To: Bureau of Land Management

From: Elizabeth Brauer

300 Andesite Drive

Jacksonville, OR 97530

\(541\) 899-1223

Date: January 10, 2008

Subject: Comments on WOPR Draft EIS (especially Medford District)

I would like to take this opportunity to make some comments on the
Revision of the Resource Management Plans of the Western Oregon Bureau
of Land Management Districts, Summary Draft Impact Statement, as I
understand it. At the outset, I find myself wishing that there was a
Hippocratic Oath for land managers \-- "first, do no harm."

It is my perception that the proposal of this new management plan is the
consequence of two things:

1)  a court ruling that the 1937 O&C act favors timber harvest as BLM's
    primary objective in managing these lands, and

2)  the favorable attitude towards resource utilization practiced by the
    current federal administration.

It puzzles me why BLM and the public seem to view the 1937 O&C act as if
it were an act of God. It's not. It is an act of Congress, which can be
amended. I urge BLM to construct the BEST POSSIBLE management plan for
the O&C lands, without regard to the primacy of timber harvest, and then
approach the Oregon congressional delegation to amend the act to match
current best land management practices. It is foolish to let the
limitations of 80-year-old thinking lead to irreversible damage to our
public lands.

Furthermore, we all know that in just one year there will be a change of
administration in Washington, D.C. No one knows just what the new
administration's stance will be on land management practices, but it
would also be foolish to establish new regulations that will be out of
date even before they can be implemented.

While I think it is eminently sensible to simply delay any changes until
the two points above are addressed, I also understand bureaucracy
sufficiently to know that selection of a management plan is likely. In
the comments below I will view the environmental consequences of each
alternative through the lens of doing "no harm" to the environment, or
to the human population as well. Where harm appears to be unavoidable,
the plan that best mitigates that harm is preferable. The best solution
will be the one that best combines these objectives.

# Ecology

Create an alternative that:

-   Does not increase fragmentation in any physiographic provinces

-   Retains legacy trees in "regeneration" harvested areas, given that
    "structurally complex forest develop almost twice as fast," (Summary
    pg LII). It would be foolish not to take this step to speed up the
    cycle of forest regrowth.

-   Examine and/or carry out research into the optimum number of legacy
    trees to be retained for most rapid regeneration; adopt this number
    in the WOPR.

# Socioeconomics 

It was instructive to look at Figure 2, *BLM projected county payments
compared to historic payments*. Payments under Alternative 1 would be
approximately the same as in the period from 1985-1987; for the No
Action Alternative the payments would be about 1/3 less.

Since moving back to Oregon in 2003 all I have heard is that "the
spotted owl ruined the timber industry." However, the earliest records I
can find for environmental protection of the spotted owl are 9/11/1987
\[90-day petition finding and initiative and status review\], 6/23/1989
\[proposed threatened status for Northern Spotted Owl\] and finally
6/26/1990 \[determination of threatened status for Northern Spotted
Owl\]. Assuming that county payments directly reflect timber harvest,
timber harvest went sharply upwards at the time the owl was listed and
has only gradually fallen since then (year 2000 data) to about the level
in 1985-1987. Also assuming that employment is proportional to timber
payments, one can assume that the number of timber jobs in 2000 was
about the same as in the later 1980s. It doesn't make sense to me for
the "timber counties" to hope for economic rejuvenation based on timber
harvest. Even if more timber becomes available to harvest, the reduction
in demand for plywood, coupled with the current precipitous drop in the
construction business, will slow the operation of mills and production
facilities in southwestern Oregon regardless.

It makes more sense for there to be a stable and sustainable number of
timber jobs to support local economies. At the same these communities
would do well to focus on creating infrastructure and a workforce that
will attract new, "knowledge-based" industries to generate additional
jobs at the "family wage" level. Replacement revenue for counties would
be generated from these new businesses and expanded payrolls.

