January 10, 2008

Dear BLM,

Thank you for your concern about forest health in Western Oregon. Please
carefully consider our comments on the WOPR.

We spend a good deal of time involved in primitive activities including
hiking, camping, and nature study on BLM lands in Western Oregon. We are
organic healers and farmers, with livestock, living adjacent to BLM
lands. Our livelihood depends on a healthy and stable environment. To
us, it is critical that \"recreation\" does not cause detrimental
effects to our environment(soil, water, air, plants, wildlife, etc.) and
our peace of mind.

[ORVs]{.underline}

Detrimental effects from excessive OHV use are quite numerous (and also
well documented),including: pollution, fire risks,
crime,reduction/extinction of native medicinal plant species which could
be used to heal future generations, contamination of healthy plant
species with diseases spread by vehicular trafic, damage to cultural and
historical sites, harm to hikers and horseback riders, reduction of
private property values, other social harms, etc. These and other
effects were not considered when John\'s Peak and Ferris Gulch were
designated as an OHV area. No new OHV areas should be designated and
existing areas should be carefully monitored (or closed) and certainly
not expanded.

Quite frankly, ORV use cannot peacefully co-exist with other uses of BLM
land and to designate these lands for OHV use violates the rights of
other public land users, now and in the future. We demand the right to
respectfully recreate on our public lands without fear for life and limb
and more. We demand the right to live on our private land without
experiencing harm from adjacent public land use.

A failure to adequately involve those with potential user conflicts has

embroiled in controversy the Timber Mountain/John's Peak OHV, an
unprecedented proposal to insert an OHV designation into checkerboard
BLM land interspersed with numerous private property owners. Of interest
to our review is the social and economic

component. It appears from this document that no real social analysis
will take place.

BLM's management of OHV traffic has been inadequate, with 90% of BLM
lands open to unmanaged OHV use. The area of the proposed Timber
Mountain/John's Peak

should be closed under Executive Order 11989(Carter/1977), requiring
federal land managers to close lands where off-road vehicles "will cause
or is causing considerable adverse effects..." Similarly, Executive
Order 11644 (Nixon/1972) says "the use of

off-road vehicles on public lands will be controlled...to protect
resources...and minimize

conflicts." The only BLM information regarding the proposed Timber
Mountain/John's Peak designation was a listing in the Medford District
1995 RMP, information that lacked the specificity required for a Notice
of Intent under CFR 40; The Timber Mountain/John's Peak proposal should
therefore be removed as part of the

WOPR.

Furthermore, we request that you consider the following closure in the
Middle Applegate.

Prohibit off road vehicles (ORVs) in the area of the Ferris Bugman (aka
Lucky Bugman) project which is north of Highway 238.

The closure of this area to ORVs is well-supported by residents of
Humbug Creek Rd. and Slagle Creek Rd. Local residents use the Ferris
Bugman project area, north of Highway 238, for horseback riding, hiking,
nature study, dog walking, pack goat training, Native American cultural
studies, historical site study, religious practices, wild crafting,
stewardship projects, and other primitive recreation activities. The
aforementioned uses are not compatible with ORV use. A horseback rider
had to shoot her horse after an encounter with some ORVs. The safety of
these local, non-motorized users must be protected as they are the
majority of users in the Ferris Bugman area north of Highway 238. At a
landscape level, the BLM must manage our public lands for multiple uses.
We would like this portion of the landscape to be non-motorized.

Executive Order 1644 provides that ORV use on federal lands must be
consistent with \"the protection of resources of the public lands,
promotion of the safety of all users of those lands, and minimization of
conflicts among the various users of those lands.\"

To date, ORV use of the area has been limited by access. Proposed
logging, burning, road construction, and oak woodland treatments would
open up the landscape, providing easier ORV access. Increased access
coupled with local population growth and increasing popularity of the
nearby 16,000 acre John\'s Peak ORV area could dramatically increase ORV
use of the Ferris Bugman project area north of Highway 238 with no
funding for policing this \"unlimited\" use area which mostly borders
private property.

It is critically important to protect especially large, wild, unroaded
tracts of BLM lands from ORV use.

Please review the nominations for special protection of the Ferris
Bugman project area (and vicinity) as Areas of Critical Environmental
Concern, Wilderness Study Areas, and an Environmental Education Area.
Perhaps another designation would be appropriate, but one of the keys to
protecting this critical area is the exclusion of motorized vehicles.

It is well-documented that ORVs cause extensive and expensive damage to
natural resources, i.e., rare and critical habitat, soils, and water
(see Ferris Bugman comments). The BLM has an obligation under FLPMA to
prevent any unnecessary or undue degradation to public lands.

