From:
David Levine
P.O. Box 439
Williams, OR   97544

January 11, 2008

Re: Comments on the Western Oregon Plan Revisions Draft Environmental Impact Statement

Thank you for accepting these comments on the Western Oregon Plan Revision (WOPR). As a resident and landowner in the rural Applegate Valley of southern Oregon, I will be harmed by the implementation of any of the action alternatives in the WOPR.  The WOPR fails to protect old growth forests, clean water, recreation, economic opportunities and other important values currently provided by these public forests in western Oregon.

Broadly, I am convinced that all of the primary action alternatives would have negative environmental, social and economic consequences for the planning area and the entire Pacific Northwest, as well as being illegal for a number of reasons.  The BLM's new interpretation of the law - particularly its elevation of the O&C Act as a timber-dominant statute - is fundamentally flawed (see Earthjustice's scoping comments on the WOPR).  The O & C Act states that O & C lands " . . . shall be managed for permanent forest production, and the timber thereon shall be sold, cut, and removed in conformity with the principal of sustained yield for the purpose of providing a permanent source of timber supply, protecting watersheds, regulating streamflow, contributing to the economic stability of the local communities and industries, and providing recreational facilities." (emphasis added)

The Act does not establish timber supply as the predominant and only value to these lands, excluding all other considerations.  Equal status is given to "protecting watersheds, regulating streamflow, contributing to the economic stability of the local communities and industries, and providing recreational facilities."  These management goals have been carried out since 1994 under the terms of the Northwest Forest Plan.  The Bush administration, in choosing to settle rather than litigate in defense of the Northwest Forest Plan in the case of American Forest Resources Council vs. BLM, has failed in its obligation to uphold the law.  The entire WOPR process is, therefore, a monumental waste of the American taxpayer's time, money, and energy that can only lead to an ongoing struggle over the fate of the Northwest's public lands.

Even if there were a legitmate need to improve the management plans for BLM-managed lands in western Oregon, the action alternatives discussed in the WOPR Draft Environnental Impact Statement are entirely unacceptable.  The environmental costs would be atrocious with the BLM's preferred alternative, which would increase clearcutting by 700%, build approximately 1,000 miles of roads over the next decade, vastly reduce and in many cases eliminate riparian buffers, and remove many existing protections for late-successional reserves.  

The preferred alternative is also an economic disaster.  For the sake of some 3,000 (projected, and relatively short-term) timber-related jobs, there will be negative impacts on tourism, real estate values, non-timber forest products, hunting and fishing, water quality, outdoor recreation, and general quality of life.  The local communities and industries that the O & C Act was designed to benefit will be left, after another round of boom-and-bust, with a seriously damaged environment, reduced economic opportunities, permanently lowered real estate values, compromised water supplies, and, to add insult to injury, still no viable long-term solution for local funding needs.

Of course, this all doesn't have to be.  The BLM, and by extension the Bush administration, could finally listen to and act on the overwhelming public support for protection of mature and old-growth forests.  There is a strong emerging consensus that the most productive way forward is to focus on thinning of overstocked, fire-prone tree plantations that are the result of past clearcutting. A policy that focused on thinning of second-growth stands, protecting communities from wildfire, and preserving our remaining old-growth would avoid controversy and litigation while providing a predictable supply of timber, enhancing the environment, and helping to stabilize and diversify the local economy.

Although the need for stable local funding is not the driving force behind the WOPR process, the issues are connected and there is a need for a viable solution.  As a taxpayer, landowner and resident of Josephine County, one of the largest recipients of O & C funding, my feeling is that it is time for us to move forward into the 21st century with a different vision than the one that has landed us in our present situation.  There are hundreds of counties in the United States that manage to fund an adequate level of local services without handouts from the federal government.  The simple truth is that it is probably time for the O & C counties and the state of Oregon as a whole to have a serious discussion about the available range of funding sources, including a sales tax, that would allow us to build a diversified economy complete with schools, libraries, and police, without basing it on environmental destruction that leaves future generations with an unpayable debt.  Other places do it, and I think we could, too.

