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January 9, 2008

Bureau of Land Management

Western Oregon Plan Revisions Office **\
**333 SW 1st. Avenue

Portland, OR 97204

\-- submitted via email to: orwopr@or.blm.gov

Dear BLM:

Enclosed please find comments on the Western Oregon Plan Revisions Draft
Environmental Impact Statement (WOPR DEIS). These comments are submitted
on behalf of the following Audubon chapters in Oregon: Rogue Valley
Audubon Society, Cape Arago Audubon Society, Audubon Society of
Corvallis, Klamath Basin Audubon Society, Lane County Audubon Society,
Audubon Society of Portland, Salem Audubon Society, and Umpqua Audubon
Society, as well as the National Audubon Society. Complete addresses and
chapter contacts for each group are given at the beginning of the
comments. Together, these Audubon groups represent well over 10,000
Oregon citizens, many of whom are regular users of BLM's Western Oregon
forests for hiking, camping, bird-watching, and other outdoor
activities.

As detailed in our comments, we believe that the WOPR represents an
unconscionable retreat from sound, scientifically-based principles of
public land management; a retreat that is without legal basis or
justification. If adopted, any of the WOPR action alternatives would be
devastating to the ecological health of Oregon's forests. In particular,
we note the drastically increased fire risk that would be created by the
plan, as shown by BLM's own analyses. In addition, we believe that all
of the WOPR action alternatives violate BLM's legal obligations under
the Endangered Species Act, by placing the Northern Spotted Owl in
serious jeopardy of extinction.

It is our recommendation that the entire WOPR process be abandoned. None
of the action alternatives would live up to BLM's legal and professional
obligations as stewards of our public lands. In contrast, the No Action
Alternative -- management based on the Northwest Forest Plan --
represents a comprehensive, science-based ecosystem management program.
It should be retained as the foundation for management of BLM's Western
Oregon forestlands.

Thank you for your consideration of these comments. We look forward to
your response.

Respectfully submitted,

Pepper W. Trail, Ph.D.

Conservation Chair

Rogue Valley Audubon Society

2011 Crestview Drive

Ashland, OR 97520

Cc: Senator Ron Wyden

Senator Gordon Smith

Representative Greg Walden

Representative Peter DeFazio

Representative Earl Blumenhauer

Representative Darlene Hooley

Representative David Wu

**Comments on the Draft Environmental Impact Statement of the Western
Oregon Plan Revisions (WOPR)**

Prepared by Pepper Trail, Ph.D.

Conservation Chair, Rogue Valley Audubon Society

January 9, 2008

These comments are submitted on behalf of the groups listed below.
Please keep all named individuals and groups informed of BLM WOPR
planning developments.

**Rogue Valley Audubon Society**

c/o Pepper Trail, Conservation Chair

2011 Crestview Drive

Ashland, OR 97520

Email: ptrail@ashlandnet.net

**Cape Arago Audubon Society**

723 7^th^ Terrace

Coos Bay, OR  97420

Contact: Eric Clough, President

**Audubon Society of Corvallis**\
P. O. Box 148\
Corvallis, OR 97339

Contact: Christopher K. Mathews, President

**Klamath Basin Audubon Society**\
P.O. Box 354\
Klamath Falls, OR 97601

Contact:  Darrel Samuels, President

**Lane County Audubon Society**

Board of Directors

P.O. Box 5086

Eugene, OR 97405

Contact: Maeve Sowles

**Audubon Society of Portland**

5151 NW Cornell Road

Portland, Oregon 97210

Contact: Bob Sallinger, Conservation Director

Phone:  503-292-6855

E-mail:  bsallinger@audubonportland.org

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**Salem Audubon Society**

189 Liberty Street NE, Suite 210

Salem, OR 97301

Contact: David Harrison

President and Conservation Chair

**Umpqua Valley Audubon Society**

312 Impala Drive

Roseburg, OR 97470-8883

Contact: Stanley Vejtasa, Conservation Chair

**National Audubon Society**

700 Broadway\
New York, NY 10003

Contact: Betsy Loyless, Vice President for Policy

**Summary:** All three "action alternatives" proposed under BLM's
Western Oregon Plan Revisions would be an ecological disaster for
Oregon. They would drastically increase fire risk and severity, threaten
the survival of the Northern Spotted Owl and other endangered species,
create massive habitat fragmentation, and severely degrade riparian
zones and streams. We support the science-based, ecological management
approach of the Northwest Forest Plan (the WOPR's "No Action
Alternative"), and reject the contention that this is incompatible with
the O&C Act.

