The Art and
Science of Sustainable Forest Use"*\]:

> "Every forest has various horizontal layers of plants. The five basic
> ones...are the canopy, the understory, the shrub layer, the herb layer
> and the forest floor. Each of these layers is critical to certain
> dependent species and each is an essential part of the overall
> ecosystem....
>
> Forest stand structure is connected to a larger landscape. Maintaining
> connectivity is vital to many species in the forest. Clearcutting
> brings forest patches back to beginning seral stages and increases
> fragmentation and forest edges. This destroys habitat for many
> species."
>
> I oppose the proposed Western Oregon Plan Revisions as non-compliant
> with the O&C Act of 1937.
>
> Sincerely,
>
> Candace Nelson
>
> P.O. Box 1163
>
> Eugene, OR
>
> 97440