BLM LIBRARY
88064084
JL 111(11
Environmental Impact
Statement
for the Revision of the
Resource Management Plans of the Western
Oregon Bureau of Land Management
Salem, Eugene, Roseburg, Coos Bay, and
Medford Districts, and the Klamath Falls Resource Area of the
Lakeview District
Volume IV
Salem, Eugene, Roseburg, Coos Bay, Medford, and Klamath Falls Offices October 2008
As the Nation’s principal
conservation agency, the Department
of the Interior has responsibility for
most of our nationally owned public
lands and natural resources. This
includes fostering the wisest use
of our land and water resources,
protecting our fish and wildlife,
preserving the environmental and
cultural values of our national
parks and historical places, and
providing for the enjoyment of life
through outdoor recreation. The
Department assesses our energy
and mineral resources and works to
assure that their development is in
the best interest of all our people.
The Department also has a major
responsibility for American Indian
reservation communities and for
people who live in Island Territories
under U.S. administration.
113716
Appendices
Volume IV
Appendix N. Areas of Critical Environmental Concern
483
C-,
Appendix O. Federally Recognized Indian Tribes With Interests in the
Planning Area 513
Appendix P. Lands 519
Appendix Q. Energy and Minerals 563
Appendix R. Vegetation Modeling 641
Appendix S. Wood River Wetland and West Eugene Wetlands Management
Plans 735
Appendix T. Responses to Public Comments and Comment Letters
From Congressional Representatives; Indian Tribes; and Federal,
State, and Local Government Agencies 761
&
Appendices - 481
FEISfor the Revision of the Western Oregon RMPs
Appendices - 482
Appendix N
Areas of Critical
Environmental
Concern
This appendix provides detailed information about Areas of Critical Environmental Concern.
In this appendix:
Areas of Critical Environmental Concern
484
Appendices - 483
FEISfor the Revision of the Western Oregon RMPs
Areas of Critical Environmental Concern
This section contains detailed information about Areas of Critical Environmental Concern (ACEC). Two
tables are included. Table N-l, which shows Areas of Critical Environmental Concern by alternative,
includes information about the categories of Relevant and Important Values and any management direction
that applies to the area. Table N-2 contains more specific information about the Relevant and Important
Values for each ACEC.
The ACECs denoted by the darker gray shading are those that were not further analyzed for designation
under the action alternatives because they did not meet relevance and importance criteria and/or do not
need special management attention. Management direction for these areas is the management direction
in the current plans, and would only be applied under the No Action Alternative. Four of these areas have
other special designations that make ACEC designation unnecessary:
• North Umpqua River is a Wild and Scenic River.
• Sterling Mine Ditch is eligible for listing under the National Historic Preservation Act.
• Jenny Creek and Pilot Rock are within the Cascade-Siskiyou National Monument.
The ACECs denoted by the lighter gray shading are those that meet all of the criteria for designation, but
would not be designated under one or more action alternatives, because the relevant and important values
cannot be managed without including the O&C harvest land base.
Appendices - 484
Management Direction For Areas Of Critical Environmental Concern
Appendix N - Areas of Critical Environmental Concern
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Appendix N - Areas of Critical Environmental Concern
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FEISfor the Revision of the Western Oregon RMPs
Appendices - 496
Appendix N - Areas of Critical Environmental Concern
Appendices - 497
FEISfor the Revision of the Western Oregon RMPs
Appendices - 498
Appendix N - Areas of Critical Environmental Concern
Appendices - 499
FEISfor the Revision of the Western Oregon RMPs
Appendices - 500
Appendix N - Areas of Critical Environmental Concern
Appendices - 501
FEIS for the Revision of the Western Oregon RMPs
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Appendix N - Areas of Critical Environmental Concern
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Appendices - 504
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Appendices
FEISfor the Revision of the Western Oregon RMPs
Appendices - 506
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Appendix N - Areas of Critical Environmental Concern
Appendices
507
FEISfor the Revision of the Western Oregon RMPs
Appendices
508
Appendix N - Areas of Critical Environmental Concern
Appendices - 509
FEISfor the Revision of the Western Oregon RMPs
Appendices - 510
Appendix N - Areas of Critical Environmental Concern
Appendices -511
FEISfor the Revision of the Western Oregon RMPs
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Appendices - 512
Appendix O
Federally
Recognized Indian
Tribes with Interests
in the Planning Area
This appendix provides the background on federally recognized American Indian Tribes in the planning area.
In this appendix:
Federally recognized American Indian Tribes in, or with interests in, the planning area 514
Appendices -513
FEISfor the Revision of the Western Oregon RMPs
Federally Recognized American Indian Tribes in,
or with Interests in, the Planning Area
There are nine federally recognized American Indian Tribes in, or with interests in, the planning area:
• Confederated Tribes of the Coos, Lower Umpqua and Siuslaw Indians of Oregon
• Confederated Tribes of the Grand Ronde Community of Oregon
• Confederated Tribes of the Siletz Reservation, Oregon
• Confederated Tribes of Warm Springs Reservation of Oregon
• Coquille Tribe of Oregon
• Cow Creek Band of Umpqua Indians of Oregon
• Klamath Tribes, Oregon
• Modoc Tribe of Oklahoma
• Quartz Valley Indian Community of the Quartz Valley Reservation of California
American Indian tribes represent unique legal entities in the United States and are distinct political
communities with extensive powers of self-government. Tribal sovereignty predates the U.S. Government.
Treaties, Federal statutes, and executive agreements over the past 200 years have established a special trust
relationship between tribes and the Federal Government. The Federal Bureau of Indian Affairs has been
designated by the Secretary of the Interior as the primary agency to protect tribal interests and administer
trust responsibilities.
During the 1950s, in a move to assimilate American Indians into mainstream America, the U.S. Government
ended Federal trusteeship of roughly three percent of the country’s American Indian population through a
process called termination. Of the 109 tribes and bands terminated, 62 were native to Oregon. Even though
the tone of the termination legislation was emancipation, the net effect of the policy on terminated tribes
was cultural, political, and economic devastation.
In recent years, however, terminated tribes have made vigorous efforts to re-establish or restore the trust
relationship. In 1977, the Confederated Tribes of the Siletz Reservation, Oregon won restoration; followed
by the Cow Creek Band of Umpqua Indians of Oregon in 1982; the Confederated Tribes of the Grand Ronde
Community of Oregon in 1983; the Confederated Tribes of the Coos, Lower Umpqua and Siuslaw Indians of
Oregon in 1984; the Klamath Tribes, Oregon in 1986; and the Coquille Tribe of Oregon in 1989.
Confederated Tribes of the Coos, Lower Umpqua and Siuslaw
Indians of Oregon
These tribes are descendants of the aboriginal inhabitants of the central and south-central coast of Oregon.
Their homeland includes the estuaries of Coos Bay, and the Umpqua and Siuslaw Rivers. The Tribes
have been operating under a confederated government since signing of the Treaty of August 1855. They
currently possess a 6.1 -acre reservation and a tribal hall erected in 1940, but past claims have not yet been
settled. The Tribes hope to work out a reservation agreement with the Federal Government. The Tribes
had a relationship with the U.S. Government from 1853 until their termination by Congress in the year
of 1956. The majority of their members were removed in 1856 from their aboriginal homelands and held
on a wind-swept spit at the mouth of the Umpqua River at a place called Fort Umpqua. Their territory
encompassed part of Coos, Curry, Douglas, Lane and Lincoln counties. Federal recognition was restored to
the Confederated Tribes of Coos, Lower Umpqua and Siuslaw Indians in October of 1984.
Appendices - 514
Appendix O - Federally Recognized Indian Tribes with Interests in the Planning Area
Confederated Tribes of the Grand Ronde Community of
Oregon
These tribes include more than 20 Tribes and bands from western Oregon and northern California that
were relocated to the Grand Ronde Reservations in the 1850s. These included the Rogue River, Umpqua,
Chasta, Kalapuya, Molalla, Salmon River, Tillamook, and Nestucca Indians. The Grand Ronde Reservation
was established by treaty arrangements in 1854 and 1855, and an Executive Order of June 30, 1857. The
Reservation contained over 60,000 acres and was located on the eastern side of the coastal range on the
headwaters of the South Yamhill River. In 1887, under the General Allotment Act, 270 allotments totaling
slightly more than 33,000 acres of the Grand Ronde Reservation were made available to individual Indians.
The result of this action was the loss of major portions of the reservation to non- Indian ownership.
Then, in 1901, U.S. Inspector James McLaughlin declared a 25,791 -acre tract of the reservation “surplus”
and the land was sold. In 1954, Congress passed the Termination Act, which severed the trust relationship
between the Federal Government and the Tribe. On November 22, 1983, with signing of Public Law 98-
165 (the Grand Ronde Restoration Act), the Tribe was restored to Federal recognition. In addition, on
September 9, 1988, the Tribe regained 9,81 1 acres of the original reservation when President Ronald Reagan
signed the Grand Ronde Reservation Act into law. The reservation lies just north of the community of
Grand Ronde.
The mission of the Grand Ronde Natural Resources Division is to manage, develop, and protect the natural
resources of the Grand Ronde Tribes, such as timber, non-merchantable young stands of trees, fish, wildlife,
recreation, minerals, air, streams, roads, and minor forest products. Their Natural Resources Division strives
to manage the Tribes’ resources in a unique, creative, and efficient manner, taking care to meet mandates
while balancing the importance of non-revenue-producing elements of the reservation.
Confederated Tribes of the Siletz Reservation, Oregon
These tribes are a federally recognized confederation of 27 bands originating from northern California,
western Oregon and southern Washington. Termination was imposed on the Siletz by the U. S. Government
in 1955. In November of 1977, the Tribe was restored to Federal recognition. The Tribe occupies and
manages a 3,666-acre reservation in Lincoln County, Oregon. The Tribe manages resources on their
reservation, including wildlife, timber, water, fish, and air quality.
Confederated Tribes of the Warm Springs Reservation of
Oregon
These tribes include bands of the Wasco, Warm Springs and Paiute. The Wasco bands on the Columbia River
were the eastern-most group of Chinookan-speaking Indians living along the Columbia River. Tire Warm
Springs bands lived along the Columbia’s tributaries, and the Paiutes lived in southeastern Oregon. In 1855,
Joel Palmer, superintendent for the Oregon Territory, negotiated a series of Indian treaties including the
one establishing the Warm Springs Reservation. Under the Treaty of 1855, the Warm Springs and Wasco
Tribes relinquished approximately 10 million acres of land, but reserved the Warm Springs Reservation for
their exclusive use. Tire Tribes also kept their rights to harvest fish, game and other foods off the reservation
in their usual and accustomed places. Tire Tribes’ Natural Resource Management Services exist to plan
and execute a balanced direction for the protection, use, and enhancement of all tribal natural resources.
Resources shall be managed as sustainable assets available for cultural, subsistence, economic and social
purposes or opportunities in perpetuity consistent with the Confederated Tribes sovereign and treaty status.
Appendices - 5 1 5
FEIS for the Revision of the Western Oregon RMPs
Coquille Tribe of Oregon
This tribe’s members are descended from people who inhabited the watersheds of the Coquille River system,
a small portion of Coos Bay at the South Slough, and areas north and south of the Coquille River mouth
where it enters the ocean at present day Bandon. The Coquille ancestral territory encompassed more than
700,000 acres, ceded to the U.S. Government. Coquille headmen signed treaties in 1851 and 1855. Because
neither treaty was ever ratified by Congress, those Coquille people and their descendants were denied a
permanent homeland. The Coquille Indian Tribe was terminated by the U.S. Government in 1954. On June
28, 1989, the Coquilles regained their status as a federally recognized Indian tribe. The modern Coquille
Tribe negotiated several land purchases, which constitute a 6,400-acre tribal land base. By an Act of
Congress in 1996, the Coquille Tribe now has reservation acreage totaling 6,512 acres.
Cow Creek Band of Umpqua Indians of Oregon
Their traditional use area lies primarily in Douglas County, from the Umpqua River headwaters to the
Pacific Ocean. The Tribe’s ceded lands lie in the Cow Creek drainage of the South Umpqua River. In 1853,
seeking a peaceful solution to tensions that had intensified after gold was discovered in their territory, the
Cow Creek Umpqua Indians entered into a treaty with the Federal Government that resulted in their ceding
their homeland in exchange for $12,000. The treaty left the Cow Creek Umpquas without land, a place to
live, or protection. The Cow Creeks had been drawn into the Rogue Indian wars in the early 1850s. As a
result of the fighting and their new treaty in 1856, survivors were rounded up and forcefully marched 150
miles north to the Grand Ronde Reservation.
In 1954, the Government declared that there were no Indians left in western Oregon, the existing Cow
Creeks notwithstanding, and the Tribe was terminated. In 1982, the Tribe was restored and entered into
formal relations with the U. S. Government through the Bureau of Indian Affairs. Public Law 100-139
(1987), the Cow Creek Umpqua “Distribution Judgment Funds Act,” adopted the tribal endowment plan.
The Bureau of Indian Affairs allowed the Tribe to use the settlement funds as collateral for the purchase of
what was known as the “Evergreen” land. In addition, the Tribe was allowed to draw the interest on their
endowment for the purpose of economic development, education, housing, and elderly assistance.
Klamath Tribes, Oregon
This tribe includes the Klamaths, the Modocs, and the Yahooskin band of Snake Indians. The Tribes’
traditional territory is in the Klamath Basin of Oregon. The Klamath Tribes ceded more than 23 million
acres of land in 1864 and entered the Klamath Reservation. In 1954, the Klamath Tribes were terminated
from Federal recognition as a tribe by Act of Congress. In 1974, the Federal Court ruled that the Klamath
Tribes had retained their Treaty Rights to hunt, fish and gather, and to be consulted in land management
decisions when those decisions affected their Treaty Rights. These Treaty Rights apply to the Klamath Tribes’
former reservation boundaries. The BLM Klamath Falls Resource Area carries out trust responsibilities on
185 acres of wetland located east of Wood River that was formerly reservation land, managing the natural
resources located within this area to enhance Tribal Trust assets and water rights.
In 1986, the Klamath Tribes were successful in regaining restoration of Federal recognition.
Appendices - 516
Appendix O - Federally Recognized Indian Tribes with Interests in the Planning Area
Modoc Tribe of Oklahoma
This tribe originally lived on Little Klamath Lake, Modoc Lake, Tule Lake, Clear Lake, Goose Lake, and
in the Lost River Valley. In 1864, the Modoc ceded lands and moved to the Klamath Reservation. Due
to starvation conditions and tensions with the Klamath Indians, some Modocs returned to their original
territory in northern California in 1870. In 1872, attempts to force their return to Oregon began the Modoc
War, and the Modocs retreated to lava beds for months. Finally overrun, 153 survivors were sent to Quapaw
Agency in Oklahoma. Other survivors were sent to the Klamath Reservation. In 1909, some Modocs were
permitted to return to Klamath Agency. In 1954, the Oklahoma and Oregon Modoc Tribes were terminated.
In 1978, the Oklahoma Modoc Tribes were reinstated.
Quartz Valley Indian Community of the Quartz Valley
Reservation of California
Located in Siskiyou County, California, they include the members of the Shasta Tribe that traditionally lived
in southern Oregon and northern California. A treaty signed by Shasta Tribal chiefs on November 4, 1851
was never ratified by Congress, and the Tribe did not get their own reservation. Some members of the Shasta
Tribe joined the Confederated Tribes of the Grand Ronde Community of Oregon.
Appendices - 517
FEISfor the Revision of the Western Oregon RMPs
Appendices - 518
This appendix provides detailed data about lands, realty, and access information found in Chapters 2
and 3 of the EIS.
In this appendix:
Land Tenure Adjustment Criteria 520
Land Withdrawals and Land Tenure Zone 3 Lands 521
PERC Relicensing for the Klamath Hydroelectric Project 555
Inventory of Communication Sites 555
Analytical Methods to Determine Legal Public Accessibility
of BLM-administered Lands in the Planning Area 558
Appendices - 519
FEISfor the Revision of the Western Oregon RMPs
Land Tenure Adjustment Criteria
In accordance with the Federal Land Policy and Management Act of 1976 (FLPMA) and other laws,
Executive Orders, and Departmental and Bureau policy, the following factors will be considered in
evaluating opportunities for disposal or acquisition of lands or interests in lands. This list is not considered
all inclusive, but represents the major factors to be considered.
General Land Tenure Adjustment Evaluation Factors
• Improves manageability of specific areas.
• Maintains or enhances important public values and uses.
• Consolidates Federal mineral estate and/or reuniting split surface and mineral estates.
• Facilitates development of energy and mineral potential.
• Reduces difficulty or cost of public land administration.
• Provides accessibility to land for public recreation and other uses.
• Amount of public investments in facilities or improvements and the potential for recovering those
investments.
• Suitability of land for management by another Federal agency.
• Significance of decision in stabilizing or enhancing business, social, and economic conditions, and /
or lifestyles.
• Meets long-term public management goals as opposed to short term.
• Facilitates National, State, and local BLM priorities or mission statement needs.
• Consistency with cooperative agreements and plans or policies of other agencies.
• Facilitates implementation of other aspects of the approved resource management plans.
Acquisition Criteria
• Facilitates access to public land and resources retained for long-term public use.
• Secures Threatened or Endangered or Sensitive plant and animal species habitat.
• Protects riparian areas and wetlands.
• Contributes to biodiversity.
• Protects high-quality scenery.
• Enhances the opportunity for new or emerging public land uses or values.
• Facilitates management practices, uses, scales of operation, or degrees of management intensity
that are viable under economic program efficiency standards.
• Secure lands adjacent to other existing Zone 1 lands.
• Protects significant cultural resources and sites eligible for inclusion on the National Register of
Historic Places
• Whether private sites exist for the proposed use.
Disposal Criteria
The following criteria will be used to identify parcels in Land Tenure Zones 2 or 3 suitable for disposal:
• Suitability for purposes including but not limited to community expansion or economic
development, such as industrial, residential, or agricultural development.
Appendices - 520
Appendix P - Lands
• Lands of limited public value.
• Lands that are difficult for the BLM to manage and unsuitable for transfer to other federal agencies
or State and local governments.
• Lands that would aid in aggregating or repositioning other public lands or public land resource
values where the public values to be acquired outweigh the values to be exchanged.
O&C Land Exchange Criteria
An O&C land exchange is an exchange within the O&C area as delineated in Public Law 105-321. Forest
management and related factors to consider when evaluating the feasibility of an O&C land exchange
include the following:
• Land exchanges which maintain the existing balance between the various land use allocations will
be considered favorably.
• Offered lands which are primarily suitable for agriculture, business, or home sites, or which would
require extensive post-acquisition management will not be favorably considered. The O&C lands
designated for timber production will generally not be exchanged for lands which will be managed
solely for a single use, such as species protection.
• Generally, where cutting rights are reserved on existing and future timber stands by the proponent,
the proposed exchange will not be considered favorably.
• Proposals which result in a material reduction in the number of acres of O&C or Coos Bay Wagon Road
(CBWR) land or acres of harvestable timber should not be considered favorably See I.M. No. OR-99-
081, dated August 4, 1999, for an interpretation of Section 3 of Public Law 105-321, which established a
requirement of “No Net Loss” of O&C and CBWR lands in western Oregon.
• The exchange of O&C and CBWR lands specifically for lands located outside of the 18 O&C
counties is prohibited by regulations in 43 CFR 2200.0-6(e). This restriction applies to timber and
other interests in lands as well.
Land Withdrawals and Land Tenure Zone 3 Lands
Table P-1 through Table P-12 contain detailed information about existing and proposed land withdrawals.
Zone 3 lands are available for disposal.
Appendices - 521
FEISfor the Revision of the Western Oregon RMPs
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Appendix P - Lands
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Appendices - 531
FEISfor the Revision of the Western Oregon RMPs
Table P-4. Existing Land Withdrawals And Recommendations For Continuance In The Coos
Bay District
Serial Number
Order Number
Legal Description
Acres
Purpose/Name
Managing
Agency
Segregation
Effect
Recommendation
(C/R)
OR 50856
PLO 7215
19S 12W Sec. 1
40.43
Pacific Coastline, Highway 101
BLM
B
C - serving original
OR 50856
PLO 7215
26S14W Sec. 28
40
Pacific Coastline, Highway 101
BLM
B
purpose, revoke
patented parcel.
OR 50856
PLO 7215
27S 14W Sec. 29
2.26
Pacific Coastline, Highway 101
BLM
B
C
OR 50856
PLO 7215
30S 15W Sec. 12
40
Pacific Coastline, Highway 101
BLM
B
C
OR 50856
PLO 7215
32S 15W Sec. 4
71.75
Pacific Coastline, Highway 101
BLM
B
C
OR 50856
PLO 7215
33S14W Sec. 31
155.16
Pacific Coastline, Highway 101
BLM
B
C
OR 50856
PLO 7215
34S14W Sec. 6
40.7
Pacific Coastline, Highway 101
BLM
B
C
OR 50856
PLO 7215
34 S 14W Sec.33
162.05
Pacific Coastline, Highway 101
BLM
B
C
OR 50856
PLO 7215
34S 14W Sec. 34
40
Pacific Coastline, Highway 101
BLM
B
C
OR 50856
PLO 7215
34 S 15W Sec. 1
7.92
Pacific Coastline, Highway 101
BLM
B
C
OR 50856
PLO 7215
38S 14W Sec. 4
40
Pacific Coastline, Highway 101
BLM
B
C
OR 50856
PLO 7215
38S14W Sec. 5
40
Pacific Coastline, Highway 101
BLM
B
C
OR 50856
PLO 7215
38S14W Sec. 34
34
Pacific Coastline, Highway 101
BLM
B
C
OR 50856
PLO 7215
39S 14W Sec. 23
40
Pacific Coastline, Highway 101
BLM
B
C
OR 50856
PLO 7215
41S 13W Sec. 6
2.56
Pacific Coastline, Highway 101
BLM
B
C
OR 50856
PLO 7215
41S13W Sec. 7
0.32
Pacific Coastline, Highway 101
BLM
B
C
ORE 016183C
PLO 3869
20S 9W Sec. 31
81.29
Smith River Falls Recreation Site
BLM
B
C - Developed Sites
ORE 016183C
PLO 3869
20S 9W Sec. 33
3.5
Vincent Creek Recreation Site
BLM
B
C
ORE 016183C
PLO 3869
23S10W Sec. 2
78.86
Loon Lake Recreation site
BLM
B
C
ORE 016183C
PLO 3869
27S10W Sec. 4
60
Park Creek Recreation Site
BLM
B
C
ORE 016183C
PLO 3869
27S 10W Sec. 18
20
Big Tree Recreation Site
BLM
B
C
ORE 016183C
PLO 3869
30S 9W Sec. 9
80
Bear Creek Recreation Site
BLM
B
C
ORE 01 61 830
PLO 3869
32S 14 W Sec. 12
120
Sixes River Recreation Site
BLM
B
C
ORE 016183C
PLO 3869
Total acres
443.65
OR 23558
SO 12-31-1930
23S 10W Sec. 1
51.51
Rec Wdl. No. 43 East Shore
Recreation Site
BLM
B
C - Developed Site
OR 1 9291 A
PLO 3530
27S 10W Secs. 17-20
590
Cherry Creek Natural Area
BLM
B
C - Protecting site, for
research opportunities
OR 6398
PL 181
27S 11 W Sec. 35
120
Lavern County Park
BLM / Coos
Cnty
B
C - Developed County
Park
OR 6398
PL 181
27S12W Sec. 35
160
Rock Prairie County Park
BLM / Coos
Cnty
B
C - Developed County
Park
OR 6398
PL 181
28S 9W Sec. 7
87.72
Judge Hamilton County Park
BLM / Coos
Cnty
B
C - Developed County
Park
OR 6398
PL 181
28S 11 W Sec. 5
80
Middle Creek County Park
BLM / Coos
Cnty
B
C - Potential for
County Park
Development
OR 6398
PL 181
28S 11 W Sec. 11
80
Frona County Park
BLM / Coos
Cnty
B
C - Developed County
Park
OR 6398
PL 181
Total acres
527.72
OR 21318
SO 6-12-1907
40S 13W Secs. 11, 14
320.75
Potential National Park
BLM
B
R - Not developed.
No planned
development. No
public support for
establishment of park
or monument.
OR 19231
EO 11-24-1903
22S 13W Sec. 14
71.1
Umpqua Jetty Maintenance
COE
B
R - COE indicated a
desire to relinquish.
OR 21901
EO 8-23-1895
22S 13W Sec. 13
130
Umpqua River Light Station
USCG
B
R - USCG indicated a
desire to relinquish.
Appendices - 532
Appendix P - Lands
Serial Number
Order Number
Legal Description
Acres
Purpose/Name
Managing
Agency
Segregation
Effect
Recommendation
(C/R)
OR 4011
EO 7-14-1884
26S 14W Secs. 2,3
5.1
Bar Watch Administrative Site
USCG
B
C - serving original
purpose
OR 19227
EO 7-14-1884
26S14W Sec. 2
2.43
Military Facility
US Navy
B
C - serving original
purpose
OR-22094
EO 6/14/1876
26S 14W Sec. 4
21.58
Sub Surface only / Cape Arago
Lighthouse
USCG
R
ORE 012693
PLO 5490
All Public Domain
lands
50,329
Multiple use management
BLM
Surface
closed to Ag
laws
C - serving original
purpose
OR 54142
PLO 7436
25S 13W Secs.
4-8,18,19
See total
acres
below.
North Spit Rec Area and ACEC
BLM
Closed to the
mining laws
C - serving original
purpose
OR 54142
PLO 7436
25S 14W Secs.
12,13,23-26
North Spit Rec Area and ACEC
BLM
Closed to the
mining laws
C
OR 54142
PLO 7436
Total acres
1,779.27
OR 24294
PL 95-450
26S14W Secs. 5,8,17-
19
15
Oregon Islands NWR
USFW
A
C - serving purpose
OR 24294
PL 95-450
27S 14W Sec. 19
8
Oregon Islands NWR
USFW
A
OR 24294
PL 95-450
28S 15W Secs.
25,26,35
3.56
Oregon Islands NWR
USFW
A
OR 24294
PL 95-450
29S15W Sec. 2
4
Oregon Islands NWR
USFW
A
OR 24294
PL 95-450
31S 16W Secs.
24,25,34,35
30
Oregon Islands NWR
USFW
A
OR 24294
PL 95-450
32S 16W Secs.
2,3,10,17,21,28-31
54
Oregon Islands NWR
USFW
A
OR 24294
PL 95-450
33S 15W Secs.
6,8,21,22,33
38
Oregon Islands NWR
USFW
A
OR 24294
PL 95-450
34S14W Sec. 30
Oregon Islands NWR
USFW
A
OR 24294
PL 95-450
34S15W Sec. 31
31.83
Oregon Islands NWR
USFW
A
OR 24294
PL 95-450
36S 15W Secs.
2,11,15-17
32
Oregon Islands NWR
USFW
A
OR 24294
PL 95-450
38S 14W Secs. 30,31
12
Oregon Islands NWR
USFW
A
OR 24294
PL 95-450
38S 15W Sec. 1
16
Oregon Islands NWR
USFW
A
OR 24294
PL 95-450
39S 14W Secs.
6,8,16,17
30
Oregon Islands NWR
USFW
A
OR 24294
PL 95-450
40S 14W Secs.
4,16,22,26
38
Oregon Islands NWR
USFW
A
OR 711
PLO 4395
28S 15W Sec. 25
See total
acres
below.
Oregon National Wildlife Refuge
USFW
B
C - serving original
purpose
OR 711
PLO 4395
31S 16W Secs.
24,25,34
Oregon National Wildlife Refuge
USFW
B
C
OR 711
PLO 4395
31 S 15W Sec. 35
Oregon National Wildlife Refuge
USFW
B
C
OR 711
PLO 4395
32S 16W Secs.
17,21,28-31
Oregon National Wildlife Refuge
USFW
B
C
OR 711
PLO 4395
33S 15W Secs.
21,22,33
Oregon National Wildlife Refuge
USFW
B
C
OR 711
PLO 4395
34 S 15W Sec. 4
Oregon National Wildlife Refuge
USFW
B
C
OR 711
PLO 4395
36S 15W Secs. 2,11
Oregon National Wildlife Refuge
USFW
B
C
OR 711
PLO 4395
38S 15W Sec. 1
Oregon National Wildlife Refuge
USFW
B
C
OR 711
PLO 4395
38S 14W Secs. 30,31
Oregon National Wildlife Refuge
USFW
B
C
OR 711
PLO 4395
39S 14W Secs.
6,8,16,17
Oregon National Wildlife Refuge
USFW
B
r*
U
OR 711
PLO 4395
40S 14W Secs. 4,22
Oregon National Wildlife Refuge
USFW
B
C
OR 711
PLO 4395
Total acres
222.56
Appendices - 533
FEISfor the Revision of the Western Oregon RMPs
Serial Number
Order Number
Legal Description
Acres
Purpose/Name
Managing
Agency
Segregation
Effect
Recommendation
(C/R)
OR 50874
PLO 7170
29S15W Secs. 35, 36
70.9
Lost Lake
BLM
B
C - serving original
purpose
OR 45401
PLO 6967
30S 15W Secs.
2,3,10,11,15,
21,28,32,33
963.38
New River ACEC
BLM
B
C - serving original
purpose
OR 51194
PLO 7170
31S15W Secs. 7,8
111.48
Floras Lake
BLM
B
C - serving original
purpose
OR 51891
PLO 7246
32S 14W Sec. 6
44.48
Edson Creek Rec Site
BLM
B
C - serving original
purpose
OR 24293
PL 91-504
40S14W Sec. 22
21
Oregon Islands NWR
USFW
A
C - serving original
purpose
OR 22376
EO 7035
40S14W Sec. 35
21
Oregon Islands NWR
USFW
B
C - serving original
purpose
OR 25306
PLO 6287
Unsurveyed Islands
rocks reefs
Oregon National Wildlife Refuge
USFW
B
C - serving original
purpose
OR 11517
EO 5-6-1935
Unsurveyed Islands
rocks reefs
100
Oregon Islands NWR Addition
USFW
B
C - serving original
purpose
OR 19130
SO of 4/30/1921
27S 11 W Sec. 35
40
Water Power Potential/ PSC 1
BLM
D
R - unless viable for
hydropower
OR 19130
SO of 4/30/1921
28S 10W Secs.
6,8,12,14
165.26
Water Power Potential/ PSC 1
BLM
D
R - unless viable for
hydropower
OR 19140
SO of 6/1 /1 926
27S 10W Sec. 31
115.35
Water Power Potential/ PSC 147
BLM
D
R - unless viable for
hydropower
OR 19140
SO of 6/1 /1 926
27S 11W Sec. 35
236.72
Water Power Potential/ PSC 147
BLM
D
R - unless viable for
hydropower
OR 19140
SO of 6/1/1926
28S 10W Secs. 5,6
169.26
Water Power Potential/ PSC 147
BLM
D
R - unless viable for
hydropower
OR 19140
SO of 6/1 /1 926
28S 11 W Sec. 1
320
Water Power Potential/ PSC 147
BLM
D
R - unless viable for
hydropower
OR 19140
SO of 6/1/1926
Total acres
841.33
OR 19144
SO of 7/19/1926
22S 8W Secs. 4***,
7,9,17,21
276.1
Water Power Potential/ PSC 162
BLM
D
R - unless viable for
hydropower
OR 19144
SO of 7/1 9/1 926
22S 9W Secs. 7-9
109.44
Water Power Potential/ PSC 162
BLM
D
R - unless viable for
hydropower
OR 19144
SO of 7/1 9/1 926
23S 8W Sec. 13
80
Water Power Potential/ PSC 162
BLM
D
R - unless viable for
hydropower
OR 19144
SO of 7/19/1926
Total acres
465.54
OR 19152
SO of 2/1 5/1 928
22S 9W Sec. 7
183.93
Water Power Potential/ PSC 198
BLM
D
R - unless viable for
hydropower
OR 20365
EO of 5/28/1912
20S 9W Secs.
