1

Scoping Report for the Government Camp – Cooper Spur Land Exchange Project 

Scoping letters received between February 16, 2016 and March 17, 2016 

Table 1. List of respondents from the scoping period (February 16, 2016 to March 17, 2016).

Letter # Respondent Letter # Respondent

1 Jeff Kohnstamm, RLK and Company 9 Barbara Wilson, Vice-Chair of the Friends of Mt. Hood

2 Art Carroll 10 Tonya Moore, Assistant District Biologist for the North 

Willamette Watershed District

3

Russell Pascoe, Conservation Chair of the Lower 

Columbia Canoe Club 11 James Howsley, Attorney

4 Janine Blaeloch, Director of the Western Lands Project 12 Kathleen Sloan, Confederated Tribes of the Warm Springs

5 Brenna Bell, Staff Attorney of Bark 13 Mike McCarthy

6 Kris Nelson 14 Heather Staten, Hood River Residents Valley Committee

7 Hugh McMahan 15 Ralph Bloemers (Crag Law) 

8

Lee Kreutzer, Cultural Resource Specialist/Archeologist 

for the National Park Service 16 Scoping comment letters received in 2010

Table 2. Preliminary remarks on scoping comments received February 16, 2016 to March 17, 2016.

Letter # Subject Comment Preliminary Remarks for DEIS Development1

1.0 Appraisal

Thank you for the opportunity to comment on the Government Camp - Copper 

Spur Land Exchange between the Forest and Mt. Hood Meadows Oregon LLC. 

Consistent with our stance all along, RLK and Company, owners of Timberline 

Lodge wholly supports it taking place. Also consistent with our support is our 

continued concern that a fair and accurate appraisal of comparable properties be 

made in the land swap process. We want to ensure that the government’s 

appraised values reflect recent land transactions and current commercial real 

estate value in the Government Camp area. It will be very important to local 

business and home owners that the valuations used to calibrate the land 

exchange are realistic, and that they don’t undermine their own investments.

Thank you for your continued support with this 

project. The appraisals will be based on specific 

federal appraisal standards and conducted by a 

qualified, licensed appraiser. The Uniform Appraisal 

Standards for Federal Land Acquisitions requires that 

appraisals are based on market value for the highest

and best use of the property. In one approach to value, 

relevant sales are analyzed, compared with the subject, 

and considered in an appraiser's value conclusion. 

 

1 As stated in the Forest Service Handbook 1909.10, Chapter 10, the results of scoping can assist in selecting an interdisciplinary team, refining the proposed 

action, identifying preliminary issues, and exploring possible alternatives and their probable environmental effects. To help serve those purposes, this 

document was initially created in April 2016 and first presented to the Interdisciplinary Team for discussion in June 2016; since that time, it has been subject to 

minor revision and was available for use and periodically referenced by the Interdisciplinary Team during development of the DEIS.
2

Letter # Subject Comment Preliminary Remarks for DEIS Development1

2.0 Easements

When these lands are conveyed the documents of the various special use 

permits for utilities, storage tank, etc. “would be converted into easements.” 

Who is the holder of these easements? Does the USFS administrate those 

easements or does that responsibility transfer to the new owner?

Once the land is conveyed and the land exchange is 

complete, Clackamas County will be the holder of the 

easements (with the exception of the wetland 

conservation and trail easements), and they will be 

responsible for administering them.

2.1 Facilities at 

Cooper Spur

Does the USFS really want to take on being administratively responsible for all 

these base area facilities and structures many of which will likely need upgrade 

one?

The facilities at Cooper Spur will be analyzed in the 

DEIS. Currently, as part of the proposed action, the 

Forest Service is proposing to issue a special use 

permit per regulations at 36 CFR 251 to authorize the 

use of these facilities. The proposed action will also 

analyze decommissioning the site if there is no interest 

in obtaining a special use permit to maintain and 

operate the Cooper Spur Ski Area and Resort. 

2.2 Forest Plan 

Amendment

The Forest Plan does not specifically address non-federal areas to be acquired. 

Given that the exchange has been talked about for years the Forest Plan should 

be amended to adopt criteria to be used in possible purchase or exchange of 

lands outside of National Forest ownership. It is not normal for any Forest Plan 

to convert lands outside the National Forest boundary, but in this case it is part 

of a significant proposal. With an amendment with approved criteria for 

acquisition/exchange of any lands outside the existing National Forest boundary 

would help the District Ranger and Forest Supervisor to indicate what does fit 

National Forest administration and what doesn’t fit. Hopefully, this criteria 

would create a better balance of public lands for the forest versus being put in a 

place of accepting lands with significant administrative costs vs. acquiring some 

acres to enhance the National Forest for the long haul.

While we appreciate this perspective, a Forest Plan 

amendment of this nature would be very difficult to do 

for several reasons. First, land exchanges are unique 

and situational; therefore, it would be difficult to 

prescribe Forest Plan direction for an action where the 

location and circumstances directing the exchange are 

not yet known. Second, land exchanges are directed by 

factors outside of Forest Plan direction; therefore, it 

would be difficult to predict what management 

direction would be prescribed by the exchange. In 

sum, a Forest Plan amendment of this type would be 

very difficult to write as it would be too speculative. 

For example, this land exchange is the result of 

legislative action and includes specific provisions for 

how the land acquired should be managed (e.g., 

designation of the Crystal Springs Watershed Special 

Resources Management Unit).

2.3 Acquired 

Lands

The lands to be acquired should automatically become part of the area where 

they are located without further action. This is a good stroke!

Yes, acquired lands typically take on the management 

direction of those Forest Service lands that are 

adjacent to them (36 CFR 254.3(f)). However, the type 

of management prescribed by Congress in the 

Omnibus Act is different from the management 

direction of the adjacent lands; thus, a Forest Plan

amendment is proposed as part of this project and will 

be fully described in the DEIS.
3

Letter # Subject Comment Preliminary Remarks for DEIS Development1

2.4 Forest Plan 

Designations

The Forest Plan Standards and Guidelines for the Cooper Spur Ski Area and 

Crystal Springs Watershed all make sense as proposed.

Thank you for your support. All of the proposed 

Forest Plan management direction will be discussed in 

the DEIS.

2.5 Forest Plan 

Designations

It is sensible management direction to allow “certain types of fuel reduction and 

forest health management treatments.” I support the stated goal for the Cloud 

Cap-Tilly Jane area. I support the stated goal of the Cooper Spur Ski Area and 

Crystal Springs Watershed. I support the proposal/existing management 

direction as presented under the Northwest Forest Plan and the Non-federal 

lands to be acquired. It might help to specifically define “Matrix lands.”

