**Deer Creek Valley Natural Resources Conservation Association**

PO Box 670, Selma, OR 97538, 541-597-4313

January 10, 2008

Western Oregon Plan Revisions

PO Box 2965

Portland OR 97208

<orwopr@or.blm.gov>

**RE: Draft Environmental Impact Statement for Western Oregon Plan
Revisions, August 2007**

Dear Ed Shepard, Dick Prather, and WOPR Project Team,

I am submitting these comments in behalf of the Deer Creek Valley
Natural Resources Conservation Association, also known as the Deer Creek
Valley Association (DCA), of Selma, in Josephine County, is a 32 year
old community organization dedicated to retaining and restoring the
health of forest and human communities in the Deer Creek and other
watersheds.

October 2005, **DCA submitted the Natural Selection Alternative (NSA)
with the request that it be included in the alternatives to be evaluated
in the Western Oregon Plans Revision process**. The NSA is based on 14
Criteria for Sustainability, proposed by DCA and local community for use
on BLM lands in the Deer Creek Watershed since 1997.

Please incorporate DCA October 21, 2005 scoping comments; Orville Camp's
Scoping Comments; our March 16, 2006 Response to Scoping Report and
Proposed Planning Criteria and State Director Guidance; and all
previously submitted comments and supporting documents submitted by DCA
regarding the WOPR.

We include by reference: *Scientific Evaluation of the Implications of
the BLM's Western Oregon Plan Revisions (WOPR) to Forests and Watersheds
of Southwest Oregon by Rich Nauman and Dominick DellaSala of the
National Center for Conservation Science & Policy, September 4, 2007;
The Brandt Report, Answering the Economic Questions Sidestepped by the
WOPR by Roger Brandt December 2007; and WOPR DEIS Comments by Gordon
Lyford, December17, 200*. These comments along with those of our forest
advisor, Orville Camp will focus on the proposed Natural Selection
Alternative and the premises and principles on which it is based. We
will also discuss some of the impacts of the WOPR on the Deer Creek
Watershed and surrounding areas.

We will also respond to this Newsletter 7 request:

> *"As you share your interests and suggestions with us, your comments
> will be most useful to us if they address one or more of the
> following:*
>
> *• Errors in our analysis.*
>
> *• New or missing information that would have a bearing on the
> analysis.*
>
> *• Suggestions of a new alternative or management principles that
> address the purpose and need of the plan revisions and meet all the
> statutory requirements applicable to the lands managed by the BLM in
> western Oregon. An example would be an alternative composed of parts
> of the other alternatives analyzed in the EIS."*

**WOPR DEIS:**

> ***Alternatives Considered but Eliminated from Detailed Study*** \[pg
> 104\]*/**Harvest Only Naturally Selected Dead and Dying Trees
> ***\[pg107\]
>
> *This alternative would remove only "naturally selected dead and dying
> trees, conditioned upon meeting the needs of other species." Timber
> harvesting of such trees would be accomplished with small equipment
> from a network of narrow roads.*
>
> *This alternative was eliminated from detailed study because it would
> not meet the purpose and need, which states that the resource
> management plan revisions must meet all applicable laws. One of the
> applicable laws is the O&C Act. The O&C Act requires that the O&C
> lands that are classified as timberlands are to be managed for
> permanent forest production following the principles of sustained
> yield, which includes determining and declaring the annual productive
> capacity of such lands with the timber from those lands (not less than
> the annual sustained yield capacity) being sold annually.*
>
> *Also, while this management approach may be practical for managing a
> small woodlot on relatively flat terrain, such an approach is
> impractical for managing a landscape of the size and ruggedness that
> is managed by the BLM in western Oregon. The level of roaded access
> and survey efforts that would be necessary to identify and harvest the
> trees that die on BLM lands in western Oregon every year would be
> prohibitively expensive both in financial and environmental terms.*

**What was the basis for these statements? They are false statements.
The community supported Natural Selection Alternative (NSA), fulfills
the plan's purpose and need.**

Conversation with BLM officials at BLM meetings and open houses indicate
that you did not understand our comments, the NSA or its basic
assumptions. **The NSA is a new to BLM alternative and offers new
"management principles"; fulfills the purpose and need of the plan
revisions and meets all the legal responsibilities applicable to the
lands managed by the BLM in western Oregon.** It is not included in any
of the WOPR proposed alternatives. This is why we submitted the
alternative during scoping. We wished to give every opportunity for the
BLM and the NSA to fulfill the NEPA requirement to rigorously explore
and objectively evaluate a reasonable range of alternatives.

Our response to BLM statements regarding eliminating the NSA from
detailed study, are further addressed later in these comments, and in
DCA Forest Advisor, Orville Camp's comments.

WOPR Newsletter #7 has identified areas that need to be addressed in the
WOPR because of expected impacts of the proposed alternatives, and
*where comments and ideas could be most helpful in developing the
revised resource management plans:*

-   *How can we increase the fire resiliency of the forests in the
    Medford District and the Klamath Falls Resource Area of the Lakeview
    District?*

-   *How can we better manage the harvestable land base in such a way
    that will increase the rate of recovery of the northern spotted owl
    and the marbled murrelet in the short term, while still providing a
    consistent and stable timber supply?*

-   *How can we speed the redevelopment of structurally complex forests
    after regeneration timber harvesting?*

-   *What management techniques might we use to lessen the effects to
    special status species?*

The NSA and natural-selection-based principles addresses all these
areas. The Natural Selection Alternative reduces fire hazards and
severity and increases fire resiliency in forests. The NSA retains and
restores natural forests thereby increasing the rate of recovery of the
northern spotted owl and the marbled murrelet in the short term and long
term, while still providing a consistent and stable timber supply. Did
the WOPR team consider these things before it eliminated the NSA?

You ask *"How can we speed the redevelopment of structurally complex
forests after regeneration timber harvesting?"* This implies that it is
possible to restore structurally complex forests after cutting them
down. Orville Camp comments in detail as to why this is a false premise.
The NSA recognizes that it is other species that retain and restore
forest ecosystems. Please explain the rational for not including any
alternatives based on this premise.

The NSA provides a sustainable solution and would greatly contribute to
the long term economic stability of the communities in the BLM Western
Oregon planning areas and achieve permanent forest production. The NSA
places forest health first, which lays the foundation for all forest
products and uses at a sustainable level, providing community long term
economic stability and social health. It cannot work the other way
around.

The Natural Selection Alternative: 1) retains natural forests for all of
the species that create and sustain them, 2) retains optimal forest
health for optimum productivity, 3) has no down time, the reason why it
produces more timber than forestry tree stand plantations, 4) retains
visual, spiritual, historical, educational, cultural, recreational, and
other non timber values, 5) provides the best possible forest fire
protection possible through stewards that retain late successional
forests and fire fighting capabilities, an extremely valuable feature
for protecting forests during global warming, 6) extraction occurs when
trees have reached the dead and dying stage because this reflects what
the forest can truly produce at any given point in time, not what
someone thinks it will produce through management, which is never as
much as what Nature's forests produce, 7) is appropriate, practical,
universal and economical approach for the smallest to largest
landscapes. While the BLM road system is large and impacting, and
degrades the landscape, the NSA small contour access system is
appropriate in much steeper terrain with much greater sensitivity, and
less impact on the hydrological, ecological and aesthetic values of
these lands. The NSA contour access trail system is minimal impact while
providing permanent access for all products and uses, 8) will shift from
high impact and destructive logging methods to forest and community
friendly permanent stewardships, providing a steady supply of forest
products in perpetuity and easy access for and constant availability of
fire fighting equipment.

Sustainable forests necessitate retaining suitable environments for all
of the species that create and sustain natural forests including timber.
Species that create and sustain forests must be allowed to continue
doing so. None of the proposed BLM tree stand/plantation alternatives
would retain natural forests, and there is no evidence to support the
contention they can. Managing natural forests as tree stand plantations
has not sustained forests or tree production.

Historical BLM forestry tree stand management practices have not been
sustainable, are not sustainable, and cannot be made sustainable. The
BLM proposed action alternatives are not biologically or ecologically
based, they are based upon the same management-based assumptions and
conversions of natural forests into tree stand plantations, and
deforestation practices that have caused our current high fuel and fire
hazards, biological, ecological, environmental, social and economical
disasters.

The Natural Selection Alternative, the first of its kind for public
forests, addresses virtually all major forest issues and has the
potential to contribute greatly to the social and economic values of the
rural communities and counties of Western Oregon.

> *"For the last ten years these lands have been managed under six
> Resource Management Plans that were developed using the standards of
> the Federal Northwest Forest Plan. Implementation of these Resource
> Management Plans has been very successful on some fronts, but has not
> been successful on others \-- particularly in meeting commitments made
> with local counties and communities for timber production." WOPR
> newsletter 1, pg3*
>
> *It's time to take a close look at these Resource Management Plans and
> make some adjustments if possible. Your contribution to this process
> is vital. WOPR newsletter 1, pg1*

DCA asked in our scoping comments for adjustments to be based on sound
data and analysis. We offered to join in this effort as the NSA will
better effect the implementation of the O&C act, ESA, CWA, MUSY, FLPMA,
and other laws the BLM must meet while building bridges between
communities, agencies, and past and future generations to live in these
regions and benefit from the multiple uses of these resources locally
and globally. Our contribution doesn't seem very vital at this point,
but it could have been and it still could be. Think of it as a new
alternative and this as a new opportunity, since it was a missed
opportunity during the scoping process.

The BLM had assured us during the WOPR process:

> "The BLM believes the key principles which guided the development of
> alternative for the Northwest Forest Plan are still valid."

**Northwest Forest Plan**

On April 2, 1993 President Clinton President Clinton asked at the Forest
Conference in Portland:

> \"How can we achieve a balanced and comprehensive policy that
> recognizes the importance of the forest and timber to the economy and
> jobs in this region, and **how can we preserve our precious old-growth
> forests**, which are part of our national heritage and that, once
> destroyed, can never be replaced?

The President set forth five principles to guide the federal interagency
effort to develop a strategy to protect the old-growth related species
and produce a sustainable level of timber:

> President Clinton said, \"First, we must never forget the human and
> the economic dimensions of these problems. **Where sound management
> policies can preserve the health of forest lands, sales should go
> forward**. Where this requirement cannot be met, we need to do our
> best to offer new economic opportunities for year-round, high-wage,
> high-skill jobs. Second, as we craft a plan, **we need to protect the
> long-term health of our forests, our wildlife, and our waterways**.
> They are gifts from God, and we hold them in trust for future
> generations. Third, our efforts must be, insofar as we are wise enough
> to know it, **scientifically sound, ecologically credible, and legally
> responsible**. Fourth, the plan should **produce a predictable and
> sustainable level of timber sales and non-timber resources that will
> not degrade or destroy the environment**. Fifth, to achieve these
> goals, we will do our best, as I said, to make the federal government
> work together and work for you. We may make mistakes but we will try
> to end the gridlock within the federal government and we will insist
> on collaboration not confrontation.\"(24)

**It is now apparent from the WOPR DEIS that the BLM intends remove NWFP
protections to remaining old-growth forest and old-forest associated
species, and abandon the NWFP Aquatic Conservation Strategy. \[Nauman
and DellaSala 9/07\]**

How can "The BLM believe\[s\] the key principles which guided the
development of alternative for the Northwest Forest Plan are still
valid." while contemplating WOPR changes that will unravel the
protections of the Northwest Forest Plan?

As was presented in our scoping comments, the NSA is based on the key
principles which guided the development of alternative for the Northwest
Forest Plan, one of the stated goals of the WOPR.

The Natural Selection Alternative proposed a viable solution to meet the
vision of the Northwest Forest Plan and comply with the O&C Act and all
applicable laws.

Brandt Report *Answering the Economic Questions Sidestepped by the
WOPR*, December 2007, page 27 concludes:

> *"The WOPR is a management strategy that produces the lowest economic
> output at the greatest expense to society. Each acre of land is
> managed to produce one timber harvest every 80-100 years. The result
> of this is the commitment of two million acres of O&C forest land to
> create a meager 3,600 jobs, all of which come at the expense of job
> loss in other sectors, loss of property value, and tax liabilities. It
> makes far more sense to retain values that contribute to quality of
> life and use the forest to put other economic sectors to work. The
> outcome of this strategy will make these forest lands productive every
> year rather than once every 80-100 years.*
>
> *Many far-reaching economic objectives could be achieved with less
> cost to society by retaining and growing forest values that contribute
> to quality of life, which opens the door for using O&C lands to
> contribute to the economic stability of communities and industries.
> This can be accomplished while HARVESTING A SUSTAINABLE YIELD OF
> TIMBER. The authors of the WOPR miss this point completely as well as
> miss the fact that this is how the O&C Act directs the BLM to manage
> the timber on O&C lands.*
>
> *The O&C Act directs the BLM to manage timber to achieve five
> purposes, and these five purposes will not go away no matter how much
> the authors of the WOPR engage in cut and paste distortion of law.
> This behavior does nothing but validate the public perception of BLM
> arrogance and the confirmation that the WOPR is nothing more than a
> federally sponsored antitrust program with a price tag of economic
> deterioration for Oregon and financial loss for Oregon residents."*

WOPR has attempted to misrepresent the O&C act's clear conservation
ethic, the first federal statute to impose sustained-yield constraints
on timber cutting, to protect streams and watersheds, to view the
long-term economic stability of local communities as priority over
short-term economic gain, and to consider recreation as part of the
purpose of these lands.

The NSA fulfills the real intention of the O&C act and the
sustained-yield constraints on timber to retain values that contribute
to quality of life and long term priorities over the destructive
practices that it was created to prevent. The five purposes, easily met
by the NSA, would not be met by WOPR proposed alternatives. The WOPR
alternatives will not make these forest lands productive every year in
perpetuity, the NSA would. Rejecting the Natural Selection Alternative
(NSA) is arbitrary and capricious.

We concur with Gordon Lyford's WOPR comments of December 3, 2007 Western
Oregon Plan Revisions (WOPR) revised 12/17/2007 pg 7 states:

> *"Page 107, rejecting the Natural Selection Alternative (NSA) is
> arbitrary and capricious. How is it that the BLM accepted the NSA as
> meeting the Purpose and Need for a portion of the South Deer Landscape
> Management Project (on O&C Lands) and not for the WOPR? The NSA is
> based on sustainable yield principles, and is suitable on steep lands.
> The WOPR is simply wrong in its description of the NSA. The NSA is not
> prohibitively expensive in financial and environmental terms. The fact
> of the matter is the exact opposite as demonstrated at the many
> locations in the Pacific Northwest where the NSA has been successfully
> employed for decades. The WOPR clearcutting plan is however
> prohibitively expensive in both financial and environmental terms. The
> WOPR states that the No Old-Growth Harvesting alternative would not
> meet the Purpose and Need. The O&C Act does not require the
> liquidation of old-growth trees. This statement shows that the true
> Purpose and Need of the WOPR is to liquidate old-growth forests."*

**The DEIS failed to provide viable solutions to the BLM stated
Preliminary Issues raised for the Scoping Process. The NSA provides a
solution for each of these as briefly described:**

[]{.mark}

**[BLM Stated Preliminary Issues]{.underline}**

BLM Issue: How should BLM provide a sustainable supply of wood and other
forest products as mandated by the O&C Lands Act while meeting
applicable laws and regulations?

