1/11/08

My comments include by reference the comments submitted by Oregon Wild,
Cascadia Wildlands Project, K-S Wild, the Coast Range Association, and
nineteen other environmental groups, in their entirety.

Please substitute the expression "forests over 120 years in age" for
"old growth" in this document, wherever appropriate.

The Bureau of Land Management is once again attempting to turn back the
clock to the1800's, when wagon trains rolled into the Oregon Territory,
and to the 1900's, when the steam donkey and railroad hauled endless
giant trees out of primeval forests that had endured for centuries
beforehand.

The problem is, they weren't endless. We may not have run out of trees,
but we have long since run out of native forests to plunder.

Humans have an infinite capacity for procreation and acquisition.
Unfortunately we live in a finite space, a world that is rapidly
shrinking. I believe our ever expanding species will eventually become
self-regulating. Until that time we should do everything we can to
preserve the tenuous layer, the biosphere that sustains all life,
including the animals, plants, fungi, lichens, mosses, insects, and
mollusks that inhabit our forests. And we need to preserve it in our own
backyard. At my age, I would like to think that the remaining native
forests in Oregon will be preserved for our descendants, that these
forest ecosystems will continue to evolve and thrive without human
intervention..

FOREST HEALTH -Decades of excessive and rampant logging, with associated
roadbuilding, have destroyed our Northwest forests. Streamflows have
been altered, our climate and watersupply have been affected, native
fisheries have been wiped out, and species dependent on older forest
habitat have declined to the point of being listed as Endangered. Less
than 10% of our native forests remain in the Northwest.

WILDFIRE - In the old growth forests around Alsea Falls, we've found and
photographed hundreds of giant trees. Practically every one of these
trees is fire scarred. Given the historic fire regime in the Coast
Range, these trees may have survived several major wildfires in their
lifetimes. Exactly how will cutting these giants down make our forests
healthier and more fire resistant?

HRV- Our forests are way, way outside the historic range of variability.
We're lucky here in Benton County, where a few patches of old growth
forests remain scattered around to explore and enjoy. I see from the
WOPR interactive map that between Portland and Astoria there are
virtually no forests left in the oldest age class.

SOIL DEPLETION - Forests in North Africa once thrived, and native
forestland once blanketed much of Eastern and Central North America.
Those forests are gone. If the timber industry has it's way, and the
preferred alternative to the Western Oregon Plan Revisions is
implemented, our Pacific Northwest forests may be on their way to
extinction. Just because we have succeeded in harvesting three or four
rotations on private industrial lands, and trees continue to grow, there
is no guarantee that soils will not become depleted to the point where
they fail to sustain trees. There is no science to support the idea that
we can continue to remove biomass from our landscape, and forests will
regenerate time after time without limit. It's ironic that the BLM's
plan advocates aggressive harvests in Southern Oregon, with it's
serpentine soils, where already, in many cases, replanted forests have
refused to grow, and permanently barren patches of rock and soil are
visible on steep hillsides that have been harvested. I'm not talking
about the bands of serpentine visible near Cave Junction and Grants
Pass. I've seen the clearcuts, and talked to longtime local residents
about the forests that used to be there.

SPECIES HABITAT -- It's on the topic of species habitat that the WOPR's
most glaring contradictions stand out. Here you've published hundreds of
pages of analysis, agreeing that old growth forests are essential
habitat for many species, and then you say it's OK to clearcut them
anyway, because we're going to come up with a BRAND NEW PLAN. Well,
everyone knows the spotted owl recovery plan was interfered with
politically. Why else would FS and BLM employees surround visitors at
the recovery plan open house in Portland and try to convince them that
reserves aren't necessary? Because they were paid to, that's why. The
recovery plan is all about logging, and it's all about greed.

Endangered species are guaranteed by law a plan that will not just avoid
jeopardy, but ensure the recovery of the species with sufficient numbers
to remove it from the list.. The spotted owl recovery plan needs to be
entirely rewritten, with the owl as the first priority, instead of
resource extraction, which is the priority now. Reserves are the only
thing currently saving the owl and the murrelet, along with the other
three hundred species on the Survey and Manage list, from extermination.
The problem is, the reserves as they are now, are inadaquate.
Designating twenty five year old stands as "late successional" is
intentionally deceiving the public. The Owl is seriously in decline and
threatened by the Barred Owl and West Nile. The only way to save the Owl
is to expand the reserves, and stop planning logging projects in the
reserves that exist now. Exactly what was the idea with Boney Skull?
Here you have a core Owl habitat area, and you set up logging units
surrounding it. How is that supposed to improve the Owl's chance of
survival?

Reducing riparian buffers is a disastrous idea. The Owl and many other
species depend on these buffers as travel and dispersion corridors
between reserves which are already too small and far apart. Exactly how
does reducing riparian buffers improve the Owl's chance of persistence,
and prevent the listing of other species of concern?

INADEQUATE AND ILLEGAL RANGE OF ALTERNATIVES- The BLM is directed in its
own handbook and under NEPA to provide the public with an adequate range
of alternatives. There's even a statement in the handbook about
considering alternatives outside the range of what's legally required,
so that our congressional representatives can consider the consequences.
But that is not the case with WOPR. What we have is one No Action
alternative, and three more scenarios that are all about the commercial
logging of our public forests. Where are the conservation alternatives?
Where is the balancing viewpoint the BLM is supposed to consider? And
where does this leave the public? Instructing concerned citizens to
restrict their comments to the analysis of these artificially restricted
alternatives is not only illegal, it's a waste of everyone's time..