Thank you for sharing your perspective. All of the 

proposed Forest Plan management direction will be 

discussed in the DEIS.

3.0 Timing of

the EIS

Your recent letter asked if the Lower Columbia Canoe Club has additional input 

to the USFS for the EIS on the Government Camp-Cooper Spur Land 

Exchange. Our only input is that the EIS and exchange should have been 

completed long ago. Please proceed as hastily as possible to complete the 

Exchange.

Thank you for your input. The Forest Service has been 

dedicated to implementing this exchange and 

continues to work hard to see the project completed.

4.0 Land 

Exchanges

For a variety of reasons, the Western Lands Project generally opposes land 

exchanges proposed through legislation rather than the agency process. We 

particularly strongly object to this exchange on the basis that it was conceived 

by private interests—the Hood River Valley Residents Committee and Mt. 

Hood Meadows— for their mutual benefit, and did not originate from an 

intention to improve public land management to serve the public interest. In 

fact, we believe that acquisition of the Cooper Spur ski area and its aging 

infrastructure is substantially counter to the public interest.

While we appreciate the perspective of the Western 

Lands Project, the Forest Service is responsible for 

implementing the direction stated in the Omnibus Act. 

In regards to the public interest, the agency will 

analyze the factors related to the public interest in the 

FEIS consistent with the regulations at 36 CFR 

254.3(b)(1). The analysis will also be informed by 

relevant direction in Forest Service Handbook 

5409.13, Chapter 30, Section 33.41b, which states: 

“The authorized officer has the responsibility to 

determine if the proposed exchange serves the public 

interest (36 CFR 254.3 (b)(2)) and supports the 

direction and guidance in the forest land management 

plan. Factors that must be considered in a public 

interest determination for a proposed land exchange 

are listed in Title 36, Code of Federal Regulations, 

section 254.3(b)(1) (36 CFR 254.3(b)(1)). The public 

interest determination must show that the resource 

values and the public objectives of the non-Federal 

lands equal or exceed the resource values and the 

public objectives of the Federal lands and that the 

intended use of the conveyed Federal land would not 

substantially conflict with established management 

objectives on adjacent Federal lands, including Indian 

trust lands.” 
4

Letter # Subject Comment Preliminary Remarks for DEIS Development1

4.1 NEPA and 

FLPMA

Both the environmental analysis under the National Environmental Policy Act 

(NEPA) and the public interest determination under Federal Land Policy & 

Management Act (FLPMA) will be useful in clarifying the consequences to the 

public of this land exchange.

In compliance with FLPMA (and in accordance with PL 111-11 Section 

1206(a)(2)(B)), please provide a detailed public interest determination.

The DEIS will analyze the social, economic and 

environmental impacts of this project per NEPA 

regulations. Also, a public interest determination will 

be included in the FEIS, pursuant to Title 36, Code of 

Federal Regulations, section 254.3(b)(1) and in 

accordance with section 206 of the Federal Land 

Policy and Management Act of 1976 (43 U.S.C. 

1716).

4.2

Altering or 

Declining the 

Land 

Exchange

In the section addressing laws and regulations applicable to the exchange, we 

request that you include a discussion of the meaning of Public Law 111-11 (i.e., 

Omnibus Act) Section 1206(a)(2)(C)(ii) in terms of the extent this language 

gives the Secretary of Agriculture discretion to alter or decline to implement the 

exchange.

As required by NEPA, the DEIS will include a No 

Action Alternative. However, although Section 

1206(a)(2)(C)(ii) provides that the conveyance of 

Federal land and non-Federal land shall be subject to 

such terms and conditions as the Secretary may 

require, this section must be interpreted within the 

context of the purpose of the Omnibus Act which 

directs the United States to implement the land 

exchange. It does not give the United States the 

authority to alter or decline to implement the exchange 

without Congressional approval.

4.3 Appraisals

Should the appraisals determine that values of the public and private land are 

not equal, how will the Forest Service prioritize which federal lands to eliminate 

from the exchange?

The Forest Service and Mt. Hood Meadows have 

provided lists of priority parcels for exchange (as 

documented in a letter signed by Lisa Northrop on 

July 5, 2016). Those choices are reflected in the 

appraisal instructions. The appraiser will first appraise 

all of the federal and non-federal property. If the value 

of the federal and non-federal property is not equal, 

the appraiser will refer to the prioritization schedule 

provided in the assignment instructions for direction 

regarding priorities for conveyance and will value only 

those parcels. If equal values are not possible, the 

Agreement to Initiate states that cash payment may be 

required by either party to equalize exchange values.

4.4 Easements Please provide a discussion of the potential impact the conservation easement 

on the Government Camp lands will have on the market value of the land.

The appraiser will consider the conservation easement 

and analyze how it may affect the value of the federal 

property.

4.5 Existing 

Condition

Please describe in detail the current condition and past management of the 

private lands that would come to the public and the environmental

characteristics that make it desirable or undesirable to bring into public 

ownership.

The historic and existing conditions of the lands to be 

acquired will be described in the DEIS.
5

Letter # Subject Comment Preliminary Remarks for DEIS Development1

4.6 Existing 

Condition

Likewise, please describe in detail the characteristics of the public land and its 

suitability for retention in public ownership or for disposal.

The historic and existing conditions of the lands to be 

exchanged will be described in the DEIS.

4.7 Facilities at 

Cooper Spur

Under the Forest Service Facility Realignment and Enhancement Act, the Forest 

Service is actually selling some properties it cannot afford to maintain in order 

to raise funds to maintain others. What is the current facility maintenance 

backlog in the Mt. Hood National Forest? How will the Forest Service maintain 

or manage the buildings and infrastructure that would come under its 

management after this exchange? Have particular properties been identified for 

future sale in order to raise funds to manage the newly acquired Cooper Spur 

infrastructure? If so, please identify them.

The existing condition for facility management on the 

Forest will be described in the DEIS. Further, the 

facilities at Cooper Spur and how the Forest Service 

intends to manage them will also be discussed in the 

DEIS. For example, as part of the proposed action, the 

Forest is proposing to issue a special use permit per 

regulations at 36 CFR 251 to authorize the use of these 

facilities. However, making decisions regarding other 

properties on the Forest are outside the scope of this 

NEPA analysis. The proposed action will also analyze 

decommissioning the site if there is no interest in 

obtaining a special use permit to maintain and operate 

the Cooper Spur Ski Area and Resort.