**Legal Background:** The WOPR came from a settlement agreement between
the Bush Administration and the timber industry group American Forests
Resources Council (AFRC), which had alleged that "the \[1937\] O&C Act
had not been appropriately considered in applying the Northwest Forest
Plan's management direction" to BLM lands in Western Oregon (Appendix A,
p.929). Under the agreement, the Bureau of Land Management asserted that
timber production was the "dominant" use of the Western Oregon O&C lands
(WOPR Vol. I, p.12), and agreed to consider a management "alternative
that would not create any reserves on the O&C lands" (Appendix A,
p.929). This legal interpretation by the Bush administration and the BLM
is highly questionable, and relies excessively on *Headwaters, Inc vs
BLM* (9^th^ Circuit, 1990), while giving insufficient weight to the
9^th^ Circuit's subsequent ruling in *Portland Audubon Society vs.
Babbitt* (1993). It is our belief that the Northwest Forest Plan is not
inconsistent with the O&C Act. This position is in line with the
dismissal of the *AFRC vs. Clark* lawsuit by the D.C. District Court.
Despite that dismissal, the Bush Administration chose to enter into a
settlement that was highly favorable to the American Forest Resources
Council's position, and initiated the WOPR process. We consider the
stated "purpose and need" for the WOPR plan to be insufficient
justification for invalidating the Northwest Forest Plan and developing
management alternatives that, despite BLM assertions to the contrary,
are contradictory to the Endangered Species Act, the National
Environmental Policy Act, and scientific principles of sustainable
forest management.

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**Logging:** All three "action alternatives" under the WOPR would
abolish the system of Late Successional Reserves (LSRs) that was
carefully designed in the Northwest Forest Plan to assure the survival
of the threatened Northern Spotted Owl and other old-growth dependent
species. Alternatives 1 and 2 create new land use allocations that would
replace the existing allocations on BLM forests. The new allocations
are: Timber Management Areas (TMAs) which emphasize timber production,
Riparian Management Areas (RMAs) and Late Successional Management Areas
(LSMAs). Alternative 3 would create a large General Landscape Area,
which would "provide continuous timber production" to "approximate
natural stand-replacing disturbances." The rotation age is estimated to
be 360 years north of Grants Pass and 240 years south of Grants Pass. 
However, in practice clearcutting could occur as soon as \"50% of an
area is older than the threshold stand age of 90 years north of Grants
Pass and 140 years south of Grants Pass,\" and commercial thinning could
occur even before that (p. XLVII).

To see how much BLM's preferred alternative, Alternative 2, would change
the landscape of Jackson County, compare Maps 5 and 7 in the WOPR map
packet. Map 5 shows the present (No Action Alternative) land use
allocations in the Medford District, with a large Late Successional
Reserve in Jackson Country along the Rogue-Umpqua divide, another
further west just across the border of Douglas County, the large
Applegate Adaptive Management Area , and extensive riparian reserves. In
contrast, Map 7 (the Alternative 2 land use allocations) shows BLM land
in Jackson County almost entirely shaded the brown of Timber Management
Areas, which has replaced the LSRs in the Rogue-Umpqua area, the entire
Applegate AMA, and most of the extensive riparian reserves. This uniform
logging-intensive prescription fails to reflect the ecological variety
of BLM lands in Jackson County, to preserve high-quality wildlife
habitat, and to protect sensitive watersheds. When a single management
scheme is applied across a diverse landscape, it is obvious that land
managers are not following scientifically defensible principles of
stewardship.

