# Western Oregon Plan Revision

# (WOPR) Comments

# January 7, 2008

I have been following the WOPR project for almost two years. I have
attended various Bureau of Land Management (BLM) meetings and submitted
comments as far back as March 8, 2006.

Although I saw no evidence that any of my comments affected the Draft
Environmental Impact Statement (DEIS) I still felt compelled to review
it in detail. I also attended the BLM's technical meeting which gave me
a better understanding of what went into the DEIS.

Many aspects of the DEIS are disappointing and some extremely troubling.
A recommendation for alternative 2 is totally unacceptable and what
follows is a discussion of the problems I see with this alternative.

## Catastrophic Events

The effect of catastrophic events such as fire, windstorms or other
natural events was not taken into account. I was told they were too
unpredictable for the model. It is very predictable that these type of
events will occur and some allowance needs to be made in the EIS.

## Unaccepted Science

The BLM's spotted owl plans were based on a Fish and Wildlife Service
(F&WS) owl recovery plan that was not even approved at the time the BLM
wrote the DEIS. In fact, the F&WS plan has been widely discounted as a
politically motivated document and requests have been made to scrap it
and start over.

Recovery of the spotted owl is directly related to preserving and
increasing their habitat. Competition with barred owls will only become
worse if old growth habitat is destroyed. The BLM's plans dramatically
reduce spotted owl habitat.

The decision to use the F&WS report is in and of itself a reason to
question the integrity of the entire WOPR DEIS.

## Climate Change

The DEIS completely ignored climate change. Preserving the forests will
provide some level of carbon dioxide sequestering, yet this was not
considered in the document.

## New Roads

As part of alternative 2 roughly 1,000 miles of new logging roads will
be built. In determining costs and impact of these roads the BLM used an
optimistic scenario of moderate use. There was no attempt to explain
what effect extreme use might have. Heavily loaded logging trucks are
not what I consider moderate use.

Any new roads will increase maintenance costs. They will increase
erosion, which will pollute streams and degrade water quality.
Communities will, as a result, have to spend additional money to deal
with lower quality drinking water.

More new roads will open areas to motorized travel and recreation. These
activities have a negative impact on habitat and wildlife. There will
also be extra costs involved in regulating and policing these
activities.

## Reduced Riparian Areas

The BLM's DEIS proposes significantly reducing riparian areas around
waterways, in some cases to as little as 25 feet. I recently hiked in an
area of old growth that would probably be clear-cut as part of the WOPR
proposal. A stream running through the area would only have 2 trees
remaining along it under the proposed guidelines. Runoff from the
surrounding clear-cut as well as additional sunlight would pollute and
dramatically change the character of the stream. The remaining 2 trees
would be vulnerable to mud slides and wind damage and probably not last
long.

This lose of habitat is unacceptable.

## Salvage Logging

The BLM says it will protect some Late Successional Management Areas
(LSMA), old growth. However, after reading the DEIS carefully I found
that an LSMA can be "salvage logged" after a disturbance, such as fire
or wind. Basically this means there is no protection for old growth
forests. This will potentially reduce owl habitat even further.

## Alternatives to Old Growth Harvest

The DEIS did not look into options which left old growth forests
untouched. Their answer was that alternatives like thinning did not
provide long-term benefits.

## 

## Ground Truthing

When I asked about ground truthing of the models and data used for the
WOPR DEIS I was assured it was adequate. I have no way to verify that
statement. In the past government agencies have done a poor job locating
critters such as the red tree vole, which is critical to the spotted
owl. In the end private groups have had to show the forest service vole
nests. I don't trust that the BLM has provided enough in depth ground
truthing to justify their conclusions.

## Non-Listed Species

The BLM has dealt with species listed as endangered but have said
nothing about non-listed species. This includes flora, fauna, fungi etc.

**Riparian Areas**

As mentioned earlier riparian areas around streams have been
dramatically reduced in the BLM's proposal. One of the consequences of
clear-cutting is that the reduced riparian areas will be more vulnerable
to wind damage. Problems of this nature will increase the probability of
stream pollution as well as effectively reduce habitat.

## 

## Socioeconomic Impact

The socioeconomic section of the DEIS was symptomatic of the problems
with the entire document. I discussed the socioeconomic section of the
DEIS with the consultant who put it together. I felt the basis for the
cost and revenue figures was simplistic. There was no attempt to take
into account any of the following things. I was told their effect was
insignificant. I am not convinced.

-   Loss of tourist income due to regeneration harvesting (clear
    cutting)

-   Loss of hunting and fishing income, same reason as above

-   Cost to communities of lower water quality due to reduced riparian
    zones, runoff from an additional 1000 miles of logging roads and use
    of herbicides on clear cut areas

-   Reduced demand for timber and lower prices due to fewer housing
    starts

-   Reduced prices due to excess timber on the market

-   The effect of Canadian timber on the market

-   The effect of climate change

-   The effect of delays and cancelled timber sales due to law suits

-   The effect of having a minimal cut and selling carbon credits

-   The effect of moving away from timber to other industries such as
    wine or guiding

I feel the depth of analysis of economic factors was too shallow and one
sided to give a clear picture of what counties might expect to gain and
lose if alternative 2 is implemented.

## Concluding Thoughts

I feel the BLM made optimistic assumptions that will push our forests to
the very limits. The models indicate that the level of timber harvest in
alternative 2 is sustainable. However, if any of the assumptions are off
or the models even slightly incorrect our forests are in trouble. Based
on the fact that many factors mentioned above were not considered I feel
the BLM projections are wrong.

I understand that the counties need additional revenue. I feel the
county commissioners have been shortsighted to think government payments
would continue into the foreseeable future. They should have started
planning years ago for alternatives. I don't believe the BLM has
proposed a sustainable solution for county payments, despite their
assurances. County commissioners are once again ignoring reality if they
go along with the BLM's recommended alternative.

My definition of sustainable forestry is: if you cut a 100 year old tree
there is another tree turning 100 years old to replace it. Waiting 100
years to replace the tree is not sustainable forestry. You cannot cut a
tree that is older than your parents and call it sustainable.

The BLM needs to start over. They must not use studies based on
political pressure but rely on proven science. They need to take old
growth off the table and at a minimum rely on the Northwest Forest Plan.
Their assumptions need to be extremely conservative.

Future generations will not complain that we protected too many old
growth forests and did not clear-cut them. They will wonder why we did
not protect more.

Submitted by:

Adolph (Bill) Aspegren

1939 Alder Street

Eugene, Oregon 97405

\(541\) 242-3828

<aspegren@comcast.net>