January 10, 2008

To Whom It May Concern:

I am writing in response to requests for public comments on the WOPR. I
live adjacent to BLM lands in the Medford District, but I have extensive
field experience in the Eugene, Roseburg, and Salem Districts.

The damage from logging in Western Oregon has compounded to the point of
heavily impacting the landscape across numerous watersheds. Due to the
ongoing fragmentation of Western Oregon watersheds from past, current,
and proposed logging operations as well as the existence of numerous
roads, I find that the majority of the watersheds are in need of
restoration in the form of road decommissioning, area closures, small
diameter (less than 18") thinning projects, and ecologically-focused
burning projects. **Individual timber sales are not isolated actions,
they exist within a major action plan which is impacting the entire
watershed. These actions have not been adequately examined or mitigated
by the WOPR!**

"Of the various threats to biological diversity on National Forest
Lands, habitat fragmentation is perhaps the most serious."
(Diefenderfer, 11.66)

More important than the [human]{.underline} eyesore of logging is the as
yet unanalyzed site-specific cumulative impacts that logging has on
soils, plants, animals, streams, seeps, springs, rivers, and the entire
interconnected ecosystem.

**[Soil Movement, Soil Structure, and Nutrient Loss]{.underline}**

Let's start with soil, in particular soil movement or landslides. Given
the steep slopes that exist in much of our area, a much larger
percentage of trees (perhaps 80%) must be left to ensure soil stability.
NFMA calls for the protection of slopes and soils. **I would like to see
you measure soil stability in a unit by unit analysis and determine what
level of retention will truly support future growth and prevent topsoil
erosion under Oregon rainfall. Please consider the following natural
equations in your analysis.**

1.  Steep slopes + Loss of living roots + Loss of Canopy + Rainfall 
    Major landslides + Flooding + Increased stream sedimentation  Lack
    of habitat for in-stream breeding of fish, amphibians

2.  Loss of canopy  Unlawful stream temperature increase

3\. Major landslides  Nutrient loss and loss of soil structure 
Difficulty/Impossibility of forest regeneration

4\. Major landslides + Flooding  Human death + Destruction of property
downstream

Soil is NOT a renewable resource. I have read that it takes hundreds of
years for one inch of soil to be regenerated. **Can you quantify soil
loss due to the loss of living roots which hold soil in place? How are
you measuring soil stability? I want to see how you will ensure soil
stability, how you will make sure nutrients and topsoil do not run off
with the rains, how you will monitor stream sedimentation, water
temperature of all associated waterways, and how you will guarantee that
landslides and floods will not occur.** Please remember the importance
of dead wood - decaying wood purifies water, stabilizes slopes, releases
nutrients, and retains water. (DeVall, 27) The presence (or absence) of
standing trees significantly impacts water flows, with clearcuts
resulting in rapid snow melt and runoff.

**I want you to measure the steepness of all proposed units and come up
with an assessment of how the soils will stay in place with the loss of
living tree roots. Can you assess how seedlings will grow with topsoil
runoff? How will you replant such steep slopes?**

I am also worried about nutrient depletion in forest soils due to the
reduction of dead wood on the forest floor. **I would like you to
reanalyze the nutrient content on soils throughout each district in
order to determine if the soils are adequately protected.** I suspect
that fixed nitrogen levels are decreasing due to the death of old growth
dependent mosses and lichens (see plants). Please define the studies
which justify further elimination of the high canopy nutrient cycling.

**[Plants]{.underline}**

I am particularly concerned about the damage to understory plants and
their habitats which will result from the destruction of canopy
coverage. A number of endangered/sensitive plant species exist in
Western Oregon. In the Upper Williamette Resource Area (for example),
endangered/sensitive understory plant species include (but are certainly
not limited to) *Cimicifuga elata, Ophioglossum pusillum, Oxypolis
occidentalis, Romanzoffia thompsonii, Scheuchzeria palustris var.
americana, Utricularia minor, Botrychium virginianum, Carex cusickii,
Drosera anglica, Gentianopsis simplex, Lathyrus holochlorus, Mimulus
pulsiferae, Montia diffusa, Orobanche pinorum, Parnassia fimbriata* var.
*hoodiana, Polystichum andersonii, Polystichum lonchitis, Scoliopus
hallii*.

