**U.S. Bureau of Land Management\
Western Oregon Plan Revision\
P.O.B. 2965\
Portland, Oregon 97208**\
\
**Comments on the Draft Environmental Impact Statement**

The Chemeketans is a hiking and outdoor recreation club with
approximately 800 members, established in 1928 and based in Salem,
Oregon. Many of our members have a strong interest in matters of natural
resource conservation. We recognize the tremendous effort that goes into
the creation of an Environmental Impact Statement. Please accept these
comments in the spirit with which they are given. We are public citizens
that care deeply about our communities and our public lands, and we
trust that our criticisms will be taken as a serious and respectful
attempt to maximize the public good.

The Chemeketan Conservation Committee strongly opposes the preferred
alternative presented in the Draft Environmental Impact Statement. We
find that all the numbered alternatives are highly skewed toward
resource extraction, and we cannot support any of the alternatives
presented in the DEIS other than the No Action Alternative.

The vision statement for the Western Oregon Resource Management Plan
Revisions lists these two basic supporting principles:

Natural resources can be managed to provide for human use and a healthy
environment.

Resource management must be focused on ecological principles to reduce
the need for single resource or single species management.

As specifically stated in your documentation, the goals of the current
project have not changed. It is therefore quite remarkable that the plan
proposed is so different from the 1994 Northwest Forest Plan. The
revision is clearly designed to increased timber resource extraction,
while discounting detrimental effect on other forest values. Both
late-succession reserves and riparian areas, which were protected from
harvest in the 1994 Northwest Forest Plan, are whittled down drastically
to increase the potential timber harvest. We find this approach to be
unacceptable -- driven by rather transparent political considerations
that place economic extraction above other forest values - and not sound
forest management principles.

In the preface to the DEIS, p. XL, it is stated: "This document
acknowledges the primacy of O&C Act in regards to the management of
timber resources." We find no convincing justification for that
statement. Neither do we agree with BLM's apparent underlying
interpretation that the O & C Act elevates timber extraction above
sustainable multiple-use forestry.

**Ownership, Fragmentation, and Habitat Preservation**

We realize that the checkerboard nature of BLM ownership in western
Oregon can make forest management complex and frustrating. Lands in
private ownership are understandably subject to far fewer restrictions.
BLM lands must make up the difference when it comes to multiple forest
uses, since adjacent privately held lands are almost entirely dedicated
to maximizing timber production. The unnatural fragmentation makes it
difficult to manage for habitat, but that is no excuse for ignoring that
critical aspect of our forests, as mandated in the Endangered Species
Act and other pertinent legislation.

It has been said that we can live without old-growth forests, but that
is clearly not certain. Extensive logging worldwide has contributed to
the precarious state of our earth's biosphere, and we are as guilty here
in Oregon as are those in countries such as Brazil and Borneo. To
protect remaining habitat, even as it exists in its current chopped and
diced state, is important to all of us. It should be clear that the
general public, our representatives at the state and federal level, and
the courts in general all value our remaining ancient forests and favor
its preservation.

Certainly protecting a few remaining impressive old-growth groves is
important, but it is akin to maintaining leopards in zoos while allowing
them become extinct in the wild. Protecting virtually all remaining
old-growth forest habitat, as was accomplished with the Northwest Forest
Plan of 1994, was the right thing to do. All of the alternative WOPR
proposals are transparent attempts to sidestep that progressive
agreement. Mature forest habitat must be preserved on a much larger
scale than would result from implementation of any of the WOPR
alternatives.

**Trails and Recreation**

It is disappointing that BLM has not provided for more non-motorized
recreational opportunities on its western Oregon holdings. The reasons
can only be guessed, but the lack of existing opportunities is not an
excuse for reducing or eliminating the potential for such opportunities
in the future. Chemeketans favor low-impact recreational use of our
public lands. We object to placing a greater emphasis on motorized
recreational uses of BLM lands and favor a greater emphasis on uses that
are less disruptive to the natural setting.

