January 11, 2008

Edward W. Shepard, State Director

United States Department of Interior

Bureau of Land Management

Western Oregon Plan Revisions

P.O. Box 2965

Portland, Oregon 97208

Dear Mr. Shepard,

I am a natural resource planner in the state of Oregon. In my contracted
work with a watershed council in Cottage Grove, OR, I work with diverse
partners to develop and implement restoration projects to benefit water
quality, terrestrial and aquatic habitat. This comment is exclusively a
private comment, and should not be construed to represent any entity or
group of people.

Summary of Issues Illustrated in this comment:

-   A sustainable economy is emerging in Oregon, and this plan poses a
    threat to that.

-   Tools exist in modern business and economics that can more fully
    quantify potential risks to water quality, carbon sequestration,
    biodiversity loss, and soil loss/erosion/landslides than is
    quantified in this plan. The full life cycle of the forests and the
    value of all related goods and services need to be analyzed.

-   The WOPR does not consider local natural resource plans adequately.

-   Water quality standards, such as Oregon TMDLs are inadequately
    considered in the plan.

-   Recruitment of Spring Chinook in the Mosby Creek watershed is
    inadequately considered in the plan.

-   Connectivity and genetic viability of sensitive species may not be
    given enough consideration or study in this plan.

-   Regulation and land use restrictions must be evenly applied and
    managed and any new plan should include existing standards as a
    minimum baseline.

-   Large federal plans like WOPR have a dramatic impact on the
    political, social and ecological landscape of Oregon. Any revision
    to existing plans should consider the direct/ indirect costs,
    efficiency and effectiveness of planning at this level. As a planner
    at a local level, I would suggest that this scale of management is
    outdated and potentially threatens the existing conditions of
    communities, economics and ecosystems. A better approach would be to
    develop plans at the District level, with community participation in
    local planning.

When I moved to Oregon in 1993, the taste of the timber wars was like
fresh blood in the mouth of rural Oregon. While most had become
desensitized to the rhetoric and hatred, the rift in the rural
communities I lived in was as plain as day (Noti, Fall Creek, and now
Cottage Grove). Since then, most have moved on from these perspectives.
Industry has reduced on the ground impacts, the National Forest
Management Act is relatively functional in its dual purpose of providing
a wood supply and protecting species on federal lands and watershed
councils and state resource agencies have been building *incredible
alliances across all of Oregon*. These alliances have meant that people
once again see each other for what they are---other people. In this
context of humanity and partnership, vast human and fiscal resources
have been leveraged to improve resources and secure the longevity of
industry *by forming the basis of a sustainable economy*. From my
perspective working in a small rural community, people are ready to
diversify the local economy and open businesses based on their skill
sets derived from working in the woods and the logging industry. A
revitalized and localized economy could easily supply from local sources
the wood products needed to support the construction industry here in
Oregon not just with raw logs and milled lumber, but with hand crafted
specialty woodwork, diverse products made from small dimensional lumber
and working in the forest thinning reprod units and restoring
ecosystems.

The proposed harvest levels in all three alternatives have economic
impacts that are not calculated in two ways. One, it does not take into
consideration the impact to an emerging sustainable economy. This
emerging economy is evidenced by: revenue generated by sustainably
harvested and related products and their success in the market; higher
recreational use on federal lands (fishing, hunting, rafting and other
water sports, bird watching, rafting, hiking and other open space
activities, ORV, ATV and horseback riding uses); higher demand for
restoration; more demand for goods harvested from the forest
(native/non-native fish runs, mushrooms, native plants) and dwindling
supplies of these assets on private and municipal lands. These impacts
to natural capital need to be considered in the economic analysis. In
addition, the economic projections made by the WOPR are on too short of
a timeline. One decade of detailed analysis is inadequate in relation to
the lifespan of the resource. A sustainable harvest must at least
account for the use of all currently alive, so that would be the
entirety of a career of a person just born---one that might end 75 years
from now. Present net value of the resource is only going to increase.
Oregon needs long-term economic and ecological security, and *the
No-Action is the only alternative that represents this.*

The values offered by the natural world are moving onto the balance
sheets of corporations. For example, Hyundai moved to Eugene in the late
1990s because the clean water in the McKenzie that flowed through EWEB's
infrastructure. As clean water, clean air, mineral resources, open space
and other once-plentiful offerings of nature become scarce, credit
trading will be a component of regulation. Already, a modal for
temperature trading is being developed in the Willamette Basin by the
Willamette Partnership---on which many industry representatives are
participating. *The WOPR needs to fiscally account for the impacts to
water quality, carbon sequestration, biodiversity loss, soil
loss/erosion/landslides and other impacts over the entire life cycle of
the impacts.*