26,28,32,34
245.22
Water Power Potential/ PSR 273
BLM
D
R - unless viable for
hydropower
OR 20365
EO of 5/28/1912
21S8W Secs. 2***, 4***
320
Water Power Potential/ PSR 273
BLM
D
R - unless viable for
hydropower
OR 19101
EO of 8/7/1917
20S 8W Secs.
17,19,21,27,33
186.57
Water Power Potential/ PSR 629,
BLM
D
R - unless viable for
hydropower
OR 19101
EO of 8/7/1 91 7
20S 9W Secs.
21,25,27,31,33,35
1,508.32
Water Power Potential/ PSR 629
BLM
D
R - unless viable for
hydropower
OR 19101
EO of 8/7/1917
21S8W Secs. 1,9,11
616.26
Water Power Potential/ PSR 629
BLM
D
R - unless viable for
hydropower
OR 19101
EO of 8/7/1917
Total acres
2,311.15
OR 19011
SO of 7/1 3/1 91 7
20S 9W Secs.
21,25,27,31,33,35
1,362.74
Water Power Potential/ WPD 11
BLM
R - unless viable for
hydropower
OR 19011
SO of 7/13/1917
20S 8W Secs.
17,19,21,27,31,33
1,586.55
Water Power Potential/ WPD 11
BLM
R - unless viable for
hydropower
Appendices - 534
Appendix P - Lands
Serial Number
Order Number
Legal Description
Acres
Purpose/Name
Managing
Agency
Segregation
Effect
Recommendation
(C/R)
OR 19011
SO of 7/13/1917
21S8W Secs. 1,9,11
1,062.95
Water Power Potential/ WPD 11
BLM
D
R - unless viable for
hydropower
OR 19011
SO of 7/13/1917
22S9W
Secs. 7, 13, 15***, 17
282.52
Water Power Potential/ WPD 11
BLM
D
R - unless viable for
hydropower
OR 19011
SO of 7/13/1917
22S 8W Secs. 5,21
20.03
Water Power Potential/ WPD 11
BLM
D
R - unless viable for
hydropower
OR 19011
SO of 7/1 3/1 91 7
22S 7W Sec. 19
47.45
Water Power Potential/ WPD 11
BLM
D
R - unless viable for
hydropower
OR 19011
SO of 7/13/1917
23S 10W
Secs. 1,11***, 13, 35
37.38
Water Power Potential/ WPD 11
BLM
D
R - unless viable for
hydropower
OR 19011
SO of 7/13/1917
23S 9W Secs.
j*** j***
200.21
Water Power Potential/ WPD 11
BLM
D
R - unless viable for
hydropower
OR 19011
SO of 7/13/1917
23S 7W Secs.
5,7,9,15,19***,
21,23,27,31,33
887.79
Water Power Potential/ WPD 11
BLM
D
R - unless viable for
hydropower
OR 19102
EO of 6/29/1917
22S 8W Sec. 24
3
Protect water power and reservoir
potential/ PSR 630
BLM
D
R - unless viable for
hydropower.
OR 19105
EO of 7/24/1917
22S 7W Sec. 19
29.93
Water Power Potential/ PSR 633
BLM
D
R - unless viable for
hydropower
OR 19105
EO of 7/24/1917
22S 8W Secs. 5,21
20.03
Water Power Potential/ PSR 633
BLM
D
R - unless viable for
hydropower
OR 19105
EO of 7/24/1917
22S 9W Secs. 7,13,
15***, 17
282.52
Water Power Potential/ PSR 633
BLM
D
R - unless viable for
hydropower
OR 19105
EO of 7/24/1917
23S 7W Secs.
5,7,9,15,19***,
21,23,27,31,33
887.79
Water Power Potential/ PSR 633
BLM
D
R - unless viable for
hydropower
OR 19105
EO of 7/24/1917
23S 8W Sec. 11
29.38
Water Power Potential/ PSR 633
BLM
D
R - unless viable for
hydropower
OR 19106
EO of 7/17/1917
22S 10W Sec. 35
239.95
Water Power Potential/ PSR 634
BLM
D
R - unless viable for
hydropower
OR 19106
EO of 7/17/1917
23S 9W Secs.
j*** j*** -j g***
200.21
Water Power Potential/ PSR 634
BLM
D
R - unless viable for
hydropower
OR 19106
EO of 7/17/1917
23S 10W Secs. 1, 13
211.51
Water Power Potential/ PSR 634
BLM
D
R - unless viable for
hydropower
OR 19106
EO of 7/17/1917
Total acres
651.67
OR 19109
EO of 7/17/1917
23S 10W Sec. 35
40
Water Power Potential / PSR 645,
BLM
D
R - unless viable for
hydropower
OR 19012
SO of 7/13/1917
23S10W Sec. 35
40
Water Power Potential/ WPD 12
BLM
D
R - unless viable for
hydropower
OR 19113
EO of
12/12/1917
26S 9W Secs.
^ J*** ^ g*** 2g*** g^***
Water Power Potential / PSR 659
BLM
D
R - unless viable for
hydropower
OR 19113
EO of
12/12/1917
27S 11 W Sec. 15
182.8
Water Power Potential / PSR 659
BLM
D
R - unless viable for
hydropower
OR 19113
EO of
12/12/1917
30S 9W Secs. 9,17
120
Water Power Potential / PSR 659
BLM
D
R - unless viable for
hydropower
OR 19113
EO of
12/12/1917
30S10W Secs. 3,13
280
Water Power Potential / PSR 659
BLM
D
R - unless viable for
hydropower
OR 19014
SO of
12/12/1917
26S 9W Secs.
/j -j*** -j g*** 29*** 0^***
Water Power Potential / WPD 14
BLM
D
R - unless viable for
hydropower
OR 19014
SO of
12/12/1917
27S 11 W Sec. 15
187
Water Power Potential / WPD 14
BLM
D
R - unless viable for
hydropower
OR 19014
SO of
12/12/1917
30S 9W Secs. 9,17
200
Water Power Potential / WPD 14
BLM
D
R - unless viable for
hydropower
OR 19014
SO of
12/12/1917
30S10W Sec. 3,13
280
Water Power Potential / WPD 14
BLM
D
R - unless viable for
hydropower
Appendices - 535
FEISfor the Revision of the Western Oregon RMPs
Serial Number
Order Number
Legal Description
Acres
Purpose/Name
Managing
Agency
Segregation
Effect
Recommendation
(C/R)
OR 19017
SO of 1/12/1921
27S 11 W Secs.
5*** y**** i y
19, 21****, 29, 31, 33****
2,418.76
Water Power Potential / WPD 1 7
BLM
D
R - unless viable for
hydropower
OR 19017
SO of 1/12/1921
27S 12W Secs.
1 1 *** 1 3*** 23***
25***,
27***, 35***
1,663.57
Water Power Potential / WPD 17
BLM
D
R - unless viable for
hydropower
OR 19017
SO of 1/12/1921
28S 9W Sec. 7
335.2
Water Power Potential / WPD 17
BLM
D
R - unless viable for
hydropower
OR 19017
SO of 1/12/1921
28S10W Seca.3, 5, 9,
11, 15***
1,296.28
Water Power Potential / WPD 17
BLM
D
R - unless viable for
hydropower
OR 19017
SO of 1/12/1921
28S 11 W Secs.
1,3, 5***, 7
883.12
Water Power Potential / WPD 17
BLM
D
R - unless viable for
hydropower
OR 19017
SO of 1/12/1921
28S 12W Secs.
/j **** 0***
11 ***,13,15***21***,
1,516
Water Power Potential / WPD 17
BLM
D
R - unless viable for
hydropower
OR 19017
SO of 1/12/1921
Total acres
8,112.93
OR 19142
SO of 12/4/1926
22S 10W Secs.
15*** 21*** 22***
26*** 27*** 64***
Water Power Potential / PSC 157
BLM
D
R - unless viable for
hydropower
OR 19142
SO of 12/4/1926
23S 10W Sec. 2***
76.86
Water Power Potential / PSC 157
BLM
D
R - unless viable for
hydropower
OR 19142
SO of 12/4/1926
24S 8W Sec. 31***
Water Power Potential / PSC 157
BLM
D
R - unless viable for
hydropower
OR 19116
EO of
12/12/1917
26S 9W
Secs. 10***, 14***
640
Water Power Potential / PSR 662
BLM
D
R - unless viable for
hydropower
OR 19116
EO of
12/12/1917
32S13W Secs. 17,
PB 37
387
Water Power Potential / PSR 662
BLM
D
R - unless viable for
hydropower
OR 19116
EO of
12/12/1917
32S14W Secs 11,12
160
Water Power Potential / PSR 662
BLM
D
R - unless viable for
hydropower
EO of
12/12/1910
25S12W Secs. 29-33
400
Resource Protection/ Coal Lands
BLM
OR-19180
USGS Order of
7/15/1947
26S 8W Sec. 8
80
Water Power Potential / PSC 382
BLM
D
R - unless viable for
hydropower
ORE 0 13683
PLO 4448
29.5 S 7W Secs. 32
4.3
Reclamation Project/ Umpqua river
COE
B
C
OR 19142
Water Power Potential / PSC 157
BLM
D
DO: Director Order
EO: Executive Order
SO: Secretarial Order
BO: Bureau Order
DO: Director Order
PL: Public Law
PLO: Public Land Order
PSR: Power Site Reserve
PSC: Power Site Classification
R&PP: Recreation and Public Purposes
WPD: Water Power Designation
FPCO: Federal Power Commission
FO: Federal Energy Regulatory Commission Order
Segregation Effect:
A: Withdrawn from operation of the general land laws, the Mining law, and the
Mineral Leasing Act
B: Withdrawn from operations of the General Land and Mining Laws
C: Withdrawn from operation of the General Land Law
D: Withdrawn from operation of the General Land Law; open to mining subject
to Public Law 359
E: Withdrawn from operation of the General Land Law; withdrawn from mining
except metalliferous
Recommendation:
C - Continue R - Revoke
*** Opened to entry subject to Sec. 24 of the Federal Power Act.
**** Opened to entry in part subject to Sec. 24 of the Federal Power Act.
Notes: Location description indicates sections within which withdrawn lands are located. Information on which portions of the cited sections are withdrawn is
available at the Coos Bay BLM District Office.
Table does not include lands that have been completely transferred out of Federal ownership subsequent to withdrawal or lands within National Forest boundaries.
Appendices - 536
Appendix P - Lands
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Appendices - 537
FEISfor the Revision of the Western Oregon RMPs
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Appendix P - Lands
Table P-7. Land Tenure Zone 3 Lands In The Salem District
Township
Range
Section
Subdivision
Acres
Status
**Location on Map 2-5
3 N
1 W
9
Lot 8
1.24
Ot
1
3 N
8 W
10
NWNE
40.00
PD
2
3 N
8 W
11
Lot 2
0.01
PD
3
5 N
6 W
6
Lot 9
2.12
PD
4
5 N
7 W
10
SWNE
40.00
PD
5
7 N
4 W
6
Lot 7
0.03
PD
6
1 S
3 W
7
Lot 1
0.18
OC
7
1 S
3 W
8
Lot 1
0.05
PD
8
2 S
2 E
4
Lot 2
0.04
PD
9
2 S
2E
9
Lot7
0.11
Ot
10
2 S
3 E
23
Lots 8, 12
6.25
OC
11
2 S
3 E
25
Lots 7, 8
1.69
OC
12
2 S
3 W
13
N1/2.SW1/4
80.00
OC
13
2 S
3 W
23
N/2NE, NENW
120.00
OC
14
2 S
4 W
31
Lot 1
1.30
OC
15
2 S
9 W
7
UN Lot
0.19
PD
16
3 S
2 E
7
Lot 1
0.87
OC
17
3 S
4 W
33
Lot 4
0.11
OC
18
3 S
9 W
20
NWNE
40.00
PD
19
3 S
9 W
28
SWSE
40.00
PD
20
3 S
9 W
33
NWNE
40.00
PD
21
3 S
10 W
30
Lot 15
0.45
PD
22
4 S
1 E
21
Lot 1
0.49
OC
23
4 S
2 E
11
NENE, SWNE, E/2SW, NWSE
200.00
OC
24
4 S
2 E
15
NWSE, SESE
80.00
OC
25
4 S
2 E
23
SWNW
40.00
OC
26
4 S
2 E
33
Lots 1 , 2
1.80
OC
27
4 S
3 E
9
SWNE, NWSE
80.00
OC
28
4 S
3 E
19
UN Lot
47.31
OC
29
4 S
3 E
21
E/2NE, SWNW, N/2SW
200.00
OC
30
4 S
3 E
29
E/2NE
80.00
OC
31
4 S
3 E
31
S/2NE, NWSE
120.00
OC
32
4 S
1 W
22
UN Lot
0.50
PD
33
4 S
3 W
2
Lot 1
0.25
PD
34
4 S
3 W
34
Lots 1 , 2
4.40
PD
35
4 S
10W
28
Lot 3
0.53
PD
36
5 S
3 W
4
Lot 1
1.16
PD
37
5 S
5 W
13
Lot 3
0.05
OC
38
5 S
5 W
31
Lot 1
3.57
OC
39
5 S
5 W
34
Lot 1
0.93
PD
40
5 S
5 W
35
Lot 1
8.00
OC
41
6 S
3 W
2
Lot 2
0.20
PD
42
6 S
3 W
5
Lot 1
2.00
OC
43
6 S
1 E
13
E/2NW, SWNW
120.00
OC
44
6 S
1 E
25
NWNE, SENW
80.00
OC
45
6 S
10 W
35
SENE
40.00
PD
46
7 S
1 E
1
SESW
40.00
OC
47
7 S
1 E
23
SESE
40.00
OC
48
7 S
3 W
29
Lot 3
5.42
OC
49
7 S
6 W
34
SWSE
40.00
OC
50
8 S
1 E
3
SWNW, SW
200.00
OC
51
Appendices - 547
FEISfor the Revision of the Western Oregon RMPs
Township
Range
Section
Subdivision
Acres
Status
**Location on Map 2-5
8 S
1 E
27
NESW
40.00
OC
52
8 S
1 E
35
Lots 1,2, NWNW, S/2
400.22
oc
53
8 S
4 W
24
M&B
1.54
ot
54
8 S
4 W
25
M&B
8.00
ot
55
8 S
10 W
20
WNWNW
20.00
PD
56
8 S
11 W
3
Lot 8
4.73
PD
57
9 S
1 W
21
Lot 7, NWNE
84.21
OC
58
9 S
3 W
21
Lot 3
0.08
Ot
59
9 S
3 W
24
UN Lot
1.40
PD
60
9 S
3 W
32
Lot 2
4.60
PD
61
9 S
4 W
9
Lot 5
1.16
OC
62
9 S
4 W
14
Lot 9
0.17
PD
63
9 S
5 W
32
Lots 1 , 2
2.90
PD
64
9 S
9 W
19
Por Lot 29
10.00
PD
65
9 S
9 W
33
Lot 17
20.00
PD
66
9 S
9 W
34
W/2NWSW
20.00
PD
67
9 S
10 W
26
SWNW
40.00
PD
68
9 S
10 W
36
POR Lots 5, 6
10.00
PD
69
9 S
11 W
1
Lot 6
1.46
PD
70
9 S
11 W
4
SWSW
40.00
PD
71
10 S
2 W
8
Lot 1
6.13
PD
72
10 S
3 W
24
Lot 6
0.90
PD
73
10 S
4 W
11
Lot 5
1.52
OC
74
10 S
5 W
19
Lots 1-4, NE, E/2NW, E/2SW
480.00
OC
75
10 S
5 W
23
Lot 4
0.79
OC
76
10 S
6 W
22
Lots 2, 3
15.70
PD
77
10 S
7 W
18
SWNE, SESW, W/2SE
160.00
PD
78
10 S
10W
2
Lot 20
20.00
PD
79
11 S
3 W
1
Lot 11
0.15
Ot
80
11 s
7 W
14
Lot 5
0.14
PD
81
11 s
7 W
23
Lots 1 , 2
1.39
Ot
82
11 s
8 W
6
NESW, NWSE, SESE
120.00
PD
83
11 s
9 W
31
Lot 2
43.25
PD
84
11 s
10W
12
N/2NE, NWSW, NESE
160.00
PD
85
11 s
10W
14
Lot 1
2.87
PD
86
11 s
10 W
15
Lot 13
3.85
PD
87
11 s
10W
23
NESE
40.00
PD
88
11 s
10 W
24
SWSW
40.00
PD
89
11 s
10 W
25
Lot 1
37.22
PD
90
11 s
10 W
36
SESE
40.00
PD
91
12 S
3 E
23
SESW, SWSE
80.00
PD
92
12 S
4 E
30
SESW
40.00
PD
93
12 S
4 E
31
Lot 1, NENW
84.81
PD
94
12 S
1 W
34
Lot 10
11.45
PD
95
12 S
2 W
13
Lot 6
7.04
Ot
96
12 S
4 W
1
Lot 3
0.23
OC
97
12 S
6 W
35
Lot 3
0.20
Ot
98
12 S
8 W
6
Lot 7
40.18
PD
99
12 S
8 W
7
Lots 1 , 2
79.04
PD
100
12 S
9 W
29
E/2NE, SESE
120.00
PD
101
12 S
9 W
32
E/2NE, SWNE
120.00
PD
102
Appendices
548
Appendix P - Lands
Township
Range
Section
Subdivision
Acres
Status
**Location on Map 2-5
12 S
9 W
34
NENW
40.00
PD
103
12 S
9 W
35
NENW, S/2SW
120.00
PD
104
12 S
10 W
6
SWSE
40.00
PD
105
12 S
10W
14
NENE
40.00
PD
106
12 S
11 W
10
Lots 3, 4
76.16
PD
107
12 S
11 W
17
Lot 5
38.84
PD
108
13 S
3 E
9
NENE
40.00
PD
109
13 S
3 E
24
N/2NE, SENE
120.00
PD
110
13 S
2 W
21
NWNE
40.00
OC
111
13 S
4 W
30
Lot 5
8.49
PD
112
13 S
5 W
29
Lot 1
0.84
OC
113
13 S
9 W
10
E/2NE, NESE
120.00
PD
114
13S
9 W
13
NWNW
40.00
PD
115
13 S
11 W
3
SWSE
40.00
PD
116
13 S
11 W
28
Lot 9
7.60
PD
117
13 S
11 W
33
NESE
40.00
PD
118
14 S
5 W
25
Lot 1
0.26
OC
119
14 S
11 W
3
Lots 1, 2, 25
111.50
PD
120
14 S
11 W
4
Lots 29, 30
84.30
PD
121
14 S
11 W
5
Lot 10
40.62
PD
122
14 S
11 W
6
Lot 16
40.00
PD
123
14 S
11 W
10
Lots 1, 11-13, 17
210.21
PD
124
14 S
11 W
15
NESE
40.00
PD
125
14 S
12 W
35
SENE
40.00
PD
126
15 S
5 W
6
Lot 5
1.46
PD
127
Total Acres
5,698.86
E = East N = North S = South W = West UN = Unnumbered PD = Public Domain Land
OC = Oregon and California Railroad Land Ot = Other Sources: Western Oregon Digital Base and District realty records
** Map 2-5 is in Chapter 2 of the EIS
Appendices - 549
FEISfor^ lilt' Revision, of the Westerly Oregon^ RMPs^
Table P-8. Land Tenure Zone 3 Lands In The Eugene District
Township
Range
Section
Subdivision
Acres
Status
"Location on Map 2-5
14 S
2 W
13
Lots 4-5 (part)2
2.00
O&C1
128
15 S
2 W
25
SE1/4SE1/4(part)
5.00
O&C*1
129
17 S
3 W
15
Lots 6, 9
1.30
O&C3
130
16 S
3 W
30
Lot 3
15.28
PD*
131
16 S
6 W
7
Lot 6
3.76
O&C*
132
16 S
7 W
11
HWASEA (part)
2.50
O&C*1
133
18 S
1 W
5
Lot 8 (part)
0.50
O&C
134
18 S
1 W
26
Lot 7
1.68
PD
135
18 S
7 W
11
NE%NE% (part)
3.00
O&C1
136
18 S
9 W
7
SE1/4SW
40.00
PD*
137
18 S
10W
11
Lot 9
6.24
PD
138
18 S
11 W
18
SE1/4SE
40.00
PD*
139
18 S
12 W
15
SE1/4NE/1/4
40.00
PD*
140
19 S
3 W
35
Lot32
2.79
O&C
141
19 S
4 W
29
HEASWA (part)
0.36
O&C1
142
21 S
1 W
31
Lot 13
1.42
O&C
143
22 S
1 W
5
Lot 18
0.25
O&C*1
144
Total Acres
166.08
’Acreage is approximate until cadastral survey is completed.
Tract may be sold only to current R&PP lessee so long as case is in effect.
3Actual acreage may vary due to erosion and accretion.
* These listings were not included in the 1995 RMP
E = East N = North S = South W =
OC = Oregon and California Railroad Land
** Map 2-5 is in Chapter 2 of the EIS
West UN = Unnumbered PD = Public Domain Land
Ot = Other Sources: Western Oregon Digital Base and District realty records
Table P-
g. Land Tenure Zone 3 Lands In The Roseburg District
Township
Range
Section
Subdivision
Acres
Status
‘‘Location on Map
2-5
26S
2 W
17
NENESESE (part North of Highway 138)
0.30
O&C
145
30 S
2 W
34
SESW
40.00
PD
146
26 S
4 W
10
Loti
7.00
PD
147
26 S
4 W
17
Lots 9 and 10
12.00
O&C
148
27 S
4 W
7
Lot 2
4.00
O&C
149
28 S
4 W
29
SENE
40.00
O&C
150
30 S
4 W
1
Lot 9
4.00
O&C
151
24 S
5 W
29
Lot 5
28.00
O&C
152
28 S
5 W
28
NWNW
40.00
PD
153
28 S
5 W
29
E2NE
80.00
O&C
154
24 S
6 W
27
W1/2, SWSE
360.00
O&C
155
25 S
6 W
3
NWNE, NESW, NESE
122.00
O&C
156
25 S
6 W
33
SESE
40.00
O&C
157
26 S
6 W
3
SENE, NESE
80.00
O&C
158
26 S
6 W
17
Lot 2, SENW, SESW, SWSE
126.00
O&C
159
30 S
6 W
18
Lots 1 and 2
39.00
PD
160
Total Acres
1,022.30
E = East N = North S = South W = West UN = Unnumbered PD = Public Domain Land
OC = Oregon and California Railroad Land Ot = Other Sources: Western Oregon Digital Base and District realty records
** Map 2-5 is in Chapter 2 of the EIS
Appendices - 550
Appendix P - Lands
Table P-io. Land Tenure Zone 3 Lands In The Coos Bay District
Township
Range
Section
Subdivision
Acres
Status
“Location on Map 2-5
19S
12W
1
Lots 1,2
40.48
PD
161
20S
9W
33
Lot 7
3.98
O&C
162
20S
10W
31
Por. Lot 10
q 00
163
20S
11W
36
Por. Lot 9
o . y o
Mcq.
164
21S
11W
31
Lot 18
37.22
PD
165
21S
11W
32
Lots 16, 23
59.01
PD
166
22S
8W
15
Lot 9, 10
25.30
O&C
167
22S
13W
14
Lots 1,2
71.10
PD
168
25S
11W
30
Lot 5
39.92
PD
169
25S
13W
4
N1/2NW1/4
80.00
PD
170
25S
13W
7
Lots 6,8, 13, 14, 15
92.78
PD
171
25S
13W
18
Lot 7, E1/2NW1/4
96.15
PD
172
26S
08W
10
SE1/4NE1/4
40.00
PD
173
26S
11W
8
NW1/4NE1/4
40.00
PD
174
26S
12W
9
Por. SE1/4SW1/4
4.00
Acq.
175
26S
14W
3
Pors. Lots 1,2, SE1/4NW1/4
62.18
PD
176
26S
14W
28
NW1/4NE1/4
40.00
PD
177
28S
12W
19
SE1/4SE1/4
40.00
CBWR
178
30S
12W
5
Lot 6
1.80
O&C
179
30S
12W
6
Lots 3,4
1.14
PD
180
30S
13W
21
N1/2NE1/4NW1/4
20.00
PD
181
32S
14W
7
N1/2SW1/4NE1/4NW1/4
5.00
PD
182
NE1/4SE1/4NE1/4,
32S
15W
4
S1/2NE1/4NE1/4,
71 7rL
PD
183
W1/2SE1/4NE1/4,
1 \ .10
Lots 1,2, 3,4
39S
12W
8
W1/2NW1/4
80.00
PD
184
Total Acres
957.79
E = East N
= North
S = South
W = West UN = Unnumbered
PD = Public Domain Land
OC = Oregon and California Railroad Land Ot = Other Sources: Western Oregon Digital Base and District realty records
** Map 2-5 is in Chapter 2 of the EIS
Appendices - 551
FEISfor the Revision of the Western Oregon RMPs
Table P-11. Land Tenure Zone 3 Lands In The Medford District
Township
Range
Section
Subdivision
Acres
Status
‘‘Location on Map 2-5
34 S
6 W
22
HWASEVa,
40.00
PD
185
33
SWASWA] EViSWA]
120.00
OC
186
35
NWAUEVa]
40.00
OC
187
35 S
1 W
15
UWASEVa]
40.00
OC
188
35 S
5 W
31
SE%NW %, SW%, WVjSE1^;
280.00
OC
189
32
SWViNEVi; WASEYa, NE!4SE%;
160.00
PD
190
35 S
6 W
5
S'AUEVa, SEVaSWA , SEV4;
280.00
OC
191
7
NEViNEl*, IMNW1/*, SWAUWA,
200.00
OC
192
SEViNEVi;
11
EVzNEVi, SW%NE!4, NEViSE%;
160.00
OC
193
14
NWy.SE1/.;
40.00
PD
194
17
NE14NE14, NW%NW%;
80.00
OC
195
19
NE%, NV2NWV4;
240.00
OC
196
21
NE%NE%;
40.00
OC
197
29
NWViNWVi;
40.00
OC
198
30
sy2s%;
80.00
PD
199
31
SW1/4NE1/4, WVz, NVWSE1/*;
400.00
OC
200
33
EVzNEVi, E^NWVi, NWy.NW1^,
SEViSEVi;
240.00
OC
201
36 S
3 W
21
NE%SW!4;
40.00
OC
202
33
SWASWA ,
40.00
OC
203
NW1/4SE1/4SW1/4;
10.00
PD
35
NE%NE1/4;
40.00
OC
204
36 S
4 W
25
SE'ASWA , S'ASWASE'A]
60.00
OC
205
35
Lot 5, WASWA]
112.40
OC
206
36 S
5 W
4
E'AHWA, NV2SWV4;
160.00
PD
207
5
SEVJNEVi, E%SE%;
80.00
OC
208
9
WfcE/z, EVzW^, E'AUWASWA]
340.00
OC
209
29
SYzSWA]
80.00
OC
210
36 S
6 W
1
Lots 2,3,4, S!4NE!4, NYzSW1/^
sei/4Nwi/4, wyzSEVi, sE'ysE'y;
440.00
OC
211
3
SW%, S%SEV4
240.00
OC
212
4
W/2W/2
160.00
PD
213
5
EVzSEVa, SWAHWA, WASWA]
200.00
OC
214
8
WASE'A, SEVaSEVa]
120.00
PD
215
9
mmrA, swauwa, e'ase'A]
200.00
OC
216
11
NW%NE!4;
40.00
OC
217
17
NVzN14;
160.00
OC
218
30
HWASWA]
40.00
PD
219
31
NWViNWVi;
40.00
OC
220
33
SEVaHEVa]
40.00
OC
221
37 S
3 W
1
Lot 8
13.82
*PD
222
4
Lot 2
4.28
PD
223
Lot 7
39.69
PD/OC
5
Lot 8
30.72
PD/OC
224
Lot 9
4.87
PD
37 S
5 W
5
NE%NW%, SW1/4NW1/4, SWASWA]
120.00
OC
225
7
WASWA]
80.00
OC
226
18
WASWA]
80.00
PD
227
Appendices - 552
Appendix P - Lands
Township
Range
Section
Subdivision
Acres
Status
1,1
‘‘Location on Map 2-5
37 S
6 W
3
SE%NE%, NE%SEVi;
80.00
OC
228
8
NE!4NE%;
40.00
PD
229
9
NE%, mSWA, SEVaSWA, WASEVa,
NE%SEVi;
400.00
OC
230
11
HmWA,
80.00
OC
231
13
SWASEYa, E'ASEVa)
120.00
OC
232
15
NE!4NE%, SW%NE1/4, SEV.NW1/.;
120.00
OC
233
24
NW!4NE!4;
40.00
PD
234
38 S
1 W
21
Lot 1, HEVSWA, SV2SWA
147.04
OC
235
38 S
2 W
10
NE1/4NW1/4;
40.00
PD
236
28
Loti
5.00
*PD
237
38 S
4 W
17
NE%NE%;
40.00
OC
238
25
Lot 7
9.26
*PD
239
39 S
1 W
1
NE%NE%;
40.00
OC
240
39 S
2 W
18
NWy4NE%SW%;
10.00
‘PD
241
40 S
8 W
1
Lots 7, 8;
11.53
OC
242
5
Lots 6, 7;
21.21
OC
243
7
Lots 1,2, EV2SWI4, WASEVa]
202.34
OC
244
32 S
2 E
17
HW/aSWASWASWA ;
2.50
*PD
245
33 S
2 E
1
SE'ASWA]
40.00
PD
246
36 S
1 E
6
SEVaSEVa]
40.00
*PD
247
36 S
2 E
34
SEYaSWA, SWASEYa]
80.00
PD
248
37 S
1 E
15
SEVaHWA]
40.00
OC
249
38 S
1 E
3
SWAHWA]
40.00
OC
250
5
SEVaHEVa]
40.00
OC
251
38 S
2 E
34
SWANWA, HWASWA]
80.00
PD
252
Total Acres
7,264.66
E = East N = North S = South W = West UN = Unnumbered PD = Public Domain Land
OC = Oregon and California Railroad Land Ot = Other Sources: Western Oregon Digital Base and District realty records
“ Map 2-5 is in Chapter 2 of the EIS
* Land added by amendment and not subject to FLTFA funds
Appendices - 553
FEISfor the Revision of the Western Oregon RMPs
Table P-12. Land Tenure Zone 3 Lands In The Klamath Falls Resource Area
Township
Range
Section
Subdivision
Acres
Status
‘‘Location on Map 2-5
37 S
14 E
10
W1/2NE
80.00
PD
253
38 S
8 E
31
LOT 4
10.30
PD
254
38 S
11 E
17
NWNE,
40.00
PD
255
E1/2SE
80.00
PD
38 S
11 E
32
NESW, NWSE
80.00
PD
256
39 S
8 E
6
LOT8
27.20
PD
257
39 S
8 E
7
LOT5
16.90
PD
258
39 S
11 E
2
LOTI
40.24
PD
259
39 S
12 E
28
NESW
40.00
PD
260
40 S
8 E
17
SWSE
40.00
PD
261
40 S
9 E
23
SWNW
40.00
PD
262
40 S
11 E
N1/2NW, SENW,
120.00
PD
263
9
SENE
40.00
PD
40S
11E
10
SENE, S1/2NW, E1/2SW, W1/2SE
280.00
PD
264
40 S
11 E
14
NWNE, NENW, S1/2NW, N1/2SW
240.00
PD
265
40 S
12 E
10
SENW,
40.00
PD
266
W1/2SE
80.00
PD
40 S
12 E
14
SENW, N1/2SW, SWSW, NWSE
200.00
PD
267
40 S
12 E
15
N1/2NE,
80.00
PD
268
SESW, N1/2SW
120.00
PD
40 S
12 E
21
NESE
40.00
PD
269
40 S
12 E
22
SWNE, SENW,
80.00
PD
270
SWSW
40.00
PD
40 S
12 E
27
W1/2NE, SENE, N1/2NW, SENW
240.00
PD
271
40 S
13 E
35
SWNE
40.00
PD
272
41 S
7 E
13
NENE
40.00
PD
273
LOT 4
24.69
PD
41 S
11 E
8
LOT 6
7.12
PD
274
Total Acres
2,206.45
E = East N = North S = South W = West UN = Unnumbered PD = Public Domain Land
OC = Oregon and California Railroad Land Ot = Other Sources: Western Oregon Digital Base and District realty records
** Map 2-5 is in Chapter 2 of the EIS
Appendices - 554
Appendix P - Lands
FERC Relicensing for the Klamath Hydroelectric
Project
The BLM’s section 4(e) conditions and other BLM decisions made in the Federal Energy Regulatory
Commission (FERC) relicensing proceeding for the Klamath Hydroelectric Project (FERC No. 2082) are
not affected by the decision regarding the revision of BLM resource management plans in western Oregon.