**How are you managing for Oregon Endangered and Threatened Plants? I
would like you to assess the impact of logging on all of endangered,
threatened, and sensitive plants. These rare plants require careful
protection at this point due to the already fragmented nature of the
landscape. In fact, sensitive species require undisturbed forest
interior habitat. A comprehensive restoration plan to protect these
plants is needed and is required. The deconstruction and reseeding of
logging roads and elimination of motorized access throughout the
districts should be examined as an option.**

> When restricted to small areas, surrounded by a modified, even alien
> environment, natural ecosystems can suffer a loss of biological
> diversity, most noticeably through the extinction of populations and
> species. (Diefenderfer, 11.66)

Some of the aforementioned plants (such as CIEL, BOVI, GESI, ORPI, POAN,
POLO, SCHA) depend on moist, shady coniferous forests and will die if
the canopy is opened up to allow more light and heat to reach the forest
floor. Even more detrimental to understory plant health than the change
in canopy structure is the disturbance to the forest floor and all
herbaceous plants by logging machinery. Logging compacts the soil, as
well as the layers of low-growing mosses and herbaceous plants. Logging
destroys soil stability, structure, and nutrient cycling through the
loss of living tree roots. Plants need their habitat protected just as
animals do. I feel that plants are of special concern because of their
limited mobility; they may migrate over many years through seed
dispersal, but for the most part they are specifically adapted to the
areas in which they grow.

It is important to consider "long term stability and relatively constant
levels of shade and moisture for slow-growing species such as Pacific
Yew." (Diefenderfer, 1.74) Likewise, "shade tolerant herbs that spread
slowly by rhizomes or other vegetative means," such as bugbane,
wintergreens, prince's pine, coral root, and rattlesnake orchid require
protected conditions. (Diefenderfer, 1.74) Liverworts are also old
growth dependent, relying on the bark of old trees.

Understory (often shade-dependent) plants are not only worth protecting
for their intrinsic beauty and human uses (medicine in particular) but
also because of their roles in an interconnected ecosystem. Loss of
plant species diversity results in less resistance to insect pathogens,
a slow in nutrient cycling, and a lack of food, medicine, and habitat
for animals. Sick, starving, and homeless animals do not make for a
healthy forest ecosystem. The negative repercussions of destroying
small, seemingly insignificant, plant life are far-reaching and
potentially catastrophic.

The management of forests for timber, primarily Douglas-Fir, results in
a long-term change in forest conditions which is not conducive to the
growth of shade-loving Western Hemlocks. Logging in 60-100 year cycles
eliminates the successional process that a forest goes through as it
matures. Non-human disturbances occur on an infrequent, irregular basis
which allows for the existence of a variety of forest successional
stages as opposed to logging which has occurred at such a rate that the
number and quality of late successional forests has been reduced to a
tiny fraction of what once was. Western Hemlock is a climax species in a
number of areas. Cutting at the level proposed in the WOPR will open up
these areas to sunlight and force the forests into earlier Douglas-Fir
stages. In destroying the shady, moist habitat conducive to Western
Hemlock growth, average temperatures of air and water rise to the point
that they destroy the habitat of Western Hemlock associated plant and
animal communities.

**In your impact statement, please address the loss of Western Hemlock
habitat. How will continued logging throughout the watershed impact
Western Hemlock and associated communities? Because the WOPR doesn't
adequately study site-specifics, where will you leave forests to reach
climax and how will their function as old growth habitat be impaired by
their existence as small islands amidst a sea of clearcuts and young
forests? How will you ensure forest structural complexity?**

In addition, very old trees serve specific, exclusive functions within
forest ecosystems. In short, aerial mosses and lichens are old growth
dependent, living in the crowns where they collect atmospheric nitrogen
which later makes its way to the soil. Tree voles and squirrels rely on
old trees for water collection, food, and shelter. Large snags provide
habitat for birds and bats. (DeVall, 27) Dead wood is a working part of
the ecosystem - passing on the "legacy" of one forest to the next,
nurturing western hemlock seedlings, wood ferns, and saprophytes.
(Diefenderfer, 1.74-5) It is critical that old trees remain a part of
forest ecosystems.

**Are you leaving old trees? How many? How old? Under what conditions -
are they isolated or among a community of their peers? What about
standing dead wood and "nurse logs"?**

**[Riparian Buffers and Beyond]{.underline}**

The WOPR has allowed for riparian corridors - streamside buffer zones in
which large mammals may travel and waterways may remain untainted - but
I question the effectiveness of such buffer zones in an interconnected
stream system. Riparian buffer zones commonly exclude seeps and
underground waterways. Cutting in such areas raises water temperatures
due to the decrease in canopy coverage. The sun beats down on the
unsheltered areas, drying them out and increasing the temperatures.
Downstream "protected" zones are thereby impacted by upstream
unprotected seeps and springs. Increased water temperatures threaten
fish, frog, salamander, and other aquatic species' habitat because these
animals require extremely cold, clean, and clear water to reproduce. Our
native fish are rapidly declining due to predation and increased stream
temperature. How will logging help this emergency situation?

