**To the Bureau of Land Management:**

I am an independent non-vascular plant surveyor, working throughout the
BLM lands of Oregon for the past 17 years. I am not able to respond to
everything in the DEIS, but the following are some comments on things
that seem the most important to me.

**Overall Premise**

I believe that the overall premise of the Alternatives is wrong, and as
someone who spends much time and earns her livelihood from these
forests, I must speak my mind.

First, the DEIS states, \"it is clear that the management of timber is
the dominant use of the O&C lands in western Oregon\"(p12). However, the
DEIS also states, \" \... the O&C Act \...does not establish a minimum
level of harvest or a minimum level of receipts.\" I think that although
the State of Oregon needs to generate revenues for County and State
needs, that does not mean that we must overharvest our forests. I think
the BLM needs to make plans for true sustainability, without looking the
money that could be gotten from short-sighted harvest.

Once these sustainable levels have been set, then the state must
establish other ways to bring revenues up to its needs. We have seen
before, with the collapse of the timber industry in the 70\'s, that
people will complain that we aren\'t harvesting enough. I believe that
no matter what level we harvest, similar complaints will be forthcoming.
We have seen that with all the effort put into the Northwest Forest
Plan, that we were not able to harvest the quantities of timber we
expected. Now is the time to reassess our natural resources, and state
clearly what we can expect to harvest without destroying our state.

**Stream Buffers**

The alternatives do not offer a viable option for management of riparian
areas. All three alternatives would narrow the buffers for riparian
areas. There are several reasons why I feel this is not appropriate.
First, we are facing global warming. This means that the alternative
chosen must address gradual increases in temperatures, and the increases
will continue for an unknown amount of time. The buffers required right
now are not enough in the current climate. \"The most common listing on
BLM lands is for water temperature\" (DEIS, p. 365).

In addition, my experience over years of surveying tells me the number
of mature trees that are now required to be left along a stream buffer
in an old-growth area does not provide enough shade to keep riparian
species in good health. I routinely see riparian shrubs overexposed to
sunlight and stunted in growth. Often after timber harvest, mature trees
in the buffer zone fall due to edge effect, leaving even less buffer.
Although the DEIS provides information about how many trees are
necessary to provide shade for streams (p369), I think there are many
more factors involved, including slope of the adjacent land, and the
fact that historical riparian forests cannot be viably compared to
single-species plantations.

In Chapter 3 of the DEIS, it is stated (p359) \"Streams that occur on
BLM lands are mostly smaller, headwater streams that are important to
determining the condition of larger streams and rivers.\" So not only
should we maintain the current buffers, but we must find a way of
providing more protection and \"cooling power\" with the buffers. In all
probability, widening buffers, enforcing the current laws on buffers,
and enhancing buffer vegetation are what is most needed to maintain
stream health. The idea of low-lying land adjacent to streams providing
a cooling buffer, not just shade, has not been addressed in the DEIS.
Such wider areas capture cool night time temperatures and high humidity
and hold them in low-lying land around streams.

Another problem with narrowing the buffers is maintenance of riparian
humidity. Riparian species require high humidity, and narrowing buffers
destroys this microenvironment. The result of lowering humidity may be
difficult to observe or measure. Some of the results are lowering
diversity of vascular plants species, bryophyte and lichen biomass and
diversity, especially in cyanolichens. Cyanolichens are very sensitive
to high light levels and low humidity, and they require protection from
these extremes throughout the year. All of the organism groups mentioned
are important to forest management. \"Vascular plants are generally
associated with an ecological feature that narrows their potential
habitat\"(DEIS p. 258). Bryophytes retain water as soil cover and as
epiphytic mats for longer than those surfaces without the bryophytes.
This creates a water sink as well as slowing water runoff, both of which
are important for forest health. Cyanolichens are an important source of
nitrogen for forests, especially old-growth forests.

In addition, retaining current buffers or enlarging them would prevent
sedimentation of streams and rivers. The farther away disturbance is
from stream channels, the less sedimentation will occur.

Although the Alternatives are trying to provide more timber to harvest,
watershed protection is far more important than providing timber. The
BLM as managers of huge amounts of public land must take a stand and
protect the public\'s resources from groups making short-sighted or
unreasonable demands.

**ACEC\'s and other Protected Areas**

In general these have been set aside or proposed because they are
valuable areas retaining some part of the natural ecosystem, usually a
vegetation type that is rare or unusual. They are proposed and
established by foresters and ecologists who know the surrounding area
and recognize the intrinsic value of these small areas. ACECs should be
retained, and more added, not taken away. Once destroyed, they will not
be able to regenerate for far longer than the scope of forestry
planning.

**Old Growth**

Structurally complex, old-growth forests are not protected enough under
any of the three alternatives. The new plan must be structured to allow
for sustained yield over the long term, not just the next 10 years, or
60 years. These time frames do not allow for sustainable yield of
old-growth, which takes over two hundred years to grow. We must keep in
mind the fact that if the old-growth trees are cut, some part of the
plan must provide for periods as long as 600 years of growth to replace
these forests. I feel a much better alternative is to leave the
old-growth forest alone and work with what has already been cut, using
more resourceful management to provide for our wood products.

**Alternatives to Timber**

I believe that we can do much more to gain revenues from truly
sustainable use of forest lands by creating in Oregon a national
recreational destination, and by managing and licensing alternative
forest products. Markets can be created for more products, and more
careful monitoring of these harvests can lead to more forestry jobs as
well as providing good baselines for harvest.

Thank you for the opportunity to comment on our land.

Daphne Stone

30567 Le Bleu Rd.

Eugene, OR 97405

stone_daphne@hotmail.com