4.8 Facilities at 

Cooper Spur

What plans does the Forest Service have for future use and management of the 

Cooper Spur ski area and infrastructure? What is the condition of the buildings 

and fixtures that would come into public ownership?

The existing condition of the facilities at Cooper Spur 

will be disclosed in the DEIS. Currently, the proposed 

action includes proposing to issue a special use permit 

per regulations at 36 CFR 251 to authorize the use of 

these facilities. The proposed action will also analyze 

decommissioning the site if there is no interest in 

obtaining a special use permit to maintain and operate 

the Cooper Spur Ski Area and Resort.
6

Letter # Subject Comment Preliminary Remarks for DEIS Development1

5.0

History of 

the Land 

Exchange

In November, 2010, Bark signed on to scoping comments on this project 

submitted by the Cooper Spur Wild and Free Coalition. We incorporate those 

comments by reference, and submit the following new comments to be included 

in the administrative record for this decision.

Land management of this part of Mt. Hood National Forest has many 

stakeholders: local communities, businesses, outdoor recreationalists, 

conservationists, timber companies, and the Forest Service with its multiple use 

directive. Often these stakeholders have found ourselves in intractable conflicts 

over land management and resource use. However, the land exchange originally 

legislated in 2009 is the result of nearly a decade of struggle, compromise and 

collaboration. This land exchange was one piece in a larger legislative package 

stemming from extensive negotiation between all the invested stakeholders 

including Bark.

Other parts of that package, such as substantive protections for the municipal

drinking watershed and designation of a new wilderness area, will not enact 

until this legislated land exchange is finalized. This was part of the original 

compromise to ensure that all parts of the bill would come to fruition at the 

same time.

Thank you for your comment and sharing your 

perspective.

5.1

History of 

the Land 

Exchange

Now, six years after the Omnibus Bill, the land exchange has still not taken 

place. The municipal drinking water protections have not become enforceable. 

The proposed wilderness is not protected. The hard work of many diverse 

stakeholders has not birthed tangible results.

As an organization committed to sound ecological management of Mt. Hood 

National Forest, we recognize the need for dialogue and discussion between 

all parties and interests. This type of negotiation can be frustrating and, 

honestly, is often ineffective. However, the legislative package that included 

the Mt. Hood Cooper Spur Land Exchange, stands out as a truly effective 

collaboration between the interested parties which is why it is so disappointing 

that the provisions of the bill have not taken effect. The delayed 

implementation of this exchange has caused strain on earnest, valuable

efforts to build relationships between our organization and the agency.

As such, we are glad that the Mt. Hood National Forest chose to re-initiate 

scoping on this project, instead of using its limited resources fighting the 

HRVRC’s Failure to Act litigation. Bark hopes that the agency stays on track 

with this process and completes the land exchange in as expeditious a manner as 

possible.

Thank you for your continued interest in this land 

exchange. 
7

Letter # Subject Comment Preliminary Remarks for DEIS Development1

5.2 Polallie 

Cooper

The scoping notice recognizes that completing the Land Exchange will result in 

the connected action of protecting the Crystal Springs Watershed Special 

Management Unit from road building and logging. The scoping notice fails to 

acknowledge that in the time lapse between when the land exchange should 

have been completed and the present, the Forest Service planned the Polallie 

Cooper Timber Sale, which includes management actions that run counter to the 

language and intent of the 2009 Omnibus Bill.

The intent of this legislation was to permanently protect this important 

watershed and aquifer from the impacts of commercial logging and road 

building that often occur on Forest Service-managed land. While active 

management was not prohibited, it was limited to occur only in the service of 

“protect[ing] the water quality, water quantity, and scenic, cultural, natural, and 

wildlife values of the Management Unit.” Treatments to maintain and restore 

fire-resilient forest structures containing late successional forest structure 

characterized by large trees and multistoried canopies, are permitted as 

ecologically appropriate, with priority given to activities that restore 

previously harvested stands, including the removal of logging slash, smaller 

diameter material, and ladder fuels.

As described in the Draft Environmental Assessment 

for the Polallie Cooper Hazardous Fuels Reduction 

Project on pages 18-20, the Forest believes that the 

project is consistent with the Omnibus Act. Also, 

while we agree that the Omnibus Act states that 

priority will be given to activities that restore 

previously harvested stands, it does not mean that 

activities are restricted only to previously managed 

stands. The primary purpose of the Polallie Cooper 

project is to move the landscape toward more historic 

conditions by restoring forest resiliency. By reducing 

fuel loading and restoring forest structure to historic 

conditions, the project would increase the quantity of 

water available in the watershed, and reduce the risk 

of impacts from wildfire on the quality of water as a 

clean water source for the residents of Hood River 

County. For these reasons, the actions proposed in the 

Polallie Cooper project would not prevent the land 

from its future designation described in the Omnibus 

Act and they would aid in protecting the many 

important ecological and social values associated with 

the area. 

5.3 Polallie 

Cooper

However, while allowing active management in the service of restoration, the 

act specifically prohibits constructing new roads, or renovating of existing nonSystem roads, except as necessary to protect public health and safety, and 

projects undertaken for the purpose of harvesting commercial timber.

Despite the prohibition on road building, the proposed Polallie Cooper Timber 

Sale would construct 1.4 miles of new road and renovate 3.26 miles of 

existing temporary roads in the Crystal Springs Management Unit. Polallie 

Cooper would also log 782 acres of commercial timber in the management unit. 

We incorporate by reference Bark’s Feb. 25, 2015 comments on the Polallie 

Cooper Timber Sale, which contain an extensive discussion of whether the 

proposed action in the Crystal Springs Watershed Special Management Unit 

complies with the intent of the legislation.

As stated above, the Forest believes the Polallie 

Cooper Hazardous Fuels Reduction Project is 

consistent with the Omnibus Act, which allows the 

Forest Service to utilize temporary roads to 

accomplish fuels reduction objectives. As defined in 

36 CFR 212.1, the Forest Service does not consider 

temporary roads to be new road construction since 

these access routes would not be considered part of the 

National Forest System roads or included in the 

agency’s transportation atlas.
8

Letter # Subject Comment Preliminary Remarks for DEIS Development1

5.4 Polallie 

Cooper

The important point for these comments is that because the Forest Service 

delayed completing this land exchange, it created the conditions where the 

protections for Crystal Springs may not be legally enforceable, and then planned 

a project that does not comply with those protections. Bark requests that the 

Forest Service move with all due speed to complete the land exchange so the 

other aspects of the Omnibus Bill are enacted, and delay a decision on the 

Polallie Cooper Timber sale until after the exchange is complete.