DCA: Sustainable supply of wood and other forest products require
sustainable forest ecosystems. The WOPR proposed alternatives destroy
functioning ecosystems by converting them into non-sustainable tree
plantations.

Issue: How can BLM-managed lands contribute to the conservation of
species consistent with the Endangered Species Act?

DCA: Retain environments that these species are dependent on. WOPR
proposed alternatives destroy functioning late successional ecosystems
that these species are dependent on.

Issue: How can BLM-managed lands contribute to meeting the goals of the
Clean Water Act and the Safe Drinking Water Act?

DCA: Retain fully functioning ecosystems that retain forest floor,
underground natural "piping" system; and protect from heavy equipment
and vehicles from operating in the forest, but keep on ecologically
responsibly constructed forest access systems.

Issue: How should BLM manage public lands to reduce the risk of
wildfires and integrate fire back into the ecosystem?

DCA: Number range CHAPTERRemoving only dead or dying trees addresses
climate change issues through optimal green plant and carbon storage
while reducing fuel and fire risks. Closed canopies cause trees to grow
taller, understory is reduced or disappears, and ground fires are less
likely to reach the canopy. Address forest fire issues through natural
processes that eliminate costly management costs.

**How does the BLM respond to each of the following points in the
*Scientific Evaluation of the BLM's Western Oregon Plan Revisions (WOPR)
Impacts on Forests and Watersheds*** by Richard S. Nauman and Dominick
A. DellaSala of the National Center for Conservation Science & Policy,
September 4, 2007 in considering the issues and intentions discussed
above and laid out by BLM during scoping?

• The BLM proposes to eliminate Northwest Forest Plan (NWFP) protections
of old-growth forests and old-forest associated species and abandon the
NWFP Aquatic Conservation Strategy.

• The preferred alternative more than doubles the area of old-growth
forest clearcut.

• The DEIS claims minimal or no-effect on fish, wildlife, peak flows,
and sediment in spite of an overall 3-fold increase in logging.

• The BLM interprets the O&C Act as placing timber production above
other land uses and values including protecting watersheds, regulating
stream flows, and providing recreational facilities that are
specifically mentioned in the O&C Act as well as the protection of areas
with special designations such as Areas of Critical Environmental
Concern.

• The proposed alternatives increase fire hazard and severity throughout
the plan area while reducing the resiliency of forests to fire.

• The DEIS fails to adequately asses the impacts of Global Climate
change and does not address the effects of logging old forests on carbon
cycles.

• The DEIS underestimates the potential impacts of the exotic plant
disease Sudden Oak Death and fails to disclose the effects of a large
increase of logging on the spread of this emerging disease.

• Relies on a flawed Recovery Plan for the Northern Spotted Owl.

• Alternative management strategies could produce a sustainable source
of wood from BLM lands while protecting the last remaining stands of
old-growth timber on BLM lands and the forests, salmon, and clean water
valued by Oregonians.

It appears that the intentions BLM laid out during scoping (Issues) were
either, arbitrary and capricious, or the WOPR DEIS is. There can be no
other conclusion by the way in which the issues laid out have failed to
be addressed by any WOPR alternatives. The Natural Selection Alternative
addresses each of the above four significant issues and was given no
comprehensive evaluation.

**Methodology requests**

On what basis did the BLM decide not to use or respond to the following
standards put forth by the DCA of natural-selection-based criteria to
analyze impacts of resource extraction on the human and natural
environment? Would the BLM consider them at this point, if they did not
before?

Indicator #1: Natural-selection-based criteria will provide a standard
and methodology by which to analyze environmental and socio-economic
consequences of each alternative and how timber production can determine
economic stability.

Methodology: Use "14 Criteria for Sustainability" as submitted by the
DCA in scoping as a standard for planning criteria to analyze each
alternative.

Indicator #2: Species traits and the environment determine
"natural-selection-outcomes."

Methodology: Human actions that change climate, soil, water, air, food,
shelter, habitat and/or reproduction necessities, will be evaluated in
terms of the "cumulative effects of natural-selection-outcomes".

**DCA raised many of the following issues during scoping and do not feel
that they have been addressed by the WOPR DEIS. Additional issues and
concerns raised by the DEIS are included here. Please reply to the
following issues and concerns in the WOPR FEIS:**

**[Alternatives]{.underline}**

**Issue: The Purpose and Need Statement for the WOPR must be broad
enough so that it does not foreclose the consideration of reasonable
alternatives.**

NEPA regulations require environmental analyses to include a statement
that \"shall briefly specify the underlying purpose and need to which
the agency is responding in proposing the alternatives including the
proposed action\". 40 C.F.R. § 1502.13. The statement of purpose and
need must be broad enough so that it does not foreclose the
consideration of reasonable alternatives. [City of Carmel-by-the-Sea v.
United States Dep't of Transp.]{.underline}, 123 F.3d 1142, 1155 (9th
Cir. 1997) ("The stated goal of a project necessarily dictates the range
of 'reasonable' alternatives and an agency cannot define its objectives
in unreasonably narrow terms.")

**Issue: The BLM is NOT committed to alternatives harvesting a minimum
amount of timber volume irrespective of environmental consequences to be
in compliance with the NWFP and/or O&C Act.**

BLM forest lands are intended to provide for more than timber
production. The BLM is [not]{.underline} committed to harvesting a
minimum amount of timber volume irrespective of environmental
consequences to be in compliance with the NWFP and/or O&C Act . This
narrow reading of the requirements of the NWFP; the O&C Act and or other
laws would artificially lead the BLM to truly consider only those
alternatives that propose significant harvesting activities. Timber
production at all costs is not required by the NWFP or the O&CAct and
should not be the principal focus of the BLM in developing and
evaluating alternatives for the WOPR.

Additionally, the Federal Land Policy and Management Act ("FLPMA")
obligates the BLM to manage public lands for multiple use and sustained
yield. 43 U.S.C. § 1701(a)(7). The term "multiple use" includes "the
management of the public lands and their various resource values so that
they are utilized in the combination that will best meet the present and
future needs of the American people ...." [Id.]{.underline} at §
1702(c). The term "sustained yield" means "the achievement and
maintenance in perpetuity of a high-level annual or regular periodic
output of the various renewable resources of the public lands consistent
with multiple use." [Id.]{.underline} at § 1702(h). Similarly, the
Oregon and California Railroads Act ("O&C Act") requires that O&C lands
\"shall be managed . . . for permanent forest production, and the timber
thereon shall be sold, cut, and removed in conformity with the principle
of sustained yield **for the purpose of** providing a permanent source
of timber supply, protecting watersheds, regulating stream flow, and
contributing to the economic stability of local communities and
industries, and providing recreational facilities.\" 43 U.S.C. § 1181a.

Single user alternatives proposed in the WOPR violates FLPMA because of
preference and priority for a short term economic gain for a single
industry; the timber industry; over the various resource values for the
rest of the local communities and American public. The exception is for
OHV industry as a second use; it too violates the majority of local
community values and uses where Emphasis Areas are proposed. There are
community based forest product users and OHV users that are compatible
with FLPMA, we are not referring to those. What has been the role of the
timber industry and the OHV industry on this process? What has been the
role of the rest of the public?

The Natural Selection Alternative ("NSA"), closely implements the NWFP,
and the multiple use/sustained yield objective of FLPMA. The NSA would
provide a broader spectrum and sustainable supply of forest products and
uses from these lands than the proposed WOPR alternatives. The
ecological superiority of the NSA is revealed throughout the BLM,
Medford District South Deer EA, as the environmental impacts of the NSA
are described as negligible. Similarly, the NSA alternative that would
to meet both of the principal objectives of the BLM WOPR, which are to
conserve the ecosystem and provide a sustainable supply of raw
materials. WPOR proposed alternatives would not. The NSA provides for a
diversity of economic, recreational, educational and other benefits and
proposes to provide a sustainable supply of a variety of forest
products, including timber, and is an alternative that conforms to O & C
Act requirements for permanent forest production under the principle of
sustained yield to contribute to the economic stability of local
communities and industries.

**Issue: WOPR is mandated by NEPA regulations to fully evaluate the
NSA**

NEPA regulations mandate that an agency "shall to the fullest extent
possible: use the NEPA process to identify and assess the reasonable
alternatives to proposed actions that will avoid or minimize adverse
effects of these actions upon the quality of the human environment." 40
C.F.R. § 1500.2(e). NEPA also requires the BLM to "study, develop, and
describe appropriate alternatives to recommended courses of action in
any proposal which involves unresolved conflicts concerning alternative
uses of available resources." 42 U.S.C. § 4332(2)(E). Environmental
analysis documents must "\[r\]igorously explore and objectively evaluate
all reasonable alternatives" to the project. 40 C.F.R. § 1502.14(a). A
decisionmaker must explore alternatives in sufficient detail to "sharply
defin\[e\] the issues and provid\[e\] a clear basis for choice among
options by the decisionmaker and the public." [Id]{.underline}. §
1502.14. All reasonable alternatives must receive a rigorous exploration
and objective evaluation "of environmental effects and values."
[Id]{.underline}. § 1501.2(b).

**WOPR DEIS:**

> ***Alternatives Considered but Eliminated from Detailed Study*** \[pg
> 104\]*/**Harvest Only Naturally Selected Dead and Dying Trees
> ***\[pg107\]
>
> *This alternative would remove only "naturally selected dead and dying
> trees, conditioned upon meeting the needs of other species." Timber
> harvesting of such trees would be accomplished with small equipment
> from a network of narrow roads.*
>
> *This alternative was eliminated from detailed study because it would
> not meet the purpose and need, which states that the resource
> management plan revisions must meet all applicable laws. One of the
> applicable laws is the O&C Act. The O&C Act requires that the O&C
> lands that are classified as timberlands are to be managed for
> permanent forest production following the principles of sustained
> yield, which includes determining and declaring the annual productive
> capacity of such lands with the timber from those lands (not less than
> the annual sustained yield capacity) being sold annually.*

**We request further explanation of what you are saying here.** You seem
to be saying that the NSA was rejected because DCA did not determine and
declare the annual productive capacity of BLM lands. Let me elaborate on
our confusion over this statement, and perhaps you may better be able to
clarify the above statements.

The NSA has declared that it takes the dead and dying, conditional upon
meeting the needs of other species. The NSA would produce not less than
the annual sustained yield capacity as it would retain the net worth of
the forest ecosystem which is necessary to retain maximum productivity
over the long term.

Do you wish to have actual numbers presented from DCA? Is that not the
role of the BLM? How would we have access to this data for BLM lands?

At the BLM WOPR technology presentation in Oct 2007 a specialist working
with the models assured me that BLM has the ability to model natural
tree mortality. Does not the BLM have the data and the models necessary
to generate the annual productive capacity of BLM lands and the timber
from those lands being sold annually under the NSA? This is part of the
NEPA requirement placed on BLM. It appears that you are saying that the
NSA was eliminated because it did not receive rigorous exploration and
objective evaluation that is part of the BLM EIS process.

Do you have the ability to model natural tree mortality? Can you, and
did you calculate volume of down wood? What is the natural rate of
mortality for each age group? Was the down wood and natural rate of
mortality calculated in your analysis of fuel reduction treatments in
each of the alternatives? Do the models incorporate trees removed under
the fuels reduction treatments that are part of all the alternatives?

Did you evaluate each alternative to see if it could sustain volume in
perpetuity? If not for how long did you run simulations? How far into
the future are the simulations considered reliable? How do the fuels and
fire reduction portion of the alternatives play out in each alternative
over the long term? Was this included in the modeling?

Why was computer modeling relied so heavily upon to guide this process?
What is the margin of error? Has there been an objective, empirical
study, research project and or peer review done to analyze limitations
and potential problems with using these models? What is the amount of
proven and tested experience that these models have in their ability to
be able to make predictions that have been born out on the ground?

At a public meeting I asked about the science used for the WOPR DEIS, I
was directed to a meeting that I also attended (October 2007). The
dependence on computer simulations and the absence of biological science
in the presentation has raises some serious questions. What was the role
of biological and ecological science in the evaluations and what
percentage of the evaluation was focused on quantitative science and
computer simulations? There seems to be a shortage of biological science
(how do forests grow) in the assessing the alternatives.

Computer simulation projections by their nature lack certain biological
and ecological components. A great deal of, current and contrary,
biological and ecological scientific studies seem to be left out of the
EIS evaluation process. Technological analysis and quantitative science
seems to be the dominant form of analysis in the WOPR DEIS. How can a
computer simulate the endless components of the natural world?
Biological, ecological and social science and research seem to be out of
balance with technological/quantitative science; how can a balanced
assessment be made? Will your projections vary according to forests that
are healthy with all evolved species and those forests that are degraded
by decades of logging, climate change, blister rust, invasive species,
disease infestations; pine beetle, etc? Have you analyzed the
limitations of your technology? While the wonders of technology and
computer simulations offer new and remarkable kinds of information; they
must not be overly relied upon; simple miscalculations; program
limitations; faulty premises or data entry can result in large errors
and hypothetical conclusions far from reality.

Full assessment would include using models or processes that are
appropriate to the alternative itself, not necessarily one that is based
on traditional logging practices and in the case of the NSA may fail to
account for the biological and sustainability benefits of the NSA, which
could result is a skewed estimate of timber volume.

How do you justify not including disturbances into your projections,
just because you cannot model it? If you do not have the tools to
justify your actions, how does that cover legal requirement to do an
analysis? Disturbances will come and because your models cannot include
them, the models are of questionable value. This is very concerning in
light of such conditions as global warming; the fact that proposed
alternatives would create combustible plantations in place of fire
resistant ecosystems; flooding will occur; etc. A forest plan based on
hypothetical situations that we know are not realistic is more than
problematic; it is arbitrary and capricious. If your model does not
include natural "disturbance", how can it present what the forest
conditions will be in one hundred years with no disturbance (no harvest)
as compared with historic conditions before European settlement that
included natural "disturbances"? Are not these comparing apples and
oranges? It seems that the "No Harvest" bars on your graphs are only
computer projected data with such limits with regards to what will
happen in reality, as to be predictably invalid and unreliable.

[See]{.underline} [Sierra Club v. Bosworth]{.underline}, 199 F.Supp.2d
at 980 (finding that environmental analysis itself must address lack of
scientific support). "Agencies shall insure the professional integrity,
including scientific integrity, of the discussions and analyses. 40 CFR
§1502.24. NEPA requires that agency decisions be based on the highest
quality data and analysis to provide for full public participation and
informed decision-making. 40 CFR §1500.1. Accurate scientific analysis,
expert agency comments, and public scrutiny are essential to
implementing NEPA. 40 CFR §1500.1(b).