# Timber

If, as you say, more timber harvesting is required in order to comply
with the 1937 O&C Act, then Alternative #1 is preferable, as it excludes
the larges percentage from the harvest land base. I do, however,
question the necessity to comply with the O&C Act, as written (see
above).

With respect to total allowable sale quantity, Alternative #1 is
preferable if one accepts that harvest must be increased. Alternative #1
also extends both the time and amount of volume from thinnings from
nonharvest land, thus providing the stable and sustainable employment
for forest industry workers mentioned above.

# Botany

It is imperative to choose or create an alternative with the absolute
minimum risk of losing plant populations or extirpating the species
altogether. It is a long-held principle of ecology that the more diverse
an ecosystem is, the healthier it is.

# Invasive Plants

Invasive plants have huge potential to harm native ecosystems. Wherever
there are roads and vehicles, weed seeds are rapidly transported. None
of the alternatives appear to propose any plans for limiting and
controlling non-native species invasion attendant on timber harvesting
activities. No timber harvesting activities should be undertaken until
such plans are put in place. At the very least keep the area at risk to
a minimum and away from riparian areas.

# Wildlife

Please recall the precept of doing no harm. If the habitat needs of
species along riparian streams would be not be met under Alternatives #2
and #3, then these alternatives should not be considered. Furthermore,
since the habitat needs of forest-floor-associated species would be at
risk of decline under any of the three action alternatives, none should
be undertaken.

With respect to the Marbled Murrelet and Northern Spotted Owl, the No
Action Alternative clearly provides the largest amount of suitable
habitat in a timely way for these species, and Alternative #1 is a poor
second choice.

# Fish and Water

The best protection for both fish and waterways is to retain or even
increase the preservation of riparian areas. This means no timber
harvesting and no road building, so that there are [no]{.underline}
increases in sediment and [n]{.underline}o increases in temperature. You
say that the best way to decrease fine sediments is by improving and/or
decommissioning roads, but I do not see these actions included as part
of the WOPR. They should be mandated.

# Fire and Fuels

Fire resilience is greater in forests with structural legacies, so it is
of utmost importance to retain structurally complex forests so that fire
severity and hazards do not increase. The monetary gain from increased
timber harvest could be wiped out in a few days if there were more
severe fires as a result.

Furthermore, the Applegate (and perhaps other) resource management areas
should be retained because fire and fuel issues are being addressed
locally. As you know, BLM is participating in the Fire Learning Network
process in the Applegate, and no changes should be made while this
research and planning process is underway.

# Recreation

In the WOPR DEIS summary, the only recreational use mentioned is by
off-highway vehicles. How strange. What percentage of the population are
OHV users and why are their needs considered when the needs of the many
walkers, hikers, campers, hunters, fishermen, photographers, bird
watchers, snow shoers, cross country skiers, students of wildflowers and
natives plants, students of indigenous cultures, nature lovers and
solitude seekers are ignored? It is sad but true that OHV use is
incompatible with any of these other recreational uses of forest lands.
It is also indisputably true that OHV use damages land. BLM lands in the
Medford district have recently been closed due to OHV damage. It is
BLM's job to "first do no harm."

Granting that the lands are public lands, some specific, limited areas
should be set aside for OHV use. I concur with Jackson County
Commissioner Dave Gilmour's recommendation of the three areas to be
designated for OHVs. Given the budget reductions BLM has experienced,
enforcement will be difficult so before any lands are opened, I hope
there will be a period of public education, and very clear signage so
that conflicts can be minimized.

# Wilderness Characteristics

All existing wilderness must be retained. It is an irreplaceable
resource. Once again, the overriding principle is to do no harm.

# Visual Resource

Once again, please "do no harm." As Alternative 1 would maintain
existing visual resource quality on the greatest portion of BLM lands
within the planning area, it is to be preferred.

# Other Characteristics

There appear to be few identifiable differences among that plans with
respect to other characteristics mentioned in the summary.

Thank you for your attention to these comments.