As stated above, the Forest believes the Polallie 

Cooper Hazardous Fuels Reduction Project is 

consistent with the Omnibus Act. Further, the need to 

treat conditions in the area that are outside the range 

that historically occurred on the landscape were 

identified in 2006, in the Hood River County 

Community Wildlife Protection Plan (CWPP). In fact,

prior to completing the CWPP, a collaborative group 

gathered for a series of meetings and fieldtrips in 2005 

and 2006 to discuss the need to reduce overstocked 

trees and fuel created by beetle-killed lodgepole pine 

near the Cooper Spur Ski Area. The group agreed that 

although a need for fuel reduction on National Forest 

System lands adjacent to private land exists on a much 

wider scale in the Cooper Spur area, their desire was 

to see a smaller project completed first. Therefore, in 

2008, a year prior to the Omnibus Act, the Forest 

Service completed the DB Cooper Fuel Reduction 

Demonstration Project. 

The Forest Service has been dedicated to 

implementing this exchange and continues to work 

hard to see the project completed.

6.0 Timing

I would like to submit my comments on the Mt. Hood Land Trade that is yet to 

be completed, although the Forest Service agreed to complete the land trade as 

its duty in the settlement of the Cooper Spur-Mt. Hood Meadows case. The 

onus remains: When will the N. Side land trade be completed? Will it be this 

year? If not, I’d like to know about the basis for any delay...as would the 

public.

The land exchange is proposed to occur in 2018 once 

the Record of Decision, exchange agreement, and final 

title opinion have all been completed.
9

Letter # Subject Comment Preliminary Remarks for DEIS Development1

7.0 Background 

information

By way of pertinent personal background, I have been recreating on Mount 

Hood for 45 years as a climber, hiker and skier. Since retiring to the hamlet of 

Mount Hood sixteen years ago, I have hiked and skied 100s of miles on mostly 

the north side of the mountain. I enjoy the solitude of the non-mechanized side 

and was involved with the congressional efforts of the Cooper Spur Wild and 

Free Coalition and the Hood River Valley Residents Committee which 

culminated in the Mount Hood portion of the Omnibus Public Land 

Management Act of 2009 (Omnibus Act). I have been a member of the Hood 

River County Water Planning Group for eight years, and in addition have an 

intense personal interest in the Crystal Springs Zone of Contribution (ZOC), a 

majority of which lies within the Mount Hood National Forest. Crystal Springs 

provides domestic water for more than 25% of Hood River County, including 

my family.

Thank you for your continued interest in the Mt. Hood 

National Forest. 

7.1 Timing

First let me say I am glad the land exchange process has begun, albeit too many 

years, for whatever unstated reasons, after Congress mandated it to start. The 

exchange should be expedited in whatever way possible. My knowledge of 

the land exchange scoping process is confined to the contents of the scoping 

letter and my comments and questions are based on that. 

The Forest Service continues to work hard to complete 

the land exchange, but there are many steps required 

in the process per federal regulations.

7.2

Level of 

NEPA 

Analysis

Having just completed my comments on the draft EA for the Polallie Cooper 

Hazardous Fuels Reduction project two weeks ago, I am left mystified as to 

how and to what end the Forest Service is complying with the NEPA process. 

Logic would indicate that the former project should have been an EIS, not an 

EA. Which brings me to my first question from the first sentence of the Land 

Exchange scoping letter: How and why does a land exchange justify an EIS? 

The scoping letter provides administrative details such as “Lands to be 

Conveyed” and “Lands to be Acquired” but makes no mention of possible or 

probable environmental impacts. The decision to do an EIS begs for an upfront 

paragraph or two of explanation. It would seem a land exchange could be 

accomplished as an administrative action or by a Categorical Exclusion. Either 

would certainly be accomplished in a much quicker time frame and with much 

less expense than an EIS. And if there are, in fact, some potential 

environmental concerns, is not the Environmental Assessment the first step? It 

is unfortunate that the land exchange was not accomplished before the current 

Polallie Cooper Hazardous Fuels Reduction process. See below. 

Based on our preliminary analysis of the potential 

impacts of this project, we believe there could be 

potentially “significant” impacts warranting 

documentation in an EIS (40 CFR 1508.27). For 

example, it has been determined that the project would 

have an adverse effect on a known cultural resource. 

Also, since Northern spotted owl habitat would be 

permanently removed as a result of this project, it was 

concluded that the land exchange may have an adverse 

effect to the Northern spotted owl. 
10

Letter # Subject Comment Preliminary Remarks for DEIS Development1

7.3

Level of 

NEPA 

Analysis

One possible answer to my question above is that the unstated intent of an EIS 

for the Land Exchange is to provide the full evaluation of the environmental 

impacts of the potential B6 treatments on the Crystal Springs Zone of 

Contribution. Is this the case? If so, excellent!

The primary purpose of the project is comply with 

congressional direction to exchange lands, which also 

sets forth two related actions that are triggered into 

effect upon completion of the exchange: the creation 

the Crystal Springs Watershed Special Resources 

Management Unit; and the wilderness addition. 

Therefore, the analysis in the DEIS will include a 

Forest Plan amendment to assign land use allocations 

to the acquired lands and wilderness designation. This 

project does not proposed any “treatments” for the 

acquired lands.

7.4 Forest Plan

I cannot find a “Watershed Special Resource Management Unit” in my copy of 

the 1990 Mount Hood National Forest Land and Resource Management Plan, so 

assume this was a special designation created for the Crystal Springs ZOC by 

the Omnibus Act, which also included paragraphs on Purposes, Administration 

and Prohibited Acts.

Yes, the Omnibus Act created the designation for the 

Crystal Springs Watershed Special Resources 

Management Unit and therefore is not included in the 

1990 Forest Plan. Because this designation does not 

currently exist in the Forest Plan, the proposed action 

includes assigning management direction for the 

Crystal Springs Watershed Special Resources 

Management Unit. The Forest Plan amendment will be 

discussed in detail in the DEIS.

7.5

Management 

Area 

Direction

It seems puzzling that the ZOC land use allocation is being immediately 

changed upon the consummation of the exchange from the Crystal Springs 

Watershed Special Resource Management Unit to a B-6 Special Emphasis 

Watershed, especially when the B6 Standards are being retooled, or added to, 

to reflect the mandates of the Omnibus Act. The B6 Special Emphasis 

Watershed standards and guidelines were written for surface water sources, not 

groundwater spring fed sources. This is an important distinction which should 

be recognized with a land use allocation classification with its own unique 

standards and guidelines tailored, in this case, to the Crystal Springs ZOC. 