Yes, I would rather pay a small sales tax than accept an economy that forever equates economic growth with environmental destruction.  The preferred alternative in the WOPR does nothing to solve our long-term economic and environmental problems in western Oregon.

The WOPR's emphasis on clearcutting ("regeneration harvests"), roadbuilding, and reduction of riparian protections will have serious impacts on aquatic habitat and fisheries.  Anadramous fish in the Northwest are in serious decline, with many stocks already extinct and others teetering on the brink.  Clearcutting leads to soil erosion, landslides, sedimentation of streams, and destruction of habitat for endangered and threatened fish populations.  Reduction of streamside buffers will lead to increases in water temperature, higher turbidity, reduced oxygen levels, and alterations in riparian vegetation.  Construction and maintenance of roads produces alterations in hydrology, constant sediment deposition in streams and rivers, introduction of non-native plants and diseases (i.e. Port Orford cedar root-rot), forest fragmentation, and increased access for OHV use, poaching, etc.  These are serious impacts to valuable, irrerplaceable resources, all of which will be sacrificed under the WOPR for short-term benefits, most of which will accrue to a few large timber corporations, not the impacted local communities.

By over-emphasizing commercial timber harvest on O & C lands, the WOPR fails to recognize progress that has been made locally in recent years to build a more sustainable economy that is based on ecological restoration and the use of small-diameter timber, non-traditional products, and an attitude of stewardship towards our local environment.  As an Applegate Valley resident since 1996, I've witnesed many ongoing experiments with sustainable forestry, some of which have benefitted from being part of the Applegate Valley Adaptive Management Area (AMA), which will be eliminated under the WOPR's preferred alternative.  Several entities stand out, such as the Lomakatsi Restoration Project and the Williams Creek Watershed Council.  These organizations have been leading the way to a restoration-based economy that represents a viable future for the Applegate Valley.  The WOPR's action alternatives seriously undermine all the work that has been achieved in the past in this area, while making future progress more difficult.

Another outstanding environmental threat contained in the WOPR is an increased emphasis on the use of Off-Highway Vehicles (OHV's).  The designation of OHV Emphasis Areas such as John's Peak, Andersen Butte, and Ferris Gulch is a threat to soils, forests, aquatic habitat, rare species, private landowner rights, and everyone's right to peace and quiet.  OHV's are noisy, intrusive, and threatening to other users of public lands.  Their use on our public lands, except in rare instances, should be discouraged, not encouraged.  The fact that they have become so popular that some see them as virtually indispensable is no reason to sacrifice a wide range of values for the recreational needs of a few.  I would be particularly impacted by the designation of the Ferris Gulch OHV Emphasis Area, as I live within approximately one mile of its boundaries, and adjacent to a main access point (Findley Rd.)  I object to the noise, environmental damage, increased fire hazard, and lack of respect for private property that are associated with OHV use, and I strenuously object to any such designation in the environmentally sensitive public lands of the Applegate Valley.

The WOPR also fails to take global climate change into account.  There is near-universal agreement in the scientific community that we must confront this issue immediately to avoid catastrophic consequences.  The management practices favored in the WOPR's action alternatives do not account for issues such as carbon sequestration in forests, shifting habitat needs for plant and animal species, and increased fire hazard due to reduced precipitation and warmer temperatures.  It is imperative that public lands management be conducted in accordance with the best available science, and WOPR utterly fails in that regard.

I urge you to reject the unproductive alternatives contained in the WOPR DEIS.  If we are going to change the direction of BLM's management practices, it must be toward sustainability and true long-term ecological and economic stability.  There are billions of board feet of small-diameter timber that could be thinned from BLM lands with little controversy and widespread public support.  There is a huge need for habitat restoration, fire hazard reduction, and rural economic development.  Between the private, public, and nonprofit sectors we have the expertise we need to move forward.  Let's consign the WOPR to history and start thinking about truly creative solutions to the serious problems we face.

Sincerely,

David Levine