The relicensing proceeding was initiated in 2000, well before the process for revising the existing resource
management plans was initiated. The BLM’s section 4(e) conditions and record of decision were developed
under the guidance of the then existing management plan. The section 4(e) conditions have been subjected
to extensive public review and comment, and a trial type hearing by an Administrative Law Judge under the
Energy Policy Act of 2005 (“EP Act”). Additionally, the BLM received and analyzed alternatives submitted
under the EP Act. These conditions ultimately became conditions of the Department of the Interior through
a submission by the Department to FERC dated January 24, 2006, and no changes are being contemplated in
the revision process that would be inconsistent with that submission.
Inventory of Communication Sites
Table P-13 through Table P-18 contain information on existing communication sites. Chapter 2 of the
FEIS contains management actions related to management of communication sites.
Table P-13. Inventory Of Communication Sites For The Salem District
Location # on
Map 2-6a
Site Name
Serial Number
T
R
S
Quarter
Section
Latitude
North
Longitude
West
1
Bald Mountain
OR049380
3S
6W
29
HWASWA
45° 17’ 00"
123° 25' 50"
2
Brightwood
OR 044996, OR 54285, OR
054287, OR 060816
2S
6E
14
SE'Am'A
45° 24' 50"
122° 02' 15"
3
Dixie Mountain
OR005491
2N
2W
27
UWAUEV*
45° 42' 00"
122° 55' 00"
4
Goat Mountain
OR034944
5S
4E
14
SWASWA
45° 07' 52"
122° 17' 16"
5
High Heaven
OROI8O8O, ORE000172
3S
5W
33
UWASE'A
45° 15' 53"
123° 18' 33"
6
Mt. Horeb
OR002086
9S
4E
17
NEAUEA
44° 47' 35"
122° 20' 21"
7
Prairie Mtn.
ORE005555
15S
7W
7
LOT11
44° 16' 48"
123° 35' 05"
8
Prairie Mtn. East
OR042998
15S
7W
4
SE1/4SE1/4
44° 16' 37"
123° 36' 31"
9
Prairie Mtn. West
OR039808
15S
7W
7
LOT 12
44° 16' 47"
123° 35' 22"
10
Prospect Hill
OR046839
8S
4W
25
LOT 2
44° 51’ 14"
123° 07' 19"
11
Snow Peak
OR047462
IIS
2E
5
LOT 12
44° 39' 30"
122° 36' 15"
12
Tater Hill
OROI68O8
4N
3W
27
SWASWA
45° 47' 45"
123° 03' 00"
13
Trask Mountain
ORC47588
2S
6W
29
HE'AHWA
45° 22' 17"
123° 27' 18"
14
Yellowstone
Mountain
OR013666
IIS
3E
32
SWAUWA
44° 34' 04"
122° 28' 57"
aMap 2-6 is in Chapter 2 of the EIS.
Appendices - 555
FEISfor the Revision of the Western Oregon RMPs
Table P-14. Inventory of Communication Sites For The Eugene District
Location # on
Map 2-6a
Site Name
Serial Number
T
R
S
Quarter
Section
Latitude
North
Longitude
West
15
Badger Mountain
OR 55473, OR 48253, ORE
02880, OR 59637, OR 34510
17 S
7 W
35
Lot 7
44.05073
123,5015
16
Brickerville
Vacant
18 S
10W
3
Lot 5
44.03375
123.886
17
Vaughn Hill
Vacant
18 S
6 W
5
SE, SW4NE4
44.03641
123.4373
18
Amy Road
OR 15674
16 S
7 W
1
NW, SW
44.20898
123.4823
19
Hawley Butte
OR 56656, OR 43048
21 S
1 W
29
Lot 7
43.71797
122.8375
20
Huckleberry Mountain
OR 51261,
24 S
1 W
6
Lot 21
43.51053
122.8571
21
Horse Rock
OR 53355, OR 02743
15 S
2 W
1
Lot 4
44.30092
122.8831
22
Buck Mountain
ORE 017963, OR28799
16 S
2 W
7
Loti
44.19825
122.9851
23
Mt. Tom
Vacant
15 S
2 W
31
SW
44.21592
122.9784
24
South McGowan
Vacant
16 S
2 W
31
NW
44.13768
122.9786
25
Windy Peak
Vacant
16 S
8 W
27
SW
44.14644
123.6521
26
Elk Mountain
Vacant
16 S
8 W
26
NE
44.15383
123.622
27
Black Canyon
Vacant
17 S
2 W
7
SW
44.10226
122.9794
28
Camp Creek Ridge
Vacant
17 S
2 W
15
NE
44.09592
122.9066
29
High Point
Vacant
19. S
6 W
23
NW
43.9065
123.3783
30
Eagle's Rest
Vacant
20 S
1 W
12
NE
43.8471
122.7465
31
Cougar Mountain
Vacant
20 S
3 W
1
NE
43.86457
122.9869
32
Laurel Butte
Vacant
22 S
3 W
23
SE
43.64147
123.0066
33
Hobart Butte
Vacant
22 S
3 W
1
NW
43.61182
123.0993
aMap 2-6 is in Chapter 2 of the EIS.
Table P-
15. Inventory of Communication Sites For The Roseburg District
Location# on ..
Site Name
Map 2-6a
Serial Number
T
R
S
Quarter
Section
Latitude
North
Longitude
West
34
Kenyon Mountain
30S
9W
3
NW
42.5944
123.4531
35
Canyon Mountain
31S
5W
3
SW
42.5436
123.1706
36
Yellow Butte
23S
6W
27
NW
43.3207
123.2413
37
Lane Mountain
27S
4W
25
NE
43.1144
1230710
aMap 2-6 is in Chapter 2 of the EIS.
Table P-16. Inventory Of Communication Sites For The Coos Bay District
Location # on
Map 2-6a
Site Name
Serial Number
T
R
S
Quarter Section
Latitude
North
Longitude
West
38
Roman Nose
OR 8652
19 S
9 W
23
NWNE,NENW
43-54-50
122-44-00
39
Johns's Peak
OR 53660
23 S.
9 W
27
SESW
43-31-56
123-45-41
40
Blue Ridge
OR 36189
26 S
12 W
35
SESW
43-16-34.7
124-5-24.5
41
Signal Tree
OR 8651
29 S
9 W
33
NWSW
43-00-07
123-46-28
42
Sugar Loaf
None
29 S
12 W
23
NE
43-02-48
124-05-14
43
Bennett Butte
OR
30 S
13 W
20
NENW
43-57-38
124-16-27
44
Edson Butte
OR 46648
31 S
14 W
23
SWNW
43-52-20
124-20-03
45
Grizzly Mountain
37 S
14 W
4
Lot 15
42-23-50
124-21-55
46
Bosley Butte
OR 16304
39 S
13 W
10
SWSE
42-12-33
124-13-25
47
Palmer Butte
40 S
13 W
10
Lot 10
42-7-36
124-12-34
48
Black Mound
OR 60391
40 S
13 W
20
NWNWSW
42-5-17
124-18-52.83
aMap 2-6 is in Chapter 2 of the EIS.
Appendices - 556
Appendix P - Lands
Table P-17. Inventory Of Communication Sites For The Medford District
Location # on
Map 2-6
Site Name
Serial Number
T
R
2 Quarter
Section
Latitude
North
Longitude
West
49
Mt. Bluie
42.2256
123.1629
50
Beacon Hill
42.2706
123.1750
51
Mt. Sexton
42.3700
123.2200
52
Mt. Baldy
42.1944
123.1117
53
Gilbert Peak
42.2932
123.1842
54
Chestnut Mountain
42.1397
122.4408
55
Mt. Isabelle
42.3034
123.1036
56
Soda Mountain
42.0648
122.4780
57
Squires Peak
42.2190
123.0330
58
Tallowbox
42.1966
123.1504
59
King Mountain
42.6920
123.2294
60
Flounce Rock
42.4360
122.3650
61
Wolf Ridge
42.4582
122.5113
62
Fielder Mountain
42.2688
123.1273
63
Tin Pan Peak
42.2558
123.0899
64
Elk Mountain
42.3240
123.1498
65
Nuggett Butte
42.2700
123.0333
aMap 2-6 is in Chapter 2 of the EIS.
Table P-18.
Inventory of Communication Sites For The Klamath Falls
Location # on
Map 2-6a
Site Name
Serial Number T R S Quarter
Section
Latitude
North
Longitude
West
66
Stukel
OR 48956
42.1010
121.6342
OR 35373
OR 46312
OR 52152
67
Hamaker
OR 15231
42.0679
121.9699
OR 36377
OR 36541
OR 36562
OR 37192
OR 45051
OR 46180
OR 56655
OR 56235
ORE 09843
ORE 10866
ORE 05614
ORE 10317
ORE 15790
68
Yaniax
OR 39227
42.3264
121.2684
69
Buck Butte
OR 55670
42.0921
121.4432
OR 2231
70
Brady Butte
OR 2087
42.0166
121.0340
“Map 2-6 is in Chapter 2 of the EIS.
Appendices - 557
hEISJor the Revision^ of the Western. Oregon^ RMPs
Analytical Methods to Determine Legal Public
Accessibility of BLM Lands in the Planning Area
Purpose
Since a majority of the BLM-administered lands in western Oregon are intermingled with private lands,
public access opportunities can vary greatly. Reciprocal right-of-way agreements, easements, and unsecured
access rights across adjacent private lands all have a determining effect on the availability of legal public
access to the BLM-administered lands.
This analysis is not designed to distinguish between motorized and non-motorized use areas, seasonal use
restrictions, or consider other resource management constraints associated with public use. Nor does this
analysis consider natural barriers that may affect public access (e.g., steep topography, dense vegetation,
impassible rivers, etc.). Only the legal accessibility of BLM-administered lands for the public will be
determined primarily using existing agency transportation database information. A small percentage of
BLM-administered lands are legally accessible to the public other than via the road network (i.e., navigable
waterways, coastal beaches, trail systems, etc.). These other access options will be considered as part of the
analysis, either in the actual calculations or in the narrative for each BLM district.
The following public access categories will be assigned to all distinct management units of BLM-
administered land throughout western Oregon:
(1 i Secured Public Access (2) Unsecured Public Access
Legal public access to BLM Legal public access to BLM land
land is secured across private is not secured across private lands,
lands.
A distinct management unit is defined by a contiguous block of BLM-administered land, not including BLM
lands that are joined by corners. Each access category is further defined below.
It is important to note that this analysis will only determine if the public can legally access a distinct
management unit, not if a particular management unit provides roaded access throughout it. In some cases,
a road may only access a small portion of a management unit; the remainder of the unit would require
cross-country travel to reach. In this instance, the entire management unit is considered legally accessible to
the public.
(1) Secured public access: Public access rights to a distinct management unit of BLM-administered land
have been secured by the United States. Physical access must be present and available via the general
transportation road network, a navigable waterway, coastal beach, or trail systems. Public access rights are
generally included in the acquisition of exclusive or access road easements where the U.S. has acquired
control of the right-of-way. However, individual access documents should be reviewed and used as the
determining factor where necessary.
(2) Unsecured public access: Public access rights to a distinct management unit of BLM-administered land
have not been secured by the United States. Administrative access is legally and/or physically available to the
BLM via the general transportation road network; however, associated reciprocal right-of-way agreements or
non-exclusive easements do not include legal access rights for the public. Individual access documents should
be reviewed and used as the determining factor where necessary.
Appendices - 558
Appendix P - Lands
Legal public access may not be secured to certain distinct management units; however, the public may
currently be allowed to access these BLM-administered lands at the consent of the adjacent private
landowner. In fact, a number of BLM recreation sites do not have secured legal public access to them. Due
to the difficulty and sensitivity of mapping private lands that provide unsecured public access to BLM-
administered lands, this analysis is not designed to map these occurrences. BLM districts may decide to
conduct a follow-up analyzes to determine the extent of this type of unsecured public access in order to
improve management of these areas.
Methods
Part I. Geographic Information System Mapping
Step 1
Develop a digital layer of distinct management units of BLM-administered land for each district - using the
‘dissolve’ tool.
Step 2
Identify which access routes (line segments) on the BLM’s transportation system have secured legal public access
rights using the selected ‘access rights’ attribute from the BLM’s ground transportation road network database
described below. Legal public access is available to a distinct management unit where a management unit
boundary intersects with an access route from a public road in which all of the line segments contain one of the
following designation in the “ accjrgt ” attribute field.
• BP = BLM Public Access
• FP = USFS Public Access
• OF = Other Federal Agency
• CO = County
• ST = State
Step 3
Determine which distinct management units do not have secured legal public access using the remaining
‘access rights’ attributes of the ground transportation road network: Located infield acc_rgt. (The remainder
of the BLM-administered lands should be captured with this step.)
• BA = BLM Administrative Access
• BR = BLM Reciprocal Right-of-Way Agreement
• FA = USFS Administrative Access
• NO = No Legal Access
• PV = Private only
• UK = Unknown (also shown as “NKN”)
• Blank (This will capture all roadless blocks of BLM-administered land surrounded by private lands.)
Step 4
Map the location and calculate total acreage for all distinct management units having either secured or
unsecured legal public access for each district by land status (O&C lands, Coos Bay Wagon Road lands,
Public Domain lands, and Acquired lands).
Appendices - 559
FEISfor the Revision of the Western Oregon RMPs
The scale of these maps must be large enough for the Realty, Roads, and Recreation Specialists to analyze
the data. It may take 10 or more maps to cover the entire land base for most districts. Develop a template for
each map that displays the following information:
( 1 ) District boundary lines
(2) Distinct management units of BLM-administered land (using a distinct boundary type). Distinct
management units will be identified using a reproducible color code or symbol based on one of the following
attributes:
• Secured legal public access (see Step 2 above)
• Unsecured legal public access (see Step 3 above)
(3) Road line segments (using distinct colors and thicknesses), based on the following attributes:
• Secured public access (based on the attributes in Step 2 above)
• Unsecured legal public access (based on the attributes in Step 3 above)
• A thicker line for BLM roads with maintenance levels 3 or higher. (This will help the Road
Specialists orient the transportation system for their analysis.)
• BTM Road numbers (e.g., 18-5-12)
• U.S., State, and County highways/roads
• County and State roads and highways labeled accordingly
(4) Township, range, and section numbers
Step 5
The District Geographic Information System Specialists will then print out the maps provided to them by
the Geographic Information System Project Coordinators. After the maps have been printed, they will be
passed to the Realty and/or Road Specialists.
Part II. Analysis of Maps
Step 1
The District Realty and/or Road Specialists verify the Geographic Information System outputs and quality
control the maps. The maps must be reviewed for accuracy of attribute data that may affect public access to
each distinct management unit of BLM-administered land. This quality control process should answer that
all the distinct management units correctly color-coded as “Secured Public Access” or “Unsecured Public
Access?” All errors should be corrected by marking up the maps using the following two rules:
• If a block is incorrectly color-coded as “Secured Public Access,” circle the letters “UPA” in the center
of the block, meaning the block should be changed to “Unsecured Public Access.”
• If a block is incorrectly color-coded as “Unsecured Public Access,” circle the letters “SPA” in the
center of the block, meaning the block should be changed to “Secured Public Access.”
This quality control check may be used in the future to correct errors in FAMS database and the Ground
Transportation Road Network “access rights.” However, for purposes of this analysis, it is only necessary to
mark up the paper copies of the maps.
Step 2
After the district maps have been analyzed by the realty and/or road specialists, the specialists will then
coordinate with the district recreation planners for a final evaluation. This is necessary so that the recreation
Appendices - 560
Appendix P - Lands
i
planners can consider other public access options other than via the road network (i.e., navigable waterways,
coastal beaches, trail systems, etc.). After all changes have been incorporated, the maps will be mailed to the
Geographic Information System staff in the State Office who will arrange for a contractor to incorporate all
the necessary changes to produce final maps.
Part III. Development of Final Results
Update digital coverages for each district in western Oregon based on the marked- up maps provided by
each BLM district in western Oregon. The final product will include:
(1) The BLM district maps of public accessibility routes and distinct management units of BLM-
administered land identified by one of the following attributes:
• Secured legal public access
• Unsecured legal public access
(2) Spreadsheets that calculate the total number of acres per attribute and a percentage of the total land base
for each district by land status (O&C, CBWR, PD and Acquired).
Appendices - 561
FEISfor the Revision of the Western Oregon RMPs
Appendices - 562
Appendix Q
Energy and Minerals
This appendix provides detailed background on mineral and energy developments.
In this appendix:
Reasonably Foreseeable Mineral and Energy Developments
in the Salem and Coos Bay Districts 564
Reasonably Foreseeable Mineral and Energy Developments
in the Eugene, Roseburg, and Medford Districts and
the Klamath Falls Resource Area of the Lakeview District 568
Proposed Restrictions and Requirements on Mineral
and Energy Exploration and Development Activity 597
Appendices - 563
FEISfor the Revision of the Western Oregon RMPs
Reasonably Foreseeable Mineral and Energy
Developments Summary
Table Q-i. Fluid Mineral Development Potential
Salem
Eugene
Roseburg
Coos Bay
Medford
Klamath
Falls
Conventional
Oil/Gas
68 wells associated
with the Mist Gas Field
N/A
Zero to 114 wells
3 exploration wells
N/A
N/A
Seismic notices
of intent
Expected to be
confined to existing
road systems;
negligible effects.
Expected to be
confined to existing
road systems;
negligible effects.
Expected to be confined
to existing road systems;
negligible effects.
Road
construction
0.25 mile per well @
40 feet = 82 acres
disturbance.
7 miles new road =
39 acres.
0.25 mile per well @
40 feet = 4 acres
disturbance
Well pad
2 acres per well. = 136
acres
Nested wells and
services = 114
acres.
2 acres per well = 6
acres
Collection pipe:
Assume 25% well
success; 2 miles per
well; 30 feet wide =
124 acres.
Collection piping
will utilize road
prism.
No discoveries; no
pipe; no disturbance.
Plug &
abandon wells
No additional effect.
No additional
effect.
No additional effect.
Coal bed
natural gas
Exploration only
N/A
N/A
37 to 77 wells
N/A
N/A
Seismic notices
of intent
Expected to be
confined to existing
road systems;
negligible effects
Expected to be confined
to existing road systems;
negligible effects
Road
construction
% mile per well @
40 feet = 45 to 90 acres
disturbance
Well pad
Assume 4 wells per pad;
2 acres per pad =19 to 38
acres disturbance
Collection pipe:
Assume 50% well
success; Assume most
collection pipe along
existing transportation
system; new
disturbance = 5 to 10
linear miles at 30 feet wide
= 18 to 36 acres.
Plug &
abandon wells
No additional effect
Geothermal
N/A
N/A
N/A
N/A
N/A
See below.
For Klamath Falls Resource Area:
Geophysical Exploration (includes seismic reflection and gravity/magnetic field surveys):
- Notices of Intent: 2; Very small acres disturbed
- Exploratory Wells: 1-2: 0.1 acre per site; .25 acre per well for roads. 0.35-0.7 acres total disturbance
Geothermal Operations:
-Notices of Intent:
Surface Geophysical Surveys: 6: very limited surface disturbance
Temperature Gradient Holes: 5: 0.1 acre per site; .25 acre per well for roads. 2.25 acres total disturbance
Exploration wells: 5 wells; One acre per well pad; 40 ft. wide ROW @ 0.5 mile per well = 17 acres total disturbance
Geothermal Power Plant Development:
1 possible in the life of the plan; if proposed, evaluate separately in cooperation with the State.
Direct Use of Geothermal Energy for space heat:
2 possible; evaluate separately if proposed
Appendices - 564
Appendix Q - Energy and Minerals
Table Q-2. Salable Mineral Development Scenario Summary For 2008-2018
Klamath
Roseburg
Salem
Eugene
Coos Bay
Medford
Falls
New quarries
1
5
2
5
3
1 to 2
2 to 3 acres
Acres
disturbed
2 acres per quarry, plus Vi acre for access.
per quarry,
plus V2 acre for
access.
Existing
quarries
60
38
71
32
188
18 quarry &
cinder sites used
Intermittently.
6 quarries
8 quarries
4 quarries
6 quarries
10% of quarries
expanded @
expanded.
expanded at
expanded.
expanded at
2 acres per
Less than 2
approximately
Less than 2
less thanl acre
quarry
acres per
1 acre each.
acres each
per quarry, plus
quarry.
quarry.
1/10 acre per
quarry for new
access.
Depletions
10 quarries
2 quarries
2 quarries
1 quarry
5 quarries
Up to 4 quarries
Decorative
stone
3 to 6
sales per
year
1 to 2
sales per
year
750 sales over
the 10-year
period
1 to 2 sales per
year
Appendices - 565
FEISfor the Revision of the Western Oregon RMPs
Table Q-3. Locatable Mineral Development Scenario
Roseburg
Salem
Eugene3
Coos Bay
Medford
Klamath
Falls
Bench Placer
notices
2
10
6
6
80
0
Roads
0.3 acres per
0.3 acres per
0.3 acres
per
0.3 acres
per
Of 80 estimated,
10 would have roads at
Vz acre per notice.
0
Test pits, support
facility
1 acre
per
notice
1 acre per
notice
1 acre per
notice
1 acre per
notice
1 acre per notice on
average.
Notice to plan
1
1
0
1
0
0
Vein notices
2
4
4
one
100 notices; surface
disturbance 1 to 5 acres
per notice.
4
Roads
3 per notice
40x200 = y2
acre per notice
3 per notice
40X200=1/2
acre per notice
3 per notice
40x200=
Vz acre per
notice
3 per
notice
40x200=
Vz acre per
notice
Mostly existing roads;
minimal temporary roads;
estimate 0.50-acre for half
of the notices; and zero
acres for the other half of
the notices.
Mostly
existing
roads;
minimal
temporary
roads.
Support
facilities
1 acre
per
notice
1 acre per
notice
1 acre per
notice
1 acre per
notice
1 acre for half of
the notices (many current
notices take ore off-site
for processing).
Sample sites
14 acre
per
notice
0.50-acre
per notice
0.50-acre
per notice
0.50-acre
per notice
Ten holes per notice; 0.1
acre per hole; estimate
1/5 of the notices will drill
a hole.
Ten holes per
notice;
0.1 acre per
hole.
Plans of
Operation
1
1
1
1
15 (lode & placer)
0
Exploratory
holes
5; 0.1 acre
per hole;
roads
40x300= 0.75
acre
Ten; 0.1 acre per
hole; roads
40x300= 0.75
acre
Ten; 0.1
acre per
hole; roads
40x300=
0.75 acre
Ten; 0.1
acre per
hole; roads
40x300=
0.75 acre
Ten; 0.1 acre per hole;
roads
40x300= 0.75
acre. Estimate
14 of the plans will
be lodes and have
exploratory holes.
Support facility
1 acre
1 acre
1 acre
1 acre
1 acre per plan
Second Phase Exploration
Roads
5 (standard as
above)= 2.5
acres
10 (standard
as above)= 2.5
acres
10 (standard
as above)=
2.5 acres
10
(standard
as
above)=
2.5 acres
Mostly existing roads;
minimal temporary roads;
estimate 14 acre for 14 of
the plans;zero acres for
the other half of the plans.
Drill pads
5 holes, 0.1
acre per hole
10 holes, 0.1
acre per hole
10 holes,
0.1 acre per
hole
10 holes,
0.1 acre
per hole
10 holes, 0.1
acre per hole; on
% of the plans.
Mine Development
Bench placer
One; 1 acre
One, 7.5 acres
one; 7.5 acres
Eight of the plans are
estimated to be bench
placers at five acres
per plan.
Appendices - 566
Appendix Q - Energy and Minerals
3 Eugene footnote: Locatable minerals with silica sand potential withdrawn from mineral entry in the Florence area. However, sand is excavated and removed from BLM property near Florence,
Oregon, on an easement granted to the adjacent landowner.
Appendices - 567
FEISfor the Revision of the Western Oregon RMPs
Ten- Year Reasonably Foreseeable Development
Of Oil And Gas Resources Scenario For The Salem
And Coos Bay Districts
Summary
Salem District
The Salem District is located in northwest Oregon, bound by the Pacific Ocean to the west, the Columbia
River to the north, the crest of the Cascade Mountain Range to the east, and the Salem District/Eugene
District boundary to the south. It encompasses lands in 13 different counties (Clatsop, Columbia,
Multnomah, Tillamook, Washington, Clackamas, Yamhill, Marion, Polk, Lincoln, Benton, Linn and Lane).
Most Public Domain and O&C railroad lands within the district will be available for oil and gas leasing,
subject to guiding stipulations.
Estimating how much oil and gas exploration and development will occur on Lederal lands managed by the
Salem District during the next 10 years is based on an existing gas field designation and historical oil and gas
investigations. The first exploration well was drilled near Newberg, Oregon in 1902. Conventional petroleum
resources in the district have been the focus of numerous studies. Two periods of intense search occurred
from 1920 to 1940, and again from 1940 to 1960. These investigations resulted in development of the Mist
Gas Pield, with a discovery well in 1979. Small amounts of gas, however, have been found throughout the
District within projected sedimentary basins.
Review of Oil and Gas Occurrence Potential, Oil and Gas System and Play Analysis, Oil and Gas Production
Activities, Potential for Resource Occurrence and Development, and Leasing are needed to understand the
Districts oil and gas potential. This information was used to project activity through 2018. Given the current
incipient nature of petroleum development in Oregon (i.e., current Coalbed Natural Gas development, new
exploration of the Mist Gas Pield), completely new assumptions and information that impact Reasonably
foreseeable Development (RED) scenarios may be applicable during the next 10 years and beyond.
Identified potential petroleum source sedimentary basins within the district include:
• Astoria Basin
• Nehalem Basin (or Arch)
• Tualatin Basin
• Willamette Valley
• Yaquina Basin
• Tillamook Basin
Both the Yaquina Basin and the Tillamook Basin are part of the off-shore Newport Basin. The BLM
manages approximately 19,400 acres of surface estate within these basins. The amount of subsurface estate is
unknown. These basins exist within the Western Tertiary Basins Geologic Province. The Mist Gas Pield lies
within the Nehalem Basin/ Arch.
As of 1985, the estimated in-place gas reserves for the Mist Gas Pield were 28.4 billion cubic feet (bcf), with
total production through 1984 of 19.2 bcf. The total estimated resource in 1985 was 47.6 bcf. As of 2007, the
State of Oregon Department of Geology and Mineral Industries (DOGAMI) reported that approximately 65
bcf of gas had been produced from the Mist Gas Pield, with 2.7 bcf produced between 2002 and 2006. This
exceeds the 1985 estimate by 17.4 bcf, indicating continued discoveries of resource.
Appendices - 568
Appendix Q - Energy and Minerals
Current non-federal lease holdings within the Salem District are focused within the Mist Gas Field. There
are currently no BLM-administered surface holdings within the Mist Gas Field. However, there appears to
be one BLM-administered subsurface estate within the field. The BLM-administered surface estate is located
to the southeast of the current field description. Previous Mist Gas Field boundaries include approximately
980 acres of BLM-administered surface estate. Similar geology and structure exists under at least 9,000 acres
of BLM-administered surface estate southeast of the Mist Gas Field, indicating that foreseeable development
of the high potential area could result in approximately 10,800 acres of BLM lease offerings.
The spacing plan for the Mist Gas Field is 160 acres. The size of the pools ranges from 40 acres to 160
acres. Extension of the Mist Field onto the adjacent Federal land, as defined by wells and mapped geology
could result in approximately 68 wells on BLM-administered estate. Additional conventional and non-
conventional development may occur in other sedimentary basins within the district. Coal bed natural gas
development is occurring within Coos County. Exploration companies are mapping coal seams throughout
Oregon for other potential resource areas. Coal has been historically mapped and mined throughout the
Salem District. Coal bed natural gas development, however, is not expected above exploration within the
next 10 years.
Coos Bay District
The Coos Bay District is located on the western edge of Southwest Oregon and encompasses lands in
Douglas, Coos, Curry, Lane, and Josephine Counties. Conventional petroleum in the district has been the
focus of numerous studies (Diller 1901 as found in Newton 1980, Niem and Niem 1990, and Ryu et al. 1996)
with the projection of numerous plays and petroleum structures. The district has also been the focus of
numerous industry explorations and investigations. Two speculative conventional petroleum systems have
been identified within the district (Ryu et al. 1996). One coal bed natural gas play has also been identified
within the district, and is currently being developed on private and Coos County lands. It is expected that
most of the public domain and O&C and Coos Wagon Road lands will be available for leasing, subject to
guiding stipulations.
Estimating how much oil and gas exploration and development will occur on Federal lands managed by the
Coos Bay District during the next 10 years is difficult. Review of Oil and Gas Occurrence Potential, Oil and
Gas System and Play Analysis, Leasing, and Oil and Gas Production Activities are needed to understand the
oil and gas potential. This information was used to project activity through 2018. Where appropriate, the
coal bed natural gas resource is discussed separately from conventional oil and gas.
The speculative conventional petroleum systems include the Umpqua-Dothan-White Tail Ridge hybrid
petroleum system and the Umpqua-lower Tyee Mountain petroleum system. Both areas are contained in the
southern Tyee sedimentary basin (Ryu et al. 1996) (see Figure Q-l). The Umpqua-Dothan-White Tail Ridge
hybrid petroleum system is located in the mid-central portion of the district and encompasses an estimated
350 square miles; approximately 26% of which is managed by the district. The northern portion of the
district contains approximately 200 square miles of the Umpqua-lower Tyee Mountain petroleum system.
The BLM-administered lands comprise about 20% of the area. The coal bed natural gas play is focused
mainly on the Coaledo Formations of the onshore portion of the Coos Basin (see Figure Q-2), which is an
area of approximately 250 square miles located on the western edge of the district.
Although oil and gas exploration has been historically associated with these systems (Ryu et al. 1996,
Newton 1980) and conventional oil and gas potential exists as identified speculative petroleum systems
(Ryu et al. 1990), there is currently no known interest in exploration or development of these systems. It
is anticipated, however, that the Coos Bay District could issue competitive and over-the-counter leases
and authorize geophysical surveys. It is also estimated that up to three exploratory wells for conventional
petroleum may be drilled during the life of this plan. Conventional exploration, coupled with coal bed
natural gas exploration within coal seams beyond the Coos Basin, could increase the number of wells
actually drilled.