**[Impacts to Socioeconomics]{.underline}**

**Issue: How may sustainability relate to local economic stability and
resource extraction?**

None of the proposed WOPR alternatives provide the sensible logical and
realistic approach to sustainable resource extraction, such as that
proposed in the NSA which is: 1) to take small amounts of timber across
the cutover forestlands over long periods of time, allowing the stands
to regenerate at a natural pace and supplying perpetual work for
small-scale harvesters, and allowing local communities to develop small
businesses and enterprises because there will be a constant supply or
resources over the long term; 2) recover ever more fire resilient
forests; 3) have an increased rate of recovery of the northern spotted
owl and marbled murrelet in the short and long term as 4) structurally
complex forests are restored and retained 5) providing ever healthier
forest habitat to support the recovery of special status species. WOPR
alternatives propose to bring in outsiders to cut down community forests
and transport these resources out of the communities; leaving instead
clearcuts, scarred landscapes; loss of endless resource values for
economic and quality of life values, including much greater fire risks.
This will not further the goal of sustainable use of BLM land and
resources; would place the northern spotted owl and marbled murrelet at
the brink of extinction or to extinction, as structurally complex
forests are converted to tree plantations, seriously degrading habitat
necessary to protect special status species.

**Issue: WOPR's Environmental Justice Assessment stated that the
consequences of the alternatives are not expected to fall
disproportionately on minority or low-income populations.**

Have you assessed the impacts to humans and communities in terms of
small contractors as compared to large operations? The NSA proposes to
create forest stewardships for small, local operations that would extend
for many years. This type of cutting-edge contract would provide
environmental justice opportunities for small operations and restore
local economic stability to disenfranchised rural economies. Will the
opportunities to purchase contracts be designed equally advantageous for
the small contractor as the large contractor? Have you assessed the
economic and quality of life impacts and benefits and impacts
comparatively for the independent forestland owner; small fishing
business owner; mom and pop businesses dependent on tourism and
recreation; the rural landowner; the rural resident; and corporate
business owner? What are the benefits of each alternative to each? What
are the negative impacts to each? Have you factored in human health
issues resulting from prescribed burning, including increased risk to
homes from runaway fires; use of pesticides; use of herbicides; noise;
pollution of water and air; stress from clearcuts and loss of quality of
life and property values? Why do the BLM service contracts of repairing
the damages caused by logging fall disproportionately on minority and
lower income populations and timbersale opportunities are designed for
large corporate timber companies? Why do the costs of implementing these
timbersale and restoration projects fall onto the American taxpayer and
not on the beneficiary, the timber industry; creating a disproportionate
advantage to the large corporate forestland owner over the small
forestland owner and other forest related small operations? Why weren't
there a responsible analysis of environmental justice issues, such as
these and many others, evaluated in the EIS?

BLM failed to fulfill the requirements for the BLM to integrate social
science and economic information in the preparation of informed,
sustainable land use planning decisions. Section 202 of FLPMA requires
BLM to integrate \"physical, biological, economic, and other sciences\"
in developing land-use plans \[43 USC § 1712\]. Section 102 of NEPA
requires Federal agencies to \"insure the integrated use of the natural
and social sciences . . . in planning and decision making\" \[42 USC §
4332\]. FLPMA regulations 43 CFR §1610 and the BLM Manual 1601 Land Use
Planning and H-1601-1 Land Use Planning Handbook elaborate on the
legislative mandate. Federal agencies are also required to \"identify
and address . . . disproportionately high and adverse human health or
environmental effects of its programs, policies, and activities on
minority populations and low-income populations in the United States,\"
in accordance with Executive Order 12898 on Environmental Justice.

**Issue: Diversity of forest products provide for local economic
stability; not timber priorities as in WOPR alternatives.**

Why weren't the alternatives evaluated for non-timber forest products
and resulting multiple economic benefits for a wide range of non-timber
beneficiaries? For example, the NSA pays close attention to
opportunities that use the forest to produce timber in a way that
attracts the interest of the traveling public and helps the community to
capture a share of the significant tourism dollars that pass through
each region annually. The NSA has the potential for bringing revenues to
both timber, tourism, and other industries. This would mean more
productivity from the forest, and a diversification of businesses that
the BLM forest can support and stronger contribution to the economic
stability of local communities as required by the O & C Act.

The NSA creates a forest environment that is both attractive and
accessible for recreational activities. Recreational opportunities
increase local property value, community health, and offer additional
activities for travelers that help to make this area a travel
destination.  The NSA would allow the public to recreate in their forest
while at the same time accommodating the needs of local forest workers
to earn a living. It would create a compromise between conflicting
forest uses that would cast a positive light on the local communities as
productive and collaborative societies that are able to generate an
innovative, diverse, stable and sustainable economies with a minimum of
controversy. Was this given any value when you considered the NSA?

Why weren't the values of these types of opportunities evaluated for
each alternative or considered in the development of alternatives?

**Issue: Resource extraction using natural-selection based criteria
contributes to economic stability**

The natural-selection-based approach to timber production outlined above
also produces other values that produce revenue that diversify the
economic benefits provided by the forest. This is in following with the
stated purpose of the O&C Act "\... timber will be sold, cut and
removed\... on a sustained yield basis\... *for the purpose of*\....
contributing to the *economic stability* of local communities and
industries\..." BLM Planning staff must understand that there has been
no court decision or interpretation of the O&C Act or mandate in
legislative history that clearly indicates *timber production* is
"dominant" over *economic stability*.

**Issue: Economic outputs include all commodities that will contribute
toward a sustainable ecomomy**

When considering economic outputs of each alternative we asked to
include all the commodities the forest will contribute toward a
sustainable economy for the community. It seems that it is primarily
timber in the WOPR Alternatives. We asked that the estimate should be
projected out over the life of a project area from initiation of a plan
to the achievement of its objective. Examples are of other products are
wood products such as small diameter trees, hardwood products, wood
crafts and other added value wood products; tourism products; quality of
life commodities include recreation, scenic landscapes, clean water and
other resources (These commodities have a secondary economic benefit
that must be included in the overall analysis of cost-benefits for each
alternative); research opportunities; and other products.

**Issue: Recreational opportunities help to improve the health of a
community**

Improved public health has been correlated with a reduction of health
care insurance. Ultimately we all benefit by paying lower insurance
rates. This must be included to in an economic analysis to provide the
data necessary for assessing how the alternatives meet congressionally
directed purposes for managing BLM administered lands to sustain the
health and economic well-being of the people of this country.

**Issue: Each alternative needs to be examined as to how it will affect
unique recreational and educational opportunities**

For example Unit 38S-07W-21-003A of the South Deer Project in Selma is
unique because it is a mature/old growth forest on flat ground with road
access for passenger vehicles. Old growth forests on flat ground in
Josephine County have all been logged decades ago except for this small
parcel. What provision has the WOPR to protect these types of areas from
being lost? In order to retain and not degrade or destroy recreational
opportunities the analysis of alternatives must include the potential
impacts to all forms of recreation by proposed logging and road
building.

**Issue: Visual Resource Management goals need to be reevaluated.**

A casual observer walking through the forest should experience VRM level
1 across the landscape. Retaining forest health is synonymous with
retaining visual and aesthetic values. If it looks and feels like a
forest is the best indicator that it is a healthy forest: Common sense
born out in cutting edge forest ecology. The level of change of the
existing landscape should not exceed that which would occur in a natural
course of events. The NSA will achieve this objective. The WOPR will
have devastating affects to visual and aesthetic values.

**Issue: "In Oregon, the relationship between the environment and the
economy is changing. Industries that extract raw materials are
stagnating, while industries that benefit from the presence of
environmental amenities are growing rapidly."(20) NSA p 2.**

The use of public lands for recreation and tourism is at an all time
high and these uses along with the fishing industry values need to be
assessed.

A significant consideration not part of the original NWFP plan is the
mid‑1996 milestone date when the state's electronic technology sector
overtook timber as its leading industry. A report by a panel of
economists led by Thomas Power found that between 1988 and 1994, despite
declines in the timber and aerospace industries, overall employment in
Oregon and Washington had grown by 18%, two and a half times the
national average. Even many rural economies have, not as was then
thought, found new life. Current data regarding the electronic
technology role in Western Oregon needs to be analyzed. What are the
implications and values of the forests with regards to this new
information?

**Issue: The effects to our communities from below cost timber sales
were not analyzed in the development of the NWFP and need to be analyzed
in the WOPR FEIS.**

The public is tired of selling timber below cost. If sales cannot be
made at the going rate for timber, they should not be made. This is a
loss to the public that they are unwilling to support. Government below
cost timber sales, combined with enforcement and use of forestry
silvicultural practices, cause the loss of private owned forests.
Private owners cannot compete with governments that sell timber below
cost.

O & C Act requirements for sustained yield of forest products,
necessitates assessment to clarify how the alternatives will contribute
to or detract from the economic stability of local communities.

**Issue: Current practices that are prepared under the influence and
direction of the Healthy Forest Initiative launches the forest into a
commitment of long-term, tax dependent activities necessary to bring the
forest into the intended level of productivity.**

An alarming aspect of this plan, especially in these times of extreme
deficits, is the imminent problems that will arise if at anytime tax
dollars are not available to carry the plan through to completion. These
include the escalation of fire hazards to extreme levels coupled with an
uncertain future for forest productivity. Plans are extremely tax
dependent and if tax support fails, which is very likely, its outcome
will be a burden on society to cover the cost of fire control and
rehabilitation of damaged lands. This is a very unstable situation
likely to result in an unstable and unpredictable economic future for
the community. DCA requests that the EIS address this issue and its long
term implications. How much of the WOPR cost is expected to be paid by
the Healthy Forest Initiative and other tax dollars?

These practices and plans impose a permanent impact on future business
opportunities in the community. The plan provides no data for the
present and future impacts to non-timber industries including tourism,
cottage industry, artists and others. Tourism is especially important in
Western Oregon as is detailed in comments by Roger Brandt. The EIS needs
to evaluate how the alternatives might make it more difficult for
tourism businesses to capture this business. The expertise of Roger
Brandt, see *Brandt Report Dec 2007*, *"Historical Economic Performance
of Oregon and Western Counties Associated with Roadless and Wilderness
Areas"* by Southwick Associates (Cited in the NSA p5), attached article
by Bruce Baraco on the new economic paradigm. The BLM may implement a
forest management program that will deprive the community millions of
dollars in sustainable income by excluding business opportunity on BLM
land for decades or enhance local economies and economic stability. The
DEIS failed to incorporate new research, data and information of these
important components of the socioeconomics of Western Oregon, or analyze
their impacts.

**Issue: Quality of life**

The NSA offered an alternative that supports a diversity of business
resources as well forest work to create a forest environment that offers
a diversity of recreational and aesthetic resources. These are values
that give residents in a community the resources they need to pursue the
life style of their choosing. A community with these opportunities will
likely attract self employed entrepreneurs or affluent retirees who all
bring with them their own incomes, all of which contribute to the
economic stability of a community. These are important economic assets
that can be made possible if the forest is managed so equal enthusiasm
is devoted to the production timber *and* non-timber products. Without
assessing how an alternative will produce all the products and resources
a forest can provide, the BLM will subject communities to an unstable
and uncertain economic future, which runs counter to O&C Land Act
requirements for contributing to the economic stability of local
communities and industry (43 U.S.C 1181a)

**Issue: Concentrated off-highway vehicle (OHV) usage is not compatible
with the checkerboard of public and private land ownership in the
proposed "Illinois Valley and Elliott Creek Emphasis Areas"**

OHV Emphasis Area is not acceptable in the Deer Creek watershed this
area and that it is up to the BLM to establish criteria as to where they
should be prior to suggesting any particular areas. It is not compatible
with adjacent private land ownerships. It is not compatible with the
multiple recreation uses that we have been promoting (other than what
OHV use there would be without making it and Emphasis Area).

The proposed OHV Emphasis Area designation gives priority to one form of
recreation at the expense of all other recreation and uses that the
community vision, as has been expressed in the community created and
supported NSA. The NSA community plan includes true multiple use for all
products and uses while retaining biological and ecological values, with
no vehicles off road even for timber removal (While OHV\'s are supposed
to stay on trails/roads, but they do not).

While the NSA allows for responsible on road vehicle use, and provides
enhanced quality experience, it also provides for protection of
biological and ecological values that provide for all forms of
recreation, education and tourism experiences. The NSA access system if
created for on-going resource extraction of all products and uses.

The NSA was designated by BLM to be implemented in one of the sections
of the South Deer Project area where the WOPR has proposed to create an
OHV Emphasis Area. These uses are highly conflicting.

Page J-1205 of WOPR (Vol III) states: Non-motorized travel is allowed on
all access routes (e.g. horseback riding, hiking, and mountain biking)
but is not encouraged due to potential conflicts and safety hazards.

DCA offers education and information events. At one recent event where
Oregon Heritage Forests made a local presentation, the room was packed
with 60-70 concerned citizens, a majority of which had heard of the
proposed Illinois Valley and Elliot Creek Emphasis Areas and wished to
find out how to oppose it. This matter would bring great conflicts
between local residents and OHV users.

**Issue: Planning Criteria for OHV Management Must Reflect Applicable
BLM Regulations.**

Existing law and policy requires the agency to designate ORV areas and
trails only where they "protect the resources of those lands,...promote
the safety of all users of those lands, and...minimize conflicts among
the various uses of those lands."

Executive Order No. 11644 (1972 as amended by Executive Order No. 11989
(1977)) and 43 C.F.R. § 8342.1 require the BLM to ensure that ORV areas
and trails are located:

• to minimize damage to soil, watershed, vegetation, air, or other
resources of the public lands, and to prevent impairment of wilderness
suitability;

• to minimize harassment of wildlife or significant disruption of
wildlife habitats, and especially for protection of endangered or
threatened species and their habitats;

• to minimize conflicts between ORV use and other existing or proposed
recreational uses of the same or neighboring public lands and to ensure
compatibility with populated areas, taking into account noise and other
factors; and

• outside officially designated wilderness areas or primitive areas and
in natural areas only if BLM determines that ORV use will not adversely
affect their natural, esthetic, scenic, or other values for which such
areas are established.

These items represent the primary factor by which the BLM must designate
both ORV areas and specific routes. When viewed through the crucible of
these regulations, the BLM's role in either assessing or promoting ORV
"use opportunities" (currently listed as a Primary Factor of the
Analysis) becomes irrelevant in comparison to higher priority issues
such as the condition of public land resources, health of wildlife
habitat and protected species, and avoidance of conflicts with other
(non-motorized) recreational uses. The CFRs imply that BLM is to allow
ORV use only where it does not interfere with these other factors.
Consequently, BLM must revise its current Planning Criteria to
accurately reflect the requirements of 43 C.F.R. § 8342.1, which should
instead constitute the Primary Factors of Analysis for ORV management.

It is BLM's responsibility to establish criteria prior to proposing
potential OHV Emphasis Areas

**[Species/Habitat]{.underline}**

**Issue: Wildlife protection:**

WOPR alternatives fail to protect wildlife, particularly special status
species, or to achieve their recovery in compliance with the Endangered
Species Act."

**Issue: Impacts to plants and wildlife**

The plan must consider impacts to wildlife and plants and provide
greater safeguards than exists today in order to protect plants and
wildlife and fulfill legal requirements of the NWFP, ESA, O&C Act, CWA,
FLPMA and NEPA and other environmental protections.

The only remaining refugia for forest dependent wildlife is on public
lands and now these areas are being stripped of mature and old growth
trees. For example: 48% of the volume of the South Deer Timber Sale
comes from mature and old growth trees.  Mature/old growth trees are
known to be fire resistant and provide habitat for late successional
forest dependent species.  Nearly all of the conifers of this size have
been logged from private lands in the Deer Creek Watershed.  Removing
protection for Bald Eagle management areas, Riparian Reserves and
spotted owl habitat such as Owl Cores and CHU--72 in the Deer Creek
watershed in violation of the NWFP, ESA, O&C Act, CWA, FLPMA and NEPA.