Alternative 2, BLM's preferred alternative, proposes to intensively
manage mature and old growth forests for conversion into tree
plantations (Fig. 178, p. 572) and identifies clearcutting without green
tree retention as the preferred logging method (Fig. 187, p. 578). Under
Alternative 2, clearcut logging would generate 89% of the volume while
thinning would generate 11% (Table 153, p. 536). In comparison, the No
Action Alternative (i.e., continuation of the Northwest Forest Plan)
would generate 65% of its volume from clearcutting and 35% from thinning
-- a far more balanced approach that would provide great benefits in
terms of reduction of fire risk and enhancement of ecosystem health.

The ecological values of old-growth forests were exhaustively documented
in the Northwest Forest Plan reports (e.g. FEMAT 1993 and the Record of
Decision 1994) and in many studies since. Moreover, clearcutting has
been conclusively proven to increase fire risk, to threaten sensitive
populations of wildlife and anadramous fish, to increase erosion and to
drastically reduce water quality. It is unacceptable for BLM to turn its
back on this established science and propose management alternatives
that will degrade the ecological health of the public lands under its
care.

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**Riparian Reserves:** Some of the most drastic and ecologically
damaging impacts of the WOPR action alternatives would be to riparian
reserves. "The No Action Alternative would have almost twice the acreage
in riparian management areas as Alternative 1, four times the acreage as

Alternative 2, and more than three times the acreage as Alternative 3"
(p. LX). According to BLM analysis, "The habitat needs of aquatic- and
riparian-associated species along intermittent streams...would be met
under the No Action Alternative and Alternative 1, but would not be met
under Alternatives 2 and 3" (p. LVII). Alternative 2 would divide
streams into "intermittent" and "perennial" streams. All mercantible
timber could be logged along intermittent streams without a "high risk
of debris flow," leaving a "25 foot area with noncommercial vegetation
on each side of the stream and 12 conifer trees per acre." Such drastic
logging in sensitive headwaters areas is likely to cause severe
ecological and hydrological damage.

**Habitat Fragmentation:** Habitat fragmentation has proven to a
critical variable in ecological health: in general, the greater the
fragmentation, the less functional are ecological linkages and the more
imperiled are area-sensitive plant and animal populations. The WOPR
devotes little attention to this crucial issue, but it is clear that the
action alternatives would greatly increase habitat fragmentation. For
example, Alternative 2 calls for the construction of over 1,000 miles of
new roads (p. 585). As usual, continuation of present management would
be better than any of the proposed alternatives: "More than any other
alternative, the No Action Alternative would increase the size and
connectivity of mature and structurally complex forest patches compared
to the current condition... The No Action Alternative is the only
alternative that would increase the size and connectivity of the mature
and structurally complex forest patches in the Western Cascades and
Klamath Provinces" (p. 498). Under the No Action Alternative, only 14%
of existing old growth would be logged over the next 100 years. For the
action alternatives, that figure would be 25% for Alternative 1, 43% for
Alternative 2, and 63% for Alternative 3 (Table 151, p. 509).

Under the Northwest Forest Plan, much habitat connectivity was provided
by riparian reserves. Under all the action alternatives in the WOPR,
this riparian connectivity would be severely limited, as is clear from
an examination of Figs. 253 and 255 (pp. 728 and 731).

BLM must do a thorough, explicit analysis of the effects of the action
alternatives on habitat fragmentation, especially impacts on threatened
species such as Northern Spotted Owls and coho salmon.

**Preservation of the Northern Spotted Owl:** Much of the analysis in
the WOPR, particularly with regards to Alternative 2, is predicated on
the recent Fish and Wildlife Service draft recovery plan for the
Northern Spotted Owl. This draft recovery plan has been the subject of
scathing criticism, including from an independent peer review conducted
by experts from the American Ornithologists' Union and the Society for
Conservation Biology. It is entirely unacceptable for BLM to make
management decisions based on this incomplete, unapproved, and deeply
flawed plan. The population models used in the WOPR lack credibility --
but even using these optimistic models, the preferred alternative
(Alternative 2) is expected to produce no increase in Northern Spotted
Owl habitat over the next century (Fig. 216, p. 635). It was, of course,
the critical lack of such habitat that led to the adoption of the
Northwest Forest Plan as a way to save

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the Spotted Owl from extinction. Both Alternatives 1 and 2 would
eliminate all protection for known and historic owl activity centers in
the Timber Management Areas (Table 1, p. XLIX).