In addition, because of the scale of economic projections made in this
plan, for each stand of trees harvested, the life of the oldest tree
should constitute the length of time required to calculate the return of
that forest. Calculations that reduce this timeframe or reduce the cost
of the impacts do not factor in all parameters. Science has proven that
an ecosystem is greater than the sum of its parts. Innovation is proving
that some of those parts are worth more than we ever imagined . . . and
risk evaluation should definitely include a variable for innovative
business, unique and undiscovered ecosystem relationships, unrealized
pharmaceutical constituents and other mysteries that may exist on public
land that we have not identified. Please refer to the rapidly developing
fields of conservation biology and ecological economics for access to
well-developed models that integrate mathematical models and this risk
assessment.

To quote renowned Ecological Economist Herman Daly, from his article
'Economics in a Full World', published in *Scientific American* Sept
2005, 'Humankind must make the transition to a sustainable economy\--one
that takes heed of the inherent biophysical limits of the global
ecosystem so that it can continue to operate long into the future. If we
do not make that transition, we may be cursed not just with uneconomic
growth but with an ecological catastrophe that would sharply lower
living standards.' He goes on to point out that, 'Recognizing and
avoiding uneconomic growth are not easy. One problem is that some people
benefit from uneconomic growth and thus have no incentive for change. In
addition, our national accounts do not register the costs of growth for
all to see'. Extensive published data of this nature behooves federal
land management agencies and federal judicial interpretation of the law
to include sound economic evaluations that consider the full range of
economic components.

*The WOPR does not consider local natural resource plans adequately.* As
is evidenced in Appendix A, an outline of Coast Fork Watershed Council
priorities, many documents exist and have existed for some time that
make local recommendations for management priorities on federal lands in
this watershed. Most of these recommendations were not evaluated in the
WOPR, and none were evaluated on a sub-watershed level. For example,
priorities identified in the BLM Mosby Creek Habitat Assessment, 2000,
include: '*preserve the character and connectivity of Late Successional
Reserves (LSRs) including: acquisition; protection of peregrine falcon,
spotted owl, elk, lynx and threatened plant (Aster vialis) habitat; and
road decommissioning*.' Please recognize that Preferred Alternative Two
would do the OPPOSITE of this recommendation because both character and
connectivity of LSRs would be lost, as would any protection that the
existing LSR system offers, because it would be categorically altered
under the new plan (except the **No Action alternative, which, I
endorse**). *Please refer to the list of published works below in
evaluating all science in the plan.* I will attempt to summarize my
understanding of potential watershed-wide impacts that I have drawn from
use of and reference to the documents in Appendix A, and all the
documents that inform these references as documented in the written
texts.

The priorities referenced in Appendix A, and many of the working plans
that watershed councils and their partners across Oregon utilize in
planning decisions are based on existing federal land use plans. To
clarify, Department of Interior historic O&C land management is
projected in these plans to follow the current trajectory of following
the Northwest Forest Plan, and many other entities depend upon this
which is clearly outlined in their plans.

Water quality standards, such as Oregon TMDLs are inadequately
considered in the plan. Temperature is the largest impact facing the
Willamette River---innumerable studies have been conducted on the risks
to native salmonids due to elevated temperatures in many tributaries.
Three undammed tributaries in the Coast Fork watershed that need further
evaluation for the impacts of temperature in this plan are: Mosby Creek,
Silk Creek and Camas Swale. Recruitment of Spring Chinook in the Mosby
Creek watershed is inadequately considered in the plan. OR Department of
Fish and Wildlife and Weyerhaeuser have been working to reintroduce
Spring Chinook to the watershed since 2005. The effects of harvest in
this subbasin need further evaluation.

I have concerns that this plan may not meet other state and federal
agency criteria for other species. BLM lands in the Coast Fork watershed
represent the northernmost connectivity habitat for Northern Spotted
Owls---it is the last connection between the genetic populations of the
Coast Range and the Cascades. Further study on the relationship between
the patchwork of late-successional trees on BLM land and the genetic
viability of local populations need to be made. In addition, further
study needs to be conducted for a myriad of sensitive species,
particularly amphibians, like the red and yellow-legged frog and
reptiles like the Northwestern pond turtle.