**Issue: Proposed alternatives should be evaluated to comply with the
principles laid down in the NWFP**

That is what you said you would do.

**Issue: We object to removal of survey and manage requirements as laid
out in the NWFP**

We are dependent on other species for forest production and to sustain
global climate and life on the planet. Proposed alternatives must
include survey and manage for special status species [prior]{.underline}
to ground disturbing activities.

To Remove Modify the Survey and Manage Mitigation Measure Standards and
Guidelines before they have even been implemented is inconsistent with
the *"Vision"* of the Medford District RMP\\EIS p vi which states: "a
carefully designed program of monitoring research and adaptation will be
the change mechanism for achieving this vision."

Number range CHAPTERThe assertion that "*Survey and Manage Standards and
Guidelines are frustrating the Agencies' ability to meet the resource
management goals and objectives as set forth in the Northwest Forest
Plan"* is based on faulty assumptions. The reasons that the agencies may
not meet these goals and objectives, are not "Survey and Manage
Standards and Guidelines" of the NWFP, but other reasons.

Productivity of forest resources within the Range of the Northern
Spotted Owl dependent on retaining healthy functioning ecosystems, not
on the ability to remove specific volumes and not on the ability to
modify or remove Survey and Manage Standards and Guidelines protections
for species as included in the NWFP. Survey and Manage litigation is the
result of failure to implement sustainable practices on our public
lands. Survey and manage costs are a critical investment in having fully
functioning ecosystems which are essential for sustainable forest
resources and sustainable communities dependent on those resources.

Past forest management practices have substantially reduced the
available timber supply. Current ecosystem productivity is far below
historic forest levels. No one knows how to restore a late successional
ecosystem. Species that created those ecosystems will restore them if
they are protected and allowed to do so. The remaining islands of late
successional forest ecosystems need to retain the protections provided
in the NWFP including Survey and Manage Standards and Guidelines in
order to retain their health and productivity and to restore degraded
landscapes.

The proposed changes to remove or reduce survey requirements will reduce
the productivity of these forest ecosystems. Productivity is related to
green foliage and the ability of all the species that created forest
ecosystems to restore and sustain them.

The concern that, "*the Survey and Manage Standards and Guidelines are
one of the factors frustrating the achievement of the stated needs of
the Northwest Forest Plan...to protect the long-term health of forests,
wildlife, and waterways because they restrict forest health
treatments"*, is not true, because it is based on the faulty assumption
that the proposed thinning and fuels programs would protect the
long-term health of forests, wildlife, and waterways. This is not
accurate or based on best science.

We do not agree with this popularized "frame" that promotes ongoing
deforestation of our public lands: "The forest is unhealthy and must be
logged to return to its natural state".

For millions of years wildfire has played a vital role in shaping our
western forests. 

Current science, such as the study *\"Watershed Impacts of Forest
Treatments to Reduce Fuels and Modify Fire Behavior\"*
(www.pacrivers.org), demonstrates that:

> • Fire suppression has NOT altered fire behavior in the vast majority
> of our western forests
>
> • Fires in most forest types are a product of weather rather than
> fuels
>
> • Fuels \"thinning\" is ineffective at stopping most fires, is
> temporary at best, and in many cases increases fire risk
>
> • Fuels \"thinning\" does the same ecological damage as clear-cutting,
> including widespread tree removal; erosion and siltation of waterways
> from road construction and use; and soil compaction from heavy
> machinery
>
> • Fuels \"thinning\" ignore the greatest fire risks of all: logging,
> grazing and more fire suppression

Wildfire is a natural, beneficial and essential element of our western
native forests. So called, "forest health and fuels treatments\", are
largely inappropriate, ineffective, and can increase fire risk. Typical
forest management logging practices and grazing are main causes of
uncharacteristic wildfire. Our forests must be returned to their natural
fire regimes.

The NSA provides an alternative to unsustainable forest practices; would
provide no threat to Survey and Manage Species or provoke litigation. It
enhances all these species habitats; allows for maximum productivity and
a sustainable supply of timber; allows native and old growth forests to
be retained, and to recover; provides the best solution to fire and
fuels issues. Failures with implementation of the plan are not those
related to Survey and Manage requirements, it is failure to recognize
that healthy forest ecosystems are sustained and restored by the
functions of all the other species, not by so called "forest health
treatments" performed by humans. Sustainable forest management practices
that support sustainable supply of forest resources and sustainable
local economies necessitate retaining environments favorable to the
species that create and sustain forests. The Survey and Manage Standards
and Guidelines are essential to determine human impacts on those
species.

**Issue: There should be no data free analysis or analysis free
decisions.** There should be evaluation of the entire plan based on
baseline data that must be obtained if missing and monitoring that must
be done where there are inadequacies. Where monitoring and statistics
are not available to demonstrate the improvement and or retaining of
ecological values by the proposed plan (or preferred alternative), all
planning and current activities must be halted until such time they are
made available.

Surveys and Monitoring are essential to the creation of a scientifically
sound, ecologically credible, and legally responsible alternative.

There must be accurate baseline data describing seral ages of all forest
ecosystems.

Analysis needs to be made by highly qualified scientists in biology,
ecology and the other sciences, subject to non-agency non-timber
industry connected peer review; and consistent with the most current
science independent, non-timber industry or government connected
researchers or institutions.

**Issue: Owl Cores should be retained and protected**

The NWFP requires that activities in areas adjacent to owl cores must be
"designed to reduce risks of natural disturbance." NWFP at C-11. Timber
harvest increases fire severity more than any recent human activity. EIS
must examine and disclose scientific studies regarding wildlife risks
associated with harvesting operations. Activity in areas adjacent to
spotted owl cores that are not designed to reduce risks from natural
disturbance and as a result, fail to demonstrate compliance with this
requirement of the NWFP and should not be approved in the WOPR; as they
are necessary protections for the recovery of the northern spotted owl.

How does the WOPR justify elimination of these protections to owl cores?
In fact two owl cores are included in the IV OHV Emphasis Area, and
another two are in adjoining sections that are part of CHU-OR-72.

**Issue: The need to comply with the endangered species act**

Section 7 of the ESA requires the BLM, as a federal action agency, to
consult with the FWS to "insure that any action authorized, funded, or
carried out by such agency ... is not likely to jeopardize the continued
existence of any endangered species or threatened species or result in
the destruction or adverse modification" of critical habitat. 16 U.S.C.
§ 1536(a)(2), (a)(4). To assist in this consultation effort, action
agencies must prepare biological assessments for all species that the
FWS has identified may be present within a program area. 16 U.S.C. at §
1536(c). Section 7 mandates a limitation on the commitment of resources
by a Federal agency after the initiation of consultation. Specifically,
the Federal agency shall not make any irreversible or irretrievable
commitment of resources, which has the effect of foreclosing the
formulation or implementation of any reasonable and prudent alternative
measures that would insure that agency actions are not likely to
jeopardize the continued existence of listed species. 16 U.S.C. §
1536(d).

**Issue: Habitat for the Northern Spotted Owl must be retained; and
Protection from adverse impact to Spotted Owls depends on reliance on
sound data and analysis**

Given the worsening condition of the owl, an indicator species for
forest health, a recovery plan should not allow BLM to abandon current
minimal protections on public lands. The WOPR fails to take into
consideration the dire situation for late successional species
extinction and notoriously the northern spotted owl.

Proposed alternatives must be assessed for the question if they will
degrade primary constituent elements within designated spotted owl
habitat. Sound data and analysis must prevail over arbitrarily
justifying losses by stating that the owl will exist somewhere,
therefore it is acceptable to destroy their habitat by eliminating
existing CHU's (such as CHU OR-72 in the Deer Creek Watershed) and
creating extreme fire hazard conditions by regeneration harvest and
other treatments in nearby areas.

A recent Ninth Circuit opinion has addressed the importance of primary
constituent elements and has concluded that CHUs must be conserved in
order to contribute to the recovery of the spotted owl. [Gifford Pinchot
Task Force v. United States Fish & Wildlife Serv]{.underline}., 378 F.3d
1059 (9th Cir. 2004) . The Court in [Gifford Pinchot Task
Force]{.underline} concluded that it is not enough for the FWS to
determine that a project will not jeopardize a species, the FWS must
also conclude that the project would contribute to the recovery of the
species. 378 F.3d at 1071.

Critical Northern Spotted Owl habitat is designated as such because it
is considered \"essential\" to the recovery of the listed species. 16
U.S.C. § 1532(5)(A). If the BLM authorizes the adverse modification of
this habitat, then the BLM will impact the listed species ability to
recover. This is particularly true if the habitat is mature and old
growth forest, which requires decades (perhaps centuries, depending on
how severely it was degraded) to re-establish

Moreover, there is a variety of new information regarding the
distribution of spotted owl populations that necessitates new
environmental analysis pursuant to NEPA. New region wide information
includes: evidence of competition increasing from barred owls, impacts
from the West Nile Virus and the Sudden Oak Death syndrome in the
southern portion of the range, impacts of wildfires, and the impact of
increased logging pursuant to the Healthy Forest Initiative. According
to Courtney *et al.* (2004) concluded that the risks currently faced by
the northern spotted owl are significant, and their qualitative
evaluation is that the risks are comparable in magnitude to those faced
by the species in 1990. The BLM and the FWS cannot accurately assess the
potential impacts to spotted owls without an assessment of this new
information.

BLM must consider the large degree of scientific controversy that
surrounds the impact of fire prescriptions on reducing future fire
risks. BLM cannot rely on a conclusion that degrading essential habitat
with the current fuels practices, will benefit owl recovery without
examining this conflicting science.

In 2007, the greatest range-wide threats to the spotted owl were
identified as competition from barred owls, loss of habitat amount and
distribution as a result of past activities and disturbances, and
ongoing habitat loss as a result of timber harvest. BLM plans must
address these key threats and management plans must allow spotted owls
to move and persist across their range given that, "based on existing
knowledge, large continuous blocks of suitable habitat are still viewed
as necessary for the Northern Spotted Owl" (Franklin and Courtney
2004:15; emphasis in original)

The proposal to eliminate critical habitat for endangered species such
as the northern spotted owl is a violation of the ESA. The WOPR proposes
to eliminate CHU-OR-East IV/Williams-Deer LSR (#RO 249)72 areas in the
Deer Creek Watershed. We have seen two spotted owls in this area in the
past several months. There is known spotted owl activity here and these
forests are visited by hundreds of people annually. The DCA has
sponsored public tours and workshops in these forests teaching people
from around the world how natural forests function. These ancient
forests are a local and national treasure that belongs to all Americans
not the timber industry or to be lost for short term economic needs.
These forests are a critical part of our culture, critical part of our
ability to retain private forestland health and protected under the ESA
and other legal obligations and responsibilities that the WOPR must
fulfill.

**Issue: Each alternative should be evaluated for two ecological large
scale issues/functions of concern: "(1) the condition of critical
terrestrial linkage between the watershed where resource extraction is
occurring and other provincial watersheds; and (2) the condition of the
aquatic habitat particularly as it relates to salmonoid species**.

We raised the above issue as it is particularly relevant in the Deer
Creel Watershed. The *Deer Creek Watershed Analysis,* October 1997
stated the following

> *Dear Reader:*
>
> *The purpose of this watershed analysis is to identify the various
> ecosystem components and their interactions at a landscape scale. It
> looks at historical ecological components, current ecological
> components and trends. It makes recommendations for future management
> actions that are needed to reach recommended ecological conditions.*
>
> ***VI. RECOMMENDATIONS***
>
> *Synthesis of data/information and interpreting current trends in the
> Deer Creek watershed points out two primary ecological large scale
> issues/functions of concern: (1) the condition of a critical
> terrestrial linkage between the Deer Creek watershed and other
> provincial watersheds; and (2) the condition of the aquatic habitat
> particularly as it relates to salmonid species. The desired future
> condition of the watershed and the recommendations in this section
> emanate from these two important ecological functions.*
>
> ***1. Terrestrial Links***
>
> *The northern mountainous ridge line that separates the Deer Creek
> watershed from the Cheney/Slate Creek watershed is an important
> dispersal route for terrestrial species, especially old‑growth
> dependent species. This dispersal route includes all of the designated
> Late‑Successional Reserve (LSR) lands and connects watersheds of the
> Illinois River basin with those of the Rogue River basin and thus
> provides a vital linkage with the coastal mountain range. Maintaining
> and increasing the effectiveness of this dispersal route would require
> the forest vegetation to be managed to provide the habitat conducive
> to old‑growth dependent species. Along this dispersal corridor, the
> forest canopy closure and structure required by old‑growth dependent
> species should be maintained on lands currently in that condition and
> created on lands that do not currently exhibit those conditions. ...*
>
> *The recommended desired vegetation condition along the dispersal
> corridor would be an old‑growth forest. ...*

**Issue: The EIS needs to evaluate new information not considered in the
NWFP planning document.**

For example, the dwindling of late successional forest resources along
with private land owners massive degrading of the forests in a way that
could not have been foreseen at the onset of the NFP.

The coho salmon is now listed as endangered and that wasn't taken into
account when the RMP/EIS was written for the NWFP. The pressure of
meeting timber targets has placed the already severely impacted salmon
and other fish over the edge.

**Issue: The EIS must gather data and take into account what citizens of
the Northwest want with regards to protections for their federal
forests.**

The public didn't realize that the NWFP would fail to protect resource
values on the public lands, the government didn't realize the strong
position against logging on public lands that would come from the
majority of the public. This must be included in the EIS.

The proposed WOPR action alternatives fail to protect our forests so
that future generations can enjoy special places and heritage forests of
the Northwest that Americans treasure?

**Issue: Necessary data must be gathered and current forest conditions
must be assessed along with theories on which current practices are
based, and proposed alternatives are evaluated.**

For instance: Current management decisions have been based on the
premise that if dense second‑growth forest plantations were aggressively
thinned to reduce competition and open the canopy, they would acquire
old‑growth characteristics sooner, accelerating their use by spotted
owls. Information has become available disproving this and incorrect
assumptions about these forests ability to become old‑growth forests.
Many of the sites prescribed for this type of treatment are not able to
be improved upon and have all the components necessary to evolve into
classic old growth ecosystems, whereas projects implemented and proposed
will and have degraded these ecosystems to a state where they are likely
to never achieve old growth conditions. For these reasons, all projects
and forest conditions must be reevaluated along with theories on which
current practices are based, including all current studies and contrary
science to tree plantation science now being used to justify these
practices. The photos of the spotted owl attached to this document are
on Camp Forest where NSA practices have allowed natural forests to
recover without thinning as has been proposed. The owl is here because
there is a CHU within a short distance and there is a full canopy and
healthy recovering natural forest as occurs under the NSA.