These TMAs account for 37% of BLM's Western Oregon forest under
Alternative 1 (p. 75), and 48% under Alternative 2 (p. 89). If
[any]{.underline} of the WOPR action alternatives are adopted, the
continued survival of the Northern Spotted Owl is in grave doubt. The
WOPR thus fails to meet BLM's legal obligations, which are stated
clearly under "purpose and need": "In accord with the Endangered Species
Act, the \[WOPR\] plans will use the BLM's authorities for managing the
lands it administers in the planning area to conserve habitat needed
from these lands for the survival and recovery of species listed as
threatened or endangered under the Endangered Species Act" (p. XLIV).

**Other Wildlife and Plants:** The WOPR DEIS acknowledges over and over
that the action alternatives would be worse for a wide array of wildlife
species and rare plants than would the No Action Alternative. For
example:

-   "The habitat needs of forest-floor associated species that are
    highly endemic to one or several locations would be at risk of
    decline in abundance and distribution under the three action
    alternatives" (p. LVII).

-   "Under the three action alternatives, some populations \[of special
    status plants\] on O&C lands would be lost and the risk of local
    extirpation or extinction to bureau sensitive species and bureau
    assessment species would increase compared to the No Action
    Alternative" (p. LVI).

-   "Alternative 2 would have the greatest risk \[of invasive plant\]
    introduction based on levels of harvesting and associated roads"
    while the "No Action Alternative would have the lowest risk of
    invasive plant introduction" (p. LVII).

-   Due to lack of snag and green tree retention, "Under Alternatives 1
    and 2, the stand establishment and young forest structural stage
    classifications created as a result of regeneration harvest would
    have little or no value for landbirds species which require residual
    trees or snags" (p. 707).

-   For Marbled Murrelets, "Under Alternative 2 and 3 in Coast Range and
    Klamath provinces, a decline in habitat conditions would be expected
    given decreased patch size, decreased core area, increasing edge
    density, and decreases in nesting habitat over the next 50 years"
    (p. 682).

While it is commendable that BLM is forthright in acknowledging the
damage their action alternatives will do, their responsibility does not
amount simply to full disclosure. Their responsibility is to manage
public land in an ecologically responsible and sustainable way -- and
that, by their own admission, the WOPR would not do.

**Climate Change:** There is general scientific consensus that global
climate change will be a dominant ecological force in the coming
century. And yet, despite filling the WOPR report with dozens of graphs
and models that confidently extend out to the year 2106, BLM
deliberately ignored this compelling problem: "The analysis assumes no
change in climate conditions, because the specific nature of regional
climate change over the next decade remains speculative" (p. 491). It is
easy to sympathize with BLM's dilemma: it is quite true that no one can
now be

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certain exactly what the magnitude and nature of climate change in
Oregon will be. However, the appropriate response to this uncertainty is
not to ignore it (while pretending an ability to model out 100 years
[without]{.underline} taking climate change into account). The
appropriate response is to allow for the increased uncertainty that
climate change implies, and manage in a cautious, conservative way. In
other words, allow the lands you manage some additional ecological
leeway -- leeway that will almost certainly be needed in a drastically
changing world. This means more riparian reserves, not less; more
unharvested old-growth, more effort to minimize fire hazard (which
global warming will exacerbate), more allowance for wildlife population
fluctuations. In short, it means throwing out Action Alternatives 1, 2,
and 3, none of which allow for the increased ecological uncertainly
which our forest will undoubtedly face in the coming decades.

The WOPR also completely fails to acknowledge, much less evaluate, the
contribution that old-growth forests make to regulating the climate and
acting as carbon sinks. These benefits will become increasingly vital in
a changing world.

**Fire:** It's hard to believe that the Bureau of Land Management would
propose to drastically and permanently increase the risk of wildfire on
their lands in southern Oregon.  And yet, that is exactly what the WOPR
would do.