*Regulation and land use restrictions must be evenly applied and managed
and any new plan should include existing standards as a minimum
baseline*. If I want to place a logjam in a waterway in Oregon, after
purchasing engineering designs and going through a lengthy planning
process, I have to get permits from at least one federal and one state
and one county entity. Staff from each entity reviews my plan. In
addition, I have to compete for state dollars in order to implement my
project, which I spend locally and in benefit to the local economy. And,
oftentimes, this is when a plan at the scale of WOPR is already in
place. I fail to see why planners working to improve the resource have
to go through more regulation than planners who provide access to a
resource for industry. *This is unbalanced and represents a competitive
advantage for business to access federal timber resources with fewer
restrictions than their counterparts who function on state or private
land.*

In addition, because of the scale of economic projections made in this
plan, for each stand of trees harvested, the life of the oldest tree
should constitute the length of time required to calculate the return of
that forest. Calculations that reduce this timeframe or reduce the cost
of the impacts do not factor in all parameters. Science has proven that
an ecosystem is greater than the sum of its parts. Innovation is proving
that some of those parts are worth more than we ever imagined . . . and
risk evaluation should definitely include a variable for innovative
business, unique and undiscovered ecosystem relationships, unrealized
pharmaceutical constituents and other mysteries that may exist on public
land that we have not identified. Please refer to the rapidly developing
fields of conservation biology and ecological economics for access to
well-developed models that integrate mathematical models and this risk
assessment.

To quote renowned Ecological Economist Herman Daly, from his article
'Economics in a Full World', published in *Scientific American* Sept
2005, 'Humankind must make the transition to a sustainable economy\--one
that takes heed of the inherent biophysical limits of the global
ecosystem so that it can continue to operate long into the future. If we
do not make that transition, we may be cursed not just with uneconomic
growth but with an ecological catastrophe that would sharply lower
living standards.' He goes on to point out that, 'Recognizing and
avoiding uneconomic growth are not easy. One problem is that some people
benefit from uneconomic growth and thus have no incentive for change. In
addition, our national accounts do not register the costs of growth for
all to see'. Extensive published data of this nature behooves federal
land management agencies and federal judicial interpretation of the law
to include sound economic evaluations that consider the full range of
economic components.

Unfortunately, I must report that the Western Oregon Plan Revision
(WOPR) appears as heavy-handed federal action that rejects these local
alliances by polarizing the issue. The fires of the timber wars are
becoming rekindled and that will make the work of local, state, and
federal entities' work more difficult. It is difficult for me to
adequately convey the graveness of this political mistake. Obviously,
Oregon BLM land managers are Oregonians, and oftentimes it has been
federal agency representatives who have borne the brunt of the hatred
from this conflict. I have many friends who work for federal agencies
who have suffered alienation over natural resource disputes. I regret
that Washington, DC leadership has delegated this problem to our local
BLM authorities. In addition, because so many people in the field of
natural resources are committed to building alliances and staying away
from the political quagmire of this proposal, *many will not comment for
fear of polarizing themselves and neutralizing their effectiveness as
practitioners on the landscape*. From a planning perspective, clearly
this cannot be a fair and democratic plan and planning process if it
requires professional risk in order to participate.

Appendix A: Coast Fork Willamette Watershed Council Action Plan,
September 2007

**Introduction: Purpose/Need of the Action Plan**

This Action Plan is intended to outline the known ecological priorities
of the Coast Fork Willamette River watershed in a hierarchy that can
guide the choices of citizen and agency restoration planners. As the
reader will discover, three areas of emphasis need the attention of
restoration efforts: water quality, aquatic habitat and terrestrial
habitat. This watershed is situated at the southern end of the rapidly
growing Willamette Valley. As such, it is important that council members
are encouraged to take actions that will both remedy existing
impairments and prevent future degradation of the existing watershed
resource.

Since 95% of Willamette Valley is in private ownership, the key to
restoring and protecting priority habitats is cooperation with
landowners. As the purpose of Oregon's watershed councils is to
facilitate this voluntary cooperation in restoration efforts, the format
of this document is meant to be succinct and easy to understand.

In order to implement restoration projects that satisfy current and
future needs, part of the action planning process of the Coast Fork
Willamette Watershed Council (Coast Fork Council) was to identify a
process for developing projects, with particular focus on the Technical
Committee of the council. Having a clear and transparent process is
useful for all council committees, local landowners, and partners of the
Coast Fork Council. Part of creating that process is developing a common
frame of reference within which council members can discuss projects.