**Issue: Bureau sensitive fungal species conservation issues**

Bureau Sensitive fungal species conservation and the Oregon State Office
of the BLM has a stated policy which vows that no BLM action will
"contribute to the need to list any of these species" This is a good
thing, however: Surveys providing "specific information regarding
connectivity, range\..., habitat requirements, and disturbance effects
are lacking. Given the current enormous lack of knowledge, it would be
sheer luck if there were no significant impacts to either Sensitive
fungal species or their habitat in implementing current management
practices. Relying on luck is not the hallmark of a responsible land
management agency. If no surveys are performed and/or an unknown
population of one or more of these species were damaged or eliminated
(from let us say for example that this loss occurred due to increased
ambient temperatures and decreased humidity, leading to excessively dry
soils, all resulting from excessive opening of the forest canopy), the
consequences could be dire for the species. Keep in mind that 1) these
species are part of the exceptional species diversity which has made the
areas like the Illinois Valley in Southern Oregon world famous, and they
are worth preserving for this reason only, but in addition, 2) all of
these species are mycorrhizal, with conifers as typical hosts. Host
plants do not typically thrive, especially as seedlings, without the
appropriate mycorrhizal fungus attached to their roots. If the health
and vigor of conifers, which form the backbone of the extractive economy
of southern Oregon, are of concern, then it is wise to preserve the
fungi which contribute substantially to this health and vigor.

Survey and Management requirements of the NWFP are critical to fungi
species and their protection. The NSA protects all these species.

**Issue: All forest ecosystems must be allowed to naturally evolve and
go through each stage of ecological succession**. This is the process
that builds soils, provides for sustainable nutrient cycles, species
habitat and retains natural fully functioning ecosystems that area
necessary to retain fully productive forests, clean water, sustained
timber yields, aesthetic and recreational values and local economic
stability.

Since the BLM documentation nor any other analysis has shown
scientifically how the reduction of canopy cover in late successional
stands and riparian reserves will lead to "improved conditions for late
successional or riparian ecosystems", "provide a sustainable supply of
forest products", "provide connectivity", "retain habitats for
late‑successional forest species", or "maintain ecologically valuable
structural components such as down logs, snags, and large trees", the
proposed tree rotation/plantation practices should be reevaluated.

The goal of "providing early successional habitat" has been accomplished
beyond natural conditions for the next 500 to thousand years, or longer.
There is a dangerously small portion of natural late successional and
old growth forests and creation of early successional forests not be a
goal anywhere until the ecological need can be scientifically justified
at a landscape level and older forests have been reestablished across
the landscape to original conditions.

**Issue: Accountability**

Activities have occurred and continue to occur where threatened and
endangered species have been overlooked by inadequate monitoring. There
must be built in safeguards, accountability and consequences for
violations regarding environmental protections.

**[Water/Streams/Watersheds]{.underline}**

**Issue: Impacts to drinking water, water quality and hydrology**

It is not plausible that the proposed alternatives would maintain or
improve water quality. The last time our watershed was logged we had
polluted domestic water for 20 years following logging and serious
erosion problems from logging roads that cause problems whenever a
vehicle uses them. Deer Creek Valley has had serious domestic water
shortages and problems; our creeks and streams have been severely
impacted by logging practices. We object to the WOPR proposed
alternatives and to the water and erosion problems that would be caused
by Illinois Valley and Elliot Creek OHV Emphasis Areas. We object to the
lack of research on the effects of forest practices on water. Research
on soils and hydrology by Richard Hart should be included in the science
and data considered for the revised plans. We object to the lack of
objective analysis of effects on drinking water, water quality for
aquatic species and for natural healthy hydrological functions.

**Issue: Impacts from road work**

We request that objective analysis of the NSA's proposed access system
be done. NSA proposes narrower roads that maintain full canopy cover,
contour the land, and result in less impact. While BLM management
approach may be practical for large industrial timber operations that do
not feel a responsibility to retain forest ecosystems for all values
including biological, ecological and hydrological values, it is
inappropriate on a landscape of the ecological complexity and statutory
protections required by BLM in western Oregon. The problems with current
road standards on BLM lands and proposed for future roads under WOPR
proposed alternatives are prohibitively costly in economical and
ecological terms.

The road system proposed by the NSA has a proven track record in the US
and Canada where it has been implemented in rugged and extremely rocky
terrain. The roads have been heralded as the most ecologically,
economically and aesthetically superior forest roads built. The
opportunities for permanent forest production across the landscape will
provide for local economic stability and reduce costs to taxpayers and
the environment in perpetuity.

**Issue: Soil compaction conditions**

The significant effect of operating heavy equipment on forest soils and
potential compaction is excessive, destroys forest productivity and
forest health. The NSA does not operate heavy equipment off roads.

**Issue: Soil compaction and erosion resulting from Machine Mastication
(MM) treatment.**

No matter how low the ground pressure of the equipment, it will result
in potentially considerable damage to soils. Use of MM may result in a
thick layer of chips which may cause smoldering when burned. If it is
too thick and/or too dense, it has the potential to also act as a mulch
layer before burning, effectively burying and killing the herbaceous
vegetation. While this would obviously eliminate a portion of the fine
fuels, one would hope that we would all agree that this would not be a
healthy stand, with no herb layer.

**Issue: Harvest methods must minimize soil and litter disturbance.**

The NWFP requires that the BLM modify site treatment practices,
particularly the use of fire, and harvest methods to minimize soil and
litter disturbance. NWFP at C-44. The NWFP recognizes that soil and
litter dwelling organisms are sensitive to soil and litter disturbance
and that site treatments or harvest methods may adversely impact these
organisms. Did the WOPR determine otherwise?

The BLM has not demonstrated that it has complied with this restriction.
This is especially problematic in light of the failure of the BLM to
comply with the Survey and Management requirements of the NWFP, which
require surveys of fungi species and their protection if surveys reveal
their existence. Sustainable forest practices require efforts be made to
protect them.

It does little good to have science describe what is necessary to retain
and restore our water and soil if practices are prohibited from
following them based on a timber quota priority. It is incredible that
mechanical harvesters are given priority over the objective to improve
and /or maintain soil productivity. The NSA is an alternative to improve
soil conditions and jobs in a manner that far exceeds the current
practices.

Logging should not occur in forests which include landslide prone areas
and other unstable soils.

**Issue: Impacts of fuel reduction program and the impacts of removal of
woody material and impacts to species must be evaluated.**

Woody material builds topsoil that sustains species that provide the
needs of new green plant growth. Removing or burning up woody material
and topsoil causes long-term adverse effects on forest health and are
unacceptable. What assessment process was used to evaluate the impacts
of each alternative on soils?

Impacts to soil are critical for assessing the impacts of proposed
alternatives. Potential soil impacts must be determined based on real
data, and future impacts estimated so that a cumulative effect analysis
can be prepared and included in the EIS. The DEIS failed to provide
adequate analysis.

**Issue: Forest and timber productivity models must have biological and
ecological basis that retain the web of life that create and sustain
forests.**

Forest productivity is relative to green foliage. Green foliage
productivity is relative to the degree of steady flow of dead green
plant and non green plant debris that creates and sustains top soil; how
well the needs of decomposers that create and sustain natural water
pipelines that regulate rain water runoff; and the recycling of
nutrients for new green plant growth. Disruption of this food chain has
negative consequences and the impacts are relative to disruption.

Computer modeling limitations must be recognized. Planners must take
into account fuels treatments, effects of biological and ecological
relationships of the forest and how they contribute productivity.
Modeling and projections limitations regarding forests for future
generations must be considered.

**Issue: Forest productivity and other consequences of reduced dead wood
due to fire suppression policy, fuels reduction, and logging still need
to be analyzed along with recent scientific literature about fire
effects to wildlife and about the important ecological services that
snag forests provide for fish and wildlife** (see Hutto 1995, Kotliar et
al. 2002, Conservation Biology Vol. 18 No. 4, and Lyon et al. 2000).

**Issue: The critical role of riparian reserves is severely compromised
by the new plan. The EIS failed to fully evaluate the impacts of each
alternative for all ACS objectives and on the current description of
riparian reserve values. The ACS and riparian reserves are central to
accomplishing the goals and principles the WOPR promised to uphold in
the NWFP.**

As an initial note it is important to recognize that as with the illegal
ROD proposing amendments to the Survey and Management requirements of
the NWFP, the present administration has similarly proposed illegal
modifications to the Aquatic Conservation Strategy ("ACS") requirements
of the NWFP. The WOPR cannot tier to these illegal modifications and
insure the protection of old growth species as intended by the NWFP. The
severe loss of ecosystem values of these remnant late successional
habitat areas is not acknowledge dby the WOPR.

DCA was founded 32 years ago by concerned citizens that noticed serious
problems in Deer Creek. They discovered the problems to be coming from
logging in the uplands of the Deer Creek watershed. BLM cannot implement
WOPR proposed alternatives and pretend that they will not have serious
consequences for streams, water and fish. Our experience tells us
otherwise. We are finally experiencing the return of coho and late
successional habitat. These forest ecosystems are just recovering from
the ravages of the 1980's; WOPR proposed alternatives are unacceptable
to the members of Deer Creek Association and the larger community.

**Issue: In riparian areas and such sensitive and high ecological value
areas, it is best, to just stay away and let nature take its course and
create old growth conditions at its own pace.**

Number range CHAPTERThe Natural Selection Alternative retains all
naturally evolved successional habitats across the landscape including
riparian reserves.

**[Wildfire/Fuels]{.underline}**

**Issue: EIS needs to address the conflicting science and the
uncertainty surrounding the BLM's fire and fuel treatment proposals.**

Another criterion for "significance" is "\[t\]he degree to which the
possible effects on the human environment are highly uncertain or
involve unique or unknown risks." 40 C.F.R. § 1508.27(b)(5).
Professional fire and vegetation ecologist Dennis Odion in comments for
the South Deer Landscape Management Project described the degree of
uncertainty surrounding the fire treatments proposed by BLM. Meaningful
review of these comments and the contrary science is required by NEPA
and is examined further below. EIS needs to address the conflicting
science and the uncertainty surrounding the BLM's fire and fuel
treatment proposals.

**Issue: Evaluate and disclose credible scientific evidence that the NSA
is a preferable technique for the ecologically sensitive management of
fire risks.**

Significant comments provide credible scientific evidence that the NSA
represents the best alternative to manage fire risks must receive full
analysis as well as other conflicting science

While NEPA does not mandate that an agency base its decision on a
particular scientific methodology, NEPA does not allow an agency to rely
on conclusions and opinions presented without supporting analysis and
data. [Idaho Sporting Congress v. Thomas]{.underline}, 137 F.3d at 1150;
[Marbled Mountain Audubon Society v. Rice]{.underline}, 914 F.2d 179,
182 (9th Cir. 1990). NEPA requires the BLM to objectively evaluate and
disclose credible scientific evidence that contradicts its course of
action. 40 C.F.R. § 1502.9(b). Specifically, NEPA requires the BLM to
examine and disclose contrary evidence as to whether its proposed
alternatives would reduce fire risks. [Sierra Club v.
Bosworth]{.underline}, 199 F.Supp.2d 971 (N.D. Cal. 2002); [Sierra Club
v. Eubanks]{.underline}, 335 F. Supp. 2d 1070 (E.D. Cal. 2004).

Comments from professional fire and vegetation ecologist Dennis Odion,
Ph. D, on the South Deer EA stated that he preferred the NSA. Dr. Odion
reached his conclusion in part based on his finding that the NSA would
not create the fire hazards associated with the other action
alternatives. In particular, Dr. Odion expressed concern regarding the
increase in fire risk that will result from opening forests and
promoting more combustible understory vegetation. Dr. Odion questioned
the need to log old growth forests that often dampen the spread and
intensity of fire. Dr. Odion also took issue with the relevance of
studies relied on by BLM as support for the proposed alternative and
addressed the potential impacts of the proposed alternative. In support
of his comments, Dr. Odion cited fifty-seven different studies, which
were included with his attached comments in DCA scoping comments on the
WOPR. The concerns of Dr. Odion were echoed by several other commenters
and great numbers of the general public.

The DEIS failed to provide meaningful response to this issue, the
scientific issues they raise, and to objectively evaluate and disclose
the extent and scientific basis for the controversy. The DEIS was not in
compliance with NEPA, as it failed to include discussion and analysis of
the conflicting science.

**Issue: The RMP requirement regarding the proposed use of natural fire
under the NSA.**

Fire management plans are supposed to be dynamic, "living" documents
that are reviewed and updated frequently as better information becomes
available. It is the BLM's responsibility to update and improve their
FMP in the WOPR especially with the additional resources provided by the
National Fire Plan (see
<http://www.blm.gov/nhp/efoia/or/fy2001/ib/b2001-052.htm>). Therefore,
there is nothing preventing the BLM from implementing a new or revised
fire plan that allows for the appropriate use of natural fire in a
project area. The lack of particular provisions in a fire plan must not
be used as an excuse not to employ the best available fire management
strategies.

**Issue: The National Fire Plan does not require the adoption of the
current fuel hazard reduction programs.**

An increased application and management of prescribed fire and other
fuel treatments is inconsistent with the National Fire Plan and its
priorities and the proposed WOPR fire and fuels plan is not the best one
to meet its direction or best science.

Wildfire -- even periodic "catastrophic" fire -- has beneficial effects
in our forests. For example, it contributes to species diversity, mosaic
effects, nutrient cycling, and hardening snags for wildlife habitat.
Many species have evolved to depend on fires.

One of the five priorities of the National Fire Plan is hazardous fuels
reduction, with the ultimate goal of "restoring forest and rangeland
ecosystems to closely match their historical structure, function,
diversity, and dynamics" (see
<http://www.fireplan.gov/overview/whatis.html>). The proposed harvest
and commercial thinning would not serve this goal, but the gradual
extraction under the NSA would. The BLM alternatives would perpetuate
the cycle of over-cutting and over-thinning, thick regeneration, and
resulting increased fire risk. By removing (or reducing) the canopy
coverage in these stands, BLM alternatives would allow more light to
reach the forest floor, drying out the existing fuels and allowing
regeneration of small-stem trees and shrubs which contribute greatly to
fuel loading. Thus, BLM's proposed commercial thinning treatments to
reduce fuels end up backfiring and increasing fire risk.

**Issue: Several scientific studies have demonstrated that the timber
industry's contention that commercial thinning reduces wildfire risk is
controversial at best**. In fact, many studies show that fire risk
increases when large trees are removed. D.A. Perry, *The Scientific
Basis of Forestry,* 29 Ann. Rev. of Ecology & Systematics 435 (1998);
S.L. Stephens, *Evaluation of the Effects of Silvicultural and Fuels
Treatments on Potential Fire Behaviour in Sierra Nevada Mixed-Conifer
Forests,* 105 Forest Ecology & Mgmt. 21 (1998); C.N. Skinner et al.,
*Plantation Characteristics Affecting Damage from Wildfire,* Proceedings
of the 17^th^ Annual Forest Vegetation Management Conference, Redding,
CA, 137 (1996); Sierra Nevada Ecosystem Project, *Status of the Sierra
Nevada: Sierra Nevada Ecosystem Project, final report to Congress,*
Wildland Resources Center Report 37:I-II, University of California
Davis, Center for Water and Wildland Resources, Davis, CA (1996); J.W.
van Wagtendonk, *Use of a Deterministic Fire Growth Model to Test Fuel
Treatments* in *Status of the Sierra Nevada: Sierra Nevada Ecosystem
Project, final report to Congress*, Wildland Resources Center Report
37:II, University of California Davis, Center for Water and Wildland
Resources, Davis, CA (1996). Former Forest Service Chief Mike Dombeck
claimed that the cycle of small tree regeneration after overstory
removal makes it "unlikely that commercial timber harvest can solve our
forest health problems." Mike Dombeck, *How Can We Reduce Fire Danger in
the Interior West?,* 61(1) Fire Mgmt. Today 5 (2001).