SETTLEMENT - The Bush administration agreed to settle out of court. Like
they were doing the public a favor. But the administration never had to
settle at all. The timber industry lost in court in the first place. It
was only on appeal that Bush made this backroom deal with his major
campaign contributors, cheating the public out of our rightful heritage.
These are public lands, after all, and they should be managed for the
public to enjoy, not handed to some lobbyist like you hand your dog a
bone to chew.

O&C - The O&C act does not place timber production on a priority above
other amenities. It says "sustained yield", and "permanent supply".
There is no such thing as a sustained yield of old growth forests. There
is no guarantee that harvested and replanted stands will develop into
old growth forests. And permanent supply could be at any level. The O&C
does not mandate maximizing the supply.A sustained yield and permanent
supply should be at a low level, if the ESA and the current state of our
forests are taken into consideration. The O&C says provide for industry.
It does not say "timber industries only". Recreation and tech industries
have far surpassed timber in Oregon's economy. The O&C Act says
"community stability". Trying to move our communities back into the dark
ages where the economy is timber based is destabilizing. The service,
recreation, and tech sectors have gained leaps and bounds in the last
thirty years. Oregon's economy has diversified for a modern age. The
extraction industries are stagnant, or dependent on a boom and bust
cycle that destabilizes our social structure, and destroys our
environment in the process.

DEMOCRACY -- When 77% of Northwest citizens want old growth forests
permanently protected, and 90% of comments received on Kelsey Whisky are
opposed to the project, how are we being represented by the agency? The
BLM ramps up the harvest on Kelsey Whisky and presents us with the WOPR.
The BLM should be disbanded. Let the Forest Service manage our forests.
At least the Siuslaw is conservation minded, and the Willamette no
longer plans old growth sales, so things are improving, albeit slowly.

RECREATION -- When you live in rural Oregon, as I do, you experience the
state of the forests everyday. Going out for a sightseeing trip here
means going out to look at some new clearcuts. Since Weyerhauser bought
Willamette, a drive to the coast is a heartwrenching experience.

Studies (Sonoran Institute, etc.) indicate that Western economies based
on recreation, scenery, and retirement income, with adjacent natural and
scenic features (like Mary's Peak) are thriving, while economies based
on resource extraction are stagnant. By some accounts, only 2% of our
economy is based on timber anyway. Why is it there are no hiking trails
whatsover in forty miles of Highway 34, between Mary's Peak and the
Drift Creek Wilderness? Why are there no hiking trails between Woods
Creek road and Newport on Highway 20, another forty mile stretch? With
all that Oregon has to offer, you would think that our agencies would do
something, anything to enable the public to enjoy our forests on these
two high traffic corridors, and enjoy a respite from the endless parade
of denuded hillsides one usually sees on the way to the coast.

For residents of Corvallis, Philomath, Monroe, Bellfountain, and Alpine,
there are two readily accessible outdoor recreational opportunities,
without driving more than a few miles. These are Mary's Peak, and Alsea
Falls. Under the WOPR'S preferred alternative, Alsea Falls would become
an intensively managed and harvested area, with a seven hundred percent
increase in old growth clearcutting, so of the two, one would be
severely impacted, with new clearcuts, logging roads, and log trucks
dominating the roads and landscape.

The Alsea Falls area is a highly popular destination for hunting,
fishing, hiking, biking, photography, camping, and picnicking.
Corvallis, just a few miles away, has been rated as one of the most
desirable places to live in the whole United States. Housing in
Corvallis in highly in demand, with prices remaining high within the
urban growth boundary. Corvallis enjoys a reputation as a center for
hi-tech industry and a breeding ground for startups. The recreation
industry in Corvallis is thriving. There are already a few biking and
hiking trails in the Alsea Falls area. For some reason (strange as it
may seem) these have been laid out to almost completely avoid the old
growth forests. Why shouldn't the BLM do more to enhance the
recreational aspects of the Alsea Falls area for valley citizens? Why
not lay out hiking trails into pristine old growth drainages like the
upper reaches of Fall Creek and Coleman Creek?

For avid steelhead and salmon fishermen, the Alsea River is a mecca and
a popular destination. On one Sunday recently, we saw over fifty
vehicles parked at popular fishing spots on the Alsea. Even on a Monday
morning, we saw ten vehicles parked near the Fall Creek Fish Hatchery on
the Alsea.

Once you pass the ridge above Alpine, everything in the Alsea Falls area
drains into the Alsea River. Under the WOPR's preferred alternative,
forty square miles around Alsea Falls would be designated as a timber
management zone and intensively harvested. The resulting siltation,
sedimentation, and runoff from both logging and roadbuilding, not to
mention the damage caused by amplified peak flows to salmon spawning
beds, could destroy these highly popular fishing grounds on the Alsea
River.

SPECIAL AREAS -- Some of the old growth stands in the Alsea Falls area
are phenomenally beautiful. There are actual stands, not just individual
trees, of Pacific yews.

In our weekly hikes, we've found fourteen firs that are over eight feet
in diameter, with two being nine feet and two being ten feet. There are
brokentops and trees with structure everywhere, leaners, splittops,
tripletops, bayonet tops, trees with twists and curves and huge mossy
branch platforms. There are snags with windows through them and nurse
logs being slowly strangled by giant hemlocks. There are salamanders,
pileated woodpeckers, mountain beaver villages, bears, cougars, pygmy
owls and red tree voles.

Without any consideration whatsoever of the impact on the quality of
human experience, these special places should be saved. Some of these
trees may date back seven hundred years, and they live in forests that
have been evolving for thousands and thousands of years. These forests
are a window back in time. They should be saved.

Reed M. Wilson

203 SW 2^nd^ St.

30892 Bellfountain Rd

Corvallis OR 97333