COMMENTARY ON WOPR: LACK OF MANAGEMENT

1\. The WOPR, and its preferred alternative, are deficient as presented.

Under the management scheme of the Northwest Forest Management Plan, a
number of serious issues of non-management have arisen. These include
initially a failure to adequately harvest timber according to the 1937
O&C Act which has led directly to several resultant failures: a lack of
revenues for counties dependent upon some subsidy for the huge
percentage of federal lands within their jurisdictions; a lack of
adequate road maintenance, and a lack of any adequate plan for fire
management.

The thrust of the WOPR project is to extricate the O&C lands from the
control of the NWFMP. The potential advantage of doing so is the
opportunity to correct deficiencies in the NWFMP. The extent to which
the WOPR and its preferred alternative do that is the measure by which
the WOPR must be judged.

2\. The WOPR, and its preferred alternative, fail to adequately address
the problems.

a\) The maximum return to permanent timber harvesting under the
preferred alternative utilizes only 48% of the landscape for general
management. Notably, this utilization is limited by land reservations
for late successional management, contribution to the National Land
Conservation System, riparian reserves, and administrative withdrawals.
Timber revenues could be maximized and remain within legal compliances
of the 1937 Act by eliminating the late successional reserves and the
contributions to the Land Conservation System - uses not contemplated by
the Act. This would lead to 71% of the landscape being used as intended
providing a broader landscape for sustainable utilization with maximum
revenues.

b\) Providing greater revenues through maximized harvesting for
administration of the lands by the BLM (25% and 25%) would increase
budget capability to address the costs of maintaining the existing
system of roads. The WOPR does not address this problem.

c\) Providing greater revenues through maximized harvesting would
increase budget capability to address the critical need for fuel
reduction across the O&C landscape. The WOPR's attempt in this direction
is abysmally inadequate, calling for treatment in the Medford District
of only 11,000 acres per year at an increased cost to the BLM budget of
60%.

d\) The WOPR as presented offers no coherent plan for overall fire
management. Apparently it continues the NWFMP plan of non-management
relying exclusively upon prescribed burning for understory management
and only initial fire suppression counter-attack followed with a
let-it-burn approach to fires outside the interface.

3\. Recommendation for Improvement

a\) Delete the land reservations in the preferred alternative relating
to late successional management and contribution to the Land
Conservation System (retaining only the Congressional withdrawals).
Manage the remaining general management areas (71%) according to the
principle of sustained yield.

b\) Stop road closures on the O&C. Use part of the enhanced revenues
derived from greater harvesting to fund road upgrades where appropriate
to concerns of sediment pollution in fish habitat and general road
maintenance.

c\) Establish an aggressive plan for understory fuel management based
upon mechanical manipulation or herbicidal treatment. For practical
safety concerns utilize prescribed burning only where the landscape has
been previously conditioned to tolerate such attack. Undertake no
management action in any stand without concurrently correcting
understory fuel accumulations. Utilize regeneration harvesting in
strategic locations as fire breaks. Fund the widespread
mechanical/herbicidal treatment plan with the enhanced revenues from
increased harvesting.

4\. Rationale

a\) The Act calls for the O&C lands to have a primary utilization for
permanent timber production. Utilization of less than half of the
landscape is not primary utilization.

b\) Roads are currently being closed, to the curtailment of recreational
access to the O&C. This is a frustration of an intended purpose of the
Act.

c\) We have had a 100 year history of fire suppression on the public
lands. Under the NWFMP we have had 13 years of non-management of fuel
accumulations. As a result in the Medford District 48% of the landscape
is rated high fire hazard and 17% and 33% rated very high fire hazard. A
catastrophic stand replacement crown fire is a loss of potential timber
revenue and a loss of habitat for wildlife. There are no winners when
the stand dies a natural death.

d\) Under the ESA, the Secretary of the Interior upon balancing of
competing interests can legally exempt certain lands from critical
habitat designation. There should be no compelling legal need to
accomodate late successional reserves.

5\. Stakeholders

a\) The neo-environmentalists advocating preservation and
non-interference management for all old and potentially old growth
forests will be compromised. However, the NWFMP encompasses 24.5 million
acres more than 80% of which has been reserved for old growth
maintenance and restoration. The removal of 71% of the O&C lands as
recommended under the modified version of the preferred alternative
would remove at most 6% of the land from the NWFMP objectives. Under the
concept of balanced multiple use of the public lands, the
neo-environmentalists are being extravagantly satisfied.

b\) The neo-environmentalists advocate road closures and preservation of
inventoried roadless areas. They advocate a number of reasons for their
position. They see roads as a source of sediment pollution for fish
streams. Enhanced revenues for road maintenance can fund improvements in
this area, as actually needed. They see roads as a source of human
entry. That is in perfect concert with the recreational purposes of the
Act. Wilderness areas are a different issue. They see roads as ignition
conduits whereby humans introduce fire to the wilderness. This would
appear faulty reasoning in that the hazard locally is fire ignition by
lightning. It is also inconsistent in that they also argue that fires
are a healthy thing in the forest and should be allowed to burn.
Finally, they see roads as a source of erosion. In reality, there is no
issue of additional erosion. It is all a matter of direction of the
runoff. Erosion is a natural process that cannot be prevented.

c\) The neo-environmentalists advocating non-intervention in fire
management will be compromised.