By contrast, the NSA would minimize openings in the canopy and allow a
gradual return to the natural structure, function, diversity and
dynamics of these stands. Lopping and scattering methods under the NSA
would not significantly increase the fuel loading because the NSA
proposes to extract trees here and there across the landscape. The
selective logging proposed by the NSA will likely improve fire hazard
conditions; in contrast, adverse consequences to fire risks caused by
typical thinning and removing portions of the canopy and extreme hazards
caused by so called regeneration harvests also known as clearcuts. You
asked in Newsletter 7: *How can we increase the fire resiliency of the
forests in the Medford District and the Klamath Falls Resource Area of
the Lakeview District?* We have already answered this and all your other
concerns with the NSA.

**Issue: The EIS must fully assess the fire risk benefits that would be
produced by proposed alternatives.**

For instance, in the NSA, stewards on site with fire tankers will
increase immediate response to fire. This can have a greater effect in
terms of fire safety than any type of fuel treatment however that does
not replace the importance of the resiliency of natural closed canopy
late successional forests; also part of the NSA and not of the WOPR
proposed alternatives.

**Issue: The best use of our limited resources is to focus fuel
reduction treatments on the areas immediately adjacent to homes and
other structures.**

The National Fire Plan emphasizes such community assistance activities
as one of its five priorities. To prevent loss of structures, the most
effective activities involve changes to the structures themselves and
their immediate surroundings, not large-scale wildland fuels reduction
activities. If the goal is community and structure protection, it is
unnecessary to engage in fuel reduction activities that are a
substantial distance from the areas targeted for protection. P.H.
Morrison, *Recommendations for Wildfire Risk Management and Historic
Structure Preservation in the Polallie-Cooper Planning Area and Adjacent
Sites on the Mt. Hood National Forest*, Pac. Biodiversity Inst. (2004).

Instead, fuels reduction activities that are within a distance of
100-200 feet of homes should be our first priority. Simple,
cost-effective strategies like metal roofing and "zero fuel" zones
around buildings will have maximum fire-stopping effects. Firefighting
is dangerous wherever it is done, but the justification for the risk to
firefighters is greater when they are protecting our homes than when
they are protecting the economic interests of the timber industry in
remote forests.

The NSA would use a "higher level of resource extraction ... in areas
... that have dwellings within the home-ignition zone."   NSA p 2. It
also allows the most fire-resistant trees to be left on site. This way
if a wildfire comes through a project area, it will cause minimal risk
to human life and homes, while simultaneously allowing the forest area
to return to its natural ecological functioning.

**Issue: Moreover, another goal of fuels reduction projects under the
National Fire Plan is to limit the proliferation of invasive species and
diseases.**

The NSA accomplishes this goal because it minimizes site disturbance
from thinning, maintains canopy coverage and consequently optimal
conditions for native species, and intentionally selects trees that are
the most disease-resistant. In turn, reducing invasives and diseases in
this way lessens fire risk. Proposed WOPR alternatives will create
irreversible epidemics of non-native species that will in turn be
treated with chemical and biological warfare on natural and human
communities. These health hazards to people and forest ecosystems must
be included into the DEIS.

**Issue: Examination of the impacts of fuel treatments and including all
available information on fire risks from prescribed burning is required
by the public disclosure requirements of NEPA.**

[See]{.underline} [Sierra Club v. Bosworth]{.underline}, 199 F.Supp.2d
at 980 (finding that environmental analysis itself must address lack of
scientific support). "Agencies shall insure the professional integrity,
including scientific integrity, of the discussions and analyses. 40 CFR
§1502.24. NEPA requires that agency decisions be based on the highest
quality data and analysis to provide for full public participation and
informed decision-making. 40 CFR §1500.1. Accurate scientific analysis,
expert agency comments, and public scrutiny are essential to
implementing NEPA. 40 CFR §1500.1(b). BLM must disclose accurate
information about the comparative fire risks of the analyzed
alternatives.

**Issue: Potential of fuel treatments to spread disease or
infestations**

Scientific literature on the best method to control fire risk needs to
be fully examined with adequate discussion of scientific controversy.
/or analyze whether the fuel treatments now used in current BLM plans
will lead to a decline in forest health because the fuel treatments will
stress trees' immunities and allow for the introduction of disease or
infestations. And analyze whether the infestation will be exacerbated by
the introduction of fuel treatments. Comments from mycologist Joe
Cerecedes on South Deer (EA#OR110-05-10) suggest that this will be the
case and the WOPR needs to analyze this potential risk. These comments
were included as an attachment to DCA scoping comments. Similarly, BLM
should address the comments of ONRC on South Deer (EA#OR110-05-10) that
raise the issue of the potential for thinning to attract insects:

> "Thinning activities attracting beetles to the area through the
> release of terpenes from fresh wood chips, slash, or wounded green
> trees. If insect attack is a concern, the agency must consider and
> disclose the factors that tend to attract insects and determine
> whether thinning will make things better or worse."

**Issue: Silvicultural prescriptions for commercial harvest areas must
be objectively analyzed in terms of degrading forest health and
increasing fire hazard.**

Stands opened up excessively to the sun respond with a flush of growth
of shrubs and hardwood trees, increases the fuel loading and the
vegetative competition for the conifers in just a few short years after
treatment. It then becomes necessary to make another entry to reduce
these fuels and this competition with slashing, burning, herbicides, or
some combination of these methods. Not only is there a spike in growth
of understory and ground vegetation, but the increase in solar radiation
reaching the forest floor dries the fuels much more than before, further
increasing fire hazard, and sometimes creating a hostile environment
even for the conifers. The result is sometimes drought stress, which can
lead to infestations by the mountain pine beetle and other insects. (It
must be emphasized that in these cases, it is not the beetle we should
be concerned about, but the opening of the stand which originally made
the trees vulnerable to the beetle.) All of these effects may be
eliminated or minimized to insignificant impact by using the NSA which
retains natural canopies.

Retaining natural closed canopies and removing the dead only, in the
NSA, will help to reduce the risk of a high intensity stand-replacement
fire, since the larger trees are nearly always more fire resistant than
the smaller ones. The NSA will also, further the development of old
growth characteristics, which are so ecologically important to so many
species.

No one can justify clearcutting at this time in history; a time of
global warming crisis; a time where we have the science to understand
the effect on the natural and human environment; a time when we are in
the midst of the greatest loss of species since the last great
extinction 60 million years ago.

**Issue: The so-called modified group selection creates a large amount
of edge, which maybe good for edge dependent species, but this has
serious consequences as do other management based practices**.

We already have an excess of edge, on public and especially private
lands. What we need much more of is *large blocks of intact, closed
canopy forest*, where spotted owls can be free of predation from great
horned owls and barred owls, or where song birds can avoid nest
parasitism by brown-headed cowbirds, or allow natural fire conditions to
be restored back into the landscape.

**Issue: The EIS must adequately assess the direct, indirect, and
cumulative impacts of the proposed alternatives as required by NEPA.**

It is the responsibility of federal agencies to take a "hard look" at
the environmental effects of a proposed action. [See]{.underline}
[Vermont Yankee v. Natural Resources Defense Council]{.underline}, 435
U.S. 519, 535 (1978); [see also]{.underline} [Kern v. U.S. Bureau of
Land Management]{.underline}, 284 F.3d 1062, 1066 (9th Cir. 2002) (NEPA
establishes "action-forcing" procedures that require agencies to take a
"hard look" at environmental consequences). The "hard look" requirement
means that the BLM must adequately examine the potential direct,
indirect, and cumulative impacts arising from each alternative.

**Issue: Cumulative Impacts**

In determining whether the Revised Plan will have a significant impact
on the environment, the BLM must consider "\[w\]hether the action is
related to other actions with individually insignificant but
cumulatively significant impacts." 40 C.F.R. § 1508.27(b)(7).
"Significance exists if it is reasonable to anticipate a cumulatively
significant impact on the environment." [Id.]{.underline} CEQ NEPA
regulations, applicable to the BLM's implementation of NEPA, define
"cumulative impact" as "the impact on the environment which results from
the incremental impact of the action when added to other past, present,
and reasonably foreseeable future actions." 40 C.F.R. § 1508.7.

The DEIS failed to consider the impact from activities occurring on the
interspersed private lands through the Planning Region in developing the
proposed action alternatives and explaining those impacts to the human
and natural environment in the DEIS. BLM Lands are a patchwork of public
and private lands, and over-exploitation of private lands has placed a
stress on the need to manage BLM lands responsibly. There needs to be a
thorough analysis and data as to how the overuse of private lands
cumulatively impacts BLM lands and influences the decision-making
process.

What is the impact of the Biscuit Fire and other fires and the post fire
salvage operations in terms of large scale loss of suitable spotted owl
habitat and the cumulative impact of fire and salvage operations in
conjunction with the proposed revised plans. This examination of the
cumulative impacts relating to the revised plans must not be
artificially constrained. [See]{.underline} [e.g.]{.underline}, [Native
Ecosystems Council v. Dombeck,]{.underline} 304 F.3d 886, 897 (9th Cir.
2002)(finding that NEPA requires examination of cumulative impacts of
all reasonably foreseeable road density amendments within entire
National Forest).

Many watersheds are poor condition. Revised Plans must reveal impacts
that will degrade valuable remaining owl habitat that has been heavily
impacted in Western Oregon.

What are the impacts to the human communities and ecosystems of OHV
Emphasis Area? The EIS must assess and reveal cumulative impacts to
soils, property values, noise level (peace and quiet), wildlife, water,
fish and streams, hiking and horseback riding and other forms of
recreation, etc.

**Issue: Important data and science are missing from your planning
process critical to the basis for formulating reasonable alternatives
that are scientifically sound ecologically credible, and legally
responsible.**

NSA Alternative "Literature Cited" was submitted (along with the entire
alternative) for objective evaluation, and to begin to fill missing data
gaps in the science and empirical data used to formulate WOPR
alternatives. We requested that tree farm science not be given priority
over best current science in order to open the door to sustainable
solutions. Why did you ignore community input, such as this and so much
more?

**Issue: DCA requested that the revised plan evaluate the proposed
alternatives for effects of timber extraction practices on forest
structure, local microclimate, and fuel accumulation to the extent that
they create in an increase risk in fire severity**.

We further requested that it weigh the costs and environmental impacts
from fuel hazard reduction measures that are necessitated from timber
extraction practices. Please see NSA and "Literature Cited for examples
of current research". Other current, non-tree plantation biased science
should be looked at to give an objective evaluation of the real costs
and advantages of all alternatives.

**Issue: The National Fire Plan needs to be evaluated for sound science
and assessed for contradiction to current and best fire science.**

For instance in the South Deer EA, BLM states: "Ninety-five percent of
the South Deer project area lies in Wildland Urban Interface, designated
by the National Fire Plan. Eighty five percent of the project area
classifies into fire condition class 3. Condition class 3 results from a
reduction in fire frequency."

A greater risk for increased fire size, intensity, and severity in is
not in the late successional legacy forests, and it isn't because of "a
reduction in fire frequency. It's the conversion of late successional
forests to early successional tree plantations that caused a greater
"risk for increased fire size, intensity, and severity."

> *\"Timber harvest, through its effects on forest structure, local
> microclimate, and fuels accumulation, has increased fire severity more
> than any other recent human activity\". ‑‑Sierra Nevada Ecosystem
> Project, 1996, final Report to Congress*

Many forests that have been managed under BLM typical forestry
practices, currently lack species diversity and structure. It needs to
be recognized that the causes of the problems are past management
practices and the WOPR gives us the opportunity to end this vicious
cycle and recognize that every part of every forest must go through each
stage of ecological succession to retain and restore natural and healthy
levels of productivity of all forest values, including timber.

**Issue: Gather data, empirical research, analyze and resolving
statements that are setting a foundation for tree plantation practices,
but lack scientific basis**.

Common held belief: "Importantly, high stocking density and underbrush
competing for light and water resources have reduced stand vigor and
resiliency, prolonging succession toward a diverse stand condition.
Low-diversity, over stocked stands provide poor wildlife corridors and
instream large wood recruitment potential. Additionally, stand growth
rates and resiliency to disease are reduced."

Contrary belief: "High stocking density and underbrush competing for
light and water resources" is a natural biologically and ecologically
healthy condition. So called "overstocked stands" provide good wildlife
corridors for many species. "Reduced stand vigor and resiliency,
prolonging succession toward a diverse stand condition" implies a need
for human intervention and treatment that has no basis in fact.

Common held belief: High stand densities are resulting in declining
vigor of conifers and shade intolerant species (i.e., ponderosa pine,
sugar pine, black oak, Pacific madrone). It has been asserted that fire
exclusion has contributed to growth stagnation as well as to slow seral
stage progression/succession. .

Contrary belief: High stand densities are how environmental testing, and
reproduction of best species traits are accomplished, how species adapt
to ever-changing environments. Fire may remove some stems and make more
room for others to grow, but this does not generally increase overall
growth and generally sets back "seral stage progression/succession."

Common held belief: in the Klamath Mountains -- as a result of fire
suppression and other human activities -- large fires are occurring more
frequently and are larger and more intense than they were in the past
(Atzet et al. 1988, USDA Forest Service 1994, 1995, 1996, 1998b, Brookes
1996). This position is predicated on assertions, that, because of fire
suppression: 1) the number of fires in the region has declined over
time, 2) fires are substantially larger today than in the past, and 3)
large, intense fires are the results of unnaturally high levels of fuels
accumulation

Contrary belief: However, none of these assertions have been supported
with empirical data from the Klamath Mountains or by analysis
demonstrating that a change in fire frequency, size or severity has
occurred from historic to present. If this hypothesis is not true, it
may lead to inappropriate forest management and adverse impacts to
regional biodiversity." (21)

Common held belief: (from South Deer EA p.124) there would be a loss of
future large woody debris recruitment from a high severity fire

Contrary belief: the opposite would be true. Post-fire wood inputs to
streams from snags would be very high as has been reported for the
Biscuit Fire Area and elsewhere (Biscuit FEIS). This is an example of
the need for current and contrary science to be included in the WOPR
process.

Analysis of recent fires over large areas of the Klamath Ecoregion
indicate that these closed canopy forests, which have not burned for
decades, have lower likelihood for stand replacing fires than open
stands (Odion et al. 2004). Important new scientific information
contradicts BLM findings and assumptions regarding fire and fuels in
their current management plans. For example, page 73 the South Deer EA
makes an erroneous statement based on untested models rather than recent
peer reviewed publications (Odion et al. 2004): \"Based on FMA modeling,
all untreated stands modeled would initiate and sustain active crown
fire behavior.\"

Converting trees to perpetual sprouting shrubs is contrary to fuels and
fire objectives. If cutting hardwood trees 8-12 inches dbh and greater
is being done to increase conifer growth, then increased fuel loading
and fire hazard needs to be stated. This type of information is
essential to a fair evaluation of alternatives and wasn't included in
the DEIS.

Where high fire hazard conditions combine with increasing rural
residential development designated Wildland Urban Interface (WUI),
current research needs to be taken into account in the WOPR.

