**Trillium Farm**

**10,000 Little Applegate River Rd.**

**Jacksonville, OR 97530**

**WOPR comments: January 11, 2008**

We operate a family farm in the remote and scenic canyon of the Little
Applegate River, nearly surrounded by BLM-managed land. Over the decades
we, and the family that preceded us, have tried many ideas to make this
farm work for us. We've raised livestock and hay, operated a sawmill and
a trout hatchery, grown organic specialty vegetables and herbs, fruit
and berries. While not always financially successful, these have all
been fun, healthy and otherwise rewarding farming activities, giving us
a deep appreciation of pure water and the land itself.

However, one different activity here has always been as fun and much
more profitable than farming: tourism. In the decades after World War
II, Grandma's Trout Farm operated here hosting tourists in rustic cabins
and riverbank camping. Guests learned fly fishing, enjoyed wilderness
hiking and horseback riding, and hunting in season. Over 30 years ago,
we took over as Trillium Trout Farm, continuing the sawmill and trout
hatchery, and expanding the organic farming. We dropped the trout when
the droughts of the late 1970's left us with inadequate water flow. In
addition to organic farming, we continued the tourism business and
expanded by adding group retreats, events, weddings, conferences, and
seasonal schools. Over the last 30+ years, several thousand guests have
enjoyed the peaceful nature and scenic beauty of the river canyon and
surrounding mountains.

Our guests tell us they come because of the peace and quiet, scenic
beauty, myriad non-motorized recreation opportunities, and the cultural
amenities of the surrounding areas. The diverse local ecosystems make
for interesting hiking and wildlife viewing. Birders have come from
Portland, California, and New England to add new birds to their viewing
lists. We've hosted a group of European physicians for a workshop on
natural healing, Japanese musicians and performers on a break, and a
group of Persian trout farmers inspecting our hatchery. Our academic
sessions have drawn attendees from local schools, distant universities,
and students from Morocco and Israel. Other guests come to just unwind
and quietly relax at a riverbank campsite or a pondside hammock.

Our guests pump money into the local economy. In addition to shopping
for food, fuel, and gear, many of our guests also swim at Applegate
Lake, attend Shakespeare in Ashland, catch some great music at Britt in
Jacksonville, and go on wine tasting tours in the Applegate. They often
visit Crater Lake, the Redwoods, and Mt. Shasta. Some will raft one or
more or our fabulous local rivers like the Rogue, Klamath, and Illinois.
Often they'll eat out at Applegate River Ranch House or restaurants in
town.

Our guests tell us they enjoy coming here because there's not many quiet
peaceful beautiful places left to enjoy. They speak of places they used
to go; places where rowdy campers, gunfire, or the racket of motorized
recreation (motorcycles & quads, speed boats, snowmobiles, etc.) ruined
their peaceful vacation. Our guests recount their efforts at finding a
place like ours, searching backroads and the internet.

In addition to our guests, we also meet up with folks hiking or riding
horseback on the popular wilderness trails on BLM lands surrounding us.
Driving down the road, our first "neighbors" are trailheads for the BLM
trails, and we'll often stop & chat with folks who have just returned
from, or are about to begin, an outing into the beautiful wildlands.
Because or out moderate elevation and dry microclimate, these trails are
usually free of snow most of the winter. We've met horseback riding
groups who tell us that this area is one of the last good trail rides
for winter sun, autumn color, and spring wildflowers. Because OHVs are
prohibited on these trails, many hikers and equestrians particularly
seek out these specific trails so they do not have to be confronted by
the noise and presence of motorcycles. We hear of many places where
folks used to recreate but were "ruined" by OHVs, logging, or road
construction.

We are alarmed that BLMs WOPR plans to designate the area around us as
an Off-Highway Vehicle Emphasis Area. An increase over what is already
unacceptable levels of OHV noise would add this beautiful canyon to the
growing list of ruined places, and would degrade the natural amenities
that help ensure our success as a tourist-based business. While OHV
enthusiasts need places to recreate, some locations are too special
because of high natural values and established recreational uses that
would be precluded by high OHV usage. People who want to pursue quiet
activities such as hiking, birding, botanizing, horseback riding,
backcountry hunting are thwarted by the OHV noise that permeates
otherwise wild backcountry for miles.