Appendices - 569
FEISfor the Revision of the Western Oregon RMPs
Figure Q-i. Southern Tyee Sedimentary Basin
124° W
7 44" N
Figure 6.1 Genen
(i.e.,
of speculate
petroleum
43°N
□ Coos Bay BLM District
Land Administration
BLM
Forest Service
BIA
Other Federal
State of Oregon
Underlying map from
Ryu, Niem, and Niem
(1996), pg 100
Indicates direction petroleum migrated
Plunging
syncline
Potential gas accumulation
prospect
-n Tyee basin and surrounding geologic provinces
3stn, and Klamath Mountains), showing the areal extent
2 Umpqua- Dothan-White Tail Ridge(?) hybrid
Source: Ryu et al. 1996
Appendices - 570
Appendix Q - Energy and Minerals
Figure Q-2. Coaledo Formations Of The Onshore Portion
Of The Coos Basin
Coal Minos and Coal Exploration Holes
South Slough Basin Coals
28. Big Cr
T22S
July 2005
TorrentEnergy Coal Geology and Coalbed Gas Prospects of Coos Bay Basin, Oregon
Source: Torrent Energy Inc. 2005
FEISfor the Revision of the Western Oregon RMPs
Current non-Federal lease holdings within the district are focused within the Coos Basin area, with the
intention of coal bed natural gas development. Approximately 115,000 acres of the 160,000 acres within the
Coos Basin are privately held. Federally-managed mineral estate represents approximately 12.3 percent of
the Basin, with BLM-administered portion of roughly 7.6 percent.
Industry has estimated an in-place gas reserve for their lease holdings at 1,166 billion cubic feet (bcf)
(1.2 trillion cubic feet (tcf)) for the privately held 115,000 acres (Sproule 2006). To develop this resource,
industry estimates a total build-out of between 300 and 719 wells, with 300 being most likely within the
next 10 years (Halferty 2007). Based on this estimate compared to proportional acreage, the Coos Bay
District could see a total development on BLM-administered lands of between 37 and 77 wells. The total
Coos Basin development could range between 436 wells and 1,001 wells. To date, industry has constructed
approximately 18 single and multiple well pads consisting of both exploration and production wells.
Foreseeable development of the coal bed natural gas play could result in an additional 25,000 acres of BLM-
administered lease offerings.
Common to All Alternatives
Introduction
Reasonably Foreseeable Development (RFD) describes scenarios for leasable oil and gas commodities.
The purpose of these scenarios is to provide rational models that anticipate the level and type of future
petroleum development activity in the planning area, and to serve as a basis for cumulative impacts analysis.
The RFD describes logical historic and current development based on plausible interpretation of available
information. Future trends and assumptions for hypothetical exploration and development operations are
then described.
Scope
The reasonably foreseeable developments are based on known and inferred mineral resource capability
of the lands involved and apply to conditions and assumptions discussed under Historic and Current
Development , as well as Future Trends and Assumptions. Possible changes in current geologic data,
interpretation, and/or economic conditions would alter the reasonably foreseeable developments, resulting
in deviation over time.
Impacts caused by oil and gas exploration and development cannot be assessed without estimating future oil
and gas activity.
Estimates of future activity on the Salem District would need to take into account:
• oil and gas occurrence potential, as documented by historic research and papers
• oil and gas system and play analysis, including existing sites such as the Mist Gas Field and the
potential development of new plays such as identified sediment basins and coal bed natural
gas
• oil and gas production, including economics and technology
• potential for resource occurrence and development
• leasing and development, including Federal and non-Federal activities
Estimates of future activity on the Coos Bay District would need to take into account:
• oil and gas occurrence potential, as documented by historic research and papers
• oil and gas system and play analysis, including looking at the potential development of new
plays, such as the identified petroleum systems and Coos Basin coalbed natural gas or interest in
unknown discoveries
Appendices - 572
Appendix Q - Energy and Minerals
• leasing, including Federal and non-Federal activities
• oil and gas production, including economics and technology.
These factors cannot be predicted with absolute certainty, but reasonable generalizations are possible.
The estimates presented here are based on past and present activities and trends, as well as future price
deviations. The estimates may be lower than what actually happens if price and play development is more
positive than anticipated. Likewise, if exploration in existing plays, such as the Coos Basin, is not successful
and new plays are not developed and/or commodity prices are less than anticipated, estimates presented
here may be exaggerated.
Potential for Resource Occurrence and Development
Potentials for resource occurrence and resource development (Haerter 2007) have been estimated for the
districts. Definitions for potential for resource occurrence include:
• Low Potential - Hydrocarbon occurrence is unlikely.
• Moderate Potential - Conditions exist for hydrocarbons to occur.
• High Potential - Hydrocarbon shows have been documented, or production has been established.
Definitions for Potential for Resource Development Include:
• Low Potential - Economic or other conditions would likely preclude development.
• Moderate Potential - It is reasonable to conclude that development could occur.
• High Potential - Development is likely to occur within the life of the plan.
Leasing
After initial field work, research, and subsurface mapping, which may include seismic testing and data
collection, leasing is often the next step in oil and gas development. Leasing may be based on speculation,
with the riskiest leases usually purchased for the lowest prices.
Geophysical Exploration
Geophysical exploration is conducted in an attempt to determine the subsurface structure of an area. The
three geophysical survey techniques generally used to define subsurface characteristics are measurements of
the gravitational field, magnetic field, and seismic reflections.
Gravity and magnetic field surveys involve small portable measuring units which are easily transported via
light-weight off-highway vehicles, such as four-wheel drive vehicles, or aircraft. Both off-highway and on-
highway travel may be necessary in these two types of surveys. Usually a three-man crew transported by one
or two vehicles is required. These two survey methods can make measurements along defined lines, but it is
more common to use a grid with discrete measurement stations.
Seismic reflection surveys, which are the most common of the geophysical methods, produce the most
detailed subsurface information. Seismic surveys are accomplished by sending shock waves, generally by
a small explosion or mechanically beating of the ground surface, through the earths surface, reflecting off
some layers, thus depicting the underlying structure of the rock. The thumper and vibrator methods pound
or vibrate the ground surface to create a shock wave. Usually four large trucks are used, each equipped
with pads about four-feet square. The pads are lowered to the ground, and the vibrators are electronically
triggered from the recording truck. After information is recorded, the trucks move forward a short distance
and the process is repeated. Less than 50 square feet of surface area is required to operate the equipment at
each recording site.
Appendices - 573
FEISfor the Revision of the Western Oregon RMPs
The small explosive method requires that charges be detonated on the surface or in a drill hole. Holes for
the charges are drilled utilizing truck-mounted portable drills to create small-diameter (two or six-inch)
holes to depths of 100 to 200 feet. Generally 4 to 12 holes are drilled per mile of line, and a 5- to 50-pound
charge of explosives is placed in the hole, covered, and detonated. The created shock wave is recorded by
geophones placed in a linear fashion on the surface. In rugged terrain, a portable drill carried by helicopter
can sometimes be used. A typical drilling seismic operation may utilize 10 to 15 men operating five to
seven trucks. Under normal conditions, three to five miles of line can be surveyed daily using this method.
A drilling program may include the use of heavy truck-mounted drill rigs, track-mounted air rigs, water
trucks, a computer-recording truck, and several light pickups to transport people conducting the survey.
Public and private roads and trails are used where possible. However, off-highway cross-country travel is
also necessary in some cases. Graders and dozers may be required to provide access to remote areas. Several
trips a day are made along a seismograph line, usually resulting in a well-defined two-track trail. Drilling
water, when needed, is usually obtained from private landowners, but may be acquired from sources used
for fire suppression, such as pump chances and ponds.
The surface charge method utilizes charges of between one and five pounds attached to wooden laths
three to eight feet above the ground. Placing the charges lower than six feet usually results in destruction
of the vegetation; placing the charges higher, or on the surface of deep snow, results in little visible surface
disturbance.
Advanced Three Dimensional Survey analyzes five to six miles using lines with 1,700 shot holes at 70-foot
spacing. The lines are spaced at 400 feet apart. The lines are hand brushed for survey. The survey crews
utilize an Inertial Survey System that allows for accurate surveying without the need to maintain a line of
sight. This allows flexibility in brushing paths. The shot hole pad is three feet by four feet in size and cleared
to mineral soil with hand tools. The drill rig is then placed on the pad. If existing access to the pad is limited,
the drill rig may be placed and removed by helicopter. The holes are drilled to 15-feet depths and the charges
exploded subsurface, leaving no surface expression. Where there is surface expression, the damage is
mitigated with hand tools. In open valleys and areas with access, thumper rigs are used, as they disturb even
less ground.
Drilling and Production Phase
Notices of Staking are anticipated during the plan period. It is anticipated that the company would then
submit an Application for Permit to Drill after the Notice of Staking is accepted. Private surface owner
input, if split estates are involved, would be actively solicited during this stage. After an Application for
Permit to Drill is approved, the operator initiates construction activities in accordance with stipulations
and Conditions of Approval. Access road lengths vary, but usually the shortest feasible route is selected to
reduce the haul distance and construction costs. In some cases, environmental factors or landowners wishes
may dictate a longer route. Drilling activity in the planning area is predicted to be done using existing roads
and constructing short roads to access each drill site location. The district will utilize currently developed
and utilized forest management Best Management Practices, in addition to the BLMs “Gold Book” (USDI/
USDA 2006), for surface disturbance in road construction and pad development similar to landings.
Surface Impacts of Drilling and Production
During the first drilling phase, the operator would move construction equipment over existing maintained
roads to the point where the new access road begins.
In the second part of the drilling phase, the operator would construct the drilling pad or platform, which is
anticipated to involve approximately two acres per well site. Support facilities are also anticipated to disturb
about two acres per well site. The likely duration of well development, testing, and abandonment is predicted
to be approximately six months to one year for each drill site.
Appendices - 574
Appendix Q - Energy and Minerals
Plugging and Abandonment
Wells completed as dry holes are plugged according to a plan designed specifically for the down-hole
conditions of each well. Plugging is accomplished by placing cement plugs at strategic locations from the
bottom of the well to the surface. Drilling mud is used as a spacer between plugs to prevent communication
between fluid-bearing zones. The casing is cut off at least three feet below ground level and capped by
welding a steel plate on the casing stub. Wells will be plugged and abandoned at the end of their production
life, with the pad, support facilities, and road reclaimed.
Surface Impacts of Plugging and Abandonment
After plugging, all equipment and debris would be removed and the drill site would be restored as near
as reasonably possible to its original condition. If new roads constructed for drilling are not needed for
future access to the area, they would be reclaimed using Best Management Practices, with the road prism
revegetated as required by the Authorized Officer. Pipelines will be plugged and abandoned in place to
minimize new surface disturbance.
District Specific
Historic and Current Development
Oil and Gas Occurrence Potential
Salem District
The Salem District is part of a structural sedimentary basin system that extends onshore and offshore
from the Klamath Terrains boundary north to the Columbia River (extending into Washington) from the
continental shelf east to the Cascade Mountain/Willamette Valley interface. This is known as the Western
Tertiary Basin Province (Olmstead et al. 1989). It has been of interest for petroleum exploration since the
1880s (Newton 1969, Orr and Orr 2000) with oil and gas drilling exploration beginning in 1902 with the
drilling of an exploration well near Newberg (Newton 1965, Olmstead et al. 1989). Two major peaks of
petroleum exploration have occurred. The first occurred between 1920 and 1940 and was very wide-spread,
as there was little geologic information guiding the exploration. The second peak occurred between 1940
and 1960, investigating the deeper Oligocene and Eocene marine sediments. These explorations cumulated
in the discovery of the Mist Gas Field in 1979 (Olmstead et al. 1989, Olmstead and Alger 1985, Houston
1997).
Petroleum development on the Salem District has been the focus of numerous studies (Washburne 1914
in Olmstead et al. 1989, Stewart 1954 in Newton et al. 1965, Newton 1969, Olmstead et al. 1989, Niem et
al. 1990, Houston 1997, and Meyer 2007). The district has also been the focus of industry explorations
and investigations by companies such as Northwest Natural (Oregon Natural Gas Development), RH
Exploration, Diamond Shamrock Corporation, Quintana Petroleum Corporation, Standard Oil Company of
California, American Quasar Petroleum Company, ARCO Oil and Gas Company, Exxon Corporation, and
The Texas Company (Texaco) (Olmstead et al. 1989).
At least 42 exploration wells, 16 water wells, and 7 seeps within the Salem District boundary and outside the
1985 Mist Gas Field boundary (see Figure Q-3 below) have had gas shows (Olmstead et al. 1989). As of 1989,
a total of at least 108 wells drilled outside of Columbia County (which holds the Mist Gas Field) and within
the Salem District (Olmstead et al. 1989) have defined specific sedimentary basins of the Western Tertiary
Basin Province that exist within the district (Newton 1969, Olmstead et al. 1989). These basins have been the
focus of historic investigation and contain potential conventional petroleum development (Newton 1969,
Niem et al. 1985, Meyer 2007).
Appendices - 575
FEJS/or the Revision of the Western Oregon RMPs
Non-conventional systems, such as coal bed natural gas, may be a possibility and are being researched where
coal is present (Wiley 2006, Pappajohn 2007, Meyer 2007).
Coos Bay District
The Coos Bay District is part of a structural sedimentary basin system that extends onshore and offshore
from the Klamath Terrains boundary (Middle Fork of the Coquille River) north to the Columbia River
(extending into Washington), from the continental shelf east to the Willamette Valley These basins have
been the focus of petroleum exploration since the 1880s (Newton 1980, Orr and Orr 2000), with oil and gas
drilling exploration of the district beginning in 1913 (Newton 1980). Conventional petroleum in the Coos
Bay District has been the focus of numerous studies (Diller 1901 in Newton et al.1990, Ryu et al. 1996) with
the projection of numerous plays and petroleum structures. The district has also been the focus of industry
explorations and investigations by companies such as AMOCO Production Company, Union Oil Company,
Phillips Petroleum Company, Northwest Natural Gas Company (Newton 1980) and Methane Energy
Corporation (Pappajohn 2002).
The most recent play and petroleum structure projections provide three possibilities within the District.
These include portions of two potential conventional petroleum structures (Ryu et al. 1996) and a non-
conventional coal bed natural gas play identified by Methane Energy Corporation (Pappajohn 2002).
Oil and Gas Structures and Plays
A speculative petroleum system presumes a direct relationship between a particular source rock and a
resulting potential petroleum (or natural gas) accumulation (Ryu et al. 1996). An oil and/or gas play is an area,
geologic formation, or geologic trend that has good potential for oil and/or gas development, or is generating a
large amount of interest in leasing and drilling (USDI BLM 2001).
Salem District
The Western Tertiary Basin Province contained within the Salem District possesses at least six identified
basins or sub-basins (Newton 1969, Orr and Orr 2000, Olmstead et al. 1989). These include:
• Tualatin Basin, a sub -basin of the Willamette Valley
• Willamette Valley
• Newport Basin, a sub-basin of the larger off-shore Newport Basin
• Tillamook Basin, a sub-basin of the larger off-shore Newport Basin
• Astoria Basin
• Nehalem Basin or arch
See Figures Q-3 and Q-4.
The basins structures are controlled by compression force of the sub-ducting easterly movement of the Juan
de Fuca plate in relation to the overriding westerly movement of the North American Plate. The fold axes are
oriented north-south (Orr and Orr 2000), and are defined by the contact between the Miocene or Oligocene
rock and Eocene rock. This is a point of erosion of the Eocene rock, which was covered by Miocene or
Oligocene rock, defined as a nonconformity (unconformity if covered by Miocene or Oligocene sedimentary
rock). This break in the geologic column is considered the Eocene nonconformity and a focus of petroleum
exploration. The Eocene rocks consist of marine sediments, with later sedimentation creating coal beds in
many areas (Newton 1969) (see Figure Q-4). The Salem District manages a total of approximately 19,375
acres of surface estate within these basins (USDI BLM 2007).
Tualatin Sub-Basin: The BLM manages approximately 8,858 acres of surface estate in the Tualatin Sub-
Basin (USDI BLM 2007), which is considered part of the Willamette Valley. The lower rock is Eocene shale
Appendices - 576
Appendix Q - Energy and Minerals
, [Astoria Basinj
[Nehalem Basinj
[Tualatin Basinj
[Willamette Valley!
1 [Newport i
\ /Sub-basin
Figure Q-3. BLM Oregon Salem District, Surface
[Tillamook j
[Sub-basin,;
Legend
O Coal Exposure
A O&G Exploration Well
A Seep
AjA Water Well
□ Geologic Basin
□ Salem BLM District
County Boundary
BLM Administered Land
Forest Service Administered Land
Indian Affairs Land
Other Federal Land
State of Oregon Land
Private or Other Land
40 Miles
1 I
Based on Newton (1969), Ferns and Huber (1984), Olmstead et al. (1989), and USDI BLM (2007)
Appendices - 577
FEISfor the Revision of the Western Oregon RMPs
Figure Q-4. Salem District BLM, Subsurface
k
0 10 20 40 Miles
1 1 1 1 I 1 1 1 I
OF N. W. OREGON.
inner
County Boundary
BLM Administered Land
Forest Service Administered Land
Indian Affairs Land
O Coal Exposure
O&G Exploration Well
6 SeeP
Water We|, Other Federal Land
□ Geologic Basin
J Salem BLM District
State of Oregon Land
Private or Other Land
Legend
Based on Newton (1969), Ferns and Huber (1984), Olmstead et al. (1989), and USDI BLM (2007)
Appendices - 578
Appendix Q - Energy and Minerals
and sandstone intermixed with basalt. Miocene Columbia River Basalts rest unconformably on top of the
sedimentary rock and are covered by gravels and silts. The Eocene rock and sands have excellent reservoir
characteristics as the faulting and overlying basalts provides trap structures (Newton 1969). The Eocene
Nonconformity is at a maximum mapped depth of 4,000 feet below sea level (Newton 1969) (refer to Figure
Q-2). It is thought that the Tualatin Sub-Basin is a source of petroleum for the Mist Gas Field (Olmstead and
Alger 1985, Houston 1997).
Willamette Valley: The BLM manages approximately 644 acres of surface estate in the Willamette Valley,
excluding the Tualatin Sub-Basin (BLM, 2007). The lower rock, or basement rock, is the Eocene Siletz
River Volcanics or Kings Valley Siltstone. Overlying these are sandstones and siltstones of the Eocene
Nonconformity, then covered by volcanics, and overlain by sandstone, limestone, and coal beds. This is
capped by the Columbia River Basalts and then covered by tuff and silt. The petroleum potential Eocene
rock boundary is defined to the east by the change from marine sediment to volcanic sediment (facies
change) (Newton 1969) (refer to Figure Q-4). Numerous wells with gas shows have been drilled within the
valley The eastern valley edge provides numerous possibilities for structural traps, with the marine beds
providing source rock. Even though numerous holes have been drilled and source and structure is present,
true potential has not been clearly defined. The Eocene Nonconformity (marine facies) is at maximum
mapped depth mapped of 5,000 feet below sea level (Newton 1969).
Newport Sub-Basin: The BLM manages approximately 443 acres of surface estate in the Newport Sub- Basin
(USDI BLM 2007), which is part of the off-shore Newport Basin (Orr and Orr 2000). As most of the basin
lays off-shore, little was found to be published about on-shore portions of the specific Newport Sub-Basin.
Generally, the off-shore basins consist of thicknesses up to 15,000 feet of marine sediments, predominately
siltstones and shales, with some sand shows. Oil and gas shows occurred in at least three of the off-shore
wells (Orr and Orr 2000). Two exploratory gas wells with shows, one seep, and one gas show in a water- well
have been reported within the Newport Sub-Basin (Olmstead et al. 1989). There are also occurrences of coal
(Ferns and Huber 1984) (refer to Figures Q-3 and Q-4). The Eocene Nonconformity is at a maximum on-
shore mapped depth of 2,000 feet below sea level (Newton 1969) (refer to Figure Q-4).
Tillamook Sub-Basin: The BLM manages approximately 25 acres of surface estate within the Tillamook Sub-
Basin (USDI BLM 2007), which is also a part of the off-shore Newport Basin (Orr and Orr 2000) described
above. Gas show has been associated with one exploratory well and two water wells in the Tillamook Sub-
Basin (Olmstead et al. 1989). The Eocene Nonconformity is at a maximum onshore mapped depth of 2,000
feet below sea level (Newton 1969) (refer to Figure Q-4).
Astoria Basin: The BLM manages approximately 39 acres of surface estate within the Astoria Basin (USDI
BLM 2007). The lowest sequence of rock, considered the basement rock, is the upper Eocene Volcanics.
There are a few thin beds of sandstone and mudstone that are inter-fingered with the Tillamook Volcanics.
A few of these sedimentary layers have gas shows. The volcanics are overlain with the mudstone-dominated
rock, with sandstone and conglomerate members. Tie mudstone is overlain by sandstone and siltstones.
These sandstones (Cowlitz Formation) contain the Clark and Wilson Sandstone, which is the gas reservoir
in the Mist Gas Field. Late Eocene mudstone and sandstone sequences then overlie the Clark and Wilson
Sandstones (Niem et al. 1985, Houston 1997). A total of 49 noncommercial gas shows were recorded in eight
wells developed within the basin. Gas shows, with the majority of hydrocarbon chains being methane, were
recorded in all units except the Roy Creek conglomerate and sandstone, the Pittsburg Bluff Formation, and
the Wickiup Mountain and Youngs Bay members of the Astoria Formation (Niem et al. 1985). Tie Eocene
Nonconformity is at a maximum mapped depth of 5,000 feet below sea level (Newton 1969) (refer to Figure
Q-4). It is thought that the Astoria Basin is a source of petroleum for the Mist Gas Field (Olmstead and Alger
1985).
Nehalem Basin: Tie BLM manages approximately 9,366 acres of surface estate in the Nehalem Basin (USDI
BLM 2007). It is in this basin that the Mist Gas Field exists (See Figure Q-5) the only official State of Oregon
Designated Gas Field. Tiis basin has the most potential for further gas development that may impact BLM-
Appendices - 579
FEISfor the Revision of the Western Oregon RMPs
administered lands (Houston 1997, Houston 2007, Meyer 2007). Although the Nehalem structure is defined
as a Tertiary Basin by most researchers (Olmstead et al. 1989, Olmstead and Alger 1985, Newton 1969,
Houston 1997), it has also been identified as an arch in comparison to the surrounding structures of the
Astoria Basin to the west and the Tualatin Sub-Basin to the east (Armentrout and Suek in Niem et al. 1985,
Orr and Orr 2000). The description of the structure as an arch provides mechanism for petroleum migration
from the adjoining Astoria Basin and Tualatin Sub-Basin to the collection traps of the Nehalem Arch (Niem
et al. 1985). However, the structure does have a down-warp, creating a closed structural basin (Newton
1969). A great deal of geologic work has occurred within the Mist Gas Field and surrounding areas of the
Nehalem Basin (Niem et al. 1985 and 1990, Olmstead et al. 1985), including Three Dimensional Survey
(Meyer 2007). Specific geologic interpretation was conducted on the Bacona Quadrangle containing BLM-
administered lands located ten miles southeast of the Mist Gas Field (Houston 1997) (refer to Figure Q-4).
The Nehalem Basin consists of deltaic to shallow-marine and deep marine depositional environments,
depositing thousands of feet of mud and sand. There was also intermittent volcanism (Houston 1997,
Olmstead and Alger 1985). This lithified material creates the basins stratigraphy The oldest rock, considered
the economic basement rock, is the Middle to Upper Eocene Tillamook Basalts. However, other localities show
that deep-water depositions of the Yamhill Formation may underlie the Tillamook Basalts (Olmstead and
Alger 1985). Houston (1997) has defined, at least in part, the Yamhill Formation as the Hamlet Formation. The
mudstone of the Hamlet Formation is mature at depth and could be a source of petroleum within the Mist Gas
Field. It is overlain by the Cowlitz Formation, separated by unconformity (Houston 1997, Olmstead and Alger
1985). The lowest member of the Cowlitz Formation is the Clark and Wilson Sandstone that serves as the
major reservoir rock for the Mist Gas Field (Olmstead and Alger 1985) and reservoir potential outside the Mist
Gas Field (Houston 1997). Coal also occurs within the sandstone (Olmstead and Alger 1985). The sandstone
in the Mist Gas Field has flow rates of 10,000 to 20,000 cubic feet per day (Niem et al. 1985 in Houston 1997).
However, the reservoir quality deteriorates southeast of the Mist Gas Field (Houston 1997) and BTU rates may
also decline southeast of the Mist Gas Field (Meyer 2007).
Overlying Clark and Wilson Sandstone is a mudstone member of the Cowlitz Formation. This formation is
a deep oceanic mudstone that acts as a seal to the Clark and Wilson Sandstone, helping form the petroleum
trap (Houston 1997). After deposition of the Cowlitz Formation, the region was faulted, creating horst
and graben environment, possibly forming structural traps. These fault patterns are not transferred to the
younger overlying formations and, therefore, more recent faulting may not have compromised these traps.
The faults truncate at the Keasey Formation-Goble Volcanics (Houston 1997 and 2007, Olmstead and Alger
1985).
Covering at least a portion of the Cowlitz Formation, and intermixed with the Keasey Formation, is
the Goble \blcanics, shown as a 2,000-meter thick sequence in the exploration hole located on BLM-
administered lands (see Figure Q-6). The Keasey Formation unconformably overlies the Cowlitz Formation
where the Goble Yblcanics are not present, and consists of silty mudstone (Houston 1997). It is in turn
covered by the sandstones, mudstones, siltstones, and volcanics of the Oligocene Pittsburg Bluff Formation
(Houston 1997, Olmstead and Alger 1985). Coal seams are also found in the Pittsburg Bluff Formation
(Houston 1997). The Scappoose Formation unconformably overlies the sandstone Pittsburg Bluff Formation
(Houston 1997) with flows from the Miocene Columbia River Basalts as an unconformable cap rock. The
Eocene Nonconformity is at a maximum mapped depth of 500 feet below sea level (Newton 1969) (refer to
Figure Q-4).
The Mist Gas Field Designation was initiated with the discovery of natural gas in 1979. The official
boundaries as of 1985 consisted of 89,575 acres, approximately 140 square miles (State of Oregon 1985,
Olmstead et al. 1985), including approximately 978 acres of BLM-administered surface estate. By 1999, the
boundaries were reconfigured to a total acreage of 81,850 acres, approximately 128 square miles, with no
BLM-administered surface estate (State of Oregon 1999, Houston 2007) (see Figure Q-7).
Appendices - 580
Appendix Q - Energy and Minerals
Figure Q-5. Mist Gas Field, 1999 Boundary
0 12 4 Miles
1 1 1 1 I 1 1 1 I
Source: DOGAMI 2003
Legend
CD Mist GFD Boundary 1999
County Boundary
BLM Administered Land
State of Oregon Land
Appendices - 581
FFIS lot the Revision of the Western. Oregon. RM Ps
Figure Q-6. Identified High Potential Area (This Report) And Bacona
Geologic Quadrangle
Legend
O&G Exploration Wells
O Coal Exposure
4- O&G Exploration Well
Seep
“A Water Well
] High Potential Area
| /] Bacona Quad
BLM Administered Land
State of Oregon Land
Private or Other Land
(Historic)
A
2 3 4 Miles
J I I I i 1
Source: Houston 1997
Appendices - 582
—
Appendix Q - Energy and Minerals
Figure Q-7. Mist Gas Field Boundaries (1985 and 1999)
T7N-R6W
T6N-R6W
T5N-R6W
T4N-R6W
T7N-R5W
T7N-R4W
Q
T6N-R5W
T6N-R4W
Mist Gas Fiel<f (1999)
Misti
T5N-R5W
Gas Field (1985)
T4N-R5W
T5N-R4W
T4N-R4W
T6N-R3W
..MHB raLi
N
A
0 12 4 Miles
1 i i i I i i i I
Legend
CZ1 Mist GFD Boundary 1985
n Mist GFD Boundary 1999
County Boundary
■i BLM Administered Land
State of Oregon Land
Private or Other Land
Appendices - 583
- FEISfor the Revision of the Western Oregon RMPs
The main target zone is the reservoir rock of the Clark and Wilson Sandstone (Olmstead and Alger 1985).
To date, there have been more than 45 separate pools identified (Meyer 2007) with two gas storage reservoirs
(DOGAMI 2003). Locations of additional pools are expected with the use of Three Dimensional Survey
(Meyer 2007). Current exploration is focused to the northwest of the Mist Gas Field (Houston 2007).
However, this is due to economics as opposed to existence of resource. Exploration to the southeast, in the
direction of BLM-administered lands, has been restricted to lower BTUs and depth of resource, not lack of
product. All areas north of Vernonia, Oregon could be considered a viable extension of the Mist Gas Field
(Meyer 2007).
Natural Gas production at the Mist Gas Field has been consistent since its discovery in 1979. As of 2006,
two companies maintained production wells, Enerfin Resources with eight producing wells, and Northwest
Natural with four producing wells. Other production wells of the companies were shut in for 2006. An
annual production history of the past 10 years is as follows (DOGAMI 2003 and 2007)(see Table Q-4 ):
Gas production has decreased from its discovery in 1979 to the present (2006), depleting known pools.
However, with the advancement of Three Dimensional Survey, it is probable that additional pools within and
outside of the Gas Field Designation Boundary will be discovered and developed.
Table Q-4.
Mist Gas Field io-Year Production
Year
Cumulative Cubic Feet
All Wells
(million cubic feet)
Cumulative Therms
All Wells
(therms)
2006a
402,713
2,482,713
2005
305,433
2,744,415
2004
466,756
4,180,445
2003
733,537
6,500,818
2002
837,067
6,926,533
2001
2,674,673
10,037,413
2000
1,596,159
14,426,257
1999
1.554,717
13,534,088
1998
1,262,550
11,009,121
1997
1,380,509
12,023,109
10-Year Total
11,214,114
86,864,912
aUpdate on March 20,2007 of DOGAMI data base (DOGAMI 2007)
Appendices - 584
Appendix Q - Energy and Minerals
Oil and Gas Production
Salem District
Annual production for 2005 for the Mist Gas Field was 305,000 thousand cubic feet (mcf) (305 million
cubic feet [mmcf] with a total life production to date of 70 mmcf (DOGAMI 2007). As of 2006, the field had
produced approximately 68 bcf with a value of about $140 million (DOGAMI 2007). The State of Oregon
applies a severance tax of 6% on the production designated to the common school fund. In total, over 500
oil and gas wells had been permitted in the field by 2003 (DOGAMI 2003). There are currently 18 producing
wells, one water disposal well, 21 observation wells, and 20 gas injection/withdrawal wells operating on
the site (DOGAMI 2007). Eight new Applications for Permit to Drill are being submitted to DOGAMI for
additional exploration and production wells (Houston 2007).
In addition to production, the Mist Gas Field also contains two underground natural gas storage projects
defined as the Flora/Bruer EFSC and the Calvin Creek EFSC (DOGAMI 2003). These storage facilities
consist of sLx drained gas structures with a storage capacity of 12.5 bcf. As additional pools become depleted
they may be converted to additional storage facilities. This is dependent on market supply and demand
(DOGAMI 2006).
Water management for the Mist Gas Field is currently by deep well injection. In Oregon, discharge of
produced water from onshore oil and gas activities into navigable waters is addressed in the 40 CFR,
Part 435, Subparts C and E. With exceptions, produced water can be used for agriculture and wildlife
propagation. Produced water discharges to streams or other surface water bodies must be authorized by
a National Pollutant Discharge Elimination System (NPDES) permit issued by the Oregon Department
of Environmental Quality (DEQ). Consistent with the Energy Policy Act of 2005, storm water discharges
from oil and gas-related construction activities are exempt from NPDES permit coverage, except in limited
instances. Injection wells used for the disposal of produced water are regulated by the Oregon DEQ
Underground Injection Control program.
Coos Bay District
There is currently no coal bed natural gas production in Oregon. However, the Coos Basin is being
developed as a production resource. Sproule (2004, 2005, 2006) has estimated base, high, and low isotherm
projections for the industry’s 115,000-acre lease holdings within the Coos Basin, with a base (average)
isotherm projected in-place gas volume of 1,166 bcf. The low isotherm projects in-place gas volume of 725
bcf, with a high isotherm projection of 1,617 bcf.
The target coal groupings are split into the Lower Coaledo, Isthmus Slough, and South Slough groups.
Sproules (2005, 2006) average estimates for gas in-place for the Lower Coaledo Group is 854 mmcf per 80
acres. Estimates for the Isthmus Slough and South Slough groups are 268 mmcf per 80 acres and 186 mmcf
per 80 acres, respectively.