Research for the Structure Ignition Assessment Model (SIAM) conclusions:
"SIAM modeling, crown fire experiments, and WUI fire case studies show
that effective fuel modification for reducing potential WUI fire losses
need only occur within a few tens of meters from a home, not hundreds of
meters or more from a home." "These research conclusions redefine the
WUI fire problem as a home ignitability issue largely independent of
wildland fuel management issues." See NSA "Literature Cited (22).

If common held beliefs are without basis in science or in empirical
data, they must not be used to justify forest management practices.
Using fire issues erroneously results in interference of a natural
functioning healthy forest. Introducing fire in early successional
forests is costly, and causes more problems over the long term than it
solves. Late successional forests in much of western Oregon don't have
high fire hazard conditions. The challenge is to serve our needs without
degrading other species' ability to restore early successional forests
to low fire hazard late successional forests.

If catastrophic fire is a consequence of harvest practices, then
alternatives that include these practices must be abandoned, as that is
a science based decision.

The WOPR process would have greatly benefited by including the NSA as an
opportunity to gather new data and look at new possibilities for
solutions to long time problems that will have best results for forest
productivity and sustainable practices. The introduction of the Natural
Selection Alternative requires that old premises and biases be revisited
and allow for resolution through this innovative, yet common sense
paradigm shift.

**Issue: Flood and sediment effects are a threat to coho salmon and each
alternative needs to quantify exacerbated sediment effects and describe
impacts from a major flood during or immediately after project
implementation.**

Floods are at least as threatening to fish habitat as wildfire. In our
area severe flooding and stream habitat damage has occurred 3 times in
the past 40 years (1964, 1972, and 1997) making floods a more likely
event than catastrophic wildfire (South Deer EA p. 39). Analysis must
not focus on one risk such as fire and ignore sediment risks from others
such as floods. Weather resulting in severe flooding cannot be
controlled. Such occurrences need to be assumed because the occurrence
of a large flood producing rainfall events would exacerbate management
related sediment delivery.

**Actions in the region should be evaluated by their impacts on the
outstanding and remarkable values of the each watershed and especially
in and near our last precious wild areas.**

**Areas such as CHU-OR-72 in the Deer Creek Watershed should be
protected. Why wasn't this area included in an administratively
withdrawn area or an ACEC?**

CHU OR-72 is located on the Medford District BLM and the Siskiyou
National Forest. Eighty-nine percent of this CHU is located within the
East IV/Williams LSR. This unit provides a very important east-west and
north-south intra-provincial (Klamath Mountains Province) connectivity,
in an area of high fragmentation. The high fragmentation is a result of
the geology, fire history, ownership patterns, and past management
practices. This unit is an important link for the Highway 199 Area of
Concern (Rogue River/South Coast BA, FY 04-Fy 08, Appendix B). The
following South Deer KSOAC's are located within CHU OR-72: Bare Nelson
(#2660) and Thompson Illinois (#1307) (See Map 2, Appendix A)

CHU OR-72 needs special protection for it's importance as some of the
rare, last, low elevation and late successional ecosystem remaining and
necessary to provide connectivity and protection threatened and
endangered species. It no appears that it would be subject to
regeneration/clearcut practices by the proposed WOPR. This is the last
remaining large island of intact forest in the area and providing a very
important east-west and north-south intra-provincial (Klamath Mountains
Province) connectivity, in an area of high fragmentation. It has
numerous special status species that depend on natural late successional
and old growth forests.

The CHU OR-72 includes is the largest area of rare low elevation late
successional and old growth forests left in the area. It is important
not only to endangered species unique to these areas, it is significant
as that it offers one of the rare opportunities for family oriented
recreation and opportunity to visit a natural old growth forest. This is
a culturally significant area to the local community, used over decades
for public education on how natural old forests function and training
for sustainable forest practices.

CHU OR-72 provides visualNumber range CHAPTER, spiritual, recreational,
educational, historical and tourism opportunities. Highway 199 is the
premiere recreation and nature-education development opportunity for
Oregon\'s coastal mountains. CHU OR-72 is within this visual corridor
and there is easy access from 199 past Lake Selmac through South Deer to
the Oregon Caves.

The Thompson Creek Overlook Trail System in CHU OR-72 has a long history
of being used for visual, spiritual, recreational, educational and
hiking values. Further development of this trail system will develop
aesthetically pleasing, hiker-friendly trails, creating opportunities
for recreation, nature-based education, and tourism and would provide
hiking access to higher elevation BLM lands along the ridge above
Thompson Creek and has been approved by BLM in the Sept 2005, South Deer
ROD

> *(Alternative 4-Natural Selection Alternative trails: Implement the
> six miles of trail construction in the Thompson Creek area, sections
> 22, 23, 26 and 27 (T38S, R7W) as identified in Map 7 in the EA. Allow
> only non-motorized use of these trails, with the exception of roads
> 27.1 and 27.2, which would be open for motorized vehicles to access
> the trailheads.)*

This is part of the Natural Selection Alternative submitted for South
Deer; addressing Deer Creek community needs for experiencing firsthand
our heritage forests and for recreation and tourism values to help
support the local economy. The upgraded trail system will have 6 miles
of various looping hiking options through a variety of ecosystems
including late successional legacy forests and rock outcroppings with
spectacular panoramic views of South Deer, Grants Pass, Oregon Coast
Range and California mountains. See attached photos.

**Each alternative should be evaluated for it's involvement of the local
communities from planning through implementation.**

The significant differences, ecologically, economically, and socially
between the alternatives must be adequately developed to provide a clear
choice between alternatives. The ecological, economic and social
benefits and costs of the alternatives need to be displayed and
discussed; including a balance sheet approach, indicating what values
will be retained, restored and or lost over time. The EIS needs to
adequately disclose the significant cumulative impacts to the human
environment.

.

Clearcutting forests is recognized as a major disruption to the climate
and contributor to global warming. What importance has this been given
in terms of research and developing alternatives? What is the total
carbon released into the atmosphere; loss of stored carbon?

We request that the WOPR EIS include the replacement values of all the
resources that will be degraded or lost by implementing each of the
proposed alternatives

For example: What would it cost to replace and repair forest ecosystems
and forest ecosystem services such as clean air, clean water, fish
habitat, loss to fishing industry, loss to property values, scenic
values, recreation opportunities; microclimate and macroclimate values
such as cooling and warming local and global environments; restore
degraded ecosystems. There are significant and cumulative impacts that
will be beyond the comprehension of most people. It is the
responsibility to make these impacts known to the American public.

The DEIS failed to inform the public about the true costs and impacts
that will result from the WOPR.

**Oregon portion of the California Floristic Province, of global
environmental significance, is within the WOPR management area (map
attached)**

The California Floristic Province is one of 34 hotspots of biodiversity
recognized by Conservation International. This is one of the earth's
biologically richest and most endangered terrestrial ecoregions.

The following are excerpts from an document from the Center for Applied
Biodiversity Science at Conservation International which may be found on
the Internet titled California Floristic Province by William R.
Konstant, Dean Taylor, David A. Wake, Scott Robbins Loarie, Roxanne
Bittman and Barbara Ertter:

*"The California Floristic Province is one of the five
Mediterranean-type hotspots on the planet and the only hotspot that
occurs largely within the borders of the United States of America. As
its name implies, the California Floristic Province is an ecological
construct based on plant species composition, a unique mixture of
northern temperate and southern xeric elements fostered by a
Mediterranean climate of hot, dry summers and cool, wet winters. Four
other hotspots share this climate: Central Chile, the Cape Floristic
Region, Southwestern Australia, and the Mediterranean Basin ([Barbour et
al.
1993](http://www.biodiversityscience.org/publications/hotspots/references.html#BM1993);
[Dallmann
1998](http://www.biodiversityscience.org/publications/hotspots/references.html#DPR1998))."*

*"Four subregions within the Province stand out as centers of
exceptionally high plant diversity: the Sierra Nevada, Transverse
Ranges, Klamath-Siskiyou region, and Coast Ranges ([Stebbins
1978](http://www.biodiversityscience.org/publications/hotspots/references.html#SGL1978);
[Davis et al.
1997](http://www.biodiversityscience.org/publications/hotspots/references.html#DSDF1997)).
The Klamath-Siskiyou region bridges the coastal mountain ranges of
California and Oregon, and is home to approximately 20 rare plant
communities, including the most diverse temperate coniferous tree
community in the world ([Vance-Borland et al.
1995--1996](http://www.biodiversityscience.org/publications/hotspots/references.html#VANCE1995)).
This region also represents the contact zone between the Pacific
Northwest Floristic Province and the California Floristic Province."*

*"Some of the highest levels of plant diversity within the California
Floristic Province are found in the southern part of the Sierra Nevada
Range and in the Klamath-Siskiyou region ([Davis et al.
1997](http://www.biodiversityscience.org/publications/hotspots/references.html#DSDF1997)."*

*High levels of species diversity and endemism have developed within
this region due to its varied topography, climate zones, geology, and
soils. Plant diversity is exceptional, with 3 488 native vascular
species, including 2 124 endemics. Fifty-two of the region\'s plant
genera are also unique. The total number of plant species is greater
than that for the central and northeastern United States and adjacent
portions of Canada, an area almost 10 times as large ([Raven and Axelrod
1978](http://www.biodiversityscience.org/publications/hotspots/references.html#RPH1978);
[Raven
1988](http://www.biodiversityscience.org/publications/hotspots/references.html#RPH1988);
[Davis et al.
1997](http://www.biodiversityscience.org/publications/hotspots/references.html#DSDF1997))."*

*"In conclusion, while the California Floristic Province lies largely
within one of the world\'s richest nations and contains some of Earth\'s
most famous and most popular national parks, it suffers from threats
similar to those operating in hotspots found within countries that are
much more disadvantaged economically. Furthermore, a great deal remains
to be done in order to ensure that the unique and threatened
biodiversity of this hotspot is adequately safeguarded in suitable
protected areas. Biodiversity loss clearly is not a problem unique to
developing tropical nations."*

"The Siskiyou Field Institute located in the Deer Creek watershed,
Selma, Oregon, has had Susan Harrison and Ellen Damschen of Washington
University -- St Louis research this past year researching species in
the Illinois Valley area. They are following Whittaker's studies,
collecting data in the same places as Whittaker did 50 years ago and
analyzing what has happened in the changes have taken place to the
vegetation and flora since 1950, whether these changes are consistent
with being caused by a warming and drying climate, and whether the
changes have been any greater (or lesser) on serpentine as opposed to
other soils

The following document was submitted during the SFI 1st Conference of
Siskiyou Ecology by Art R. Kruckeberg1 and Frank A. Lang2 1Department of
Botany, University of Washington, Seattle, A 98195; 2Department of
Biology, Southern Oregon University, Ashland, OR 97520, November 4,
1997, It was obtained from the SFI website.

*"Few places in North America offer the physical and biological
complexity of the Klamath-Siskiyou Bioregion. It is one of those places
on our planet that can evoke wonder, reverence, and unending curiosity
among all who delight in the natural world.  Nowhere is such a rich
display of landforms, geology, and an indigenous, richly endemic biota
more grandly displayed in the American West. Its richness, displayed in
all branches of natural science and in major economic mineral and timber
resources, as come to provoke the ultimate question: How to preserve
this province and bioregion in all its distinctive ecosystems -- in the
face of ongoing resource extraction and other human incursions? "*

*.....*

*The flora of the Klamath-Siskiyou includes an unusually high number of
endemic species, many of them serpentine. Smith and Sawyer's 1988 study
of northwestern California and southwestern Oregon discovered 281
endemic taxa from the broader area that includes the Klamath Mountains.
Their study emphasizes the botanical importance of the area.*

*One square mile (2.6 sq. kilometers) in the Russian Peak Wilderness in
the Salmon Mountains is home to 17 different conifers, a record seldom
rivaled on this planet or any other. In the Siskiyou Mountains portion
of the bioregion the Bear Basin Butte Botanical Area has 16 conifers
within a 500 hectare area. Botanists describe these places as "enriched
stands in the Klamath Mountains." Thirty one conifer species are native
to the Klamath Mountains. Some species, Douglas fir (Pseudotsuga
menziesii) and incense cedar (Calocedrus decurrens), are common and
widely distributed. Others, such as subalpine fir (Abies lasiocarpa) and
Alaska yellow cedar (Chamaecyparis nootkatensis) reach their southern
limits in craggy Klamath heights. Foxtail pine (Pinus balfouriana) has
an odd distribution split between the southern Sierra Nevada many miles
to the south and scattered populations in the Klamath Mountains as far
north as Lake Mountain above the Klamath River. Other species, Brewer
spruce (Picea breweriana) and Port Orford cedar (Chamaecyparis
lawsoniana) are the Klamaths' own.*

*Port Orford cedar is at risk. Its straight-grained fragrant wood is
worth a fortune in Japan. Not only is it and its relative Alaska yellow
cedar the only conifers that can still be exported from federal lands to
foreign markets as whole logs, but POC, as it is abbreviated by its
enthusiasts, is at great risk from another foreign threat, a devastating
root-rot, Phytophthora lateralis. At higher elevations in the mesic
western Siskiyous impressive old-growth stands of  POC still remain . .
. for the time being.*

*The Klamath-Siskiyou forests are not all conifers. Evergreen hardwoods
mix liberally with the conifers to form a complex series of plant
communities. Many are members of the oak family: golden chinquapin
(Chrysolepis chrysophylla), tan oak (Lithocarpus densiflorus), and
canyon live oak (Quercus chrysolepis). The madrone (Arbutus menziesii)
is a member of the heath family, and its broad evergreen leaves,
handsome smooth red bark, clusters of creamy flowers, or masses of red
berries, depending on the time of year, always make it a welcome sight.*

*The abundant serpentine exposures in Klamath-Siskiyou country have
their own singular plant associations. Throughout the region a Jeffrey
pine-grassland savannah commonly occurs on serpentine flats and gentle
slopes. Upslope to ridges, serpentines are clothed with xeric shrub
communities that include an endemic shrub form of the tan oak
(Lithocarpus densiflorus var. echinoids), the huckleberry oak (Quercus
vaccinifolia) and Brewer oak (Q. garryana var. breweri). On serpentine
exposures along barren ridge-tops, sparse, prostrate patches of Siskiyou
mat (Ceanothus pumilus) and Juniperus communis var. jackii commingle
with widely spaced, often endemic herbs such as evergreen everlasting
(Antennaria suffrutescens) and the Siskiyou fritillaria (Fritillaria
glauca) to create the sere barren landscape so typical of the serpentine
"syndrome."*

*Nowhere is the "syndrome" better seen than at Rough and Ready Botanical
Wayside south of Cave Junction, Oregon in the Illinois Valley. These
dry, barren looking serpentine flats look like a desert in late summer,
fall, and winter. In the spring and early summer these dry areas are a
riot of color: pink, purple, lavender and blue from phlox, onions, rock
cress and larkspurs. Later, yellow wild buckwheat, wall-flowers and
composites dominate the scene. Many of these are rare, unusual species:
more local serpentine endemics.*