In its Western Oregon Plan Revision (WOPR) Draft Environmental Impact
Statement (DIES), BLM has listed Anderson Butte as a potential
Off-Highway Vehicle (OHV) Emphasis Area of over 11,742 acres. This vast
area encompasses the entire north half of the river canyon, and nearly
surrounds our location, including our entire drinking watershed. While
the criteria for choosing such Emphasis Areas appears to have been
limited to current OHV use, a high level of important natural resource
values indicate that Anderson Butte would be a poor choice for a
destination OHV Emphasis Play Area.

According to the WOPR DEIS (page 331), 11,094 acres of designated Deer
Habitat Management Area, also known as Critical Deer Winter Range are
within the potential 11,742-acre Anderson Butte OHV Emphasis Area. The
present Resource Management Plan (RMP) Record of Decision (ROD) (page
48) directs BLM to "manage (these wildlife areas) with an emphasis on
providing thermal cover and minimizing disturbances"; and to "restrict
activities to avoid disturbance between approximately November 15 and
April 1." Since most OHV activity occurs during autumn/winter/spring
seasons and by nature is an activity that constitutes a major
disturbance to wildlife, designation of this area as an OHV Emphasis
Area would be counter-productive to its management as an important
wildlife resource value.

This deer range constitutes an important traditional hunting ground for
many local families and hunters from even distant locations who desire a
wilderness quality hunting experience. Such hunters contribute to our
local rural economy by patronizing campgrounds, stores, gas stations,
and inns.

The Izaak Walton League of America recently published *Collision Course:
Off-Road Vehicle Impacts on Hunting and Fishing.* This study contains a
survey of State Wildlife and Fisheries Managers in 34 states conducted
in July and August 2007. 61% of the managers agreed that "ORV's
negatively impact hunting and habitat" in their state. Regarding
specific impacts to hunting, the managers reported: resource damage to
habitat (83%), disruption of hunters during hunting season (72%),
increased accessibility to formerly remote hunting areas (67%),
disruption of game species during hunting season (61%). Only 47% of the
resource managers felt that "existing regulations adequately protect
hunting from harmful ORV impacts."

60% of the managers agreed that "ORV's negatively impact fishing and
fishing habitat" in their state. Regarding specific impacts to fishing,
the managers reported: ORVs driven along stream banks &/or lake shores
(87%), ORVs driven in streams &/or lakes (80%), ORVs causing erosion or
siltation into streams &/or lakes (67%). Only 37% of the resource
managers felt that "existing regulations adequately protect fishing from
ORV impacts.

How will BLM consider the wildlife habitat needs and importance of
non-motorized recreation when deciding about the OHV areas, particularly
Anderson Butte? Why doesn't BLM currently close all critical deer winter
range and other important wildlife areas to OHVs right now, as directed
by the RMP?

This proposed Anderson Butte OHV area contains many special attributes
besides critical wildlife habitat. The proposed OHV Emphasis Area
centers on Anderson Butte east to Bald Mountain, a long east-west
trending ridge separating the Bear Creek watershed to the north and the
Little Applegate River watershed to the south. While both the north and
south slopes of this ridge contain Spotted Owl core areas that require
seasonal protections, the two sides of the mountain are dramatically
different. The north slopes are primarily forested and intensively
roaded as a result of extensive timber harvest activities on BLM and
private industrial lands. In contrast, the south slopes of Anderson
Butte are characterized by roadless wildlands composed of a complex
mosaic of various ecosystems. These southern slopes contain multiple
natural resource values that must be examined when considering
designation as an OHV Emphasis Area.

This proposed OHV Emphasis Area comprises an approximately 6500 acre
roadless area that was first nominated for consideration as the
Dakubetede Wilderness in 1980. This area's extensive and popular
Sterling Mine Trail System, outstanding scenery, wilderness character,
and unique biodiversity all make it a superlative candidate for the
unique level of protection afforded by Wilderness designation. The
Dakubetede is prominently featured in the book *Oregon Wild: Endangered
Forest Wilderness* and is a unit of the proposed Siskiyou Crest
Wilderness advocated by several conservation organizations. Its trail
system is featured in several guidebooks to Oregon hiking trails. For
some inexplicable reason the Dakubetede was not chosen by BLM in the
WOPR DEIS process for inclusion in the list of lands with Wilderness
Characteristics (pages 417-18, and Appendix K), even though it has a
longer and more intensive level of advocacy for wilderness than other
areas that were chosen. The issue of Wilderness protection for this area
has made the Dakubetede Wildland a high profile and controversial area
for decades. The lack of its inclusion as described above will likely be
a source of critical comments on the WOPR DEIS. Meanwhile, designation
of the Anderson Butte OHV Emphasis Area would be a most controversial
decision, a controversy BLM would do well to avoid.