**I want to see you map out and establish buffer zones for seeps and
springs in ALL logging units in order to maintain cold downstream
temperatures for aquatic life.**

**[Ridge Tops and Road Removal]{.underline}**

Riparian corridors supposedly provide passageways in which large mammals
may travel. However, large mammals also like to travel along ridges for
ease of travel and for better vantage points of the valleys below.
Putting in roads along ridge tops and establishing open yarding areas
disrupts these natural migratory patterns. **Further study is needed to
investigate large mammal travel and to assess how proposed ridge top
roads may impact such animals. Displaced large mammals are at risk for
extinction and may also result in undesirable confrontations with human
settlements. I would like you to assess how road removal in the
management areas will enhance large mammal travel, reduce invasive
species, improve drainage patterns, and limit ecosystem fragmentation.**

Fragmentation of forest ecosystems (the patchwork pattern of cutting
proposed) destroys both plant and animal habitat. The resulting island
geography disrupts forest connectivity. An interconnected ecosystem
requires interconnected forests. **Please explain in your report how you
will maintain an interconnected forest ecosystem with habitat that will
support populations of native species (particularly those associated
with late-successional and old-growth forests), including protection for
riparian areas and waters. I would like to see an in-depth investigation
of "edge" effects on plant and animal diversity.**

Natural disturbances "diversify and perpetuate" forests while the
patchwork pattern of clearcuts simplifies and stresses forests. (DeVall,
26) The "mosaic" pattern created by natural fires, insects, storms, and
other non-human disturbances results in a diverse canopy structure and a
variety of habitat types. Partial cuts, thins, shelterwoods, and other
management practices can in no way hope to approximate this complex
process. If the cuts you propose are supposed to approximate nature, I
would like a detailed explanation of how that is so.

It is human control-oriented arrogance which perpetuates the myth of
industrial forest management. How can people manage what we do not
understand? **How are you going to manage for species that you do not
know exist?** Recognizing the ridiculous presumption that a forest
ecosystem is "knowable," "controllable," or "manageable" is the first
step towards implementing acceptable forest policy.

**[Economic Arguments Against Timber Sales]{.underline}**

In short, please consider the long-term restoration expenses associated
with the aforementioned ecological considerations. The hidden costs of
road failures, soil depletion, mud slides, flooding, species extinction,
and other unforeseen environmental tragedies far outweigh the short-term
economic gains of timber harvest.

In closing, I direct you to the dedication of *Clearcut* (Devall):

This book is in memory of the plantlife, birds, insects, animals, and
indigenous cultures

that have been driven to extinction by the greed and delusion

of human arrogance. All of us in the Industrial Growth Society must take
the responsibility

for this condition and make it our duty to halt the continuation

of economic and social structures that perpetuate this "death of birth."

We must try to visualize extinction and learn

to understand accurately how certain patterns of human behavior lead to
the

extinction of species. We *do* have the ability to enrich,

not impoverish, our lives and the planet wherein we dwell. We pray and
hope

for the continuing evolution of forest ecosystems.

We work for realistic, ecological, sustainable interpenetration of
humans and forest

ecosystems, living by ecological terms rather than economic terms.

Thank you for your attention. Please include me in the on-going dialogue
about the WOPR.

Sincerely,

Michelle LaFave

1030 Left Fork Humbug Creek Road

Applegate, OR 97530

541-846-9842

REFERENCES

Burditt, Lynn. Letter. October 3, 1997.

DeVall, Bill. *Clearcut: The Tragedy of Industrial Forestry.* San
Francisco: Sierra Club Books/Earth Island Press. 1993.

Diefenderfer, Heather. *Protecting a Vanishing Ecosystem: The Ancient
Forests of the Pacific Northwest.* Oregon Ancient Forest Alliance. 1992.

Dimling, Jennifer. *Willamette National Forest Sensitive Plant Field
Guide.* Pacific Northwest Region: Forest Service, USDA. 1991.

Franklin, J. F. and Dyrness, C. T. *Natural Vegetation of Oregon and
Washington.* Pacific Northwest Forest and Range Experiment Station:
Forest Service, USDA. 1973.

Logan, S. E., Hemstrom, M. A., Pavlat, W. *Plant Association and
Management Guide: Willamette National Forest.* Pacific Northwest Region:
Forest Service, USDA. 1987.

Pojar, J. and MacKinnon, A. *Plants of the Pacific Northwest Coast.*
Canada: B.C. Ministry of Forests and Lone Pine Publishing. 1994.

*Record of Decision for Amendments to Forest Service and Bureau of Land
Management Planning Documents Within the Range of the Northern Spotted
Owl.* Forest Service, USDA, US Dept. of the Interior, BLM. 1994.

*State of Oregon Endangered and Threatened Lists for Plants*. Oregon
Department of Agriculture.