*Yet of all serpentine habitats, the most spectacular has to be the
Darlingtonia fen. These wetlands support an amazing flora dominated by
various sedges, rushes and grasses, and the insectivorous California
pitcher plant (Darlingtonia californica). Western azalea (Rhododendron
occidentale) with its masses of cream and peach colored, heavenly
scented flowers surround the wetlands along with California
lady-slippers (Cypripedium californicum) and Vollmer's lily (Lilium
pardalinum var. vollmeri). Other members of the community include yellow
California coneflower (Rudbeckia californica) and California bog-aspodel
(Narthecium californicum), often in large quantities, and some very rare
plants like the bright blue Waldo (Mendocino) gentian (Gentiana
setigera) and white and purple large flowered rush-lilies (Hastingsia
bracteosa s.l.). The Hastingsias are limited to the wetland seeps along
the west side of the Illinois Valley, Josephine Creek and around Eight
Dollar Mountain; found there and nowhere else on earth. Rare indeed.*

*The botanical riches of the Klamaths brought botanists to collect and
study the many new and unusual species of the bioregion. Thomas
Jefferson Howell, a self-taught botanist and an Oregon endemic himself,
made three major collecting trips to the Illinois Valley in the 1870s.
While there he discovered many species new to science that were named by
Asa Gray and Sereno Watson at Harvard University. Another, later
botanical visitor was Lilla Leach, who with her husband John explored
the region in the decade between 1928 and 1938. On June 14, 1930 Lilla
discovered a small pink flowered shrub that turned out to be a new
endemic genus, Kalmiopsis leachiana, a remarkable discovery.*

*Another early 20th Century visitor was Alice Eastwood of the California
Academy of Sciences who walked from Crescent City to Waldo in the
Illinois Valley so as not to miss the manzanita (Arctostaphylos) species
described by Howell. The stagecoach ran at night.*

*Charles Vancouver Piper (Washington State University), Louis Henderson
(University of Oregon), Elmer Applegate (Stanford University), and
Morton Peck (Willamette University) were also attracted to the area. It
seems like most of the western professional botanists of the later part
of the 20th Century have visited the region, as have seeds men and
nurserymen, and wildflower enthusiasts of all types: rock gardeners,
photographers, and artists.*

*Pioneering plant ecologist Robert Whittaker was also attracted to the
area.  His studies of the vegetation of the Siskiyous brought world-wide
attention to the region. Whittaker first pointed out the botanical
richness of the area and compared it with the southern Appalachians in
floral diversity and species richness. He credited the Klamath-Siskiyou
Region as having "central significance" for the floristic origins and
diversity of Pacific Northwest floras. Here, past floras found mesic
refugia as late Tertiary aridity increased in the far West. Then as a
discrete bioregion, it became an evolutionary nursery for the genesis of
many endemic species and unique ecosystems. Probably nowhere else in the
West is endemism so abundant: endemic Conifers, already mentioned, a
host of woody angiosperms and a diverse array of endemic herbs. As
mentioned, totals for plant endemism are impressive, and on serpentine
alone endemics total 30 species and infraspecific variants!*

*The Klamath-Siskiyou Bioregion abounds in a diversity of animal life.
Much is known about the vertebrate fauna. All major classes of mammalian
vertebrates are well represented from insectivores to carnivores to
primates, if you believe that Sasquatch walks the Earth. The Siskiyou
wild lands are the source of many Sasquatch tales. Other vertebrates,
birds, reptiles, amphibians, and fishes figure prominently in most of
the region's ecosystems. Most are common and wide-spread. A few like Del
Norte salamander (Plethodon elongates) and the Siskiyou salamander
(Plethodon stormi) are endemics. And a few, like the once-bounteous runs
of salmon in Klamath Mountain rivers are testimony to the deterioration
of the regions once pristine ecosystems.*

*One of us (ARK) was introduced to the region in 1950. Fresh from the
botany of southern California, I was plunged into a whole new flora \--
bewildering and fascinating. With the eminent taxonomist, C. Leo
Hitchcock, I compiled a synoptic collection of the plant life mostly
along the West Fork of the Illinois River and of the country east of
Takilma to Bolan Peak. Ever since that introduction to the flora, I have
been lured back by the singular diversity of the region. As a newcomer
to the flora, just one encounter with the eerie cobra-like
pitcher-leaves of Darlingtonia was to make me a believer in miracles.*

*The other of us (FAL) arrived at Southern Oregon College in the fall of
1966 to teach botany and never found a good reason to leave. Every class
field trip was an adventure with endless plants to find and study. A
visit to the Dalingtonia fens, no matter what the season of the year,
resulted in always finding something interesting to see. One of the
great pleasures of teaching plant systematics and ecology under such
circumstances is the look of amazement on students' faces when they see
(and smell) the innards of a Darlingtonia pitcher, or see real hybrid
Calochortus with both parents, or when they realize the special value of
the rare endemics that they observe. I have felt quite blessed to have
had the good fortune to spend most of a career working in one of the
great botanical areas of the world. What success I have had with
students can be attributed in large measure to the fascinating flora of
the Klamaths.*

*It was inevitable that a global view of outstanding bioregions would
single out the Klamath-Siskiyou Province as meriting the highest rank. A
World Wildlife Fund study recently ranked the Klamath-Siskiyou Bioregion
as one of the three top conifer biomes in the world. This worthy
recognition comes hard up against the reality of attaining a good
measure of preservation for the region. Complex ownerships -- private
and public -- as well as continuity of ecosystems across state
boundaries, and long-standing preoccupation with extraction of is
resources, all present immense challenges for conservationists. This was
a key component of the First Conference Siskiyou Ecology: finding ways
to begin the protection of one of North America's most amazingly rich
and complex bioregions.*

*Ironically, the very feature that helps make the region a botanical
Eldorado, its mineral riches, also creates a major conservation
conflict. The first Europeans flooded into the area in the 1850s in a
never-ending quest for gold. Gold is still sought today, but so are
nickel, chromium and cobalt. Humans want to mine the minerals for profit
and the minerals are where the rare endemic wildflowers grow. How to
deal with this conflict is one of the many environmental dilemmas of our
times.*

*To many people the biological significance of the region and its beauty
outweigh any short-term destructive, consumptive benefits that might be
derived from mineral or timber extraction. The biologically significant
portions of the area should be set aside as preserves or parks and
managed for their biological values. If destroyed, the region will never
recover and these wonders of creation will be lost forever.*

**We request that the Oregon portion of the area called The California
Floristic Province be administratively withdrawn from the WOPR.**

> *"The one process now going on that will take millions of years to
> correct is the loss of genetic and species diversity by the
> destruction of natural habitats. This is the folly our descendants are
> least likely to forgive us." [E. O.
> Wilson](http://www.brainyquote.com/quotes/quotes/e/eowilson176384.html)*

Speciation and Biodiversity internet interview with Edward O. Wilson

> ActionBioscience.org: *With extinction happening globally, where
> should we focus conservation efforts?\
> \
> *Wilson: *On the hot spots, such as tropical forests. Hot spots are
> the habitats that are most endangered and have the largest number of
> species found nowhere else but in them. These include the forests of
> Hawaii and Madagascar and the rich scrub lands of southwestern
> Australia and southern Africa. Tropical wildernesses, such as the
> Amazon and the Congo, have the last of the great frontier forests able
> to support a mega fauna, i.e., large mammals and birds. The
> preservation of these places is critical. ActionBioscience.org: In
> your new book Future of Life you deflate the myth that environmental
> policy is hostile to economic growth. Can you elaborate?\
> \
> *Wilson: *The living resources of the world \-- ecosystems and its
> species \-- are still largely unexplored, much less studied for the
> benefits they might hold for humans, for example, new pharmaceuticals
> or water purification. Some ecologists and economists have estimated
> that the total value of these natural ecosystems, that\'s the total
> amount of services they provide to humanity, is in the vicinity of 30
> trillion dollars a year. That\'s more than the total of the gross
> national products of all nations combined. And it\'s free!\
> \
> To save and make fuller use of them in a non-obtrusive way is
> economically valuable to us. To destroy them is to force humanity into
> an artificial world in which we have to personally manage our water
> systems, our food supply, and our atmosphere by prosthetic devices day
> by day instead of relying on powerful organisms to do the work for us.
> Do we want to turn Earth literally into a spaceship that requires
> constant tinkering?*

**Your current WOPR EIS and proposed alternatives are unacceptable.**
**You are managing these lands for all Americans, and future generations
deserve a living legacy**. You have a mandate. I am including the
following insert on the current rate of species extinction and request
that it be included in the analysis of the WOPR. You may wish to read
it, as you are making history and you should know what kind and how
important your decisions are. Keep in mind that the historical rate of
extinction, between mass extinctions is one species every 6 years.

> The Sixth Extinction By Niles Eldredge \
> \
> *"About 30,000 species go extinct annually.*
>
> * There is little doubt left in the minds of professional biologists
> that Earth is currently faced with a mounting loss of species that
> threatens to rival the five great mass extinctions of the geological
> past. As long ago as 1993, Harvard biologist E.O. Wilson estimated
> that Earth is currently losing something on the order of 30,000
> species per year \-- which breaks down to the even more daunting
> statistic of some three species per hour. Some biologists have begun
> to feel that this biodiversity crisis \-- this \"Sixth Extinction\"
> \-- is even more severe, and more imminent, than Wilson had supposed.*
>
> *Can conservation measures stop the Sixth Extinction?*
>
> *The world\'s ecosystems have been plunged into chaos, with some
> conservation biologists thinking that no system, not even the vast
> oceans, remains untouched by human presence. Conservation measures,
> sustainable development, and, ultimately, stabilization of human
> population numbers and consumption patterns seem to offer some hope
> that the Sixth Extinction will not develop to the extent of the third
> global extinction, some 245 mya, when 90% of the world\'s species were
> lost.*
>
> *Though it is true that life, so incredibly resilient, has always
> recovered (though after long lags) after major extinction spasms, it
> is only after whatever has caused the extinction event has dissipated.
> That cause, in the case of the Sixth Extinction, is ourselves \-- Homo
> sapiens. This means we can continue on the path to our own extinction,
> or, preferably, we modify our behavior toward the global ecosystem of
> which we are still very much a part. The latter must happen before the
> Sixth Extinction can be declared over, and life can once again
> rebound."*

Paleontologist Dr. Niles Eldredge is the Curator-in-Chief of the
permanent exhibition \"Hall of Biodiversity\" at the American Museum of
Natural History and adjunct professor at the City University of New
York. He has devoted his career to examining evolutionary theory through
the fossil record, publishing his views in more than 160 scientific
articles, reviews, and books. Life in the Balance: Humanity and the
Biodiversity Crisis is his most recent book.[\
](http://www.gc.cuny.edu/directories/faculty/E.htm)

**Deer Creek Valley Association requests the BLM maintain Northwest
Forest Plan Protections on Oregon BLM Lands**

The three WOPR action alternatives would convert much of the old growth
forest reserves and streamside buffers established under the Northwest
Forest Plan (NWFP) into regulated tree farms and off-highway vehicle
areas which would severely degrade neighborhood environments and
economic stability. We believe that the WOPR No-Action Alternative
(which is the NWFP) should be selected as the preferred alternative. In
addition it appears that the No Action Alternative is not correctly
represented in the WOPR. On page 4 it states that the allowable sale
quantity (ASQ) under the NWFP is 211 mmbf but that only 40% to 70% was
offered for sale. Even with that reduced logging rate under NWFP the
endangered and threatened species populations and habitats are still
declining in quantity and quality. Therefore, the sustainable logging
rate may be an ASQ that is less that the actual level under the NWFP. If
any of the three action alternatives of the WOPR were to be approved,
many changes to the NWFP would be required that would reduce logging on
the non O&C lands. This could result in an endless feedback loop of
government reports and lawsuits. BLM should focus on working within the
legal constraints of the NWFP and the WOPR should be abandoned.

Sincerely,

Mary Camp,

President, Deer Creek Valley Association

Number range CHAPTERCC:

+-----------------------+-----------------------+-----------------------+
| Tim Reuwsaat          | Senator Gordon Smith  | Senator Ron Wyden     |
|                       |                       |                       |
| Medford District      | 121 SW Salmon St.     | 1220 SW Third Ave.    |
| Office                | #1250,                | #585                  |
|                       |                       |                       |
| 3040 Biddle Road      | Portland, OR 97204    | Portland, OR 97204    |
|                       |                       |                       |
| Medford, OR 97504     | Email:                | Email:                |
|                       | www.gsmith.senate.gov | www.wyden.senate.gov  |
+-----------------------+-----------------------+-----------------------+
| Rep. Peter DeFazio    | Governor Ted          | Board of County       |
|                       | Kulongoski            | Commissioners         |
| 405 E Eighth Ave.     |                       |                       |
| #2030                 | State Capitol, Room   | Josephine County      |
|                       | 250                   | Courthouse            |
| Eugene, OR 97401      |                       |                       |
|                       | Salem, OR 97310       | 500 NW Sixth Street,  |
| Email:                |                       | Dept. 6               |
| www.defazio.house.gov |                       |                       |
|                       |                       | Grants Pass, OR 97526 |
+-----------------------+-----------------------+-----------------------+

Enclosures:

7Photos:

Spotted owl adjacent to CHU OR-72, in Camp Forest where the NSA has been
practiced for 40 years

Orville Camp Taking photo of the owl, Sept 9, 2007

Lower portion of Thompson Creek Overlook Trail in CHU OR-72

A little farther down the trail with Dick Prather and community members

Camp Forest tour with Dick Prather and community members, May 21, 2006

Typical education tour at Camp Forest, which continued into CHU OR-72,
2005

Orville Camp constructing forest road for private forestland owner, Fall
2007

Map of California Floristic Province

Northwest Ecosystem Survey Team red tree vole nest documentation from
CHU OR-72 (in area and nearby)

August 7, 2006; September 22, 2006; January 4, 2008

Petitions

References:

Bureau of Land Management. 1988. National Environmental Policy Act
Handbook. BLM Handbook H-1790-1

Bureau of Land Management. 2002. Social and economic analysis for land
use planning. Instruction Memorandum No. 2002-167, ref 1610(210)P

Bureau of Land Management. 2003a. The BLM's priorities for recreation
and visitor services. BLM Workplan Fiscal Years 2003-2007.

Bureau of Land Management, 2005a. Western Oregon Plan Revisions, Scoping
for issues. Newsletter Issue 1, August 2005. Portland, Oregon.

Bureau of Land Management, 2005b. Land Use Planning Handbook (Public),
BLM Handbook H-1601-1

Gorte, Ross. W. 1994. Below-cost timber sales: Overview. CRS Report for
Congress

Oregon 2000 Commission. 1979. The challenges and costs of rapid
population growth. Pacific Northwest Regional Commission.

Sonoran Institute. 2005. A socioeconomic profile, Josephine County,
Oregon. Economic profile system (EPS). Sonoran Institute. Tuscon,
Arizona.

Number range CHAPTERNatural Selection Alternative by Orville Camp For
the Medford District BLM South Deer Landscape Management Project,
submitted by Deer Creek Valley Natural Resource Conservation Association

Other resources: South Deer Landscape Management Project EA
(EA#OR110-05-10) comments of Rich Nawa, Bill Grey, Dennis Odion, and the
Protest of the South Deer Timber Sale and Associated South Deer
Landscape Management Project Environmental Assessment (EA-OR110-05-10)
and Decision Record/Finding of No Significant Impact (FONSI) by James
Brown of Cascade Resource Advocacy Group.