This Action Plan reflects the interest of the Coast Fork Council to
identify and develop the best and current opportunities for partnership
in the highest priority areas---it is intended that this is a working
document that will allow for new projects to evolve and completed
projects to be recorded and understood. It is likely that this Action
Plan will be the groundwork for a future 5 year + plan, but for now the
goal is to move forward on restoration project development and
implementation in the most efficient way possible.

#### 

#### Existing Data, Concerns and Priorities

# 

# **[Lower Coast Fork Willamette River Watershed Assessment (2005)]{.underline}**

The Lower Coast Fork Willamette consists of the river section from the
confluence with the Middle Fork Willamette near Mt. Pisgah, upstream to
the confluence with the Row River in Cottage Grove. Stream surveys were
conducted, fish trap data was collected and the resulting document was a
summary of this new data as well as some existing data sets, e.g. the
ODEQ 303d list of impaired waterways.

The Lower Coast Fork Watershed Assessment identified the following as
priority limiting factors:

-   Aquatic habitat for Spring Chinook salmon, cutthroat trout and
    Oregon chub including a lack of structure (such as large woody
    debris or vernal pools).

-   Historic stream channel modification---reduction of the floodplain
    and riparian zone as well as channel alteration (straightening,
    revetments, etc.)

-   Water Quality (temperature, mercury, bacteria)

-   Wetlands (loss to development and invasive species)

**[BLM Mosby Creek Watershed Analysis (2000)]{.underline}**

In 2000, a watershed analysis of the Mosby Creek watershed was completed
by the BLM, Eugene district.

Priority actions relevant to the council identified in this document
include:

-   Temperature: Minimize activities than increase water temperature
    (canopy removal, etc.)

-   Increase channel complexity with large woody debris (LWD) and
    boulders

-   Actions that preserve the character and connectivity of Late
    Successional Reserves (LSRs) including: acquisition; protection of
    peregrine falcon, spotted owl, elk, lynx and threatened plant
    (*Aster vialis*) habitat; and road decommissioning.

-   Inventory (locate and map) oak woodlands.

**[Coast Fork Willamette Watershed Priority Stream Ranking
(2007)]{.underline}**

The ODFW Conservation Strategy, PNW Ecosystem Research Consortium and
the Nature Conservancy Wetlands Inventory are individual documents (see
below) that set priority conservation areas by ecosystem type on a
regional level. Technical team members Pamela Wright, ODEQ, and Laurie
Bernstein, USFS, used GIS to unite these three datasets, along with
existing council priorities, to develop a set of rankings. The map below
displays the streams that came out as highest, moderate and lower
rankings for potential riparian, floodplain and aquatic habitat
restoration and conservation.

**[References:]{.underline}**

> Campbell, B. H. 2003. 'Restoring Rare Native Habitats in the
> Willamette Valley'. *A Landowner's Guide for Restoring Oak Woodlands,
> Wetlands, Prairies, and Bottomland Hardwood and Riparian Forests.*
> Defenders of Wildlife. Portland, OR.
>
> Dykaar, B.B. July 2005. Status and trends of Middle and Coast Forks
> Willamette River and their floodplain habitat using geomorphic
> indicators. Prepared for Willamette Partnership and U.S. Army Corps of
> engineers by Ecohydrology West, Santa Cruz, CA.
>
> Hulse, D., S. Gregory and J. Baker (eds.), 2002. *Willamette River
> Basin Planning Atlas Trajectories of environmental and ecological
> change.* 2^nd^ Edition. Prepared by the Pacific northwerst Ecosystem
> Research Consortium. Oregon State University Press, Corvallis.
> (**Referred to in this document as PNW Conservation Opportunity
> Areas**)
>
> Oregon Department of Environmental Quality (ODEQ). 2000. Source Water
> Assessment Report: City of Cottage Grove, OR PWS #4100236.
>
> Oregon Department of Environmental Quality (ODEQ). 2000. Oregon's
> Water Quality Status Assessment Report. Salem, OR.
>
> Oregon Department of Environmental Quality (ODEQ). September 2006.
> Willamette Basin Total Maximum Daily Load (TMDL) and Water Quality
> Management Plan (WQMP). Salem, OR.
>
> Oregon Department of Fish and Wildlife. 2006. The Oregon Conservation
> Strategy. Salem, OR.
>
> Scheerer, P. 1999. Oregon chub research in the Willamette Valley
> 1991-1999. OR Department of Fish and Wildlife, Corvallis.
>
> US Army Corps of Engineers, 2007. Willamette River Floodplain
> Restoration Study Base Conditions Report: Coast Fork and Middle Fork
> Willamette Sub-basins.
>
> USDA Forest Service, Umpqua National Forest/ USDI Bureau of Land
> Management, Eugene District. 1999. Sharps Creek Watershed Analysis.
> Cottage Grove Ranger District and Eugene BLM.
>
> USDA Forest Service, Umpqua National Forest. 1995. Layng Creek
> Watershed Analysis. Cottage Grove Ranger District.
>
> USDA Forest Service, Umpqua National Forest. 1997. Brice Creek
> Watershed Analysis. Cottage Grove Ranger District.
>
> USDI Bureau of Land Management, Eugene District. 2000. Cottage Grove
> Lake-Big River Watershed Analysis.
>
> Weyerhaeuser Company. 1999. Sharps Creek Watershed Analysis.
> Springfield, OR.