The proposed Dakubetede Wilderness discussed above is a biodiversity hot
spot, comprising an unusual concentration of diverse ecosystems and
biodiversity elements. Located in the rain-shadow of the Siskiyou's
highest peaks, this area's arid microclimate is possibly the driest and
sunniest location in western Oregon. As such contains the largest, most
diverse, northern extent of California chaparral shrub communities in
Oregon. It is home to the largest groves of old-growth juniper stands in
western Oregon; contains the second largest populations of the listed
*Frittilaria gentneri*, and the endemic *Sedum oblanceolatum*, and the
only known Oregon location of a rare birch, *Betula occidetnalis
inopina.* The area has extensive intact native grasslands (a magnet for
OHV traffic), and is noteworthy for its lack of yellow star thistle.
Many, if not all, of these important biodiversity values (and the
wildlife that depend on them for habitat) would be negatively impacted
by increased OHV use.

Sterling Mine Ditch Special Management Area (SMA is an important
cultural and historical resource that BLM has managed as an SMA in
compliance with the Antiquities Act. The Sterling Mine Ditch,
approximately 20 miles in length on BLM land, traverses the south slopes
of the Anderson/Bald ridge. According to the present RMP ROD (page 60)
and the WOPR DEIS (page 142), this SMA is closed to OHV use, a closure
that would be extremely difficult to enforce if the surrounding 11,742
acres was designated an OHV Emphasis Area.

The Sterling Mine Ditch Trail System has always been closed to OHV use,
and as such, has been very popular with hiking, hunting, and horse
enthusiasts who desire a wilderness trail experience without the user
conflicts associated with motorized recreation. Because of its location
in dry lower elevations, this trail system provides year-round access
and is especially popular during winter months when higher elevation
trails are covered with snow. The WOPR DEIS (table page 127) is in error
regarding the extent of the Sterling Mine Ditch Trail system. The
mileages in this trail system should read: Sterling Mine Ditch Trail
(Deming Gulch to Little Applegate): 18 miles, Wolf Gap Trail: 2 miles,
Bear Gulch Trail: 1 mile, Tunnel Ridge Trail: 1 mile (not 41 miles!),
and Little Applegate Trail: 1 mile. The combined 23 miles of
historically maintained hiking trails make this trail system second only
to the Pacific Crest trail in length within the Medford District.
According to the present RMP ROD (page 60) and the WOPR DEIS (page 142),
most of the Sterling Mine Ditch Trail system is closed to OHV use, a
closure that would be extremely difficult to enforce if the surrounding
11,742 acres was designated an OHV Emphasis Area.

Hidden Creek and Listening Tree are short hiking trails (1 mile each
according to WOPR DEIS \[page 127\] that have been managed as
Environmental Education Areas with OHV use restricted to existing roads
according to the present RMP ROD (page 58). Recreation opportunities and
OHV related negative impacts are similar to those described in the
Sterling Mine Trail System discussion above.

The WOPR DEIS (page 127) lists a potential 1796-acre Dakubetede Wildland
ACEC located on the south slopes of Anderson Butte. Designating the
surrounding several thousand acres as an OHV Emphasis Area would create
negative OHV impacts to this sensitive area incongruent with adequate
protection mandated as an ACEC.

The Holton Creek Research Natural Area is a 423-acre old-growth reserve
located on the north slopes of Point Mountain. According to the present
RMP ROD (page 61), this RNA is closed to OHV use, a closure that would
be extremely difficult to enforce if the surrounding 11,742 acres was
designated an OHV Emphasis Area.

There is an indigenous sculpture (boulder arrangement) in the grassland
below the summit of Bald Mountain. OHV use is the biggest threat to the
continued integrity of this important cultural resource.

OHV damage currently exists along most of the major crests in the
potential Anderson Butte OHV Emphasis Area, including unauthorized
trails cleared by OHV users. The damage ranges from an eroded hill climb
on Goat Cabin Ridge to excessive use on the old crest trail that once
connected the lookout towers that topped Anderson and Wagner Buttes.
Unlike the areas hiking trails, the OHV trails are extensively littered
with beer cans, bottles used for target practice, shotgun shells, and
other trash. Through personal communication with several OHV users in
the area over the years, it appears current OHV use is limited to
relatively small groups of users, some of whom fear that designation of
the area as an OHV Emphasis Area would bring in unwanted new users and
further degrade the area. Such designation would undoubtedly lead to
severe increases in all negative impacts of OHV use.