Executive Order 11989 further provides that the agency head must,
\"whenever she determines that the use of off road vehicles will cause
or is causing considerable adverse effects on the soil, vegetation,
wildlife habitat, or cultural or historic resources of particular areas
or trails of the public lands, immediately close such areas, or trails,
to the type of off road vehicles causing such effects until such time as
she determines that such adverse effects have been eliminated and that
measures have been implemented to prevent further recurrence.\"

[Logging]{.underline}

We recommend that the WOPR be modified to include an action alternative
that is focused on restoration, small diameter thinning, non-motorized
recreation, and prescribed burning (see below). We are opposed to all
clearcutting due to the multitude of negative effects associated with
the use of this antiquated procedure. Much literature supports this
point of view. We are opposed to the cutting of large diameter trees
because they play a significant role in maintaining the stability,
vitality, and structure of a healthy forest. As a rule, trees larger
than 18" -- 22" should NOT be cut. We are opposed to the construction of
new roads since our forests are already over-run with roads. Logging
roads are not only ecologically costly but also economically unsound.

[Prescribed Burning and Fuels Reduction]{.underline}

We would like to encourage the agency and contractors for the agency to
avoid the use of diesel fuel in lighting fires. We would also like to
see a move away from the burning of black plastic used to cover piles.
Jacksonville Woodlands has used a paper material to cover their wood
piles just outside of Jacksonville. We suggest that the burning of
plastic and use of diesel fuel is harmful to the environment and likely
violates the law. Piles should be burned in the Fall before they have a
chance to get too wet or become animal homes.

We are concerned about the use of the Slashbuster machine because of its
unknown longterm impacts. The machine should be washed and DRIED off
site because Sudden Oak Death is spread via Water. Sudden Oak Death is a
real significant threat in our area. It is much more likely to spread
S.O.D. (Sudden Oak Death) via machinery, disturbed earth, and new roads.
Please research this disease before implementing any thinning
prescriptions because even the soil on workers\' boots may transmit the
fungus from other regions! A useful web page is
[[www.suddenoakdeath.org]{.underline}](http://www.suddenoakdeath.org/).
Phytophthora is a serious problem which is not well understood and yet
it is not adequately addressed. To us, this sounds like a significant
impact! Human management of the landscape increases the rate and
distance of S.O.D. spread. Mechanically thinned areas are more prone to
S.O.D. (according to findings in Marin County).

To mitigate this significant impact of Sudden Oak Death spread, we
suggest the following.

We urge your agency to research and make use of Indigenous burning
practices and uses of fire to manage the landscape. Frank Kanawha Lake
(Oregon State University, Corvalis) and Dennis Martinez (Indigenous
Peoples Network of the Society for Ecological Restoration) are both
excellent sources of information who should be contacted.

According to a lecture given by Lake, fire was used by Native Americans
for the following reasons: Hunting, Improvement of crops, Insect
collection, Pest management, Range management, Fireproofing, Clearing
trails for travel, Tree felling, and Stimulating Riparian areas. We
would include forest pathogen management on this list. We suggest that
the current spread of Sudden Oak Death and Port Orford Cedar Disease
might be controlled by the careful use of fire. Trying to mimic Native
American burning practices where possible (like cool underburns) is an
excellent proposal. We suggest that Fall burning is often superior to
Winter or Spring burning and there is much knowledge and research to
back up this statement.

According to Lake, we need to look at both the overstory and the
understory. The understory holds some of the most important resources
for humans including medicinal and edible plants and significant
cultural plants like tarweed, beargrass, milkweed, and yerba santa. The
preservation of understory species is just as important as the
preservation on an intact and healthy overstory.

We recommend minimal ground disturbance, minimal or no use of vehicles
in units. We recommend closing all burned areas to ORV use with signs
clearly posted so that pathogens are not introduced into the recently
thinned and vulnerable woodlands. No analysis is given regarding ORV
entry into the treated units so we hope that the agency seriously
intends to keep ORVs OUT of the treated areas. If not, we would like to
state that there are numerous significant impacts associated with ORV
use of the freshly opened up soils in units. These significant impacts
have een discussed in depth by ourselves and others in our previous
comments regarding the John\'s Peak E.A. of 2000 and the on-going
scoping of John\'s Peak and the Ferris Bugman E.A. and Amended Ferris
Bugman E.A.

Please do the right thing. Thank you for your attention.

Sincerely,

John and Michelle LaFave

1030 Left Fork Humbug Creek Rd.

Applegate, OR 97530