####### [Additional Council Priorities]{.underline}

*Local Issues of Importance*

-   Protection/enhancement of *Western pond turtle habitat*

-   *Mercury*: Community education and key actions to minimize risk.

![](media/image1.wmf){width="6.9222222222222225in"
height="8.98263888888889in"}

#### *Coast Fork Willamette Watershed Restoration Priorities Outline*

**Goal #1: Improve Water Quality**

# Objective 1.1: Mitigate temperature impairment

> Action 1) Increase shade along stream channels

i.  Identify high priority areas for riparian enhancement

-   Conduct further GIS analysis on Lower Coast Fork and Mosby Creek

ii. Restore riparian habitat to native vegetation in priority streams

-   Recruit landowners by sending a mailer to landowners in these
    sub-watersheds

    -   Upper Camas Swale

    -   Lower Coast Fork

    -   Mosby Creek

-   Continue riparian work in other tributaries and where landowners
    come forward in other priority stream areas:

    -   Hall Creek

    -   Lower Coast Fork Mainstem

    -   Row River Corridor

    -   Hill Creek

    -   Gettings Creek

iii. Encourage bioengineering strategies to reduce temperature impacts
     of structural impairments like revetments and channelization (areas
     where vegetation or aquatic structure is prevented from emerging
     naturally).

-   Remove or modify revetments along Lower Coast Fork

-   Work with city of Cottage Grove to address Silk Creek
    erosion/channelization issues

iv. TMDL Implementation Planning: reduce stream temperatures to meet DEQ
    water quality standards.

-   Work in concert with local DMAs (Cottage Grove & Creswell) to
    provide review of TMDL matrices, identify restoration opportunities
    and conduct education & planning forums on water quality issues.

> Action 2) Maintain or enhance riparian areas effectively shading
> streams

i.  Collaborate with local agencies on park and greenway planning

ii. Educate landowners on importance of and maintenance of waterways

> Action 3) Remove impoundments that contribute to elevated temperatures

i.  Identify and evaluate dams and other water retention devices on
    perennial streams; remove when beneficial to water quality.

# Objective 1.2: Reduce impacts of mercury contamination on human & environmental health 

> Action 1) Educate the community about mercury risks.

i.  Disseminate existing & council-prepared documentation on mercury
    issue.

> Action 2) Collaborate with state & federal agencies

i.  Clean up at Black Butte mine (EPA/DEQ lead)

-   Keep community informed

-   Maintain lines of communication between local community & federal
    cleanup managers.

ii. Explore opportunities to resolve issues of contaminated sediments

# Objective 1.3 Reduce bacteria contamination to Coast Fork Willamette River

> Action 1) Collaborate with local municipalities and state agencies

i.  TMDL implementation planning

-   Identify solutions and use communication tools to encourage their
    implementation.

> Action 2) Educate and partner with landowners to reduce non-point
> sources of nutrients.

i.  Provide (create or locate) educational materials about on-site
    manure management

ii. Provide (create or locate) educational materials on septic
    contamination.

> *Objective 1.4 Minimize erosion & sedimentation*
>
> Action 1) Collaborate with landowners to implement best management
> practices for road maintenance (culverts, sediment), forest practices
> (riparian buffer, roads) and other land uses (grazing, etc.)

i.  Develop partnerships with industrial landowners and work towards
    common goals.

ii. Develop relationships with agricultural stakeholders and work
    towards common goals.