Present BLM guidance under the RMP ROD (page 63) states: "Manage OHV use
on BLM-administered land to protect natural resources, provide visitor
safety, and minimize conflicts among various users." The potential
Anderson Butte OHV Emphasis Area is already a long-established home to
hikers, birders, hunters, horseback riders and others seeking quiet
recreation; increased OHV use should not be added to the mix. How would
BLM propose to manage and enforce OHV activities? Why hasn't BLM taken
steps to close some popular hiking areas (not just the trails) to OHV
use as provided in the RMP?

Many residents of the Little and Upper Applegate areas who are concerned
about BLM management have entered into a cooperative Memorandum Of
Understanding (MOU) agreement with BLM to better explore possible
solutions to management conflicts. This process has thus far been
beneficial in addressing timber, wildlife, water quality and other
issues. Designation of an Anderson Butte OHV Emphasis Area would be a
big step backward in what has been a hopeful exercise for both residents
and Ashland Resource Area management and staff.

On behalf of our neighbors in the Applegate, we urge you to use the
discussions above as rationale for our recommendation to BLM that the
Anderson Butte area be removed from further consideration as potential
OHV Emphasis Area in the Final EIS for WOPR. While much focus has been
placed on providing OHV areas, where is the balanced focus on providing
quality areas for non-motorized recreation? This is inconsistent with
your DEIS, which predicts a 27% increase in non-motorized recreation vs.
only a 5% increase in motorized recreation. Additionally, the 2004
Oregon Statewide Trail User Survey (used to create the *Oregon Trails
2005-2014: A Statewide Action Plan*;
(see: [[http://www.oregon.gov/OPRD/PLANS/docs/trails/StatewideTrailsPlanFinal.pdf]{.underline}](http://www.oregon.gov/OPRD/PLANS/docs/trails/StatewideTrailsPlanFinal.pdf))
indicates 438,000 Oregon households engage in non-motorized trail
recreation, while only 98,000 Oregon households engage in motorized
trail recreation. Why isn't the amount of recreation planning balanced
with predicted & actual uses? Please explain in the FEIS how your OHV
proposals are linked to funding (provide figures) from Oregon State fuel
taxes, and how that funding might continue if contemplated changes are
made to the existing motorized recreational tax funding programs.

Another problem BLM needs to address that was not contained in the DEIS
is gunfire. There has been a great increase of gunfire on BLM lands in
recent years. We have experienced bullets whistling through the trees
and hitting buildings from gunfire on BLM land over a mile away. BLM
should provide special areas for all gunfire not associated with
hunting, e.g. target practice. Such areas should not be on hilltops and
ridgecrests where bullets and sound carries longer distances. Roadside
quarries off ridges are good candidate locations. Presently, a ridgetop
quarry a few miles away has become popular with even military-type
weapons. The guns sound much closer, and several clips of an assault
rifle going off during a wedding ceremony here is an unnecessary
intrusion on our right to enjoy the peace and quiet on our property.

Regarding economics, we consider ourselves part of the transition of
southern Oregon to a more diverse economy with one focus on tourism. The
WOPR proposals would result in a drastic change in the scenic and
environmental amenities on our area. We fear that tourist related
business would suffer in any of the action proposals are implemented.
Research indicates that economic growth in rural Oregon counties is
associated with protected areas on federal land. To quote from
*Environmental Protection, Population Change and Economic Development in
the Western United States*:

> "This analysis shows that the presence of protected federal lands is
> associated with population growth, income growth and employment
> growth. While it does not prove that protected lands cause this
> growth, it does provide support for the argument that, in the rural
> West, economic security is associated with counties that no longer
> rely on the environment as a source of raw materials for export, but
> instead use the environment as a magnet to attract tourism, retirees,
> and small businesses."

We would appreciate any answers you can provide in the following
questions to help us address our concerns.

Has BLM conducted research on the possible impacts that the WOPR will
have on individual Oregon residents and the economic future of
non-timber businesses in rural Oregon communities?

How will the WOPR impact the value of Oregon residential, agricultural,
and business property in the O&C corridor? We are concerned that the
WOPR will make our property investments more difficult to market for the
highest dollar value.

Has BLM conducted any research that explains the potential loss of
property value and property marketability the WOPR might inflict on land
owners in the O&C corridor? What research have you done to clarify how
the loss in property value will be off-set by a higher or equal value in
the reduction of property taxes?