 

The facts are detailed in the section "Fire Severity, Hazard, and
Resiliency in the South" buried in BLM's WOPR DEIS (Vol. II, pp.
769-772).  This compares three "action alternatives" in comparison with
continuation of the present management plan (the "No Action
Alternative"). So which alternative would provide us with the best fire
future?  

BLM's own analyses show that a continuation of present management would
be best: "The No Action Alternative would result in the most decrease
\[in fire hazard and severity\], reducing the acres of high severity
fire when wildfires occur and fire hazard to less than half of the
current condition in 100 years" (p. 769).  What about BLM's "preferred
alternative," Alternative 2?  This is the very [worst]{.underline} in
terms of fire.  In the Medford District alone, Alternative 2 would
result in approximately 200,000 more acres in the "high fire severity"
category than would continuation of present management (Figure 273, p.
769). 

 

But the bad news doesn't end there.  There is also the issue of "fire
resiliency" ­ the ability of a forest to survive a wildfire.  Once again,
BLM's preferred alternative offers us the [worst]{.underline} fire
future:  "Alternative 2 would have the greatest reduction in fire
resiliency by creating the largest number of acres of forest without
such green tree structural legacies combined with high crown fire
hazard" (p. 772).  "Green tree structural legacies" is BLM's term for
living trees left standing after logging operations.  Alternative 2
would accomplish almost all its logging by clearcutting (or
"regeneration harvests", in the BLM's preferred jargon), and thus would
produce even-aged plantations without any standing large trees.   The
forests that Alternative 2 would create are the worst in every fire
category:  high fire severity, high fire hazard, and low fire resiliency
(Table 214, p. 767).  BLM's preferred alternative would leave us with
less than a third of the fire-resilient forests in the Medford District
than we'd have if we kept our current management (Figure 274).  That's
well [over half a million more acres]{.underline} without the ability to
survive wildfire.

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The great majority of BLM's western Oregon forests are in checkerboard
ownership intermingled with private property, including increasing
numbers of homes.  It would be completely irresponsible for BLM to adopt
its WOPR preferred alternative.  To do so would expose the residents of
southern Oregon to drastically increased fire risk over the coming
decades.  This ill-conceived plan would also risk great reduction in
anticipated timber revenues and great increase in ecological damage due
to widespread wildfires. BLM must develop an alternative that adequately
takes into account the high fire risk of southern Oregon, and actively
manages its lands to reduce, not increase, that risk. BLM also needs to
conduct a realistic analysis of the effect of likely increased fire
under its preferred alternative on timber supply. If Alternative 2
results in as much additional fire as it threatens to, there may be
little unburned timber left to cut.

**OHVs:** Finally, it must be noted that the WOPR section on recreation
(pp. 775-783) is completely unbalanced, and is tailored almost
exclusively to the expansion of OHV opportunities. The WOPR proposes 10
new Off-Highway Vehicle areas for the Medford District BLM, which,
combined with the three existing OHV areas, would total over 100,000
acres. One of those areas, John's Peak, is so contentious that over
1,600 local residents have petitioned BLM not to designate it for OHV
use. In the words of BLM, Alternative 2 "would result in a four-fold
increase in acres of off-highway vehicle emphasis areas as compared to
the No Action Alternative...Alternative 2 would result in a loss of
nonmotorized recreational opportunities in the Medford District due to
the larger proportion of land that would be designated specifically for
motorized recreation use (12% of the district's total land base)" (p.
778).

The negative ecological impacts of OHV use are well-documented, and
include increased erosion, habitat fragmentation, air and water
pollution, disturbance of wildlife, and greatly increased fire ignition
risk. The OHV constituency is a small minority of the users of BLM
lands, as compared to hunters, fishermen, hikers, and campers. And
despite the responsible behavior of many OHV users, it is also a
constituency that is responsible for a disproportionate amount of damage
to the landscape. There is nothing in the WOPR "purpose and need," as
outlined by BLM, that justifies the proposed expansion, and certainly
the WOPR does not provide sufficient analysis of the ecological impacts
to allow responsible evaluation of even one of the proposed new OHV
areas. The focus on providing hugely expanded opportunities for OHV use
in the WOPR is completely inappropriate, and these proposals should be
withdrawn.

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