WOPR DEIS COMMENTS

I attended the WOPR modeling presentation in September as well as the
workshop in October. Having some experience in modeling I was impressed
with the amount and the detail of the data the BLM has organized on the
status and condition of the lands they administer. I also applaud their
choice of the Options model which seems to be versatile and robust
enough to handle all this data. However I do have some concerns with the
choice of the preferred alternative, \# 2, and some suggestions. Rather
than cite specific references to support my comments, I will refer to
the DEIS itself, since I feel it represents a thorough job of covering
the current literature.

One of the biggest differences between all of the alternatives is the
amount of riparian management habitat designated. Alternative 2 has the
least amount and allows regeneration harvesting much closer to streams
than any of the others. According to the DEIS, the potential for fine
sediment delivery from logging activities would be greatest under
alternative 2. Although there may not be much literature available on
the effects of vegetation/the distance the harvest area is from the
stream on stream sedimentation and peak flow, it should have been more
seriously considered, if not in the model due to uncertainties, then in
the choice of a 'middle of the road' alternative. As the DEIS states,
for every 1% increase in sedimentation there is a possible 2% (or
greater, 3.4 %?) decrease in fish survival. This can have far reaching
effects on native fish populations, many of which are listed species.
Salmon fishing was halted this year and the industry is already
suffering economic hardship.

In addition, the largest number, by far of special status species are
found in riparian areas and in conifer mixed evergreen forests. Yet,
special status species are not protected on O&C lands (when it
interferes with logging.) It stands to reason that the greater species
diversity found in riparian areas is conducive to the health of the
overall watershed and should be conservatively protected. Along with the
increased risk of losing sensitive species, alternative 2 supports the
highest risk of invasive plant introduction. Exotics often hasten the
disappearance of natives, further decreasing diversity. Healthy forests
are desired by us all, including the logging industry. Therefore, it
seems counterproductive to choose the alternative with the least amount
of riparian management area.

The majority of logging in the preferred alternative is the regeneration
harvest type. As the DEIS points out, land logged under this method will
not regenerate mature, structurally complex forests even after 100
years. This is another concern as old growth forests are the only
habitat suitable for sustaining populations of threatened and endangered
species like the northern spotted owl, the management plan of which
still needs to be considered in the RMP. Only in the no-action
alternative would the size and connectivity of mature, structurally
complex patches increase. At the workshop a graph was shown that
depicted only a 1% difference in these patches between the no-action
alternative and the rest of the alternatives over time. This was
somewhat deceiving because it included all lands in the planning area.
And yes, 1% doesn't seem like much even when you include the total land,
but this sets a dangerous precedent for land use policy and should be
avoided if possible.

As I reviewed the DEIS I found the only area where alternative 2 rises
above all the others is in the economic benefit to both the logging
industry and the counties. This is a great advantage, not to be
discounted, particularly since it is the primary reason for revising the
RMP. Perhaps some compromises could be made that address these concerns
and make alternative 2 acceptable to more people.

First, it appears that all public domain parcels intermingled with O&C
are treated as O&C land. It would seem fair to reverse that on half of
the intermingled parcels, increasing areas of harvest on public land
next to O&C land, and on the other half, increasing the size of land
devoted to habitat. It would be better for both uses to be able to
increase patch size. If this is not legally possible, there are other
smaller compromises that could be done.

For instance, instead of increasing riparian management areas adjacent
to steams in alternative 2, (or choosing another alternative) why not
prohibit the regeneration harvest method \~100-300 feet from streams.
Also, under alternative 2 marbled murrelet habitat would decrease more
than the other alternatives. Rather than choosing another alternative,
as a compromise require marbled murrelet surveys be done prior to any
regeneration harvest. Since the birds are rare and their inland
territory has been less than expected, this would not take much land out
of harvest, but may pacify those with opposing views. Another suggestion
is to include carbon sequestration in the Options model. Global warming
is a scientifically accepted theory, the consequences of which most
believe to be serious enough to justify compromise in regard to
regeneration harvesting of mature forests. These are just a few examples
of how alternative 2 could be adjusted to suit a wider audience.

In conclusion, regeneration harvesting under alternative 2 is projected
to be done on 140,000+ acres in the next decade, the most of any of the
alternatives. Despite the fact that the RMP may very likely be revised
in the next 10 years, the modeling done was specifically for an
organism/ecosystem that takes centuries to mature. Considering that "a
comprehensive measure of community health and resiliency does not exist"
(DEIS, p.216) and the fact that non-market values like wildlife,
recreation and water quality were not included in the socio-economic
analysis, I urge you to reconsider or revise the preferred alternative,
#2.

Thank you for allowing me to express my concerns,

Vicki Tripoli, PhD

Environmental Scientist

690 Spring Creek Drive

Ashland, Oregon 97520

541 482-0872 or 702 267-7910

vtrip_23@msn.com