There are other spring fed sources with some of their ZOCs on Forest Service 

lands such as the City of Hood River and possibly the Ice Fountain Water 

District. Therefore, a designation such as “Crystal Springs Zone of 

Contribution Special Resource Management Unit” would be appropriate, if 

not done, retain Crystal Springs Watershed Special Resource Management Unit. 

The Bull Run Watershed has its own designation, also created by legislative 

action, so a designation for special circumstances or conditions is not 

unprecedented.

The Forest Plan’s management direction for Special 

Emphasis Watershed (B6) is most similar to the 

designation set forth in the Omnibus Act. Although it 

does not wholly meet the management direction 

prescribed by Congress in the Omnibus Act, this land 

designation was used as a starting point for further 

establishing the management direction for the new 

land allocation. Further, the Omnibus Act directs the 

area to be known as the “Crystal Springs Watershed 

Special Resources Management Unit; therefore, upon 

completion of this project, the area will be referred to 

as such and reflected in the Forest Plan. 
11

Letter # Subject Comment Preliminary Remarks for DEIS Development1

7.6 Omnibus 

Act

Unfortunately, there is a very wide latitude between the Omnibus Act’s Section 

1205, (a) Crystal Springs Watershed Special Resources Management Unit, 

paragraph (2), Purpose (A) “to ensure the protection of the quality and quantity 

of the Crystal Springs watershed as a clean drinking water source ...” and the 

stipulations in paragraph (4) Administration and paragraph (5) Prohibited 

Activities. As described in the scoping letter, it appears that these stipulations 

have been carried over to the B6 category and depending on interpretation could 

lead to activities very detrimental to Purpose (A).

Thank you for your comment and sharing your 

perspective.

7.7 Omnibus 

Act

I am very uncomfortable with the standards language, coming mostly from the 

Omnibus Act, of the B6 for the Crystal Springs ZOC:

- B6 Goal, quoted on fourth paragraph, page 5 of scoping letter: “A 

secondary goal is to maintain a healthy forest condition through a variety of 

timber (italics mine) management practices.” What exactly does that mean on 

the ground? 

- Standard B6-030, page 5: “...new road construction and renovation 

of existing non-System roads shall only be permitted to protect public health 

and safely (sic).” (Italics mine). What, exactly, does “to protect public health 

and safety” mean or allow in this context? 

- Standard B6-018/B6-019: “Regulated timber harvest shall not occur, 

other than activities related to the harvest of merchantable products that are 

byproducts of activities conducted to further the designated purposes (italics 

mine) of the Crystal Springs Watershed Special Resource Management Unit.” 

B6-042 also refers to the designated purposes of the CWSRMU. It is assumed 

these purposes are (A) and (B) from the Omnibus Act. To me these standards 

say “timber harvest/pesticide applications shall not occur except when they do!”

Unfortunately, the final version of the Omnibus Act contained loopholes big 

enough to drive a logging truck through.

Analysis in the DEIS will describe the goal, as well as 

Standards and Guidelines, of the Crystal Springs 

Watershed Special Resources Management Unit. 

Language in the proposed Forest Plan amendment will 

reflect the language in the Omnibus Act. For example, 

the DEIS should include in the description of the 

Forest Plan amendments that the Omnibus Act 

specifically states, “the Secretary may conduct fuel 

reduction and forest health management treatments to 

maintain and restore fire-resilient forest structures” 

(Section 1205(a)(4)(B)).
12

Letter # Subject Comment Preliminary Remarks for DEIS Development1

7.8 Timber 

Harvest

Many, myself included, believe adamantly that there should be no 

commercial/mechanized logging in/on the Zone of Contribution. Period. 

The known risks of logging (fuel spills, road building, soil erosion and 

degradation, loss of canopy, etc.) exceed the risks of a potential wildfire as 

hydrologist Ed Salminen’s April 27, 2006 report to the Crystal Springs Water 

District entitled “Likely effects of catastrophic wildfire on Crystal Springs water 

quality and quantity” concludes. In my opinion, ladder fuels reduction should 

be carried out with hand crews or horse logging. There are studies dealing 

with the impacts of wildfire on watersheds (surface water sources), however to 

my knowledge, other than Salminen’s report, minimal work addresses wildfires 

on groundwater spring fed sources. Therefore, the Precautionary Principle and 

Primum Non Nocere (First, do no harm) should prevail until such time as we 

know more about the impact of wildfire on ground water sources. Hopefully, 

the Crystal Springs ZOC will never be a case study (the 2008 Gnarl Ridge Fire 

and the upper elevations of the ZOC’s Zone 3 not withstanding).

The proposed Forest Plan amendments for the Crystal 

Springs Watershed Special Resources Management 

Unit will be consistent with the direction outlined by 

Congress in the Omnibus Act. The effects from project 

proposal will be addressed in the project-specific 

analysis using the best available science. 

7.9 Polallie 

Cooper

Hood River District Ranger Tervo will be coming out with the Polallie Cooper 

Hazardous Fuel Reduction project final EA and her decision sometime this 

summer and the draft EIS for the Land Exchange is due out in November. Will 

a moratorium be placed on any activities on the Crystal Springs ZOC 

resulting from the Polallie Cooper decision until the Land Exchange EIS 

and process has been completed? 

As previously stated, the Forest believes that the 

Polallie Cooper Hazardous Fuels Reduction Project is 

consistent with the Omnibus Act.

7.10 Questions

I intend to be involved with all the commenting opportunities associated with 

this Land Exchange process and wish to be educated and informed in so doing. 

Accordingly, would you or one of your staff please reply to this letter 

answering my three main questions: 1) How and why an EIS vs. 

administrative action or CE, 2) Is the EIS being done for the Crystal 

Springs ZOC? and 3) How will any discordance (in timing and/or findings) 

between the Polallie Cooper EA and the Land Exchange EIS be handled?

The Forest Service has been in contact with the 

commenter to answer his questions as best as possible. 

Also, responses to these questions are included in the 

responses above.

8.0 Mailing List

The National Park Service asks that National Trails Intermountain Region,

which administers the Oregon National Historic Trail, be added to the contact 

list for this project.

The NPS will be added to the mailing list for this 

project.
13

Letter # Subject Comment Preliminary Remarks for DEIS Development1

9.0 Background 

Information

Friends of Mount Hood, founded in 1988 to protect Mount Hood from rampant 

urbanized development, expresses its strong support for the proposed land 

exchange between the Forest Service (120 acres next to Government Camp) and 

Mt Hood Meadows (770 acres of privately owned land on the north side of the 

mountain). The land exchange proposal was approved by Congress as part of 

the 2009 Mount Hood Wilderness bill. Although the Forest Service was directed 

to fulfill certain responsibilities within a 16-month period, seven years have 

elapsed, and the Forest Service has not completed the exchange. We urge the 

Forest Service to move ahead with this proposal, with diligence.

