I am writing to urge the Bureau of Land Management to reject the proposed Western Oregon Plan Revision and adopt the No Action Alternative.  This request is based on a number of issues briefly summarized below.

1) Economic realities do not support the projected economic benefits to counties of Oregon, which appears to be the primary rationale for the WOPR.  The projections are based on peak prices that no longer hold.  Auctioning timber at current prices which the U.S. Forest Service indicates do not cover administrative and restoration costs is nothing but a give-away of public resources to private timber companies.  Alternative mechanisms to provide support to counties, such as a tariff based on current value on all logging on timber removed from public lands, should be considered.

2) The WOPR does not adequately protect the irreplaceable and dwindling public resource of old growth trees.  In light of the fact that more and more Oregon mills have shifted to smaller timber and no longer require old growth, BLM can protect old growth and at the same time satisfy the needs of industry. 

3) The WOPR does not consider the major issue of climate change resulting from global warming.  The climatic effects of clear cutting, such as removing the carbon stored in old growth forests, are not adequately addressed.  Forest management should shift from clear cutting to sustainable utilization of secondary forest products such as underbrush and thinned trees for bio-fuels.  

4) The WOPR does not adequately consider environmental impacts.  The effects upon ground water, wildlife, and recreation must be addressed more carefully and with public input.

The Bureau of Land Management is entrusted with the management of public lands which are an important part of public wealth and must be used for the common good.  While providing economic benefits for counties may be part of this mandate,  these benefits can be realized in ways that protect the public wealth and responsibly address the pressing issues of climate change and environmental protection rather than giving the wealth to private individuals based upon faulty projections and incomplete analyses.

The WOPR needs to be rejected and an entirely new plan developed.  For this reason I urge BLM to adopt the No Action Alternative.

Peter Moulton
P.O. Box 11752
Eugene, OR 97440