How will the WOPR impact the economic viability, sustainability, and
future of tourism dependent businesses in the O&C corridor? The reason
for our concern is the severity of the impacts the logging in
Alternative 2 will have on visual resources, which the BLM describes in
their visual resource index (VRI) as visually obvious and distracting to
the casual observer.

Research on tourism indicates the majority of Americans travel to see
scenery while other studies indicate the majority of travelers choose
destinations where the community has preserved is natural and cultural
heritage. How are we supposed to market ourselves in a landscape of
clear-cut logging? Has BLM done any research on marketing strategies for
O&C communities who must readjust their current economic planning to
survive under the force of these impacts?

We are also concerned about the perception that the traveling public
will have when they see clear-cuts. Most people who have never seen a
clear-cut describe their first experience as if they had just seen an
area ravaged by an atomic blast. This is going to make it difficult to
market ourselves as place that preserves its natural and cultural
heritage! Has BLM done any research on how tourism businesses are going
to market the O&C corridor as a travel destination with the loss of this
strategic marketing value? What will be the net loss of this
marketability and how are you proposing to assure tourism businesses
will survive and grow after the WOPR destroys Oregon's strategic tourism
industry marketing values?

We have read that tourism is predicted to be the number one industry in
America within the next decade. How will the WOPR impact the ability of
communities in the O&C corridor to expand and grow in a direction that
will enable them to capture these dollars for their economy? Do you have
any information to assure us and owners of tourism-based businesses that
the WOPR is not going to cause a gradual decline and annihilation of
tourism dependent businesses and hence the annihilation of the
community's ability to capture tourism dollars?

Can you explain how the economic value we gain from logging will provide
an equal or greater economic return to the communities that have lost
their tourism industry? Will there be new jobs for the tourism
businesses that may go out of business as a result of the WOPR?

Considering that the American dollar is weakening against other
currencies around the world, have you done any research to help O&C
counties understand how the WOPR might impact their ability to compete
in the global tourism market and help get our money back into this
country? Tourism cannot be outsourced as a resource. No one can take our
tourism resources away from us and move them to another country. For
that reason, we feel it is foolish to support a forest management plan
that risks destroying tourism resources that could bring hundreds of
millions of dollars to the O&C corridor *every year*. We are extremely
concerned about the economic future of Oregon under a plan that destroys
tourism for the purpose of committing our O&C lands to timber production
that contributes to Oregon's economy at an agonizingly stale cycle of
once every 80-100 years.

Has BLM done any research on the impacts the WOPR will have on the
quality of life in the O&C corridor and how this might impair the
ability of communities to attract business development or attract
home-based entrepreneurs and service providers who create their own
jobs?

We are concerned that the intense logging proposed in the WOPR is going
to detract from our quality of life by making O&C lands unusable to the
public and that this in turn will reduce or limit the ability of a
community to expand or diversify its quality of life resources.

The loss of quality of life resources will have extended impacts. For
example, if we were able to expand the number of equestrian trails on
O&C lands, we might attract more people to move into the area who own
horses. This will benefit local feed and tack stores and increase the
opportunity of selling agricultural products such as locally grown hay.
Equestrian trails on O&C lands would increase the opportunity for
attracting riding clubs or holding annual riding events, which increases
tourism spending. Has BLM done any research on how the exclusion of
quality of life from WOPR planning is going to impact significant
economic opportunities for the community?

Has BLM done any research on the role quality of life plays in
attracting business development or recruiting the development of
non-timber industries in a community?

Has BLM created a list of potential quality of life alternatives and
researched the potential economic contribution they could make to a
community and estimated what will be lost if they are displaced by
timber practices that minimize quality of life values? For example:

> [Equestrian trails]{.underline}: Increases property value, benefits
> local shops, increases tourism opportunities.
>
> [Walking trails]{.underline}: Walking is the number one recreation in
> America. Healthy lifestyles are a strongly marketable attribute.
> Increases property value, increases tourism opportunities, increases
> community health.
>
> [Biking trails]{.underline}: Mountain biking is a popular sport with
> Gen X. Increased mountain biking would benefit local shops, increase
> tourism opportunities, and make the community a more diversified
> living experience which contributes to the value of property.
>
> [Wildlife habitat]{.underline}: Birding is the fastest growing
> activity in America. Forest attributes that create a diversity of bird
> habitats increases the opportunity for marketing the area as a place
> for a diversified living experience. Property value increases,
> increases opportunities for tourism marketing.
>
> [Quality of life values]{.underline}: QOL values attract home-based
> entrepreneurs and internet-based service providers. Increases the
> number of jobs in the community, their income is able to purchase
> other services in the community such as construction, landscape
> maintenance, house cleaning, etc.. QOL may also play a role in
> attracting business and clean industry.
>
> [Unique logging practices such as the Natural Selection
> Alternative]{.underline} (Page 108 Vol. 1 of the Draft WOPR): This
> proposed alternative was rejected by the BLM but should have been
> given more consideration because it creates a unique cultural
> marketing opportunity with a forest management practice that harvests
> timber in a way that creates recreational and tourism resources. A
> unique forest management practice give us powerful publicity marketing
> values, long term local forest jobs, increased opportunities for
> tourism, walking trails, equestrian trails, mountain biking trails,
> birding, and interpretive trails.

Does timber harvesting on O&C lands create an equal or greater economic
return than these six alternative economic strategies?

Has BLM given any thought as to how we can use timber management to
obtain wood fiber AND create quality of life values that enable each
acres of O&C land to contribute to the local economy every year rather
than once every 80-100 years? We are very concerned about how the WOPR
will impact Oregon's future economy with its strategy that commits each
acre of O&C land to a cycle contributing to the economy at an extremely
stale rate of once every 80-100 years. Has BLM done any research on how
we can make these lands productive every year rather than once every
80-100 years?

The WOPR combines forestry and economics toward a specific set of goals.
The entire plan is based on the assumption that there is a hungry timber
industry waiting anxiously to bid on every timber sale the federal
agencies can design and offer. However, such has not been the case. Even
prior to the current housing market slump and mortgage crisis, many BLM
timber sales in the Medford District did not attract bids. Now, as any
investment analyst will declare, the housing market and related
industries are not looking good these days. How does BLM plan to meet
its WOPR goals if a reduced demand for wood products even further
reduces demand for BLM timber sales?

In the forestry realm, the WOPR DEIS proposes vast acceleration of
converting native forest stands to intensively managed plantations. This
proposal triggers questions more than comments. Please answer these
questions in the FEIS.

Any long-range forestry plan must justify anticipated growth of
plantations. Previous research in the Medford District (on file at
Medford BLM) indicates that the ORGANON modeling program used by BLM to
estimate future growth of plantations grossly overestimated tree growth
while underestimating negative impacts such as clumpiness, non-stocked
openings, and animal damage. What surveys and modeling is BLM using for
these WOPR proposals? Please indicate how which data were utilized to
obtain results displayed in the FEIS.

Even adequately growing plantations must survive to maturity to provide
the economic values described in the DEIS. Review of plantations in the
Medford District indicate that compared to native forest stands,
plantations are more susceptible to damaging, and often fatal, impacts
from several sources. Even-aged plantations are more susceptible to
animal damage, pathogens, and environmental damage (windthrow, solar
insolation, drought, vegetative competition) than native forests. Fire
history also indicates that plantations are more likely to burn
catastrophically than native forest stands. How has BLM computed these
risks into the predictions of plantation growth?

BLM admits in the DEIS that the thinned forests and native forests
converted to fiber plantations will significantly increase fire danger
at the landscape scale while reducing the resiliency of the forest
stands to survive fire. Please indicate quantified rationales for
increasing such fire danger, and include amount of increased funding
required for more firefighting, slash management, impacts on local
communities.

From our research, it appears the WOPR is based on faulty science
regarding the viability of the spotted owl and salmon and inadequate
measures to protect them under the Endangered Species Act. The WOPR
should stop now and wait for the issues and scandals surrounding
endangered species to be investigated and rectified before completing a
FEIS. Otherwise, this process will be a huge waste of time and taxpayer
dollars. Should that happen, who is responsible and accountable for
deciding to continue pushing the process forward?

We are very alarmed that the WOPR is sending Oregon in a direction of
economic stagnation, reduction of property value, increased tax
liabilities, lower quality of life, impairment of our ability to recruit
business and industry, and loss of tourism and tourism dependent
businesses. The questions above must be answered during the preparation
of the FEIS. We recommend that the WOPR process be halted while the
questions are answered and the answers are presented as an amendment to
the DEIS.

Thank you for reading our comments. Please ensure our questions and
concerns are tracked and answered in a transparent manner.

Susanna and Chant Thomas, owners,

Trillium Farm

Jacksonville, OR