Thank you for your interest in the exchange; the Forest 

Service continues to work diligently on the project.

9.1 Background 

Information

As you are aware, Government Camp is an already urbanized area of Mount 

Hood. Condominium development would potentially be appropriate at that 

location. Much of Mount Hood is already logged and developed. The 

undeveloped areas on the north side require protection. This is an opportunity 

to protect some still undeveloped sections of the forest, for use by future 

generations. 

Because of Mount Hood's close proximity to Portland, it is vulnerable to the 

public's propensity to "love it to death." There is public demand for the 

protection of the natural beauty, the hydrology, biology, and ecological 

attributes of the mountain. Areas like the north side of Mt Hood are becoming 

more and more scarce as the population and recreation needs increase and such 

areas need protection from development.

Thank you for your comment. 

9.2

Crystal 

Springs 

Watershed

Two thousand acres of the Crystal Springs watershed are included in the 

proposed land exchange. The watershed provides drinking water for a large 

number of Hood River residents. Friends of Mount Hood objects to old growth 

logging and roadbuilding in that watershed. We ask the Forest Service for a 

management plan to protect this historic backcountry.

The primary goal of the land exchange is to permanently protect a large amount 

of acres of Mount Hood's north side, while providing land of equal value to 

Mount Hood Meadows at Government Camp. We support that goal.

As stated in the scoping letter dated February 11, 

2016, the Forest Plan would be amended to meet the 

congressional direction described for the Crystal 

Springs Special Resources Management Unit. 
14

Letter # Subject Comment Preliminary Remarks for DEIS Development1

10.0 Wildlife/Big 

Game

Thank you for the opportunity to provide comments on the Government Camp –

Cooper Spur Land Exchange between the Forest and Mount Hood Meadows, 

LLC on the Zigzag and Hood River ranger districts. Under the Mt. Hood 

National Forest Land and Resource Management Plan, the land use allocation of 

the parcels to be conveyed is A11 – Winter Recreation Areas, and includes a 

future desired condition that embraces summer recreation activities. The Oregon 

Department of Fish and Wildlife (ODFW) does not object to the land exchange, 

but would like to take this opportunity to highlight the importance of summer 

range habitat for big game species like deer, elk, bear, and cougar. Mt. Hood is 

a unique landscape in the local region that possesses summer range habitats that 

benefit wildlife, particularly migratory big game species. For example, 

according to emerging research on elk, summer range habitat may directly 

affect the growth of young animals, pregnancy rates of adult females, and body 

fat levels of animals entering wintering. ODFW began a pilot telemetry study in 

2015 of elk that utilize summer range habitat on Mt. Hood and have collected 

location data of elk in the vicinity of the parcels to be conveyed. ODFW is 

concerned that future management of summer recreation could displace elk and 

other wildlife species. ODFW anticipates an opportunity to coordinate with 

Clackamas County during their review of land use development proposals on 

the conveyed parcels in order to minimize adverse effects to vegetation, 

fisheries, and wildlife. Thank you again for the opportunity to provide input on 

this proposal. 

Big game and other wildlife species will be analyzed 

in the DEIS. We look forward to continued 

coordination with ODFW.

11.1 Tram 

Corridor

As proposed, the land exchange could thwart the eventual development of an 

aerial tram connecting the Timberline and Ski Bowl ski areas with Government 

Camp. The USFS needs to carefully consider the requirements set forth not only 

in the Mt Hood Forest Bill Authorization and the United States Code (“U.S.C.”) 

governing land transactions, but also the Clackamas County Code and 

Comprehensive Plan and other support for this corridor. A tram between 

Government Camp and the ski areas will significantly reduce vehicle trips, 

lessen greenhouse gas emissions, provide for a safer means of access to the ski 

areas during the winter months, and provide economic development 

opportunities for the Mt Hood communities. 

In the Memorandum of Understanding (MOU) dated 

November 4, 2010, Mt. Hood Meadows evidenced an 

intent to honor the terms of the MOU – namely 

working collaboratively with Timberline and Skibowl 

ski areas for an appropriate corridor should it be 

determined that a gondola is feasible. As the Forest 

Service indicated in an April 23, 2013 letter submitted 

to your organization, the agency believes it is 

unnecessary for the United States to reserve an 

easement for the potential future development of a 

gondola connection.
15

Letter # Subject Comment Preliminary Remarks for DEIS Development1

11.2 Tram 

Corridor

Section 1207(a)(1) of the Mt Hood Forest Bill mandates that the Secretary of 

Agriculture participate with the Oregon Department of Transportation (ODOT) 

on its Mt. Hood transportation plan. The purpose of this plan is to find 

comprehensive solutions to the specific transportation challenges on Mt Hood. 

In particular, this section calls for an integrated, multi-modal transportation 

plan. Congress requires that the Secretary of Agriculture and ODOT look for 

transportation solutions other than the automobile. Congress declared their 

preference for a gondola connecting Government Camp to Timberline Lodge by 

authorizing a feasibility study for the project. The authorization act went as far 

as specifying that the gondola should be located in the proximity of the historic 

gondola corridor. The authorization act also provides a blueprint for developing 

funding mechanisms to implement the transportation plan with the gondola, 

stating such financing tools as Federal Government funding.

In order to meet the direction included in the Omnibus 

Act, the Forest Service, along with its partners, 

completed the Mt. Hood Multimodal Transportation 

Plan in 2014. In regards to the aerial tram, the 

Omnibus Act requires the Forest Service to seek to 

address the feasibility of establishing a gondola 

connection, which has been completed.

11.3

Easements 

and Tram 

Corridor

The Mt Hood Forest Bill calls for the land exchange with Mt Hood Meadows. 

But it specifically requires that the Secretary of Agriculture reserve easements 

for non-motorized use by the public, and for roads, utilities and infrastructure 

facilities to cross the trails. 

Congress’ intent and will is clear with this law. They want to accomplish the 

land exchange while preserving the ability of the public to access trails currently 

on the land. And Congress is very firm that they want to develop a gondola or 

tram that will connect Government Camp and Timberline. Protecting the rightof-way with a reserved easement for the gondola or tram thus becomes an 

essential part of any exchange.