> Action 2) Educate private landowners and council members about
> practices that help reduce erosion.

i.  Utilize the expertise of agencies such as ELSWCD for reference
    materials and expertise for best management of agricultural
    practices.

**Goal #2 Improve Aquatic Habitat**

## Objective 2.1 Improve stream channel structure & function

> Action 1) Restore aquatic habitats likely to be used by Spring Chinook

i.  Improve or create spawning habitat in Mosby Creek

ii. Improve channel complexity in Lower Coast Fork (rearing & migrating)

> Action 2) Enhance habitats for resident cutthroat trout, lamprey &
> others

Action 3) Reduce velocities when beneficial: restore meander & channel
character to reduce down-cutting.

Action 4) Monitor for target species to determine habitat quality &
effectiveness of restoration actions.

i.  Partner with ODFW & other state/federal agencies to monitor for
    aquatic species.

# Objective 2.2 Restore channel connectivity

> Action 1) Remove or improve known barriers

i.  Gather data about Hill Creek issues: diversion, dam and push-up dam

ii. Review revetment data for use in planning projects in Lower Coast
    Fork

> Action 2) Inventory & address barriers in priority watersheds

i.  Prioritization of barriers in close proximity to mainstem (Jeff
    Ziller 2/07)

## Objective 2.3 Restore floodplain habitats

> Action 1) Enhancement of backwater & side channel habitat

i.  Take restoration actions that benefit Oregon chub.

ii. Implement restoration strategies that benefit Western pond turtles

> Action 2) Improve hydrologic connectivity
>
> Action 3) Restore & maintain wetlands, wet prairie and wetland forests

i.  Encourage wetland banks and effective restoration

ii. Use check dams and other water-slowing strategies to reduce flow and
    provoke natural hydrologic regimes, as possible.

> Action 4) Monitor for target species to determine habitat quality &
> effectiveness of restoration actions.

i.  Monitor for existing turtle populations in key locations by placing
    logs and developing a monitoring plan for late April through
    mid-June in priority areas.

ii. Partner with ODFW & other state/federal agencies to monitor for
    aquatic species.

**Goal #3 Improve Terrestrial Habitat**

> *Objective 3.1* Enhance *Western pond turtle habitat*
>
> Action 1) Improve habitat in and around appropriate water-bodies
> (vernal pools, gravel ponds, etc) including: slope banks, plant or
> maintain compatible vegetation and basking logs.
>
> Action 2) Facilitate information sharing and best management practices
> around the Western pond turtles in the Coast Fork basin.

######## Objective 3.2 Restore, enhance & conserve native ecosystems

> Action 1) Bottomland hardwood and riparian forests

i.  Identify key bottomland and riparian forests within priority
    sub-basins, particularly the Lower Coast Fork using GIS analysis of
    aerial photos.

    a.  Prioritize specific reaches and tributaries that are high
        priority for temperature, hydrologic function and noxious weed
        impairment.

ii. Conduct landowner recruitment, plan and implement projects.

> Action 2) Wetlands and wet prairie

i.  Recruit landowners, plan and implement projects in the Camas Swale
    basin.

ii. Encourage wetlands mitigation & mitigation bank development that
    improve species composition and hydrologic function.

> Action 3) Oak/upland prairie habitats

i.  Maintain existing oak woodlands and savannahs through conservation
    strategies such as acquisition, conservation easements and
    restoration.

ii. Restore and enhance existing oaks by releasing encroaching conifers.

> Action 4) Late-successional Douglas fir forests

i.  Partner with landowners to protect & enhance habitat using
    restoration, education & acquisition.

ii. Identify priority areas for conservation.

> *Objective 3.3 Develop strategies to address noxious weeds*
>
> Action 1) Access best management practices for use by council and
> partners.

i.  Gather reference data on strategies for target invasive species in
    terrestrial habitats.

ii. Find, partner to develop or create a document that outlines the
    target non-native plant species for the watershed.

iii. Update website to reflect available online resources

> Action 2) Work with local landowners to implement best management
> practices for removal and management of noxious weeds.
>
> Action 3) Address noxious weeds on all project sites
>
> Action 4) Develop a noxious weed education strategy (specific to the
> Coast Fork or Upper Willamette River Watershed)
>
> Action 5) Inventory noxious weeds to develop database/map to guide
> actions