Site-specific calculations for volumetric in-place gas content calculated from average in-situ-isotherms were
completed by Sproule (2005). Some of these estimates were conducted for sections including or adjacent to
Federally managed mineral rights. See Tables Q-5, Q-6, and Q-7 for estimates for the three groups:
Appendices - 585
FEISfor the Revision of the Western Oregon RMPs
Table Q-5. Isthmus Slough Group Near Federal Mineral Rights
Location
Gas Content
(scG/ton)
Total Gas
(millions of
cubic feet)
Acres
Sampled
Average Gas
Per Acre
(mmcf/acre)3
I 27S, R. 13W., Sec. 11
71.4
828.521
300
2.76
T27S., R. 13W., Sec 14
54.1
168.327
70
2.40
T 27S., R. 13W., Sec 15
90.4
2342.751
480
4.88
I 27S., R. 13W., Sec 24
80.1
3115.784
640
4.87
Table Q-6. South Slough Group Near Federal Mineral Rights
Location
Gas Content
(scf/ton)
Total Gas
(millions of
cubic feet)
Acres
Sampled
Average Gas
Per Acre
(mmcf/acre)
T 26S, R. 13W., Sec. 6
148.4
665.871
308
2.16
T26S., R. 14W., Sec. 1
154.7
150.968
100
1.51
T26S., R. 14W., Sec. 3
147.6
15.254
15
1.02
T 26S., R. 14W., Sec. 4
68.2
0.0
0
0.00
T 26S., R. 14W., Sec. 28
110.6
280.005
160
1.75
Table Q-7. Lower Coaledo Group Near Federal Mineral Rights"
Location
Gas Content
(scf/ton)
Total Gas
(millions of
cubic feet)
Acres
Sampled
Average Gas
Per Acre
(mmcf/acre)
T 27S, R. 13W., Sec. 11
158.4
2,174.382
360.8
6.03
T27S., R. 13W., Sec. 12
147.6
590.400
285.9
2.07
T27S., R. 13W„ Sec. 13
146.0
0.0
0.0
0.0
T 27S., R. 13W., Sec. 14
149.1
2,981.251
580
5.14
I 27S., R. 13W., Sec. 24
158.4
1,140.074
640
1.78
aMost of the Lower Coaledo Isotherm Data in Sproule (2005) did not specify section location within a township. Therefore, position of Federal managed rights
could not be determined in relation to the Methane Energy Corporation’s cited acreage. These townships were not included in this report, but it should be noted
that Federal holdings may be located near Sproule’s (2005) projections.
Although, based on limited analysis (Sproule 2005), Federally managed mineral rights may contain less in-
place gas volume than the average of industry’s holdings, in-place gas is present in measurable volumes.
The analysis of coal bed natural gas potential is limited to the Coos Basin coals to a depth of 4,244 feet.
Other coal seams occur at deeper intervals, with areas in the South Slough containing coals at depths greater
than 10,000 feet. These deeper seams have not been included in the analysis (Sproule 2005). Gas content in
the overlying coals may also imply migration of gas from deeper thermogenic sources as well as biogenic
development in the target seams (Sproule 2004).
The Methane Energy Corporation is utilizing directional drilling of multiple wells from single pad locations.
Engineering analysis (Sproule 2004) estimated a 160-acre well spacing on a 50,000-acre lease development.
This would yield a maximum potential number of wells for 115,000 acres of development to approximately
719 wells.
Appendices - 586
Appendix Q - Energy and Minerals
The Methane Energy Corporations pilot production program includes the Radio Hill, Beaver Hill, and
Westport sites located in the center of the Coos Basin. Collection systems are currently being engineered for
the Westport site, which will deliver production gas from the well to the Coos County Natural Gas Pipeline.
Initial results from the Radio Hill and Beaver Hill sites indicated that the coal bed natural gas was a dry
gas, with little production water. This type of system is similar to Horseshoe Canyon coals of Alberta, the
Hartshorne coals of the Arkoma basin, and the Fruitland coals of the south San Juan basin (Sproule 2006).
However, future production of coal bed natural gas could encounter a wet gas system similar to the Powder
River basin type. This could create substantial amounts of production water that will need to be managed.
Initial results indicate brackish salinity in the production waters. Industry is currently reviewing injection
potentials.
Examples of water management issues exist within current coal bed natural gas producing areas outside of
Oregon and may be used for possible guidance of coal bed natural gas development in the District. Powder
River Basin coal bed natural gas development has produced nearly four billion barrels (bbl) of water through
2006, equating to two bbl of water for every 1,000 cubic feet of gas. Operators discharge 61 percent of the
water into ephemeral and perennial surface drainages, 31 percent into off-channel pits, and 5.7 percent
for irrigation. Of the remainder, 1.4 percent is re-injected into the wells, and 1.2 percent is treated by ionic
exchange. Only 25 percent of the shallow injection wells have been successful (Petzet 2007).
Potential for Resource Occurrence and Development
Salem District
Six distinct sedimentary basins or sub-basins have been the focus of petroleum explorations, the Eocene
Unconformity being the primary target of exploration. In areas outside these basins, the target is above
surface and eroded, creating the highlands. There has been little exploration of these areas, as any plays that
might exist would be below the basement rock of Tillamook or Siletz River Basalts with low potential for
occurrence and low potential for development. It is within these areas that the majority of the Salem District
lands exist. It should be noted that private timber companies have been marketing the potential of all their
lands in Oregon and Washington for the exploration and development of petroleum resources (Meyer
2007). Exploration has demonstrated the presence of petroleum in all six basins, although commercial
development has been limited to one. Although the potential for resource occurrence in all six basins is
moderate to high, the potential for resource development for five of the basins would be moderate, with little
expectation for development within the 10-year life span of this scenario. The basins that would have high
potential for resource occurrence, and moderate potential for resource development include:
• Newport Sub- Basin
• Tillamook Sub-Basin
• Astoria Basin (although, given the location of the Mist Gas field, development potential should be
considered higher)
• Tualatin Sub-Basin (as with the Astoria Basin, development potential could be higher). However,
a small portion of the Tualatin Sub-Basin may be included in the identified high potential area
described below
• Willamette Basin
The Nehalem Basin, or Arch, has been the most extensively explored structure, resulting in the development
of a commercially viable gas field. The basin maintains a high potential for resource occurrence and a high
potential for resource development.
Based on geologic mapping showing similarities to the geology of the Mist Gas Field (Houston 1997), drilled
exploration wells with petroleum shows (Olmstead et al. 1989) and discussions with DOGAMI and industry
(Houston 2007, Meyer 2007), it is estimated that up to 50,200 acres containing both BLM-administered
Appendices - 587
FEISfor the Revision of the Western Oregon RMPs
surface estate and non-federal estate could be explored and developed for petroleum in the 10-year life
of this scenario. Of this acreage, the district maintains approximately 10,800 acres of BLM-administered
surface estate. The remaining 39,400 acres appears to be non-federal lands.
The lands are associated with the geologically mapped Bacona Quadrangle (Houston 1997), bound to the
southeast by Leaseholding Syndicates 1925-1927 exploration hole named Dutch Canyon. The well was
located at the NW!4 of Section 17 in Township 3 North, Range 2 West. The well encountered gas at a depth
of 1,850 feet. The pressure of the gas blew water and mud 20 feet above the casing. However, analysis of
the gas determined that only 7.9% was methane and 91.8% was nitrogen. The identified high potential
area is located southeast of the existing field (refer to Figure Q-6). Additional petroleum development
could likely occur to the northwest of the current Mist Gas Field, an area of current focus of exploration.
However, there is no known BLM-administered estate in that area (USDI BLM 2007).
It is assumed that if this area containing both federal and non-federal lands were developed, it would be
as an extension of the current Mist Gas Field. Therefore, the current spacing plan of one well per 160 acres
would likely apply (DOGAMI 2003, State of Oregon 1999), allowing for a total of approximately 314 wells
within the identified high potential area, approximately 68 of which could be on BLM-administered surface
estate. The district could foresee approximately 22 percent of the expansion development, with non-federal
lands carrying approximately 78 percent of the expansion development (see Figure Q-8).
Figure Q-8. Salem District
Mist Gas Field Expansion
Estimate, i6o-Acre Spacing
Salem District RFD Mist Gas Field
Expansion Estimate, Wells. Based on
160 Acre Spacing
□ Non-Federal ■ BLM
Appendices - 588
Appendix Q - Energy and Minerals
Coos Bay District
Three areas within the Coos Bay District have been identified as having petroleum potential. The two
conventional petroleum structures described by Ryu et al. (1996) have a moderate to high potential for
occurrence. The structures have been identified, and historic exploration has had both oil and gas shows.
However, resource development potential is low to moderate. Although hydrocarbons may exist, it has not
been historically economic to produce these resources. This is due to the lack of infrastructure, low price,
and limited investigations.
The Coos Basin has a high potential for occurrence of coal bed natural gas. The structure has been identified
and hydrocarbon shows have been documented. Although actual economic production from this play has
not occurred, initial steps with the placement of infrastructure and wells as well as the Gas Field Designation
process has been implemented. The potential for resource development is also high. It is likely that
development will occur within the life of this plan, with private development already occurring.
Leasing
Salem District
Foreseeable development of the Mist Gas Field could result in potentially an additional 10,800 acres of
BLM-administered lease offerings. If these offerings were sold for the 2006 average of $17.71 per acre, the
net receipts would be nearly $191,268.
Coos Bay District
After lands are nominated and reviewed by BLM, leases on lands where the Federal government manages the
oil and gas rights are offered via oral auction on a quarterly basis. The maximum lease size is 2,560 acres at a
minimum bid of $2.00 per acre. An administrative fee of $75 per parcel is charged, and each successful bidder
must meet citizenship and legal requirements. Lands not leased at auction are then available for over-the-
counter leasing for a period of two years. Leases are issued for a 10-year term and charged a 12.5% royalty on
production. In the first five years of a lease, annual rental is $1.50 per acre, and $2.00 per acre thereafter. Leases
that become productive are “held by production” and do not terminate until all wells on the lease have ceased
production.
Foreseeable development of the Coos Basin coal bed natural gas play could potentially result in an
additional 25,000 acres of BLM-administered lease offerings. If these offerings were sold for the 2006
average price of $17.71 per acre, based on Federal proceeds from leasing in eastern Washington, the net
receipts would approach $500,000.
Future Trends and Assumptions
Introduction
Salem District
Based on history of past exploration; historic, current, and projected development of the Mist Gas Field;
mapped geology; and foreseeable development potential in the planning area, activity over the next
decade may be stable to increasing. Current development within the Mist Gas Field as well as petroleum
developments and interest in other BLM districts in Oregon, and the increasing value of petroleum
products, indicate continued interest within the Salem District. Oil and gas activity on BLM-administered
mineral rights within the district is expected to consist of competitive and over-the-counter leases,
geophysical surveys, and processing of Applications for Permit to Drill for approximately 68 wells.
Appendices - 589
FEISfor the Revision of the Western Oregon RMPs
Some exploration for coal bed natural gas in the form of coal seam investigation and mapping is predicted,
but development of coal bed natural gas is not expected within the next 10 years. The supply of natural gas
in the region may be augmented by one or more proposed Liquefied Natural Gas terminals. Natural gas
prices are expected to rise 0.3% (2004 purchase power) by 2034 with a 0.7% increase in demand over the
same period (Energy Information Administration 2007). Consequently, while the petroleum industry does
experience economic and production cycles, demand and price are projected to continue to increase.
Coos Bay District
Based on history of past drilling, current development of coal bed natural gas and foreseeable development
potential in the planning area indicate activity over the next decade may be stable to increasing. Current
development within the Coos Basin and the increasing value of petroleum products indicate continued interest
within the Coos Bay District. Oil and gas activity on BLM-administered mineral rights within the district
is expected to consist of competitive and over-the-counter leases, geophysical surveys, and processing of
Applications for Permit to Drill for 50 to 80 wells.
Continued exploration and development for coal bed natural gas is expected. Some exploration for conventional
natural gas is also predicted. The supply of natural gas in the region has been augmented by the Coos County
Natural Gas Pipeline. A liquefied natural gas terminal and an associated second natural gas pipeline are being
proposed. These systems provide export opportunities for natural gas produced in the district. Natural gas
prices are expected to rise 0.3% (2004 purchase power) by 2034, with a 0.7% increase in demand over the same
period (Energy Information Administration 2007). Therefore, although the petroleum industry does experience
fluctuations in economic and production cycles, demand and price are projected to continue to increase.
The speculative conventional petroleum systems are the Umpqua-Dothan-White Tail Ridge hybrid
petroleum system and the Umpqua- Lower Tyee Mountain petroleum system, located in the northern
portion of the Coos Bay District are contained in the southern Tyee sedimentary basin (Ryu et al. 1996)
(refer to Figure Q-l).
System 1: The Umpqua-lower Tyee Mountain petroleum system is located in the center of the Smith River
Sub-Basin. The system may include a tight-gas sandstone reservoir. According to Ryu et al. (1996), gas could
migrate along faults, forming small accumulations in the lower Tyee Mountain sandstones. Mudstones
within the member would serve as additional seals within the traps. An unconventional over-pressured
tight-gas mudstone reservoir is possible in the Umpqua Group of the Smith River area. Deep wells within
the system have encountered over-pressured zones at approximately 7,000-foot depth. Characteristics of the
zone are sufficient to generate thermogenic wet-gas (Ryu et al. 1996). The approximate area of this system
within the district is 200 square miles. The BLM-surface management consists of approximately 20 percent
of that area.
System 2: The Umpqua-Dothan-White Tail Ridge Hybrid Petroleum System is in the southern portion of
the Tyee Basin, with a southern boundary defined by the Tyee Basin-Klamath Mountain contact. According
to Ryu et al. (1996), the system may contain dry gas from both biogenic methane (similar to coal bed
natural gas) and deeply buried conventional petroleum sources. It is possible the created gas migrates to
accumulation zones which are located east of the Coos Bay District, extending into the BLM Roseburg
District. It is also possible that the entire structure projects under the Klamath Mountains (Ryu et al. 1996).
The approximate area of this system within the district is 350 square miles. The BLM-surface management
consists of approximately 26% of that area.
System 3: The third opportunity is the coal bed natural gas play within the Coos Basin. This is the play
that is currently producing the most interest and activity. The focus of production is within the Coaledo
Formations mapped by Newton (1980). During deposition and compaction of the organic material which
ultimately becomes coal, large quantities of methane are generated. Methane gas produced from coal may
have lower energy content than conventional natural gas (USDI BLM 2001).
Appendices - 590
Appendix Q - Energy and Minerals
The approximate area of the coal bed natural gas play is 250 square miles, with producing Lower Coaledo
Formation coals currently being sought at depths up to 4,500 feet. The Coos Basin is a folded structural
basin, one of a series of onshore and offshore basins along the northwest coast, ranging from the Klamath
Mountains north to the Columbia River in Oregon, and from the Columbia River north to the Puget Sound
in Washington. The basins are located from the continental shelf offshore, east to the Willamette Valley.
Sedimentary deposits including coals, sandstones, siltstones, and shales are within these structural basins
(Orr and Orr 2000).
The Coos Basin structure is controlled by compression force of the subducting easterly moving Gordia
subplate and Juan de Fuca plate in relation to the overriding westerly moving North American Plate. The
fold axes are oriented north-south, plunging northward. The Coaledo Formation-Flournoy Formation
contact generally defines the basin boundaries to the north, east, and south. The basin is thought to extend
offshore to the west. The basins rock sequence consists of sedimentary layers of sandstone, siltstone, and
shales, with coal seams (Newton 1980). Surface exposures of the basins coal seams have been economically
mined since the 1800s (Orr and Orr 2000).
Current development of the coal bed natural gas resource is being conducted by Methane Energy
Corporation which has completed numerous exploratory and production wells in the Coos Basin. The
company has projected an “Area of Mutual Interest” incorporating the Coos Basin, an area of approximately
160,000 acres (see Figure Q-9).
The Methane Energy Corporation maintains approximately 115,000 acres of non-federal mineral lease
rights, with an estimated in-place volume of 1.2 trillion cubic feet (Sproule 2006). Of the estimated 45,000
Coos Basin Acreage
160,000 acres
□ MEC □ BLM □ Non-BLM Fed □ Non-Federal
Figure Q-9. Coos
Basin Acreage In Area
Of Mutual Interest
Appendices - 591
■F£/'S/or the Revision of the Western Oregon RMPs
acres not yet controlled by lease agreements, the
Federal Government manages approximately 19,694
acres or approximately 44 percent (see Figure Q-10).
Federal mineral rights account for approximately
19,694 acres of the basin area, and BLM-
administered subsurface mineral rights (split and
non-split estate) account for approximately 12,228
acres of the basin area. The remaining lands consist
of non-federal and non-leased estate in private, city,
county, and state ownership.
The State of Oregon Department of Geology and
Mineral Industries (DOGAMI) initiated a public
meeting process to establish a Gas Field Designation
for the Coos Basin. The first public meeting was
conducted January 29, 2007. There is only one
other Gas Field Designation in Oregon, which is the
Mist Gas Field in northwest Oregon. The Gas Field
Designation is required to fulfill state requirements
to establish well spacing designations and control
drainage. It may also increase competition, as more
development companies may be interested in the
resource after such a designation. The proposed
Gas Field Designation is likely to incorporate the
boundaries defined in Methane Energy Corporations
“Area of Mutual Interest”. The boundary of the Gas
Field Designation is simple to alter, needing only evidence of gas potential (additional formation mapping or
shows of gas within a well). The designation will incorporate BLM and Forest Service lands, as well as other
federal jurisdictions (Houston 2005).
All coal seams in western Oregon could produce coal bed methane. However, the potential is completely
unknown, as these resources have not been investigated. Potential could exist within the coal seams of the
Umpqua Group, as well as their correlating formations north through the coast range. If coal bed methane is
producible in the Coos Basin, exploration could occur within these other speculative formations (May 2005).
Geophysical Exploration
Salem District
Advanced Three Dimensional Survey is utilized within the Mist Gas Field. These requirements are in place
because the Mist Gas Field is located in commercial forest land and is required by the land manager to
minimize disturbance to near non-existent levels (Meyer 2007).
Surface Impacts of Geophysical Explorations
Salem District
It is anticipated that the foreseeable geophysical activity in the identified high potential area would consist
of the currently used the Three Dimensional Survey. The total area of the identified potential expansion
is 81 square miles, or approximately 50,200 acres. Using the Three Dimensional Survey spacing of shots,
it is anticipated that complete investigation of the area could utilize 22,950 shots. With pad ground
disturbance of 12 square feet, the total disturbance area could be up to 6.3 acres. The Salem District manages
Coos Basin Unleased Acreage
45,000 acres
□ Non-Federal a Federal
Figure Q-io. Coos Basin Unleased
Acreage
Appendices - 592
Appendix Q - Energy and Minerals
approximately 22% of the area of interest, so potential surface impacts to BLM-administered lands by
Geophysical Explorations are expected to be approximately 1.4 acres. This disturbance is created exclusively
with hand tools and based on experience in the Mist Gas Field, is completely reclaimed in five years or less
(Meyer 2007). Disturbance will be less where pre-existing roads and/or landings can be used.
Coos Bay District
Geophysical exploration techniques are not commonly utilized in coal bed natural gas production, but may
be utilized in developing conventional petroleum plays within the Coos Bay District. It is anticipated that
the foreseeable geophysical activity in the planning area will consist of seismic reflection surveys, utilizing
existing roads. Surface impacts would involve temporary blockage of the roads by the large trucks used to
gather the data, but this type of equipment is not expected to damage the roads.
The small explosive method is also anticipated to be used on approximately 20 miles of line. Surface
disturbance is expected to consist of drilling 4 to 12 holes per mile of line. Each drill hole would impact
about 200 square feet, but 90 percent of these holes would be drilled on existing landings, spur roads, or
timber haul roads. Altogether, 7,200 square feet (approximately 0.2 acre) of existing road surface would
temporarily be impacted by drilling activities and low power blasting.
Blasting would not be powerful enough to impact any surface resources or improvements. It is anticipated
that four drill holes would be made on currently undeveloped areas. Drill holes would impact about 200
square feet each, and short spur roads 100 feet by 25 feet wide constructed to each drilling location another
2,500 square feet each. Total surface disturbance for the anticipated four drill holes would be approximately
0.25 acre. Total surface disturbance for blasting and drilling combined is expected to total approximately 0.5
acre. An increase in conventional petroleum development would increase these estimates.
Drilling and Production Phase
Salem District
Based on past oil and gas drilling in Oregon, it is projected that three conventional petroleum
exploratory “wildcat” wells would be drilled within the Salem District. The estimated success rate
of finding hydrocarbons is predicted to be no greater than 10 percent, based on the average U.S.
wildcat well success rate. Future identification of additional structures would increase this estimate.
Development within the identified high potential area would be directed by Three Dimensional Survey
as opposed to wildcatting (Meyer 2007).
Coos Bay District
The Methane Energy Corporation estimates of development for coal bed natural gas for their current leases
range from 300 to 719 wells. Based on well spacing assumptions (Sproule 2004) of 160 acres per well, Coos
Basin development could eventually involve 436 to 1001 wells. As previously described, spacing rules will
be developed during the DOGAMI Gas Field Designation process. If all remaining Federal and non-federal
leasable land was open for surface occupancy, well development on federally-managed lands (BLM, USFS,
and BIA) could range between 59 and 124 wells. Both highs and lows are extremes (see Figures Q-ll and
Q-12).
Surface Impacts of Drilling and Production
Appendices - 593
FEISfor the Revision of the Western Oregon RMPs
Figure Q-ii, Coos
Basin Wells Based
On 338-AcRE Spacing
Figure Q-12. Coos
Basin Wells Based
On i6o-Acre Spacing
Coos Basin Wells Based on 160 Acre
Spacing
Appendices - 594
Appendix Q - Energy and Minerals
Salem District
The Mist Gas Field has maintained production since 1979. More than 500 wells have been permitted,
although 60 wells are currently in operation. Abandoned well sites have been reclaimed and surface
disturbance mitigated. Consequently, the current surface disturbance is limited to 60 wells. Development
of the identified high potential area or development of an unknown field could add an additional 314 wells,
with 68 wells on BLM-administered lands. It is anticipated that all gas production would be transported
by pipelines, most of which would be located within road rights-of-way. It is estimated that up to 20 miles
of pipelines could be sited outside road rights-of-way. All well service requirements would be provided by
established companies.
Pipelines totaling 20 miles in length within a 30-foot wide right-of-way would disturb about 72.5 acres. Due
to the checkerboard public land ownership in this area, it is estimated that only 22 percent or 16 acres would
be on lands administered by the BLM.
Given the existing infrastructure of the Mist Gas Field, timber management of other lands within the
district, the amount of existing roads within the identified high potential area, use of Three Dimensional
Survey to optimize directional drilling, the ability to place multiple wells on a single pad (Meyer 2007), and
development scenarios of other BLM Oregon districts, it is anticipated that most well development will
utilize existing road infrastructure to develop the resource. However, it may be necessary to construct up to
0.25-mile of access road for each pad to remove the facilities from active roadways. Based on the ability to
cluster wells, an assumption for calculation of four wells per pad was used. Therefore, it is estimated that no
more than 20 miles of new road construction would be needed in full development. This would be moderate
duty access road with a surface 18 to 20 feet wide, anticipated to be constructed on both private and BLM-
administered lands. The clearing width would average 40 feet including ditches, utilities, pipelines, cuts, and
fills. The total acreage impacted would total approximately 97 acres for all lands within the Salem District,
approximately 22 acres of which would involve BLM-administered lands. Roads not retained for other
resource management purposes would be reclaimed at the end of the project.
Total disturbance of both BLM-administered lands and other lands for wells, support services, pipeline
and new road construction is expected to be approximately 1,426 acres or 2.8% of the total high potential
acreage. Surface disturbance would be restricted, as much as possible, to previously disturbed areas such
as logging roads and landings. Industry is currently utilizing a multi-well to single pad approach which
minimizes impact. Interim reclamation will also reduce initial disturbance. After initial construction, well
sites pad areas will be reclaimed while the wells are in production. Disturbance will be limited to areas
within overwork foundation structures and necessary infrastructure, such as well heads, pipelines, and
access roads.
Coos Bay District
It is estimated that the productive life span of a single well within the coal bed natural gas could range to
greater than 14 years. Total lifespan of the field would be determined on the type of phased development and
exploration of the previously untested deeper resources greater than 4,000 feet. All gas production would
be carried by pipelines. Most, if not all, pipeline will be contained within road rights-of-way. It is estimated
that up to 40 miles of pipeline could occur outside a road right-of-way. Additional conventional petroleum
structures totaling 550 square miles have also been identified within the Coos Bay District.
Based on potential for resource development (described above) and utilizing access road built for well
accessed timber development (most likely for the BLM-administered parcels within the Coos Basin), it was
estimated that between five to no more than 10 miles of moderate duty access road with a surface 18 to 20
feet wide is anticipated to be constructed. The surface disturbance width would average 40 feet including
ditches, utilities, pipelines, cuts, and fills. The acreage impacted by new road building would total between
approximately 24.25 acres and 48.5 acres for the Coos Bay District. Roads not incorporated into other
resource management would be reclaimed at the end of the project.
Appendices - 595
FEISfor the Revision of the Western Oregon RMPs
Altogether, the total disturbance for the wells, support services, and new road construction on BLM-
administered mineral estate is expected to range between 194.25 acres (1.6% of BLM-administered area: 37
wells) to 404.25 acres (3.3% of BLM-administered area: 77 wells). Surface disturbance would be restricted,
as much as possible, to previously disturbed areas such as logging roads and landings. Industry is currently
utilizing a multi-well to single pad approach which minimizes impact.
A pipeline 40 miles in length with a right-of-way width of 30 feet would disturb about 145 acres. Due to
the checkerboard public land ownership in this area, it is estimated that only 50 percent of that acreage
would be on public lands administered by the BLM. Altogether, it is estimated that about 73 acres of BLM-
administered land would be impacted from pipeline construction. The total surface disturbance of field
development and production on BLM-administered land would range between 291.5 acres and 525.75 acres.
Total field development disturbance within the district, both Federal and non-Federal, could range between
2,289 acres (338.33-acre well spacing) and 5,255.25 acres (160-acre well spacing). Communitization and
Unitization agreements (both State and Federal) can drastically reduce surface disturbance for both Federal
and non-Federal lands. These cooperative agreements allow the sharing of wells, pads, and infrastructure;
combining uses; and minimizing the need for new development.
Limitations
Salem District
The acreage estimates used for BLM-administered surface estate are based on current GIS layers.
The accuracy of this information has not been verified by Master Title Plat Maps. The GIS coverage
for subsurface estate within the District is incomplete. Therefore, the existence and location of BLM-
administered subsurface estate on the Salem District is unknown.
A brief review of the Master Title Plat Maps was completed within and near the 1985 Mist Gas Field
boundaries. Federal subsurface estate identified on the Master Title Plat Maps was not recorded on the GIS
layers. Most of the Master Title Plat Maps identified federal subsurface parcels outside the Mist Gas Field
boundaries. Due to the incompleteness of the GIS layers, especially within subsurface estate, the potential of
BLM-administered subsurface estate was not addressed in this report.
Appendices - 596
Appendix Q - Energy and Minerals
Ten- Year Reasonably Foreseeable Development
Of Oil And Gas Resources Scenario For The
BLM Eugene, Roseburg, And Medford Districts
And The Klamath Falls Resource Area Of The
Lakeview District
Summary
This report estimates the potential for occurrence of oil and gas activity on Federal acreage managed by
the BLM in the Eugene, Roseburg, and Medford Districts, and in the Klamath Falls Resource Area of
the Lakeview District during the next 10 years. The analysis is based on current developments within
and outside of these Districts, including historical Oil and Gas investigations that began with the first
exploration well dilled near Newberg in 1902. This analysis compliments the similar discussion for the Coos
Bay and Salem Districts where proven hydrocarbon resources exist.
It is expected that, with a few exceptions, most public domain and revested Oregon and California Railroad
Grant lands will be available for leasing of hydrocarbon energy resources subject to management by guiding
stipulations. A review of oil and gas occurrence Potential, oil and gas system and play analysis, oil and gas
production activities, potential for resource occurrence and development, and leasing was made to establish
the understood the oil and gas potential presented here. This information was used to project activity
through 2018. Given the current incipient nature of petroleum development in Oregon in 2007 (i.e., current
coalbed natural gas development and new exploration of the Mist Gas Field), completely new assumptions
and information that could impact Reasonably Foreseeable Development scenarios for each district may be
had during the course of the next 10 years and beyond.
The districts are in western Oregon and encompass lands within all or parts of eight counties: Linn, Lane,
Douglas, Jackson, Josephine, Curry, Coos, and Klamath. The potential for occurrence of conventional
petroleum in the districts has been the focus of numerous studies. These investigations have resulted in one
developed field in the Salem District (Mist Gas Field), beginning with a discovery well in 1979. A prospect
for coalbed natural gas is being developed in the Coos Bay District. However, small amounts of conventional
and unconventional oil and gas have been found throughout western Oregon, based on the projected
sedimentary basins.
Research has identified sedimentary basins, petroleum systems, and coal basins. Based on these petroleum
systems, five plays and associated prospects have been identified. The research cited within this report
projects that these plays have low to moderate potentials for development.
Based on BLM protocol for mineral potentials, it is further projected that the Eugene and Medford
Districts, and the Klamath Falls Resource Area have low to moderate potential for petroleum occurrence
and low potential for development. Therefore, it is unlikely that petroleum will be developed in these BLM
administrative areas within the 10-year Reasonably Foreseeable Development scenario for the planning
area. The Roseburg District contains plays, prospects, and an area of focused petroleum shows that project
a moderate potential for petroleum occurrence and a moderate potential for development. The BLM-
administered acreage with this moderate potential is approximately 37,000 acres.
It is anticipated that the Roseburg BLM-administered lands could have a development of up to 114 wells,
with total disturbed acreage up to approximately 153 acres within the 10-year Reasonably Foreseeable
Development scenario.
Appendices - 597
FEIS for the Revision of the Western Oregon RMPs
Common to All Alternatives
Introduction
This Reasonably Foreseeable Development (RFD) describes scenarios for leasable oil and gas commodities
within lands managed by the BLM’s Eugene, Roseburg, and Medford Districts and the Klamath Falls
Resource Area of the Lakeview District (collectively referred to as districts). The purpose of this RFD
scenario is to provide models that anticipate the level and type of future petroleum development activity
in the planning area, and to serve as the basis for analyzing cumulative impacts. The RFD first describes
historic and current development. Future trends and assumptions for hypothetical exploration and
extraction operations are then described. All projections are estimates based on available information
presented in the Historic and Current Development section.
Methodology
Extensive review of existing literature was completed, as well as acquisition of unpublished information.
Resulting information, such as prospects, plays, basins, exploration wells, seeps, coal exposures, and
petroleum encounters in water wells, were crafted into Geographic Information Systems (GIS) map layers.
These layers were then incorporated into GIS maps of BLM-administered lands and geologic mapping. The
results provided quantifiable locations and acreages estimates of petroleum potentials, or lack of, for BLM-
administered lands within each district boundary (USDI BLM 2008).
Scope
This RFD is based on the known and inferred mineral resource capabilities of the lands involved, and applies
to conditions and assumptions discussed under Historic and Current Development, as well as Future Trends
and Assumptions. Changes in geologic data, interpretation, and/or economic conditions that alter the RFD
may result in deviation of these projections over time.
Impacts caused by oil and gas development, as well as impacts to oil and gas development, cannot be
assessed without estimating future oil and gas activity. Such estimates of future activity incorporate:
• oil and gas occurrence potential, as documented by historic research and papers
• oil and gas system and play analysis (including existing plays currently developed and the potential
development for new plays such as identified sediment basins and Coalbed Natural Gas
• oil and gas production, including economics and technology
• potential for resource occurrence and development
• leasing and development, including Federal and non- Federal activities
The above factors cannot be predicted with certainty, but some generalizations are possible. The estimates
presented here are based on past and present activities as well as on trends within and without the Districts,
including future price deviations. These estimates may be lower than what may actually happen if price
and play developments are more positive than anticipated. Likewise, if expansion of existing plays is not
successful, if new plays are not developed, and/or if commodity prices are less than anticipated, these
estimates may be exaggerated.