Forest Service policy and directives advise against the 

type of deed restriction that you seek as part of the 

exchange. The easement you are requesting primarily 

addresses a political or social issue, which Forest 

Service policy states such deed restrictions should be 

used only for addressing environmental issues. Deed 

restrictions create a perpetual responsibility on behalf 

of the United States to monitor and enforce the 

restrictions. Due to these restrictions encumber the 

estate conveyed, they have the potential to reduce the 

appraised value of the land, which would necessitate 

adjustments of the acreage to be exchanged to equalize 

the values. Agency policy is to the effect that, if a 

restriction significantly reduces value or creates 

obligations to the United States, those lands should be 

removed from an exchange proposal. However, in this 

instance, Congress specified the lands to be 

exchanged.
16

Letter # Subject Comment Preliminary Remarks for DEIS Development1

11.4 Tram 

Corridor

The land exchange documents are needed to reserve the necessary right-of-way 

to ensure that the tram will be constructed. In fact, the U.S.C. requires that 

within the land exchange conveyance documents, the Secretary of Agriculture 

will mandate ant “..terms, covenants, and reservations as he deems necessary to 

insure proper land use and protection of the public interest...”. The Mt Hood 

Forest Bill proclaims that the land exchange must be carried out under “..section 

206 of the Federal Land Policy and Management Act of 1976 (43 U.S.C. 

1716).”The Secretary of Agriculture must consider these requirements and the 

specific language of the Mt Hood Forest Bill.

As stated above, Congress already told the Secretary of Agriculture what 

conditions, terms, and reservations must be in the exchange. First, that there will 

be an easement to preserve trails for non-motorized public access. This is stated 

very specifically in the act. But Congress was even more detailed in regards to 

the gondola. First, they stated that there should be a gondola connection 

between Government Camp and Timberline, and the location should be in close 

proximity to the historic alignment. And in the land exchange section, it 

requires the Secretary of Agriculture to reserve necessary infrastructure 

easements. This would naturally include the right-of-way/easement for a 

gondola.

Please see the response above.

11.5

Local 

Planning 

Law

The land exchange between USFS and Mt. Hood Meadows also carries with it 

limitations on development. Namely, that the land exchange does not alter or 

limit Oregon or Clackamas County from enforcing any “..law (including 

regulations), rule or standard relating to development...” Oregon, Clackamas 

County, and other public and private organizations have already included a 

gondola/tram in their planning documents, laws, and regulations. The USFS 

must therefore examine what these plans, laws, and regulations state and 

incorporate them into the land exchange. A brief overview is provided below (a 

number of local ordinances are included).

Please see response to 11.3.

11.6 Tram 

Corridor

On behalf of our clients, we request several action items form the USFS. First, 

that the USFS affirms the proposed corridor for the aerial tram between 

Timberline and Government Camp in any exchange documents. More 

specifically, that the USFS explicitly reserve easements for the aerial tram 

corridor to ensure the fulfillment of the stated goals, policies and statutes 

mentioned in detail above.

Please see response to 11.3.

11.7 Trail 

Easements

Second, the USFS must preserve the existing trail network through the 

reservation of easements over the exchanged property. Protection of these 

public trails is mandated in the Mt Hood Forest Bill. The assurances that have 

been given by the USFS thus far are inadequate.

Non-motorized trail easements are included in the 

proposed action, as described in the Omnibus Act; and 

more details will be available in the DEIS when it is 

available.
17

Letter # Subject Comment Preliminary Remarks for DEIS Development1

11.8

Land 

Exchange 

with Collins 

Lake 

Development

Third, the USFS must exchange to the Collins Lake Development the strip of 

land between Government Camp Loop Road and the Collins Lake development. 

By deeding over this small strip of land, the USFS will correct a deed error and 

will further a previously agreed-to memorandum of understanding between the 

ski areas.

The strip of land mentioned in this comment lies South 

of the Southerly Right-of-Way line of Government 

Camp Loop Road (in Section 13, T3S, R8E). The 

Federal Land Status report identifies the land as 

Reserved Public Domain Land under the Creative Act 

of March 3, 1891. It is included within the limits of the 

Mt. Hood National Forest. Thus, this strip of land is 

being conveyed as part of this land exchange.

12.0 Treaty 

Rights

As you know, the CTWSRO have treaty rights for hunting, gathering and 

utilizing for cultural uses resources that exist throughout their lands ceded by 

treaty in 1855. These are referred to as Usual and Accustomed (U&A) Places 

and include significant cultural resources such as berries, fish, plants used for 

foods, medicines and ceremonies, sacred sites and traditional use areas. The Mt. 

Hood National Forest is one of those areas for the CTWSRO.

The Forest has been engaged and will continue to be 

engaged with the CTWSRO on treaty rights associated 

with the lands subject to this exchange. The DEIS will 

analyze impacts to both treaty rights and cultural 

resources.

12.1

Culturally 

Significant 

Resources

CTWSRO THPO concerns about land transfers/exchanges that is owned by the 

federal government to non-federal entities include concerns about potential 

impacts to significant cultural resources, gathering and use areas, hunting and 

other traditional uses as a result of taking the land out of federal ownership. One 

resource of concern for that area is Huckleberry gathering areas, but there are 

potentially other culturally-significant resources important to CTWSRO that 

need to be considered as part of your agency’s review under NEPA and NHPA.

The DEIS will analyze impacts to both treaty rights 

and cultural resources.

12.2 Treaty 

Rights

It is the position of the CTWSRO that there should be No Net Loss of lands, 

access to lands for traditional cultural uses, or treaty resources and rights for the 

CTWSRO in federal land exchanges that occur within CTWSRO ceded and 

U&A lands. It is important that these potential impacts be considered in the 

Final EIS for the proposed exchange. We would request that not only 

archaeological sites be considered in this review pursuant to NEPA and NHPA, 

but also Historic Properties of Cultural and Religious Significance to Indian 

Tribes (HPRCSITs). To-date it does not appear that the DEIS has covered some 

of these resource issues adequately. This issues should be matters of tribal 

consultation with both the CTWSRO Council and the CTWSRO THPO, plus 

with the CTWSRO Culture and Heritage Committee.

The DEIS will analyze impacts to both treaty rights 

and cultural resources. Additionally, the agency will 

consult on the land exchange with the CTWSRO.
18

Letter # Subject Comment Preliminary Remarks for DEIS Development1

13.0

Benefits of 

Omnibus 

Act

The 2009 Omnibus Public Lands Management Act will benefit our farming and 

timber production interests by:

1. Maintaining lands in non-developed uses which means fewer uses and 

people in the area that are incompatible with our farm and forest 

practices.