Increased logging (an almost tripling of the harvest in Option #2) and
road building (possibly 600 miles of new roads) reduces the potential
number and length of trails as well as the quality of the hiking
experience.

**Soil Erosion, Landslide, and Blowdown Potential**

Increased clearcut logging and the reduction of stream buffers will
certainly increase the likelihood of landslides which can potentially
destroy recreation opportunities important to our members. Both existing
opportunities and the potential for future trails will be severely
impacted. Landslides can also severely impact downstream water quality
and salmon spawning success. Increased siltation is often associated
with logging, especially when streamside buffers are narrowed or
eliminated. The DEIS does not adequately address these issues.

We are particularly concerned about the effect of storm winds causing
large blowdowns as the edge/volume ratio of remaining uncut forests
increases. Given the fragmentation due to land ownership, this becomes
an area of critical concern that can lead to heavy wind damage to
remaining habitat ostensibly protected under the plan. As unlogged
ancient reserves become smaller and less protected (and thus more
precious), the potential for loss of nesting habitat for the Northern
Spotted Owl and Marbled Murrelet due to unforeseen blowdown increases,
thus jeopardizing recovery efforts.

The possibility that the number and severity of Pacific storms is
increasing due to global climate change should not be ignored in your
analysis, as these storms can severely impact endangered species if
nesting habitat is already precariously low.

The contribution of these forests as a carbon dioxide sink is only now
becoming apparent and should be addressed.

**Modern Balanced Forestry**

Given what has been learned during the past 30 years, it seems that the
proposed plan (and particularly the preferred alternative) is a long
step backward. In many ways, from fire suppression to landslide impact
to the importance of habitat diversity, the DEIS seems to ignore much
that has been learned over the last few decades relating to forest
health.

Of the three alternatives presented in the DEIS, the preferred
alternative (#2) maximizes timber harvest while also maximizing the
negative impact on other, non-timber resources. Claims that the
preferred alternative will have minimal and acceptable effect on
erosion, siltation, stream temperature, fish habitat loss and reduced
habitat for the Northern Spotted Owl, Marbled Murrelet and other forest
dependent species is absurd on its face. Timber harvest may have been
front and center in the 1930's when these lands reverted to public
ownership and much of Oregon's forested landscape remained pristine. But
even the Oregon and California Lands Act of 1937 was an attempt to
implement sustained-yield forestry. Seventy years later, we are more
sensitive to the complexities of this natural resource, and additional
laws now apply. Our courts have found and will continue to find that
resource extraction has its limits is not to take precedence over other
equally important factors.

Sustainability is a goal often touted in your forest plans. A forest
plan that does not provide for stream quality, adequate wildlife
habitat, and human uses other than timber production is on its face
unsustainable and will not stand legal scrutiny. Considerable economic
value may be found in previously roaded and logged stands, particularly
through focused thinning. And certainly value increases every year as
timber matures. But pre-assigning a timber harvest quantity to the land
and then designing a plan around that expectation is clearly not an
approach predicated on sustainability.

We strongly oppose all three of the alternatives because none of
them result in a healthy and sustainable forest ecosystem. The last
remaining stands of old-growth timber should be preserved for wildlife
habitat, water quality, and the enjoyment of hikers and other
non-motorized users.

Massive effort and public input, including input from the Chemeketans,
helped to develop the 1994 Northwest Forest Plan. As public policy the
plan has been quite successful, generally satisfying the concerns of all
interested parties except those focused on monetary considerations.
Although extraction goals have not been met, it can also be argued that
damage from landslides, fire, blowdown, and degraded stream quality and
wildlife habitat remains too common. The balance provided by the current
forest management plan is reasonable and important to maintain, and
should not be discarded to placate short-term and short-sighted economic
interests. In our view, the only reasonable course of action is to
reject all three alternatives presented in the DEIS and continue to work
within the guidelines of the plan now in effect -- the No Action
Alternative.

Thank you for the opportunity to comment.

Sincerely,

George Adkins, Chair

Conservation Committee

Chemeketans

P.O. Box 864

Salem, OR 97308