Appendices - 598
Appendix Q - Energy and Minerals
Historic And Current Development
Oil and Gas Occurrence Potential
The districts encompass lands in eight counties, including Linn, Lane, Douglas, Jackson, Josephine, Curry,
Coos, and Klamath counties. The districts are located in western, southwestern, and southern Oregon. The
BLM-management extends to both Public Domain (PD) and revested Oregon and California Railroad
(O&C) lands. It is expected that most of these lands will be available for mineral leasing.
Petroleum development in the districts has been the focus of numerous studies such as Dillar (1909, 1914,
as found in Weissenborn 1969 and others), Washburne (1914 as found in Olmstead et al. 1989), Stewart and
Newton (1954), Newton (1969), Newton (1980), Olmstead et al. (1989), Niem and Niem (1990), and Ryu et
al. (1996). The districts have also been the focus of numerous industry explorations and investigations, by
such companies as Northwest Natural (Oregon Natural Gas Development), Mobil Oil Corporation, Methane
Energy Corporation, Standard Oil Company of California, Guarantee Oil Company, Sinclair Oil & Gas
Company, Amoco, as well as numerous others (Olmstead et al. 1989, Niem and Niem 1990, Stewart and
Newton 1954, Meyer 2007).
Although exploration of Western Oregon has been more or less continuous since 1902, three major peaks of
petroleum exploration have occurred. The first took place between 1920 and 1940. This peak of exploration
was very wide-spread, as there was little geologic information guiding the exploration. The second peak
occurred between 1940 and 1960, and investigated the deeper Oligocene and Eocene marine sediments.
This phase cumulated in the discovery of the Mist Gas Field in 1979 (Olmstead et al. 1989, Olmstead and
Alger 1985, Houston 1997). The third occurred in the 1980s, with the placement of deep wells up to 13,177
feet total depth (Niem and Niem 1990). This third peak has continued into the search and development of
unconventional petroleum resources such as Coalbed Natural Gas, with a play being developed in the Coos
Bay Basin.
Little oil and gas exploration has been conducted in the Medford District and Klamath Resource Area
(Niewendorp 2008, Wiley 2008, Wells 2008). Oil and gas exploration wells have been drilled, with at least
two shows (see Figure Q-13). A potential oil shale deposit was also been identified. These are located in
or near a delineated coalfield, identified as the Rogue River Coalfield (Olmstead et al. 1989, Stewart 1954,
Sidle 1981; Jackson County 1989, 2004, 2006). Most energy investigations have focused on geothermal
explorations (Niewendorp 2008).
Appendices - 599
FEISfor the Revision of the Western Oregon RMPs
Figure Q-13. Western Oregon Oil and Gas Investigations and Projections
Legend
Historic Exploration Well w/ Shows
A Oil Shale
^ Exploration Well-O&G
° Coal
G Exploration Well
' Exploration Well-Gas
■*- Exploration Well-Oil
Producer-Former-Gas
Producer-Gas
Seep
Water Well
Basin Outline
■ j Basin
Coal Basin
1 I Petroleum Shows-Focus
I I Gas Field
□ Gas Prospect
1 1 Petroleum System
Play
— — — BLM Administrative Boundary
State Boundary
10 0 10 20 30 40 50 Miles
10 0 10 20 30 40 50 Kilometers
M I 1 I 1 I 1
Albers Equal Area Projection
North American Datum of 1983
Source: Bureau of Land Management Corporate Data
revised for WOPR Analysis. No warranty is made by the
Bureau of Land Management as to the accuracy,
reliability, or completeness of these data for individual
or aggregate use with other data.
Western Oregon Plan Revisions
Final Environmental
Impact Statement
Klamath Falls
■
M07-10-01
—
Source: USDI BLM 2008, Olmstead et al. 1989, Niem and Niem 1990, Newton et al. 1980, Stewart and Newton 1954,
Sidle 1981, Newton 1969, Kvenvolden et al.1995, Mason and Erwin 1955
Appendices - 600
Appendix Q - Energy and Minerals
Oil and Gas System and Plays
The Eugene and Roseburg Districts are part of a structural sedimentary basin system that extends onshore
and offshore from the Klamath Terrains boundary north to the Columbia River (extending into Washington
as the Puget-Willamette Trough); from the continental shelf east to the Cascade Mountain/Willamette
Valley interface. This is known as the Western Tertiary Basin Province (Olmstead et al. 1989). This province
has been of interest for petroleum exploration since the 1880s (Newton 1969, Orr and Orr 2000), with
exploratory oil and gas drilling beginning in 1902 near Newberg (Stewart and Newton 1954, Olmstead et al.
1989).
The northern portion of the Western Tertiary Basin Province possesses at least six identified basins or sub-
basins (Newton 1969, Orr and Orr 2000, Olmstead et al. 1989). These basins include:
• Tualatin Basin (a sub-basin of the Willamette Valley)
• Willamette Valley
• Newport Basin (a sub-basin of the larger off-shore Newport Basin)
• Tillamook Basin (a sub-basin of the larger off-shore Newport Basin)
• Astoria Basin
• Nehalem Basin (or arch)
Of these, the Willamette Basin extends into the Eugene District (see Figure Q-14).
The Willamette Valley basin extends from the southern end of the Puget Sound Trough at the Columbia
River south into the Eugene District. This basin is mapped adjacent to the Tyee Basin through parts of the
Salem District and the Eugene District (see Figures Q-14 and Q-15 ) (Newton 1969, Ryu et al. 1996). The
lower rock, or basement rock, is the Eocene Siletz River Volcanics or Kings Valley Siltstone. Overlying these
are sandstones and siltstones to the Eocene Nonconformity. This nonconformity is covered by volcanics,
overlain by sandstone, limestone, and coal beds. The assemblage is capped by the Columbia River Basalts,
which are covered by tuff and silt. The petroleum potential boundary in the Eocene rock is defined to
the east by the change from marine sediment to volcanic sediment (facies change) (Newton 1969) (see
Figure Q-14). Numerous wells with gas shows have been drilled within the valley. The eastern edge of the
valley provides numerous possibilities for structural traps, with the marine beds providing source rock
for petroleum accumulations. Even though numerous holes have been drilled and source and structure
is present, true potential has not been clearly defined. The Eocene Nonconformity (marine facies) is at
maximum the mapped depth of 5,000 feet below sea level (Newton, 1969).
The southern portion of the Western Tertiary Basin Province is identified as the Tyee Basin. This basin
extends north from the Klamath Terrains to approximately the Lincoln City-Salem Latitude (Ryu et al,
1996). The Tyee Basin is actually composed of two basins: the NE-SW oriented Umpqua basin of early
Eocene age and the north-south oriented Tyee Forearc Basin of middle Eocene age. The Umpqua Basin is
divided by the Umpqua Arch, composed of a volcanic high. The two sub-basins include the Smith River
Sub-Basin, located east of Florence and Reedsport, and the Myrtle Point-Sutherlin Sub-Basin along the
southern boundary (Ryu et al. 1992, 1996). The Yaquina Sub-Basin of the Salem District could be considered
as part of the Tyee Basin, as well as the southern portion of the Willamette Valley Sub-Basin (Ryu et al. 1996;
Newton 1969). The Coos Basin overlies and bounds by mapping, the Tyee Basin to the west (Ryu et al. 1996)
(refer to Figure Q-14).
The basin structure is controlled by compression resulting from the subducting easterly moving Juan de
Fuca plate in relation to the overriding westerly moving North American Plate. The fold axes are oriented
north-south (Orr and Orr 2000). The northern basins are defined by the contact between the Miocene
or Oligocene rock and Eocene rock. This is a point of erosion of the Eocene rock, which was covered by
Miocene or Oligocene rock, defined as a nonconformity (unconformity if covered by Miocene or Oligocene
sedimentary rock). This break in the geologic column is considered the Eocene nonconformity and a focus
Appendices - 601
FEISfor the Revision of the Western Oregon RMPs
Figure Q-14. Basic Underlying Geology
Legend
BLM Administrative Boundary
State Boundary
Underlying Geology Maps:
Newton, V.C. Jr., 1969, Subsurface
Geology of the Lower Columbia and
Willamette Basins, Oregon: State of
Oregon Department of Geology and
Mineral Industries Oil and Gas
Investigations No. 2, 121 p.,
Cross-sections and Maps.
Ryu, I. C., Niem, A. R., Niem, W. A.,
Wells, R. E., and Hales P. O., 1996,
Oil and Gas Potential of the Southern
Tyee Basin, Southern Oregon Coast
Range: State of Oregon Department
of Geology and Mineral Industries Oil
nd Gas Investigation 19, Cross
Sections and 1 41 p.
10 0 10 20 30 40 50 Miles
l — l i i i 1 i =i
10 0 10 20 30 40 50 Kilometers
Albers Equal Area Projection
North American Datum of 1983
Source: Bureau of Land Management Corporate Data
revised for WOPR Analysis No warranty is made by the
Bureau of Land Management as to the accuracy,
reliability, or completeness of these data for individual
or aggregate use with other data.
Type ffl kaogw
El Raxrrafaragfc
E ‘tSSr1'®'*”' © SQlddflsH,,
frl Ca* p3orvc<frd In
low-pointy and
fWnnesftje rock
Shat*
Mudxtona
Pi urging
ttOfc fell
I radicates dlrtrtinn petra) ^ ^
— I Running
y •A'ncfcne
P&t«nUi gas 4octimuUdo.Tt
prospect
Western Oregon Plan Revisions
Final Environmental
Impact Statement
Klamath Falls
+
INDEX JVIA?
Source: Newton 1969, Ryu et al. 1996
Appendices - 602
Appendix Q - Energy and Minerals
Figure Q-15. Basin, Petroleum Systems, Plays, and Prospects
Sources: USDI BLM 2008, Olmstead et al. 1989, Niem and Niem 1990, Newton et al. 1980, Stewart and Newton 1954,
Sidle 1981, Newton 1969, Kvenvolden et al. 1995, Mason and Erwin 1955
Appendices - 603
FEISfor the Revision of the Western Oregon RMPs
of petroleum exploration. The Eocene rocks consist of marine sediments, with latter sedimentation creating
coal beds in many areas (Newton 1969) (refer to Figure Q-14).
The Tyee Basin structure is a result of compressional tectonics. However, rotation of tectonic forces
produced differing orientations for the Umpqua Basin and the Tyee Forearc Basin (Ryu et al. 1996, Wells
et al. 2000). In general, the projected conventional oil and gas systems result from organic rich source rock
and coal from the Umpqua Basins being trapped by the rock of the overlying Tyee Forearc Basin (Ryu et al.
1996). The coal seams of the Coos Basin (Coos Bay District) are currently being investigated for coal bed
natural gas. However, deeper source rocks may exist and contribute to the coal bed natural gas resource.
These source rocks would be part of the underlying Tyee Basin (Pappajohn 2007, Newton et al. 1980).
Based on geologic interpretation and petroleum exploration, Ryu et al. (1996) identified petroleum systems,
plays, and prospects within the Tyee Basin. An oil and/or gas play is an area, geologic formation, or geologic
trend that has good potential for oil and/or gas development, or is generating a large amount of interest in
leasing and drilling (USDI BFM 2001). As defined by Magoon (1988 as found in Ryu et al. 1996):
• A Petroleum System is a relationship of source rock and the resulting petroleum accumulation.
This relationship contains a source rock for petroleum; migration paths; reservoir rock; seal; trap;
and the appropriate geologic processes that form these hydrocarbon materials. The extent of the
Petroleum System can be delineated as an area that contains both the mature source rock and
oil or gas accumulations. The name of the Petroleum System would consist of the name of the
source rocks, followed by the name of the reservoir rock, followed by the level of certainty for its
occurrence.
There are three levels of certainty: known, hypothetical, and speculative. Known systems have a strong
geochemical match between the source rocks and an existing petroleum accumulation. These are identified
in the name by an exclamation point in parentheses: (!). Hypothetical systems have geochemical data that
identify a source rock, but do not link the source rock to a known petroleum accumulation. These are
identified in the name by a period in parentheses: (.). An example is the Mist Gas Field. The Speculative
system has geological or geophysical evidence used to project the existence of a link between source rocks and
potential petroleum accumulations. These are identified in the name by a question mark in parentheses: (?).
• A Play is the existence of a trap (a geologic structure that allows petroleum to accumulate) that is
detectable with geological, geophysical, or geochemical technology. A play does not need all of the
elements of a petroleum system.
• A Prospect is a drillable trap that is located within a play.
Ryu et al. (1996) identified three distinct speculative petroleum systems, five distinct plays, and three
distinct gas prospects within the Tyee Basin (refer to Figure Q-15). The identified petroleum systems include:
— The Umpqua-Dothan-White Tail Ridge (?) Hybrid Petroleum System : There is a potential of
dry gas (methane) from buried coals and carbonaceous mudstone of the White Tail Ridge
Formations, with migrations to traps of the Tyee Sandstones. Because there is no known
connection between the potential source of petroleum and the potential traps and because
there is no known commercial accumulations of natural gas, the system is considered
speculative. According to BFM GIS-based estimates, the total acreage of this petroleum system
is approximately 574,000 acres. Of this, approximately 215,000 acres are within the Coos Bay
District, approximately 352,000 acres are within the Roseburg District, and approximately 8,000
acres are within the Medford District.
— The Umpqua-lower Tyee Mountain (?) Petroleum System; Basin Center Gas (?): This system
may contain a tight-gas sandstone reservoir, collecting thermogenic (temperature-induced
conversion to petroleum) wet-gas and oil derived from mudstone of the Umpqua Group.
The model projects natural gas migrating along fractures to accumulate in Tyee Mountain
turbidite sandstones. An unconventional mudstone reservoir is possible in the Umpqua Group.
According to BFM GIS, the total acreage of this petroleum system is approximately 145,000
Appendices - 604
Appendix Q - Energy and Minerals
acres. Of this, approximately 1 16,000 are within the Coos Bay District and approximately 29,000
acres are within the Eugene District.
— The Spencer- White Tail Ridge- Western Cascade Arc (?) Petroleum System: The petroleum
sources of this system are the coals and carbonaceous mudstone and sandstones of the Spencer
Formation and White Tail Ridge Formation, generated by the deep burial and heating by the
Western Cascades arc plutons. The reservoir rock would be the overlying sandstones and delta
facies. According to BFM GIS, the approximate total acreage of this petroleum system is 1 19,000
acres. Of this, approximately 69,000 acres are within the Eugene District and approximately
50,000 acres are within the Roseburg District.
All of these systems are considered speculative. Additional drilling and exploration may alter that qualifier
(or completely remove the potential). As an example, the Mist Gas Field was considered a speculative field
until the discovery well was drilled in 1979, which lead to its designation as a gas field (Ryu et al. 1996).
In addition to the three petroleum systems, Ryu et al. (1996) have identified five different plays described
below in the order of their potential to produce hydrocarbons, as shown in Figure Q-15:
1. The Williams River-Burnt Ridge anticlinal Plays: This is a complex domal structure in the Tyee
Formation (Play 1 of 5). Natural gas might be found in the lower Umpqua strata in the footwall
beneath Siltez River Volcanics. The White Tail Ridge sandstone could also serve as a trap. Isolated
faults and thrust faults, as well as pinchouts and unconformities, also provide potential traps. A
gas prospect may exist within this play. According to BFM GIS, the total acreage of this play is
approximately 94,000 acres. Of this, approximately 20,000 acres are within the Roseburg District
and approximately 74,000 acres are within the Coos Bay District.
2. Western Cascades plays and Bonanza thrust near Nonpareil: This system incorporates anticlines
and faults, including the extension of the Bonanza Fault, at the contact of the Tyee Basin and the
Western Cascades (Play 2 of 5). The potential reservoir rocks include the Spence and White Tail
Ridge formations. Source rock includes several one- to six-foot thick coal beds, carbonaceous
sandstone, and mudstone. Other plays may exist in the foothills of the Western Cascades, with
the buried Spencer Formation being the structural or stratigraphic play. The Spencer Formation
is exposed from Glide to Cottage Grove. A gas prospect is projected within the play. According to
BFM GIS, the total approximate acreage of this play is 64,000 acres, all of which is contained within
the Roseburg District.
3. Klamath Mountains sub-thrust play. Glide area: It is interpreted that the Klamath Mountains
(Klamath Terrains) are thrust over the Coast Range rocks, burying parts of the Southern Tyee
Basin. Possible plays may exist in the underlying Tyee Basin stratigraphy in the areas of the Wildlife
Safari fault and southeast and southwest of Glide (Play 3 of 5). The White Tail Ridge Formation
is the potential reservoir unit with source being derived from the Remote Member and Tenmile
Formations. However, it is debated whether the Tyee stratigraphy (Siletz River Basalts) formed
in place through an abandoned rift zone. This would mean that there is no overthrusting of the
Klamath Terrains over the Tyee Basin, and therefore no associated traps or plays (Ryu et al. 1996).
However, more recent geology mapping has indicated that the overthrusting does exist (Well et
al. 2000, DuRoss et al. 2002, Wells 2008). Therefore, while unexplored, potential for petroleum
traps along the Klamath Terrains/Tyee Basin boundaries may exist. According to BLM GIS, the
total approximate acreage of this play is 96,000 acres, all of which is contained within the Roseburg
District.
4. Tyee Mountain anticlinal plays: Several untested anticlines exist in the Tyee Mountain and
Baughman members of the Tyee Formation beyond the Williams River-Burnt Ridge anticlinal plays
(Play 4 of 5). Stratigraphic traps could exist along the flanks of the Siletz River Volcanics in the
Umpqua Arch. A specific untested anticlinal structure exists at Stony Point. While these untested
structures exist, the potential of the northern anticlines is low when compared to the southern
anticline systems, due to the lack of maturation, organic- rich source rock, and reservoir rocks.
Appendices - 605
FEISfor the Revision of the Western Oregon RMPs
However, a gas prospect may exist in the northern portion of the play. According to BLM GIS, the
total approximate acreage of the play and prospect is 203,000 acres. Of this, approximately 25,000
acres are located within the Coos Bay District, approximately 91,000 acres are located within the
Eugene District, and approximately 87,000 acres are located within the Roseburg District.
5. Anticlinal and subthrust plays in the Myrtle Point-Sutherlin Sub-Basin: These plays consist of
thrust faults and anticlinal and synclinal folds of rock of the Umpqua Group, Bushnell, and
White Tail Ridge formation in the Myrtle Point-Sutherlin Sub-Basins. The area of the play is the
Roseburg-Sutherlin-Glide area (Play 5 of 5). Gas shows have been encountered in tight sandstones
and methane emanations from water wells. However, there has been no commercial production.
According to BLM GIS, the total approximate acreage of the play is 60,000 acres, all of which is
contained within the Roseburg District.
Additionally, numerous exploration wells, seeps, and petroleum producing water wells exist within the
districts. As shown in Figure Q-15, an area of concentration of petroleum shows is located within the
Umpqua-Dothan-White Tail Ridge (?) hybrid petroleum system. Although shows are found throughout the
four districts, this concentration provides a concentrated area of petroleum shows. According to BLM GIS,
the total acreage of this focus of petroleum shows is approximately 68,000 acres, of which all is contained
within the Roseburg District.
All of these structures and systems completely or in part underlay the Eugene and Roseburg Districts. Areas
of gas and oil exploration and shows also exist throughout the Districts (Olmstead et al. 1989, Niem and
Niem 1990, Newton et al. 1980, Stewart and Newton 1954, Newton 1969, Sidle 1981, Kvenvolden et al. 1995)
(refer to Figure Q-15).
The Medford District is south and east of the Tertiary Basin System/Tyee Basin, incorporating Klamath
accreted terrains in the west and the Cascade Volcanics and Basin and Range structures to the East. The
Klamath Resource Area of the Lakeview District lies east of the Medford District and incorporates “Basin
and Range” structures. The accreted Klamath terrains are bound by the Tyee Basin (The Tyee Basin is the
southern portion of the Western Tertiary Basin System) to the North. They extend into northern California
and are variously bounded on the east by Cascade Volcanics and rocks within the Basin and Range province.
The Oregon portion of the Basin and Range province is a northern projection of the crustal extension that
extends through the southwestern United States.
Coal exposures and basins exist throughout western Oregon (Mason and Erwin 1955) (refer to Figure
Q-13). One major coal basin has been identified in the Medford District within Jackson County (Sidle
1981; Jackson County, 1989, 2004, 2006; Weissenborn 1969). This coal field is known as the Rouge River
Coal Field. The field extends southward from Evans Creek to a point about 10 miles south of the Oregon-
California border (Weissenborn 1969) (see Figure Q-16). According to BLM GIS, the total approximate
acreage of the Rouge River Coal Field is 221,000 acres, all of which is contained within the Medford District
boundaries (the portion in California is not analyzed).
All coal seams in western Oregon could produce coal bed natural gas. However, the true potential is
unknown, as investigations for coal bed natural gas potential for these seams are just beginning (Wiley 2006,
Pappajohn 2007, Meyer 2007). Potential could exist within the coal seams of the Umpqua Group, as well as
with coeval formations north throughout the coast range. If coal bed natural gas is producible in the Coos
Basin, exploration may extend to other speculative formations (May 2005, Pappajohn 2007).
Current development of the coal bed natural gas resource is being conducted by the Methane Energy
Corporation within the Coos Bay District. The company has completed numerous exploratory and
production wells within the Coos Basin. Based on this exploration, the company has projected a defined
area for coal bed natural gas development, described as an “Area of Mutual Interest” (AMI). This
incorporates the Coos Basin (Torrent Energy Corporation 2008).
Appendices - 606
Appendix Q - Energy and Minerals
Figure Q-16. Coal Basins
Legend
Historic Exploration Well w/ Shows Basin Outline
A
Oil Shale
: : Basin
Y
Exploration Well-O&G
Coal Basin
o
Coal
1 8 Petroleum Shows-Focus
A
1 IGas Field
Exploration Well
Gas Prospect
Y
Exploration Well-Gas
f 'll Petroleum System
Exploration Well-Oil
1 IPlav
-fr
Producer-Former-Gas
BLM Administrative
Boundary
Vr
Producer-Gas
State Boundary
0
Seep
Y
Water Well
10
15
20 Miles
Source: Bureau of Land Management Corporate Data
revised for WOPR Analysis. No warranty is made by the
Bureau of Land Management as to the accuracy,
reliability, or completeness of these data for individual
or aggregate use with other data.
Western Oregon Plan Revisions
Final Environmental
Impact Statement
M07-10-01
, — „ ,
Sources: USDI BLM 2008,0lmstead et al. 1989; Niem and Niem 1990, Newton et al. 1980, Stewart and Newton 1954,
Sidle 1981, Newton 1969, Kvenvolden et al. 1995, Mason and Erwin 1955
Appendices - 607
' FEISfor the Revision of the Western Oregon RMPs
The following descriptions of oil and gas occurrence potential are projected for BLM-administered mineral
rights within the western Oregon Districts. Prospects, Plays, Basins and other potentials overlap district
boundaries. Therefore, a total system potential may incorporate more than one district.
Eugene District
The Eugene District incorporates portions or all of Linn, Lane, and Douglas counties. At least one
exploration well with shows of oil and gas (Fed-Mapleton 1) and two petroleum seeps are within the Eugene
District boundary. Sedimentary basins underlying the Eugene District include both the Tyee Basin and
the Willamette Valley Basin. Two Petroleum Systems extend into the district, as well as the Tyee Mountain
anticlinal play and its associated Gas Prospect (see Figure Q-17, later in this appendix )
Table Q-8 represents the approximate acreage of the basins, systems, plays, and prospects located within the
Eugene District.
Roseburg District
The Roseburg District incorporates the major portion of Douglas County, with minor portions of Linn
and Jackson Counties. The district has been the focus of historical exploration with at least 2 oil and gas
exploration well shows, 7 exploration gas well shows, 3 exploration oil well shows, 5 petroleum seeps,
12 petroleum shows in water wells, and 12 coal exposures. Sedimentary basins underlying the Roseburg
District include the Tyee Basin. Two petroleum systems extend into the Roseburg District, as well as five
projected plays. One complete gas prospect and another partial gas prospect associated with two plays exist,
as well as one focused area of petroleum exploration (see Figure Q-18).
Table Q-9 represents the approximate acreage of the basins, systems, plays, and prospects within the
Roseburg District.
Medford District
The Medford District incorporates portions or all of Jackson, Josephine, Douglas, Curry and Coos Counties.
At least two oil and gas exploration wells with shows, one petroleum seep, one oil shale prospect, and
one coal field exist within the Medford District boundary. A small portion of the Tyee Basin sedimentary
basin and a petroleum system underlies the northwest part of the district. No plays or prospects have been
mapped within the District (see Figure Q-19).
Table Q-10 represents the approximate acreages of basins, petroleum systems, and coalfields located within
the Medford District.
Klamath Falls Resource Area of the Lakeview District
The Klamath Falls Resource Area of the Lakeview District incorporates Klamath County. No recorded
exploration wells with shows, seeps, water wells with petroleum shows, or coal were found in the literature
search or in agency communications (see Figure Q-20). Most energy wells drilled have been in the search
and delineation of geothermal energy. It should be noted that the lack of exploration does not indicate a lack
of petroleum potential, but simply a lack of information. Therefore, future potential cannot be analyzed.
Gas and oil production has been located in similar basin and range provinces, such as in the state of Nevada
(Hess 2001).
Appendices - 608
Appendix Q - Energy and Minerals
Table Q-8. Eugene District Acreages
System
Total Acreage
Within the
Eugene District
Total BLM-Managed
Surface Acreage
Total BLM-Managed
Sub-Surface
Split-Estate Acreage
Tyee Basin
794,000
160,000
500
Willamette Sedimentary
Basin
252,000
5,000
12,000
Spencer-White Tail Ridge-
Western Cascade Arc (?)
Petroleum System
69,000
13,000
100
Umpqua-lower Tyee
Mountain (?) Petroleum
System
29,000
4,000
0
Tyee Mountain anticlinal
play and associated gas
prospect (Play 4 of 5)
91,000
55,000
0
Table Q-9. Roseburg District Acreages
System
Total Acreage
Within the
Roseburg District
Total BLM-Managed
Surface Acreage
Total BLM-Managed
Sub-Surface
Split-Estate Acreage
Tyee Basin
889,000
207,000
300
Spencer-White Tail Ridge-
Western Cascade Arc (?)
Petroleum System
50,000
11,000
0
Umpqua-Dothan-White Tail
Ridge (?) hybrid Petroleum
System.
352,000
83, 000
0
Williams River-Burnt
Ridge Anticlinal Play and
associated Gas Prospect
(Play 1 of 5)
20,000
7,000
0
Western Cascades Plays
and Bonanza Thrust near
Nonpareil and associated
Gas Prospect (Play 2 of 5)
64,000
10,000
0
Klamath Mountains
Subthrust Play, Glide Area
(Play 3 of 5)
96,000
18,000
0
Tyee Mountain Anticlinal
play (Play 4 of 5)
87,000
41,000
0
Anticlinal and Subthrust
Plays in the Myrtle Point-
Sutherlin Subbasin (Play 5
of 5)
60,000
3,000
0
Area of Focused Petroleum
Shows
68,000
2,000
0
Table Q-10. Medford District Acreages
System
Total Acreage
Within the
Medford District
Total BLM-Managed
Surface Acreage
Total BLM-Managed
Sub-Surface
Split-Estate Acreage
Tyee Basin
20,000
4,000
0
Umpqua-Dothan-White Tail
Ridge (?) Hybrid Petroleum
System
8,000
2,000
0
Rogue River Coal Field
221,000
33,000
3,000
Appendices - 609
FEISfor the Revision of the Western Oregon RMPs
Figure Q-17. Eugene District
Legend
Historic Exploration Well w / Shows Basin Outline
▲
Oil Shale
: j Basin
Y
Exploration Well-O&G
Coal Basin
O
Coal
H Petroleum Shows-Focus
Y
C..7.1 Gas Field
Exploration Well
Gas Prospect
Y
Exploration Well-Gas
! J Petroleum System
*
Exploration Well-Oil
1 1 Play
YY
Producer-Former-Gas
— — — BLM Administrative
yY
Producer-Gas
Boundary
State Boundary
*
Seep
Y
Water Well
IW BLM Administered Land
Sources: USDI BLM 2008, Olmstead et al. 1989; Niem and Niem 1990, Newton et al. 1980, Stewart and Newton 1954, Sidle 1981,
Newton 1969, Kvenvolden et al. 1995, Mason and Erwin 1955
M07-10-01
5 0 5 10 15 20 Miles
I — I I 1 1
Source: Bureau of Land Management Corporate Data
revised for WOPR Analysis. No warranty is made by the
Bureau of Land Management as to the accuracy,
reliability, or completeness of these data for individual
or aggregate use with other data.
Western Oregon Plan Revisions
Final Environmental
Impact Statement
Appendices - 610
Appendix Q - Energy and Minerals
Oil and Gas Production
Conventional Oil & Gas Resources
There is no current petroleum production within the Eugene, Roseburg, or Medford Districts or the
Klamath Falls Resource Area of the Lakeview District. The only commercial production within Western
Oregon occurs in the Mist Gas Field, located within the Salem District.
The Mist Gas Field Designation (see Figure Q-21) was initiated with the discovery of natural gas in 1979.
The main target zone is the reservoir rock of the Clark and Wilson Sandstone (Olmstead and Alger 1985).
As of 2007, there have been over 45 separate pools identified (Meyer 2007) with two gas storage reservoirs
(DOGAMI 2003). Locations of additional pools are expected with the use of 3-D Survey (Meyer 2007).
Current exploration is focused to the northwest of the Mist Gas Field (Houston 2007). However, this is due
to economics as opposed to existence of resource. All areas north of Vernonia, Oregon could be considered
possible extensions of the Mist Gas Field (Meyer 2007).
Annual production for 2005 from the Mist Gas Field was 305 million cubic feet (MMcf), with a total field
production to date of 70 billion cubic feet (Bcf) (DOGAMI 2007). As of 2006, the Mist Field had produced
approximately 68 Bcf, with a value of about $140 million (DOGAMI 2007). The State of Oregon applies a
severance tax of 6% on production, which goes to the common school fund. In total, over 500 oil and gas
wells have been permitted in the field by 2003 (DOGAMI 2003). There are currently 18 actively producing
wells, one water disposal well, 21 observation wells, and 20 gas injection and/o withdrawal wells operating
on the site (DOGAMI 2007). Eight new Applications for Permit to Drill (APD) are being submitted to
DOGAMI for additional exploration and production wells (Houston 2007).
An annual production history of the Mist Gas Field for the past 10 years is shown on Table Q-4 earlier in
this appendix (DOGAMI 2003 and 2007).
Non-Conventional Petroleum (Coal Bed Natural Gas)
There is currently no coal bed natural gas production in Oregon. However, the Coos Basin, located in Coos
County, is being developed as a production resource. The current development of the coal bed natural gas
resource is being conducted by the Methane Energy Corporation. Tire company has completed numerous
exploratory and production wells within the Coos Basin. The Methane Energy Corporation has also
received National Pollutant Discharge Elimination System permits for surface disposal of production water.
The DOGAMI has initiated a public meeting process to establish a Gas Field Designation for the Coos
Basin. The first public meeting was conducted on January 29, 2007. There is only one other Gas Field
Designation in Oregon, which is the Mist Gas Field. The Gas Field Designation is required to fulfill state
requirements regarding well spacing designations, mineral rights, and control drainage.