2. Less escalation of land prices, which helps farmers stay on the land 

and expand their operations.

3. Less trespass and vandalism.

4. Less traffic to interfere with farm operations and slow moving tractors 

on highways.

5. Less competition for water so that we can irrigate our crops.

6. Less harvest of USFS lands will help maintain log prices so private 

forest land owners can afford to keep their lands. 

Thank you for your comment and sharing your 

perspective.

13.1

Benefits of 

Omnibus 

Act

Community and environmental interests will be served by completing this 

Congressional Act because:

1. The Crystal Springs Watershed which serves the domestic water needs 

of over 50% of the area of the Hood River Valley will be protected by 

the Crystal Springs Special Resources Watershed Management Unit 

(2267 acres).

2. Backcountry recreational areas (1710 acres) will be protected for 

perpetual public use by the new Wilderness Area.

3. Designation of these two large units will maintain natural habitat for 

big game and plant species.

4. Cooper Spur Ski Area and Cooper Spur Inn will be leased to private 

managers so that these facilities can continue to serve the public in the 

same low impact manner. 

Destination resorts and subdivisions will be prevented in this special natural 

area on Mt. Hood and the wishes of the community will be realized.

Thank you for your comment and sharing your 

perspective.
19

Letter # Subject Comment Preliminary Remarks for DEIS Development1

14.0

History of 

Land 

Exchange

Since 2001, HRVRC has been working in collaboration with Oregon’s

Congressional delegation, local county governments, Mount Hood Meadows, 

citizen groups and businesses to resolve three decades of dispute over the future 

of the north side of Mount Hood. In 2009, that broad collaboration worked 

together on the passage of the Public Lands Omnibus Act. The Mount Hood 

Cooper Spur Land Exchange was the keystone component of that settlement 

and is the perfect Oregon solution to the threats that would otherwise face 

Oregon’s iconic peak. In the seven years that followed passage of the act we 

have been dismayed by the Forest Service’s slow progress at completing the 

exchange. Last year we filed suit against the Forest Service for the agency’s 

unreasonable delay in completing the trade as directed by Congress. Given the 

slow progress in recent years, we were heartened to receive the scoping letter 

for the EIS for the land trade. We salute the Forest Service for their recent 

willingness to devote more attention to the land trade and their efforts to 

accelerate its completion.

Thank you for your comment and sharing your 

perspective.

14.1 Polallie 

Cooper

The Cooper Spur-Government Camp Land Exchange provides tremendous 

public benefits; however, we are concerned about the proposed Polallie Cooper 

logging project in the Crystal Springs Watershed Special Management Unit. 

The proposed forest treatment is inconsistent with the 2009 Act. We request that

Forest Service postpone any forest treatment in the Crystal Springs area until 

after the land exchange is complete and a specific management plan has been 

adopted for the Crystal Springs watershed. The 2009 Act was intended to 

provide substantive protections for the Crystal Springs area; proposed road

building and the logging of older, “previously unmanaged stands” is outside the 

management protocol intended by the Act.

Please see responses to #5.2, 5.3, 5.4 and 7.9.
20

Letter # Subject Comment Preliminary Remarks for DEIS Development1

15.0 Crag Law 

Submissions

Ralph Bloemers of Crag Law submitted several attachments on behalf of two of 

his clients: 1) Hood River Valley Residents Committee; and 2) Cooper Spur 

Wild and Free Coalition. Five emails submitted on his clients’ behalf contained 

the following:

 A letter and press release from Senator Wyden and Congressman 

Blumenauer regarding the Polallie Cooper Hazardous Fuels Reduction 

Project;

 Comments submitted by his clients for the Polallie Cooper Hazardous 

Fuels Reduction Project;

 A Government Accountability Office report from 2006 to be shared 

with the appraiser; 

 A Clackamas County memo from 2013 regarding the density 

calculations and allowed uses for Low Density Residential; and,

 Submission of the comments submitted for this land exchange in 

November 2010.

Also, Ralph Bloemers of Crag Law submitted several attachments on behalf of 

his clients – the Hood River Valley Residents Committee – which included 

appraisals completed in 2005 by Steve Hall for the Cooper Spur and 

Government Camp parcels; sales data from Clackamas County for properties 

within the Mt. Hood corridor to be shared with the appraiser; and a proposed 

amendment to the Omnibus Act.

Ralph Bloemers also submitted other emails where he did not state that he was 

submitting the information on behalf of his clients. These emails included: sales 

data from Clackamas County to be shared with the appraiser; and a written 

statement of Congressman Blumenauer on the Mount Hood Cooper Spur Land 

Exchange Clarification Act.

Most of the comments about the land exchange in 

these documents has already been addressed in the 

responses provided above. It is important to note that 

the proposed changes to the Omnibus Act (i.e., Mount 

Hood Cooper Spur Land Exchange Clarification Act) 

will be analyzed in the DEIS. Also, all of the 

documents submitted will become part of the project 

record for this land exchange. In regards to the 

requests to provide information to the appraiser, the 

information has been sent to the Acting Regional 

Appraiser and the Assigned Senior Review Appraiser. 

The Review Appraiser will provide the list of sales 

included in the spreadsheet titled "mt hood corridor 

2005" to the Contract Appraiser for consideration; 

however, the Contract Appraiser will determine what 

data will be used in the appraisal. Also, our 

understanding of the appraisals completed in 2005 by 

Steve Hall were not instructed by Forest Service 

Review Appraisers and were not approved for Agency 

use. 

16.0 Previous 

Comments

The scoping comments from did not bring up any different topics than the scoping comments received in 2016. All of the comments from 

2010 are either addressed above, opinion, or outside of the scope of the land exchange.
21

Table 3. List of respondents from comments received outside of the designated scoping period (received after March 17, 2016).

Letter # Respondent Date Received/Submitted

1 Ralph Bloemers (Crag Law) on behalf of the Hood River Valley Residents Committee March 21, 2016

2 Ralph Bloemers (Crag Law) April 10, 2016

Table 4. Preliminary remarks on comments received outside of the designated scoping period (received after March 17, 2016).

Letter # Subject Comment Preliminary Remarks for DEIS Development

1.0 Appraisal Sales data received from Clackamas County for properties in the Mt. Hood 

Corridor to be shared with the appraiser. Please see response to #15.0 in Table 2.

2.0 Wetlands

Letter from Clackamas County Board of Commissioners to Senator Wyden, 

Senator Merkley, and Congressman Blumenauer dated September 16, 2015, 

which discusses information about policies and regulations to protect wetlands, 

stream corridors, and other natural resources in the County.

Thank you for sharing this information.