Coal bed natural gas development is also beginning in southwest Washington, approximately 20 miles north
of the Salem District. Exploration is being completed by the Methane Energy Corporation’s sister company
(a subsidiary of Torrent Energy Corporation), Cascade Energy Corporation (Torrent Energy Corporation
2008). There is also interest in the southwest Washington coal fields from Comet Ridge Limited (Meyer
2007).
Potential for Resource Occurrence and Development
Potentials for resource occurrence and potentials for resource development (USDI BLM 1985) have been
estimated for the districts. Definitions for potential for resource occurrence include:
• Low Potential - Hydrocarbon occurrence is unlikely.
• Moderate Potential - Conditions exist for hydrocarbons to occur.
• High Potential - Hydrocarbon shows have been documented or production has been established.
Appendices -611
FEISfor the Revision of the Western Oregon RMPs
it i4 if t
Figure Q-18. Roseburg District
Legend
Historic Exploration Well w / Shows Basin Outline
A
Oil Shale
l j Basin
y
Exploration Well-O&G
Coal Basin
o
Coal
11 Petroleum Shows-Focus
Y
Exploration Well
1 8 Gas Field
Gas Prospect
Y
Exploration Well-Gas
1 1 Petroleum System
-*■
Exploration Well-Oil
Play
Producer-Former-Gas
— — - BLM Administrative
Producer-Gas
Boundary
State Boundary
*
Y
Seep
Water Well
1# 181 BLM Administered Land
20 Miles
Source: Bureau of Land Management Corporate Data
revised for WOPR Analysis. No warranty is made by the
Bureau of Land Management as to the accuracy,
reliability, or completeness of these data for individual
or aggregate use with other data.
Western Oregon Plan Revisions
Final Environmental
Impact Statement
M07-10-01
Sources: USDI BLM 2008, Olmstead et al. 1989, Niem and Niem 1990, Newton et al. 1980, Stewart and Newton 1954,
Sidle 1981, Newton 1969, Kvenvolden et al.1995, Mason and Erwin 1955)
Appendices - 612
Appendix Q - Energy and Minerals
Legend
Historic Exploration Well w/ Shows Basin Outline
A
Oil Shale
l -Basin
Y
Exploration Well-O&G
Coal Basin
0
Coal
1 1 Petroleum Shows-Focus
Y
Exploration Well
l |Gas Field
Gas Prospect
Y
Exploration Well-Gas
1 1 Petroleum System
*
Exploration Well-Oil
i !j Play
YY
Producer-Former-Gas
BLM Administrative
Producer-Gas
Boundary
State Boundary
*
Y
Seep
Water Well
BLM Administered Land
A\ fa
Figure Q-19. Medford District
5 0 5 10 15 20 Miles
Sources: USDI BLM 2008, Olmstead et al. 1 989, Niem and Niem 1 990, Newton et al 1 980, Stewart and Newton 1 954,
Sidle 1981, Newton 1969, Kvenvolden et al.1995, Mason and Erwin 1955
M07-10-01
Source: Bureau of Land Management Corporate Data
revised for WOPR Analysis. No warranty is made by the
Bureau of Land Management as to the accuracy,
reliability, or completeness of these data for individual
or aggregate use with other data.
Western Oregon Plan Revisions
Final Environmental
Impact Statement
Appendices -613
FEISfor the Revision of the Western Oregon RMPs
Figure Q-20. Klamath Falls Resource Area
- , w
Legend
Historic Exploration Well w / Shows Basin Outline
▲
Oil Shale
• j Basin
Y
Exploration Well-O&G
Coal Basin
0
Coal
i i Petroleum Shows-Focus
Y
1 J Gas Field
Exploration Well
L ; J Gas Prospect
>
Exploration Well-Gas
L __i Petroleum System
*
Exploration Well-Oil
| | Play
Producer-Former-Gas
BLM Administrative
#
Boundary
Producer-Gas
State Boundary
Seep
Y
Water Well
BLM Administered Land
10 15
20 Miles
Z)
Source: Bureau of Land Management Corporate Data
revised for WOPR Analysis. No warranty is made by the
Bureau of Land Management as to the accuracy,
reliability, or completeness of these data for individual
or aggregate use with other data.
Western Oregon Plan Revisions
Final Environmental
Impact Statement
M07-10-01
Sources: BLM 2008, Obnstead et al. 1989, Niem and Niem 1990, Newton et al.
Newton, 1969, Kvenvolden et al. 1995; Mason and Erwin 1955
1980; Stewart and Newton 1954, Sidle 1981,
Appendices - 614
Appendix Q - Energy and Minerals
Source: DOG AMI 2003
Appendices - 615
FEISfor the Revision of the Western Oregon RMPs
Definitions for potential for resource development include:
• Low Potential - Economic or other conditions would likely preclude development.
• Moderate Potential - It is reasonable to conclude that development could occur.
• High Potential - Development is likely to occur within the life of the plan.
The districts contain two identified sediment basins, three petroleum systems, five plays, three prospects,
one focused area of petroleum shows, and one identified coal field. However, according to Ryu et al.(1996),
the southern Tyee Basin (which incorporates the Eugene and Roseburg Districts) has a low to moderate
petroleum potential. Yet, as shown by the potential systems, plays, and prospects, there are several areas that
have not been investigated.
Ryu et al. (1996) have ranked the five plays in order of potential to produce hydrocarbons, with “1” being the
greatest potential and “5” having the least potential. This is based on the size and closure of the structures;
position of source, reservoir, and seals; and the timing of the play formation in relation to the timing of
potential hydrocarbon migration to the play.
There has been little exploration of portions of the districts outside the Tyee Basin (i.e., Medford District
and Klamath Falls Resource Area). Therefore, future potential cannot be analyzed. However, gas and oil
production has been located in similar basin and range provinces, such as in the State of Nevada (Hess
2001).
Eugene District: Moderate Potential for Occurrence
Low Potential for Development
Two sedimentary basins, two petroleum systems, one play, and one prospect have been projected for the
Eugene District. The sedimentary basins have a low to moderate petroleum potential. The identified play is
ranked as fourth of five plays in potential. The petroleum systems, plays, and prospect have potential for the
existence of hydrocarbons (Ryu et al. 1996). Wells and seeps have confirmed the presence of hydrocarbons
within the district. However, because production has not been established and the play has a low potential in
its ranking compared to the five identified plays, the potential for occurrence is moderate.
There is no additional public record that indicates petroleum investigation of lands within the Eugene
District has occurred since 1996 (Ryu et al. 1996). The last petroleum exploration well was drilled in 1955
(refer to Figure Q-17) (Olmstead et al. 1989). There has been no commercial development of the systems.
The identified play is ranked fourth of five. Petroleum accumulations would need to be confirmed and the
petroleum system move to “known” status for resource development to occur. Therefore, the potential for
development within the plan’s 10-year forecast is low.
The potential acreage of BLM-administered lands to have moderate potential for occurrence and low potential
for development is approximately 72,000 acres.
Roseburg District: Moderate Potential for Occurrence
Moderate Potential for Development/Low Potential for Development
One sedimentary basin, two petroleum systems, five plays, two prospects, and one concentration of
petroleum shows have been projected for the Roseburg District. The sedimentary basin has a low to
moderate petroleum potential. The identified plays rank from highest to lowest ( 1 to 5) in potential out of
five plays. The petroleum systems, plays, and prospects have potential for existence of hydrocarbons (Ryu
et al. 1996). Numerous wells and seeps have confirmed the presence of hydrocarbons within the district.
However, because production has not been established, the petroleum systems are speculative, and the plays
have not been confirmed, the potential for occurrence is moderate.
Appendices - 616
Appendix Q - Energy and Minerals
There is no additional public record that indicates petroleum investigation of the lands within the Roseburg
District has occurred since before 1996 (Ryu et al. 1996). The last petroleum exploration well was drilled
in 1990 (refer to Figure Q-18) (Niem and Niem 1990). There has been no commercial development of the
systems. However, the projected plays range in a ranking of one to five for potential and there has been a
definable area of exploration and petroleum shows. Therefore, based on the ranking of the plays and their
associated petroleum systems, the potential for development within the Plan’s 10-year forecast is low to
moderate.
The potential acreage of BLM-administered lands to have moderate potential for occurrence and
moderate potential for development (Plays 1, 2, and 3 and the area of exploration and petroleum shows) is
approximately 37,000 acres.
The potential acreage of BLM-administered lands to have moderate potential for occurrence and low potential
for development (Plays 4 and 5 and petroleum systems outside of Plays 1, 2, and 3) is approximately 124,000
acres.
Medford District: Low Potential for Occurrence
Low Potential for Development
Non-Conventional: Moderate Potential for Occurrence
Low/Moderate Potential for Development
The Medford District contains petroleum shows, an oil shale prospect, a small portion of a petroleum
system boundary, and an identified coal field. However, for conventional petroleum systems, there is
insufficient information for the occurrence of commercial quantities of hydrocarbons. Therefore, the
potential for occurrence is low.
Due to the lack of evidence for commercial petroleum accumulations, the potential for development within
the plans 10-year forecast is low.
Non-conventional petroleum development in the form of coal bed natural gas is occurring within the Coos
Basin of Oregon and within southwest Washington. The Rogue River Coal Field exists within the Medford
District. It is known by the nature of coal that methane is associated with the beds. Investigations of known
coal exposures are currently being done. If coal bed natural gas becomes commercial in the developing
fields, industry may look at the potential of developing other coal fields (Pappajohn 2007). In addition,
a single identified Oil Shale prospect also exists. Therefore, the potential for nonconventional oil and gas
resource occurrence in the Medford District is moderate.
Currently there is a lack of an existing commercial coal bed natural gas project. If coal bed natural gas
becomes commercially successful in other districts, development potential of other coal systems could
occur within the 10-year scenario (Pappajohn 2007). Resource development potential is dependent on the
future of current enterprises. Although the Medford District does have an oil shale potential and the Energy
Policy Act of 2005 (U.S. 109th Congress 2005) emphasizes the development of oil shale, any potential for
future development will be many years away, and the focus of development is on larger prospects within the
United States. Therefore, the potential for nonconventional development within the plan’s 10-year forecast is
extremely low.
The potential acreage of BLM-administered lands to have moderate potential for occurrence and low potential
for development is approximately 33,000 acres.
Appendices - 617
FEISfor the Revision of the Western Oregon RMPs
Klamath Falls Resource Area: Low Potential for Occurrence
Low Potential for Development
There are no petroleum seeps or exploration shows, identified sedimentary basins with petroleum
potentials, petroleum systems, plays, or prospects located within the Klamath Falls Resource Area of the
Lakeview District. While oil and gas potentials do exist in similar geologic provinces (Basin and Range),
little to no investigation has been performed within this Resource Area. Energy exploration that has been
conducted has focused on geothermal potential. Therefore, largely due to the lack of information, the
potential for occurrence is low.
Likewise, due to the lack of information, the potential for development within the plan’s 10-year forecast is low.
Leasing
After initial field work, research, and subsurface mapping (which may include the acquisition of seismic
data), leasing is often the next step in oil and gas development. Leasing may be based on speculation, with
the riskiest leases usually purchased for the lowest prices.
Leases on lands where the Federal Government manages the oil and gas rights are offered via oral auction.
Auctions typically occur at least quarterly. The maximum lease size is 2,560 acres, and the minimum
bid is $2.00 per acre. An administrative fee of $75 per parcel is charged and each successful bidder must
meet citizenship and legal requirements. Leases are issued for a 10-year term, and a 12.5% royalty rate on
production is required to be paid. Federal Regulations pertaining to oil and gas leasing are located at 43 CFR
3100. All monies from lease and royalty receipts are payable to the Mineral Management Service. Leases
which become productive are “held by production,” and typically do not terminate until all wells on the
lease have ceased production, with all of the wells plugged and abandoned, and the surface reclaimed to an
acceptable condition.
The Oregon- Washington BLM lease sales are generally held on a quarterly basis, offering nominated and
internally selected lands. Federal oil and gas leases sold within the Oregon/Washington BLM for 2006 have
ranged from a high of 227,392 acres in the March sale, to a low of 20,919 acres in September. The total lease
acreage sold from March to December (four sales) was approximately 308,610 acres. From those sales, the
Oregon/Washington BLM received approximately $5,467,720 in oil and gas lease revenues.
Non-federal leasing and APDs for production in the State of Oregon are currently focused in the vicinity
of the Mist Gas Field, the Coos Basin, and Eastern Oregon. Tfie Mist Gas Lield currently maintains 16
production wells. The DOGAMI has recently (2006-2007) received eight APDs submitted for production
(Fiouston, 2007). The Coos Basin currently has 1 15,000 acres of leased land, with three multi- well/ single pad
and single pad/single well production systems. Loreseeable development of the Mist Gas Field in the Salem
District could result in potentially an additional 10,800 acres of BLM-administered lease offerings. If these
offerings were sold for the 2006 average of $17.71 per acre, the net receipts would be nearly $191,268.
At this time, there has been no expressed interest in oil and gas leases in Western Oregon outside of the
Salem and Coos Bay Districts.
Future Trends And Assumptions
Based on history of past exploration; historic, current, and projected development of oil and gas in other
BLM Districts; mapped geology; and foreseeable development potential in the planning area, activity over
the next decade may be stable to increasing. Current petroleum developments and interest in other BLM
Districts in Oregon, and the increasing value of petroleum products (Energy Information Administration
2007), indicates potential interest within the districts. The supply of natural gas in the region may be
augmented by one or more proposed Liquefied Natural Gas terminals that may be sited within the districts’
boundaries. Oil and gas activity on BLM-administered mineral rights within the Districts is expected to
Appendices - 618
Appendix Q - Energy and Minerals
consist of competitive and over-the-counter leases, geophysical surveys, and processing of Applications for
Permit to Drill.
Some exploration for coal bed natural gas in the form of coal seam investigation and mapping is also
predicted, especially of the Rouge River Coal Field. However, development of coal bed natural gas in
the district is not expected within the next 10 years. This is due to the length of research time needed
to delineate a field and the current rate of advancement of the Coos Basins field. It should be noted that
if commercial coal bed natural gas developments do occur within the State, other coal bed natural gas
prospects could develop rapidly.
Of the districts analyzed, the Roseburg District maintains the highest potential, although moderate in
classification. Three identified plays and area of exploration have a moderate potential for occurrence and a
moderate potential for development. Therefore, it is projected that the acreages managed by the Roseburg
BLM within these plays and area of exploration would have the greatest probability for exploration and
development within the next 10 years. All of the other Districts analyzed in this study would have a low
probability for development within the next 10 years. Therefore, acreages of impacts will only be analyzed for
those BLM-administered moderate potential lands located within the Roseburg District.
Because the lands in the Roseburg District are considered moderate in potential (USDI BLM 1985) and due
to the classification of low to moderate potential by Ryu et al. (1996), development of these lands could
range from none to the maximum. Therefore, while there is no indication of eminent development, the
following analysis will utilize the maximum potential. That potential is based on development of moderate
potential lands at one well per 160-acre spacing (spacing currently employed at the Mist Gas Field). The total
BLM-administered and non-BLM-administered acreage of this defined moderate potential is approximately
247,000 acres The total acreage of BLM-administered moderate potential lands in the Roseburg District
is approximately 37,000 acres or 15% of the area. Total well development of both BLM and non-BLM
managed area would be 1,555 wells. Maximum development on BLM-administered lands would be 228
wells. However, as these are unproven potentials, and the reservoir will not be uniform, it is unlikely that
more than 50% of total development will occur within the 10-year scenario. Therefore, given the moderate
potential of the area, the range of development for BLM lands in the 10-year scenario is 0 to 1 14 wells.
Geophysical Exploration
Geophysical exploration is conducted to try to determine the subsurface geologic structure of an area. The
three geophysical survey techniques generally used to define subsurface characteristics are measurements of
the gravitational field, magnetic field, and seismic reflections.
Gravity and magnetic field surveys usually involve the use of aerial surveillance, utilizing aircraft. There are
usually no ground disturbing activities to the project areas associated with this analysis.
Seismic reflection surveys, which are the most common of the geophysical methods, produce the most
detailed subsurface information. Seismic surveys are accomplished by sending shock waves, generally by a
small explosion or mechanically vibrating the ground surface. Instruments measure the time and intensity
with which the waves reflect off stratigraphic layers. This information can be used to depict the subsurface
structure of the rock. Vibroseis (Thumper) methods vibrate the ground surface to create a shock wave.
“Thumper” trucks are quite large and are equipped with “pads” that cover about four-feet square. The pads
are lowered to the ground, and the vibrators are electronically triggered in close coordination with the
technicians operating the recording equipment. After the signal is recorded, the trucks move forward a short
distance and the process is repeated. Up to 50 square feet (five square meters) of surface area is required to
operate the equipment at each recording site.
The small explosive method requires that charges be detonated on the surface or in a drill hole. Holes for the
charges are drilled utilizing truck-mounted portable drills to create small-diameter (two or six-inch) holes,
Appendices - 619
FEISfor the Revision of the Western Oregon RMPs
which are typically drilled to depths of between 50 and 100 feet. Generally 4 to 12 holes are drilled per mile
of line and a 5 to 50-pound charge of explosives is placed in the hole, covered, and detonated. The created
shock wave is recorded by geophones placed in a linear fashion on the surface. In rugged terrain, a portable
drill carried by helicopter can sometimes be used. A typical drilling seismic operation may utilize 10 to 15
men operating five to seven trucks, although portable “buggies” that can be hauled behind smaller four-
wheel drive All Terrain Vehicles are also commonly used in more sensitive areas.
Advanced Three Dimensional Survey (3-D Survey) is utilized within the Mist Gas Field. This process
analyzes five to six miles using lines with 1,700 shot holes at 70-foot spacing. The lines are spaced at 400
feet apart. The lines are hand brushed (no surface disturbance) for survey. The survey crews utilize an
Inertial Survey System that allows for accurate surveying without the need to maintain a line of sight. This
allows flexibility in brushing paths. The shot hole pad is three feet by four feet (3x4) in size. The pad is hand
cleared to mineral soil with hand tools. The drill rig is then placed on the pad. If existing access to the pad is
limited, the drill rig is placed and removed by helicopter. The holes are drilled to 15-foot depths. The charge
is exploded subsurface, leaving no surface expression. Where there is surface expression, the damaged is
mitigated with hand tools. In open valleys and areas with access, thumper rigs are used, as they disturb even
less ground. These requirements are in place because the Mist Gas Field is located in Commercial Forest
land and is required by the land manager to minimize disturbance to near non-existent (Meyer 2007).
Surface Impacts of Geophysical Explorations
It is anticipated that the foreseeable geophysical activity in the identified Moderate Potential lands within the
Roseburg District would consist of the currently used 3-D Seismic process. The total area of the identified
BLM-administered potential expansion area is approximately 57 square miles (approximately 37,000 acres).
Using the 3-D spacing of shots, it is anticipated that complete investigation of the area could utilize 16,150
shots. With pad ground disturbance of 12 square feet, the total disturbance on BLM-administered lands
could be up to 4.5 acres. This disturbance is created using hand tools, no power tools other than those
needed for brushing, and, based on experience in the Mist Gas Field, is completely reclaimed within five
years or less (Meyer 2007). Disturbance will be less where pre-existing roads and/or landings can be used.
Therefore, estimates to disturbance on non-BLM managed lands are indeterminate.
Drilling and Production Phase
Notices of Staking may occur during the plan period. Companies usually submit an Application for Permit
to Drill after the Notice of Staking is accepted. Private surface owner input, if a split estate is involved, would
be actively solicited during this stage. After the Application for Permit to Drill is approved, the operator
initiates construction activities in accordance with stipulations and Conditions of Approval (COAs).
Access road lengths vary, but usually the shortest feasible route is selected to reduce the haul distance
and construction costs. In some cases, environmental factors or landowners wishes may dictate a longer
route. Drilling activity in the planning area is predicted to be done using existing roads and constructing
short roads to access each drill site location. The district will utilize currently developed and utilized forest
management Best Management Practices, in addition to the BLM’s “Gold Book” (USDI/USDA 2007), for
surface disturbance in road construction and pad development similar to timber harvest landings.
Based on past oil and gas drilling in Oregon, it is projected that three conventional petroleum exploratory
“wildcat” wells could be drilled within the Roseburg District. The estimated success rate of finding
hydrocarbons is predicted to be no greater than 10 percent, based on the average U.S. wildcat well success
rate. Future identification of additional structures would likely increase this estimate. Development within
the identified moderate potential area would be directed by 3-D Survey as opposed to wildcatting (Meyer
2007).
Based on spacing units established within the Mist Gas Field, full production development of the projected
approximate 37,000 acres of BLM-administered moderate potential lands within the Roseburg District would
Appendices - 620
Appendix Q - Energy and Minerals
require a total of 228 wells. However, as these are unproven potentials, and the reservoir will not be uniform,
it is unlikely that more than 50% of total development will occur within the 10-year scenario. Therefore,
given the Moderate Potential of the area, the range of development for BLM-administered lands in the 10-
year scenario is 0 to 1 14 wells.
Surface Impacts of Drilling and Production
There are currently no production or exploration wells or pads within any of the districts’ boundaries.
Development of the moderate potential lands identified within the Roseburg District could require up to 114
wells on BLM-administered lands within the 10-year scenario. It is anticipated that all gas production would
be carried by collector pipelines placed within road rights-of-way.
The identified plays range from 5 miles to 22 miles from the north-south Northwest Pipeline System that
runs within the 1-5 Corridor. A review of existing private and public roadways between the plays and
the pipeline indicates an adequate transportation system of road right-of-way to accommodate collector
pipelines (USDI BLM 2008). The only additional pipeline right-of-way that would be required would
be to connect new wells to existing roadways. These lines would be placed along right-of-ways for new
road construction. Therefore, it is not anticipated that pipeline rights-of-way would create an additional
disturbance beyond existing and new road rights-of-way.
Initially operators would move construction equipment over existing roads to the point where the new drill
site access road begins. Based on existing road systems and access, the use of 3-D Survey, and directional
drilling, it is anticipated that most well development will utilize existing road infrastructure to develop the
resource. However, it may be necessary to construct up to a quarter mile of access for each pad to remove
the facility from the active roadway. Based on the ability to cluster wells (assumed to be four wells per pad),
it is estimated that no more than 97 miles total of new road construction would be required on both BLM-
administered and non- BLM lands. No more than 7.0 miles of new road construction on BLM-administered
lands would be needed in full development of 1 14 wells. Most would be moderate duty access roads with a
travel surface 18 to 20 feet wide. The total surface disturbance width would average 40 feet including ditches,
utilities, pipelines, cuts, and fills. The total acreage impacted by new road building for both BLM and non-
BLM managed lands would be 470 acres. Total disturbance for new roads on BLM-administered land
would be approximately 34 acres. Roads not subsequently needed for other resource management would be
reclaimed at the end of the project (USDI/USDA 2007).
In the second part of the drilling phase, the operator would construct the drilling pad or platform,
anticipated to involve approximately two acres per well site. Support facilities are anticipated to disturb
about two acres per well site. Total disturbance could be up to four acres per pad, with each pad containing
four or more wells. The likely duration of well development and testing is predicted to be approximately
six months to one year for each drill site. Total disturbance to BLM-administered and non-BLM lands in
the moderate potential area is estimated to not exceed 1,555 acres. Disturbance of BLM-administered lands
within the Moderate Potential area is not to exceed 1 14 acres.
Total disturbance of both BLM-administered lands and other lands for wells, support services, pipeline
and new road construction within the District is expected to be approximately 2,025 acres (1% of the total
Roseburg District Moderate Potential acreage). Total disturbance for just BLM-administered land with
development of 1 14 wells is expected to be approximately 153 acres (0.5% of projected BLM-administered
within the Roseburg District Moderate Potential acreage).
Surface disturbance would be restricted, as much as possible, to previously disturbed areas such as logging
roads and landings. Industry is currently utilizing a multi-well to single pad approach which minimizes
impact.
Appendices - 621
FEISfor the Revision of the Western Oregon RMPs
Interim reclamation would reduce initial disturbance. After initial construction, unused portions of well
site areas would be reclaimed while the wells are in production. Disturbance will be limited to areas within
overwork foundation structures and necessary infrastructure, such as well heads, pipelines, and access
roads, as described in federal reclamation guidance (USDI/USDA 2007).
Therefore, the maximum development disturbance for the moderate potential lands managed by the BLM
assumed in this 10-year scenario would range from zero to the maximum disturbance of approximately 153
acres.
Plugging and Abandonment
Wells that are completed as dry holes are plugged according to a plan designed specifically for the down-
hole conditions of each well. Plugging is usually accomplished by placing cement plugs at strategic locations
from the bottom of the well to the surface. Drilling mud is used as a spacer between plugs to prevent
communication between fluid-bearing zones. The casing is cut off at least three feet below ground level and
capped by welding a steel plate on the casing stub. Wells will be plugged and abandoned at the end of their
production life, with the pad, support facilities, and road fully reclaimed.
Surface Impacts of Plugging and Abandonment
After plugging, all equipment and debris would be removed and the drill site would be restored as near
as reasonably possible to its original condition. If new roads constructed for drilling are not needed for
future access to the area, the road would be reclaimed using Best Management Practices established for the
District, with the road prism revegetated as required by the Authorized Officer. Pipelines will be removed or
plugged and abandoned in place to minimize new surface disturbance (USDI/USDA 2007).
Limitations
The acreage estimates used for BLM-administered surface estate are based upon current GIS layers, with
acreage approximations to the nearest thousand. The accuracy of this information has not been verified
against the Master Title Plats. The GIS coverage for subsurface estate within the district is incomplete.
Therefore, the existence and location of BLM-administered subsurface estate within the district is not fully
known.
A brief review of the Master Title Plats was completed within and near the Mist Gas Field, 1985 boundaries.
Federal subsurface estate identified on the Master Title Plats was not recorded on the GIS layers. Most of
the Mater Title Plats that identified federal subsurface parcels were outside the Mist Gas Field boundaries.
One parcel was identified within the Mist Gas Field boundary. Due to the incompleteness of the GIS layers,
BLM-administered acreage of the surface and subsurface will need to be verified through review of Mater
Title Plats prior to exploration and development.
Appendices - 622
Appendix Q - Energy and Minerals
Proposed Restrictions and Requirements
on Mineral and Energy Exploration and
Development Activity
Introduction
This section discusses the leasing stipulations as they will be applied to BLM-administered lands in the
planning area under each alternative. Operating standards pertinent to the locatable and salable minerals
program are also described. Mineral exploration and development on Federal lands must also comply with
laws and regulations administered by several agencies of the State of Oregon; however, these requirements
are not discussed in this document.
Leasable Mineral Resources
Oil and Gas Leasing
The Mineral Leasing Act of 1920 (as amended) provides that all publicly owned oil and gas resources be
open to leasing, unless a specific land order has been issued to close the area. Through the land use planning
process, the availability of these resources for leasing is analyzed, taking into consideration development
potential and surface resources. Constraints on oil and gas operations are identified and placed in the leases
as notices and stipulations. Oil and gas leases are then issued from the BLM Oregon State Office in Portland.
Specific proposed notices and stipulations are listed by alternative later in this appendix.
The issuance of a lease conveys to the lessee an authorization to actively explore and/or develop the lease,
in accordance with the attached stipulations and the standard terms outlined in the Federal Onshore Oil
and Gas Leasing Reform Act (FOOGLRA). Restrictions on oil and gas activities in the planning area will
take the form of timing limitations, controlled surface use, or no surface occupancy stipulations used at the
discretion of the Authorized Officer to protect identified surface resources of special concern.
The field office that reviews the lease tract will attach stipulations to each lease before it is offered for bid. The
review will be conducted by consulting the direction given in this Resource Management Plan. In addition,
all lands administered by BLM within the planning area will be subject to the lease notices as shown on the
following pages. All Federal lessees or operators are required to follow procedures set forth by: Onshore Oil
and Gas Orders, Notices to Lessee (NTL), The Federal Oil and Gas Royalty Management Act (as amended),
The Federal Onshore Oil and Gas Leasing Reform Act, and Title 43 Code of Federal Regulations, Part 3100.
Oil and Gas Operations
Geophysical Exploration
Geophysical operations may be conducted regardless of whether the land is leased or not. Notices to
conduct geophysical operations on BLM surface are received by the resource area. Administration and
surface protection are accomplished through close cooperation of the operator and the BLM. Seasonal
restrictions may be imposed to reduce fire hazards, conflicts with wildlife, watershed damage, etc. An
operator is required to file a “Notice of Intent to Conduct Oil and Gas Exploration Operations” for all
geophysical activities on public land administered by the BLM. "Hie notice should adequately show the
location and access routes, anticipated surface damages, and time frame. The operator is required to comply
Appendices - 623
FEISfor the Revision of the Western Oregon RMPs
with written instructions and orders given by the Authorized Officer, and must be bonded. Signing of the
Notice of Intent by the operator signifies agreement to comply with the terms and conditions of the notice,
regulations, and other requirements prescribed by the Authorized Officer. A pre-work conference and /
or site inspection may be required. Periodic checks during and upon completion of the operations will be
conducted to ensure compliance with the terms of Notice of Intent, including reclamation.
Drilling Permit Process
The federal lessee or operating company selects a drill site based on spacing requirements, subsurface
and surface geology, geophysics, topography, and economic considerations. Well spacing is determined
by topography, reservoir characteristics, protection of correlative rights, potential for well interference,
interference with multiple-use of lands, and protection of the surface and subsurface environments.
Close coordination with the State would take place. Written field spacing orders are issued for each field.
Exceptions to spacing requirements involving Federal lands may be granted after joint State and BLM
review.
Notice of Staking
After the company makes the decision to drill, it must decide whether to submit a Notice of Staking or
apply directly for a permit to drill. The Notice of Staking is an outline of what the company intends to do,
including a location map and sketched site plan. The Notice of Staking is used to review any conflicts with
known critical resource values and to identify the need for associated rights-of-way and special use permits.
The BLM utilizes information contained in the Notice of Staking and obtained from the on-site inspection
to develop conditions of approval to be incorporated into the application for permit to drill. Upon receipt of
the Notice of Staking, the BLM posts the document and pertinent information about the proposed well in
the District Office for a minimum of 30 days prior to approval, for review and comment by the public.
Application for Permit to Drill (APD)
The operator mayor may not choose to submit a Notice of Staking; in either case, an Application for Permit
to Drill must be submitted prior to drilling. An Application for Permit to Drill consists of two main parts:
a 12-point surface plan that describes any surface disturbances and is reviewed by resource specialists for
adequacy with regard to lease stipulations designed to mitigate impacts to identified resource conflicts with
the specific proposal, and an 8-point subsurface plan that details the drilling program and is reviewed by
the staff petroleum engineer and geologist. This plan includes provisions for casing, cementing, well control,
and other safety requirements. For the Application for Permit to Drill option, the onsite inspection is used to
assess possible impacts and develop provisions to minimize these impacts.
Geothermal Leasing
The Geothermal Steam Act of 1970 (as amended) provides for the issuance of leases for the development and
utilization of geothermal steam and associated geothermal resources. Geothermal leasing and operational regulations
are contained in Title 43 Code of Federal Regulations, Part 3200. Through the land use planning process the
availability of the geothermal resources for leasing is analyzed, taking into consideration development potential and
surface and subsurface resources. Constraints on geothermal operations are identified and placed in the leases as
stipulations. Geothermal leases are then issued by the BLM Oregon State Office in Portland.
Geothermal resources are first offered by competitive sale. Prior to a competitive lease sale, or the issuance of
a noncompetitive lease, each tract will be reviewed, and appropriate lease stipulations will be included. The
review will be conducted by consulting the direction given in this resource management plan. The issuance
of a lease conveys to the lessee authorization to actively explore and/ or develop the lease in accordance
with regulations and lease terms and attached stipulations. Subsequent lease operations must be conducted
in accordance with the regulations, Geothermal Resources Operational Orders, and any Conditions of
Appendices - 624
Appendix Q - Energy and Minerals
Approval developed as a result of site-specific NEPA analysis. In the planning area, restrictions in some areas
will include timing limitations, controlled surface use, or no surface occupancy stipulations used at the
discretion of the Authorized Officer to protect identified surface resources of special concern.
In addition to restrictions related to the protection of surface resources, the various stipulations and
conditions could contain requirements related to protection of subsurface resources. These may involve
drainage protection of geothermal zones, protection of aquifers from contamination, or assumption of
responsibility for any unplugged wells on the lease. Development of geothermal resources can be done
only on approved leases. Orderly development of a geothermal resource, from exploration to production,
involves several major phases that must be approved separately. Each phase must undergo the appropriate
level of NEPA compliance before it is approved and subsequent authorizations are issued.
Leasing Notice and Stipulation Summary
On the following pages, the mineral leasing notices and stipulations are shown as common for all
alternatives. These are considered to be the minimum necessary to issue leases in the operating area. Under
all alternatives, the standard and the special status species leasing stipulations will be utilized on most lands.
The powersite stipulation (USDI BLM Form 3730-1, Powersite Stipulation) would be utilized on lands
within powersite reservations.
Stipulations also include waiver, exception, and modification criteria. If the Authorized Officer determines
that a stipulation involves an issue of major concern, waivers, exceptions, or modifications of the stipulation
will be subject to at least a 30-day advance public review. Waiver, exception, and modification are defined as
follows:
• Waiver - The lifting of a stipulation from a lease that constitutes a permanent revocation of
the stipulation from that time forward. The stipulation no longer applies anywhere within the
leasehold.
• Exception - This is a one time lifting of the stipulation to allow an activity for a specific proposal.
This is a case-by-case exemption. The stipulation continues to apply to all other sites within the
leasehold to which the restrictive criteria apply. It has no permanent effect on the lease stipulation.
• Modification - This is a change to a stipulation that either temporarily suspends the stipulation
requirement or permanently lifts the application of the stipulation on a given portion of the lease.
Depending on the specific modification, the stipulation mayor may not apply to all other sites
within the leasehold to which the restrictive criteria apply.
Whenever a special stipulation, such as No Surface Occupancy (NSO), Timing, or Controlled Surface
Use (CSU) is used, the need for the special stipulation is described in the “Objective” that follows the
stipulation. By imposing these special stipulations, it has been concluded that less restrictive stipulations
would not be adequate to meet the stated objective.
Leasing Notices
The following Notices are to be included in each lease for all lands administered by BLM within the
planning area where the pertinent resource potential exists. Lease notices are attached to leases in the same
manner as stipulations; however, there is an important distinction between lease notices and stipulations:
lease notices do not involve new restrictions or requirements. Any requirements contained in a lease notice
must be fully supported by either laws, regulations, policy, onshore oil and gas orders, or geothermal
resources operational orders.
Appendices - 625
FEIS for the Revision of the Western Oregon RMPs
Leasing Notices Common to All Alternatives
Notice
Special Status Species Stipulation
Resources : Botany and Wildlife
Stipulation : (All the)/(Certain) lands within this lease are within the suitable habitat of the (identify all
Federal Threatened (FT), Endangered (FE) or Proposed Threatened (PT) and Proposed Endangered (PE)
species, including scientific names), (an officially listed)/(a proposed for listing) Threatened or Endangered
species. The Authorized Officer, through an environmental review process, has determined that because of
the habitat characteristics of this species, all future post-lease operations must be analyzed and subjected to
a U.S. Fish and Wildlife Service (FWS) Section 7 consultation or conference to ensure the action is not likely
to jeopardize the continued existence of the species or result in the destruction or adverse modification of
critical habitat.
(All the)/(Certain) lands within this lease are known to bear the species listed (Insert list of species) which
has (have) protected status as (State Threatened (ST); State Endangered (SE); Federal Candidate (FC);
Bureau Sensitive (BS)); or are within the suitable habitat of (identify all State Threatened, State Endangered,
Federal Candidate, or Bureau Sensitive species, including scientific names). These species are protected
by BLM policy as described in Manual 6840. All future post-lease operations must be analyzed, utilizing
recent field data collected at the proper time of year, to identify the presence of such species. If the field
examination indicates that the proposed activity may adversely impact FC species, technical assistance will
be obtained from FWS to ensure that actions will not contribute to the need to list a federal candidate as a
federal threatened or endangered species. Technical assistance may be obtained from FWS to insure that
actions will not contribute to the need to list a ST, SE, or BS species as a federal threatened or endangered
species. Therefore, prior to any surface disturbing activities or the use of vehicles off existing roads on (this
lease)/(the lands legally described as: . BLM approval is required. This restriction also
applies to geophysical activities for which a permit is required. The approval is contingent upon the results
of site specific inventories for any of the above mentioned species. The timing of these inventories is critical.
They must be conducted at a time of year appropriate to determine the presence of the species or its habitat.
The lessee is hereby notified that the process will take longer than the normal 30 days and that surface
activity approval will be delayed.
If no FT, FE, PT, or PE species, or suitable habitat, are found during the inventories, then no formal Section
7 consultation with the USFWS will be necessary and the action will be processed using the procedures
found in the applicable oil and gas Onshore Orders or geothermal resources operational orders. However,
the lessee is hereby notified that, if any FT, FE, PT, PE, ST, SE, FC, or BS species are found during the
inventories, or if the actions are proposed in designated or proposed critical habitat, then surface disturbing
activities may be prohibited on portions of, or even all of the lease, unless an alternative is available that
meets all of the following criteria: (a) The proposed action is not likely to jeopardize the continued existence
of a threatened or endangered species; (b) the proposed action is not likely to destroy or adversely modify
critical habitat for a threatened or endangered species; (c) the proposed action is consistent with the
recovery needs in approved Fish and Wildlife Service recovery plans or BLM Habitat Management Plans
for the threatened or endangered species; and (d) the proposed action will not contribute to the need to list
species as federal threatened or endangered.
Objective : To protect officially listed or proposed threatened or endangered plant or wildlife species; and to
insure that post leasing oil and gas or geothermal operations will not likely contribute to the need to list
other special status species as threatened or endangered.
Appendices - 626
Appendix Q - Energy and Minerals
Exception: An exception may be granted by the Authorized Officer, if review of the proposed plan submitted
by the operator indicates that the proposed action will have no effect on the (common name of species).
Modification: The boundaries of the stipulated area may be modified, by the Authorized Officer, if it is
determined that portions of the area do no have any officially listed or proposed threatened or endangered
species, federal candidate, state threatened or endangered species, or Bureau sensitive species, or their
habitat.
Waiver: This stipulation may be waived if the (common name) is declared recovered and is no longer
protected under the Endangered Species Act, or if other species found within the lease are no longer
considered to be in the federal candidate, state threatened or endangered, or Bureau sensitive categories.
Notice
Cultural Resources: An inventory of the leased lands may be required prior to surface disturbance to
determine if cultural resources are present and to identify needed mitigation measures. Prior to undertaking
any surface-disturbing activities on the lands covered by this lease, the lessee or operator shall:
1. Contact the Bureau of hand Management (BLM) to determine if a cultural resource inventory is
required. If an inventory is required, then;
2. The BLM will complete the required inventory; or the lessee or operator, at their option, may
engage the services of a cultural resource consultant acceptable to the BLM to conduct a cultural
resource inventory of the area of proposed surface disturbance. The operator may elect to inventory
an area larger than the standard 10-acre minimum to cover possible site relocation, which may
result from environmental or other considerations. An acceptable inventory report is to be
submitted to the BLM for review and approval no later than that time when an otherwise complete
application for approval of drilling or subsequent surface-disturbing operation is submitted.
3. Implement mitigation measures required by the BLM. Mitigation may include the relocation of
proposed lease-related activities or other protective measures such as data recovery and extensive
recordation. Where impacts to cultural resources cannot be mitigated to the satisfaction of the
BLM, surface occupancy on that area must be prohibited. The lessee or operator shall immediately
bring to the attention of the BLM any cultural resources discovered as a result of approved
operations under this lease, and shall not disturb such discoveries until directed to proceed by the
BLM.
Authorities: Compliance with Section 106 of the National Historic Preservation Act is required for all actions
that may affect cultural properties eligible to the National Register of Historic Places. Section 6 of the Oil
and Gas Lease Terms (DOI BLM Porm 3100-11, Offer to Lease and Lease for Oil and Gas) requires that
operations be conducted in a manner that minimizes adverse impacts to cultural and other resources.
Appendices - 627
FE7S /or the Revision, o/ the Western. Oregon. KMPs
Special Leasing Stipulations
The following special stipulations are to be utilized on specifically designated tracts of land as described
under the various alternatives.
Leasing Stipulations Common To All Alternatives
No Surface Occupancy
Resource : Land Use Authorizations
Stipulation : Surface occupancy and use is prohibited on Recreation and Public Purposes (R&PP) and
FLPMA leases.
Objective: To protect uses on existing R&PP and FLPMA leases.
Exception: An exception to this stipulation may be granted by the Authorized Officer, if the operator submits a
plan demonstrating that impacts from the proposed action are acceptable or can be adequately mitigated.
Modification: The area affected by this stipulation may be modified by the Authorized Officer, if the
land use authorization boundaries are modified.
Waiver: This stipulation may be waived by the Authorized Officer, if all land use authorizations within the
leasehold have been terminated, canceled, or relinquished.
No Surface Occupancy
Resource: Recreation Sites
Stipulation: Surface occupancy and use are prohibited within developed recreation areas.
Objective: To protect developed recreation areas.
Exception: An exception to this stipulation may be granted by the Authorized Officer, if the operator submits
a plan demonstrating that impacts from the proposed action are acceptable or can be adequately mitigated.
Modification: The boundaries of the stipulated area may be modified by the Authorized Officer, if the
recreation area boundaries are changed.
Waiver: This stipulation may be waived, if the Authorized Officer determines that the entire leasehold no
longer contains developed recreation areas.
No Surface Occupancy
A 30-day public notice period will be required prior to modification or waiver of this stipulation.
Resource: Special Areas Stipulation: Surface occupancy and use are prohibited within Areas of Critical
Environmental Concern (ACEC).
Objective: To protect important historic, cultural, scenic values, natural resources, natural systems or
processes, threatened and endangered plant species, and/or natural hazard areas of the ACEC.
Exception: An exception to this stipulation may be granted by the Authorized Officer, if the operator submits a
plan demonstrating that impacts from the proposed action are acceptable or can be adequately mitigated.
Appendices - 628
Appendix Q - Energy and Minerals
Modification: The boundaries of the stipulated area may be modified by the Authorized Officer, if the ACEC
or Environmental Education Area (EEA) boundaries are changed.
Waiver: This stipulation may be waived, if the Authorized Officer determines that the entire leasehold no
longer contains designated ACECs or EEAs.
No Surface Occupancy
Resource: Progeny test sites.
Stipulation: Surface occupancy and use are prohibited within progeny test sites.
Objective: To protect progeny test sites.
Exception: None.
Modification: The boundaries of the stipulated area may be modified by the Authorized Officer, if the
progeny test site boundaries are changed.
Waiver: This stipulation may be waived, if the Authorized Officer determines that the entire leasehold no
longer contains progeny test sites.
No Surface Occupancy
A 30-day public notice period will be required prior to modification or waiver of this stipulation.
Resource: Visual Resource Management (VRM) Class I
Stipulation: Surface occupancy and use are prohibited in VRM Class I areas.
Objective: To maintain soil productivity, provide necessary protection to prevent excessive soil erosion
on steep slopes, and to avoid areas subject to slope failure, mass wasting, piping, or having excessive
reclamation problems.
Objective: To preserve the existing character of the landscape. Exception: An exception to this stipulation
may be granted by the Authorized Officer, if the operator submits a plan demonstrating that impacts
from the proposed action are acceptable or can be adequately mitigated.
Modification: The boundaries of the stipulated area may be modified by the Authorized Officer, if the
boundaries of the VRM Class I area are changed.
Waiver: This stipulation may be waived by the Authorized Officer, if all VRM Class I areas within the
leasehold are reduced to a lower VRM class. Areas reduced to VRM Class II will be subject to the Controlled
Surface Use stipulation for visual resources, and areas reduced to VRM Class III will be subject to standard
lease stipulations.
Appendices - 629
FEISfor the Revision of the Western Oregon RMPs
Controlled Surface Use
Resource : Soils
Stipulation: Prior to disturbance of any suspected unstable slopes or slopes over 60 percent, an engineering/
reclamation plan must be approved by the Authorized Officer. Such plan must demonstrate how the
following will be accomplished:
• Site productivity will be restored.
• Surface runoff will be adequately controlled.
• Off-site areas will be protected from accelerated erosion, such as rilling, gullying, piping, and mass
wasting.
• Water quality and quantity will be in conformance with state and federal water quality laws.
• Surface-disturbing activities will not be conducted during extended wet periods.
• Construction will not be allowed when soils are frozen.
Exception: An exception to this stipulation may be granted by the Authorized Officer if the operator submits
a plan, which demonstrates that the impacts from the proposed action are acceptable or can be adequately
mitigated.
Modification: The area affected by this stipulation may be modified by the Authorized Officer, if it is
determined that portions of the area do not include suspected unstable slopes or slopes over 60 percent.
Waiver: This stipulation may be waived by the Authorized Officer if it is determined that the entire leasehold
does not include any suspected unstable slopes or slopes over 60 percent.
Controlled Surface Use
A 30-day public notice period will be required prior to modification or waiver of this stipulation.
Resource: Visual Resource Management (VRM) Class II.
Stipulation: All surface-disturbing activities, semi-permanent and permanent facilities in VRM Class II
areas may require special design including location, painting and camouflage to blend with the natural
surroundings and meet the visual quality objectives for the area.
Objective: To control the visual impacts of activities and facilities within acceptable levels.
Exception: None. Modification: None.
Waiver: This stipulation may be waived, if the Authorized Officer determines that there are no longer any
VRM Class II areas in the leasehold.
Note: The following controlled surface use stipulations do not apply to the No Action Alternative.
Controlled Surface Use
Resource: Deferred Timber Management Areas
Stipulation: Unless otherwise authorized, drill site construction and access through Deferred Timber
Management Areas within this leasehold will be limited to established roadways.
Objective: To substantially maintain the existing level of older and multi-layered conifer forest through year
2023.
Appendices - 630
Appendix Q - Energy and Minerals
Exception : An exception to this stipulation may be granted by the Authorized Officer if the operator submits
a plan demonstrating that impacts from the proposed action are acceptable or can be adequately mitigated.
Modification: The area affected by this stipulation may be modified by the Authorized Officer if it is
determined that portions of the area do not include Deferred Timber Management Areas.
Waiver: This stipulation may be waived by the Authorized Officer if it is determined that the entire leasehold
does not include Deferred Timber Management Areas.
Controlled Surface Use
Resource: Riparian Management Areas
Stipulation: Unless otherwise authorized, drill site construction and access through riparian management
areas within this leasehold will be limited to established roadways.
Objective: To protect riparian vegetation and reduce sedimentation.
Exception: An exception to this stipulation may be granted by the Authorized Officer, if the operator submits
a plan which demonstrates that impacts from the proposed action are acceptable or can be adequately
mitigated.
Modification: The area affected by this stipulation may be modified by the Authorized Officer, if it is
determined that portions of the area do not include riparian areas, floodplains, or water bodies.
Waiver: This stipulation may be waived by the Authorized Officer, if it is determined that the entire leasehold
no longer includes Riparian Management Areas.
Controlled Surface Use
Resource: Tate-Successional Management Areas
Stipulation: Unless otherwise authorized, drill site construction and access through Tate-Successional
Management Areas (LSMAs) within this leasehold will be limited to established roadways.
Objective: To protect vegetation and to retain and/or restore old-growth forest characteristics.
Exception: An exception to this stipulation may be granted by the Authorized Officer if the operator submits
a plan which demonstrates that impacts from the proposed action are acceptable or can be adequately
mitigated.
Modification: The area affected by this stipulation may be modified by the Authorized Officer if it is
determined that portions of the area do not include LSMAs.
Waiver: This stipulation may be waived by the Authorized Officer if it is determined that the entire leasehold
does not include LSMAs.
Appendices - 631
FEISfor the Revision of the Western Oregon RMPs
Locatable Minerals Surface Management Standards for Exploration, Mining,
and Reclamation
The following operational standards for mining activities have been compiled to assist the miner in
complying with the 43 CFR 3809 regulations, which apply to all mining operations on BLM administered
lands. The manner in which the necessary work is to be done will be site specific, and all of the following
standards may not apply to every mining operation. It is the mining claimants and operators responsibility
to avoid “unnecessary or undue degradation,” and to perform all the necessary reclamation work. Refer to
the 43 CFR 3809 regulations for general requirements.
There is an intergovernmental agreement between the BLM and the Oregon Department of Geology
and Mineral Industries that is designed to avoid duplication of regulations, inspections, and approval of
reclamation plans as well as to minimize repetitive costs to mining operators. The following guidelines
include some, but not all, of the requirements of the various State agencies overseeing mining operations.
Prospecting, Exploration, and Mining
Surface Disturbance
BLM Requirements
Operations ordinarily resulting in only negligible disturbance as defined in 43 CFR 3809.0-5(b) are considered
to be casual use and no notification to or approval by the BLM is required. All operators proposing occupancy,
timber removal, use of mechanized earth moving equipment, or suction dredges having hoses with an inside
diameter greater than 4 inches which would cause a surface disturbance of 5 acres or less during any calendar
year must provide written notice to the District Office at least 15 days prior to the commencement of any
surface mining disturbance. For operations in sensitive areas or which will cause greater than 5 acres of surface
disturbance, the operator is required to submit a plan of operations pursuant to the regulations in 43 CFR
3809.1-4.
State of Oregon Requirements
Any person engaging in mineral exploration that disturbs more than one surface acre or involves drilling
to greater than 50 feet must obtain an exploration permit from the Oregon Department of Geology and
Mineral Industries (DOGAMI). Mining operations involving 5,000 or more cubic yards of material per year
or disturbing one or more acres of land will require an operating permit from DOGAMI.
Vegetation/Timber Removal
Remove only that vegetation which is in the way of mining activities. An application must be submitted
to the Authorized Officer pursuant to 43 CFR 3821.4 describing the proposed use of merchantable timber
from O&C lands for mining purposes. No merchantable trees may be cut until the application is approved
and the trees are marked. The Roseburg BLM office recommends that small trees (less than 7 inches dbh)
and shrubs be lopped and scattered, or shredded for use as mulch. Trees greater than or equal to 7 inches
diameter breast height (dbh) are to be bucked and stacked in an accessible location unless they are needed
for the mining operation
Firewood
Merchantable timber may not be used for firewood. Firewood permits may be issued to the operator for
use in conjunction with the mining operation but no wood may be used until a permit is obtained from
the BLM. Permits will be limited to hardwoods or salvage timber which is not considered to be merchantable.
Firewood authorized for use in conjunction with a mining operation is not to be removed from the mining
claim.
Appendices - 632
Appendix Q - Energy and Minerals
Topsoil
All excavations should have all the productive topsoil (usually the top 12 to 18 inches) first stripped,
stockpiled, and protected from erosion for use in future reclamation. This also includes removal of topsoil
before the establishment of mining waste dumps and tailings ponds, if the waste material will be left in place
during reclamation.
Roads
Existing roads and trails should be used as much as possible. Temporary roads are to be constructed to a
minimum width and with minimum cuts and fills. All roads shall be constructed so as to minimize negative
impacts to slope stability.
Water Quality
When mining will be in or near bodies of water, or sediment (or other pollutants) will be discharged, contact
the Department of Environmental Quality. A settling pond is required when mining operations discharge
turbid water. It is the operators responsibility to obtain any needed suction dredging, stream bed alteration,
or water discharge permits required by the DEQ or other State agencies. Copies of such permits shall be
provided to the Authorized Officer when a Notice or Plan of Operations is filed. All operations including
casual use shall be conducted in a manner so as to prevent unnecessary or undue degradation of surface and
subsurface water resources and shall comply with all pertinent Federal and State water quality laws.
Claim Monuments
State law prohibits the use of plastic pipe for claim staking in Oregon. The BLM policy requires all existing
plastic pipe monuments to have all openings permanently closed. Upon loss or abandonment of the claim,
all plastic pipe must be removed from the public lands. When old markers are replaced during normal claim
maintenance, they shall be either wood posts or stone or earth mounds, constructed in accordance with the
requirements of State law.
Drill Sites
Exploratory drill sites should be located next to or on existing roads when possible without blocking public
access. When drill sites must be constructed, the size of the disturbance shall be as small as possible. Any
operator engaging in mineral exploration that involves drilling to greater than 50 feet must obtain an
exploration permit from the Oregon Department of Geology and Mineral Industries (ORS 517.962).
Dust and Erosion Control
While in operation, and during periods of shut-down, exposed ground surfaces susceptible to erosion will
need to be protected. This can be accomplished with seeding, mulching, installation of water diversions, and
routine watering of dust-producing surfaces.
Fire Safety
All State fire regulations must be followed, including obtaining a campfire permit or blasting permit, if
needed. All internal gas combustion engines must be equipped with approved spark arresters.
Safety and Public Access
Under Public Law 167, the Government has the right to dispose and manage surface resources (including
timber) on mining claims located after July 23, 1955. These rights are limited to the extent that they do not
Appendices - 633
H FEISfor the Revision of the Western Oregon RMPs
endanger or materially interfere with any phase of an ongoing mining operation or uses reasonably incident
thereto. Claims located prior to July 23, 1955 may have surface rights, if such claims were verified as being
valid under Sections 5 and 6 of the Act. Most of the claims of record do not have surface rights.
Mining claimants shall not exclude the public from mining claims with force, intimidation, or “no
trespassing” signs. In the interest of safety, the general public can be restricted only from specific dangerous
areas (e.g., underground mines, open pits, and heavy equipment storage areas) by erecting fences, gates and
warning signs. It is the operators responsibility to protect the public from mining hazards. Gates or road
blocks may be installed on existing or proposed roads only with BLM approval. Gates restricting public
access onto a mine site will only be considered in such cases where there is a large area safety hazard created
by the mining activity. The determination as to whether a safety hazard is large enough to warrant a gate will
be determined on a case-by-case basis. Fences (rather than gates) or other approved barriers shall be utilized
to protect the public from hazards related to small excavations, tunnels, and shafts.
Roads that cross private land to reach BLM-administered lands are controlled by the private parties.
Although some of these roads have been assigned BLM road numbers, access may only be granted for
administrative use to the BLM and its licensees and permittees under a nonexclusive easement. Mining
claimants are not considered licensees or permittees and, therefore, must make their own arrangements with
the private party to use such roads. No right is granted under any of the mining laws to use a road involved
in a nonexclusive easement.
Sewage
Self-contained or chemical toilets are generally to be used at exploration or mining operations and their
contents shall be disposed of at approved dump stations. Out-houses and uncontained pit toilets are
considered unnecessary and undue degradation and are not allowed. Uncontained pit toilets are not allowed
for other users of the public land in this district. No special rights regarding this issue are granted under the
mining laws. County sanitation permits are required for all other types of sanitation facilities.
Structures
Permanent structures will not be allowed for exploration or prospecting operations. Permanent structures
are fixed to the ground by any of the various types of foundations, slabs, piers, poles, or other means allowed
by State or County building codes. The term shall also include a structure placed on the ground that lacks
foundations, slabs, piers or poles, and that can only be moved through disassembly into its component
parts or by techniques commonly used in house moving. Any temporary structures placed on public lands
in conjunction with prospecting or exploration are allowed only for the duration of such activities, unless
expressly allowed in writing by the Authorized Officer to remain on the public lands. Temporary structures
are defined as structures not fixed to the ground by a foundation and that can be moved without disassembly
into their component parts.
Permanent structures (as described in the paragraph above) may be allowed for mining operations if
they are deemed reasonably incident to conducting the operations. Mining operations are defined as all
functions, work, facilities, and activities in connection with development, mining, or processing mineral
deposits.
All permanent or temporary structures placed on public lands shall conform with the appropriate State or
local building, fire, and electrical codes, and occupational safety and health and mine safety standards.
Equipment
The claimant must maintain the claim site, including structures and equipment, in a safe and orderly
condition. Only equipment and supplies that are appropriate, reasonable, and regularly used for exploration
Appendices - 634
Appendix Q - Energy and Minerals
or mining will be allowed on the claim. Equipment transportable by a pickup or small trailer or used
only infrequently should not be stored on the claim and will not be considered as a justification for
site occupancy. Accumulation of unused and/or inoperable equipment, materials not related to actual
operations, and trash, garbage, or junk is not allowed on the public lands. The storage of such on the public
land is unnecessary and undue degradation and will be treated accordingly.
Animals
If dogs or cats are to be present at the work site, the operator is required to keep them under control at
all times so that they do not chase wildlife, or threaten other people, including government employees
conducting site inspections on the public lands. Unless otherwise permitted, animals such as cows,
chickens, goats, pigs or horses are not considered necessary to conduct mining operations and are not
allowed on mining claims.
Suction Dredging
BLM Requirements
Cases Where a Notice or Plan of Operations is Required
Filing either a Notice or Plan of Operations may be required for all suction dredge operations where the
dredge has an intake nozzle equal to or greater than 4 inches in diameter, or where any suction dredge
operator proposes occupancy on BLM land (in excess of 14 calendar days per year) or the installation of
structures of any kind. The determination of the need for a notice on smaller dredges will be made on a case
by case basis.
No Notice or Plan of Operations Required
The use of a suction dredge in a stream, and having an intake nozzle of less than 4 inches in diameter,
where no structures or occupancy beyond the 14 calendar day per year camping limit is proposed, will not
generally require the filing of a Notice or Plan of Operations. Such activity is generally considered casual
use.
State of Oregon Requirements
All suction dredge operations must be authorized by Permit #0700-J issued by the Department of
Environmental Quality. This permit is issued free of charge for dredges having hoses with an inside diameter
of 4 inches or less. Registration and a filing fee of $50 is required for suction dredges having hoses with an
inside diameter greater than 4 inches. Mining operators should contact the Department of Environmental
Quality, Water Quality Division, 811 S.W Sixth Avenue, Portland, Oregon 97204, or the Roseburg DEQ
office.
Suction dredging outside the “permitted work period” established for certain waterways by the Oregon
Department of Fish and Wildlife (ODFW) will require written permission by an appropriate ODFW District
Biologist.
The river beds of navigable waterways are controlled by the Oregon Division of State Lands.
Tailings Ponds
Settling ponds must be used to contain sediment, and any discharge must meet the standards of the Oregon
Department of Environmental Quality.
Appendices - 635
FEISfor the Revision of the Western Oregon RMPs
Solid and Hazardous Waste
Trash, garbage, used oil, etc. must be removed from public land and disposed of properly. Trash, garbage
or hazardous wastes must not be buried on public lands. The accumulation of trash, debris, or inoperable
equipment on public lands is viewed as unnecessary degradation and will not be tolerated. Operators
conducting illegal disposals shall be held financially responsible for the clean-up of such disposals.
Cultural and Paleontological Resources
Operators shall not knowingly alter, injure, or destroy any scientifically important paleontological (fossil)
remains or any historical or archaeological site, structure, or object on federal lands or any identified
traditional use areas. The operator shall immediately bring to the attention of the Authorized Officer,
any paleontological (fossil) remains or any historical or archaeological site, identified traditional cultural
properties, structure, or object that might be altered or destroyed by exploration or mining operations, and
shall leave such discovery intact until told to proceed by the Authorized Officer. The Authorized Officer shall
evaluate the discovery, take action to protect or remove the resource, and allow operations to proceed.
Threatened and Endangered Species of Plants and Animals
Operators shall take such action as may be needed to prevent adverse impacts to threatened or( endangered
species of plants and animals and their habitat that may be affected by operations, as stipulated in guidelines
developed through consultation with the U.S. Fish and Wildlife Service. Under Notice-level operations, if
the review of the notice by BLM reveals that a potential conflict with a threatened or endangered species
exists, the operator will be advised not to proceed and informed that a knowing violation of the taking
provision of the Endangered Species Act will result in a notice of noncompliance and may result in criminal
penalties. If the operator wishes to develop measures that will eliminate the conflict, then the Authorized
Officer will arrange for the participation of BLM resource specialists and the U.S. Fish and Wildlife Service
in reviewing the proposed revision to the Notice. If processing a proposed Plan of Operations indicates
that a potential conflict exists with a threatened or endangered species or its habitat, the Authorized Officer
shall notify the operator that the plan cannot be approved until BLM has complied with Section 7 of the
Endangered Species Act. Special status species (Federal Candidate/ Bureau Sensitive) plants and animals,
and their habitat will be identified by the Authorized Officer, and shall be avoided wherever possible.
Occupancy at Mining Sites
Living on public land in excess of 14 days per calendar year must be reasonably incident to and required
for actual continuous mining or diligent exploration operations and will require either a Notice or Plan of
Operations. In general, operations at the casual use level are not sufficient to warrant occupancy on a mining
claim. The following discussion of occupancy only applies to those operators wishing to assert their right
to live for an extended period or full-time on public lands pursuant to privileges granted under the mining
laws. It does not apply to operators proposing to camp at prospecting or mining sites on weekends or one to
two days during the week
Only those persons working on a continuous mining or exploration operation will be allowed to live on the
claim beyond the 14-day per calendar year camping limit. A continuous mining or exploration operation is
defined as an operation necessitating at least 40 hours of work per week at the operating site. The Oregon
State Bureau of Labor and Industries generally considers that full-time work consists of a minimum of 40
hours worked per week. Each person proposing to live full-time at the site would be expected to conduct a
minimum of 40 hours of work each week. Work hours are to be specified in the Notice or Plan of Operation
at the time of submittal to the district BLM office. Should work hours be altered periodically or seasonally,
it is the responsibility of the operator to notify the BLM (prior to the change) so that the Notice or Plan
can be modified. Camping sites used in conjunction with mineral exploration or extraction operations are
expected to be kept in a neat and orderly condition. If operations cannot be pursued due to high fire danger
Appendices - 636
Appendix Q - Energy and Minerals
in forested areas, then living on the claim site will not be permitted. Any occupancy beyond 90 days must be
in accordance with the requirements of the County Planning Department.
Security Guard
In some cases, it may be reasonably incident for a security guard to live onsite to protect valuable property,
equipment, or workings that are necessary for the mining operation, or to protect the public from site
hazards. The need for a security guard shall be such that the person with those duties is required to be
present at the site whenever the operation is shut down temporarily; or at the end of the workday; or
whenever the mining claimant, operator, or workers are not present on the site. The proposed occupancy by
a security guard must be described in the Notice or Plan of Operations.
Reclamation
Reclamation of all disturbed areas must be performed concurrently or as soon as possible after exploration
or mining ceases and shall conform to the guidelines described in BLM Handbook H-3042-1. Reclamation
shall include, but shall not be limited to:
1 ) saving topsoil for final application after reshaping disturbed areas;
2) measures to control erosion, landslides, and water runoff;
3) measures to isolate, remove or control toxic materials;
4) reshaping the area disturbed, applying topsoil, and revegetating disturbed areas where
reasonably practicable; and
5) rehabilitation of fisheries and wildlife habitat.
When reclamation of the disturbed area has been completed, except to the extent necessary to preserve
evidence of mineralization, the BLM must be notified so that an inspection of the area can be made.
Equipment and Debris
All mining equipment, vehicles, and structures must be removed from the public lands during extended
periods of non- operation and/or at the conclusion of mining, unless authorization from the BLM is given
to the operator or claimant in writing. Accumulations of debris and trash on mining claims are considered
unnecessary and undue degradation and must be removed immediately regardless of the status of the
operation. Failure to do so will result in the issuance of a notice of noncompliance or a citation under State
law.
Backfilling and Re-contouring
The first steps in reclaiming a disturbed site are backfilling excavations and reducing high walls, if feasible.
Coarse rock material should be replaced first, followed by medium sized material, with fine materials to be
placed on top. Re-contouring means shaping the disturbed area so that it will blend in with the surrounding
lands, minimize the possibility of erosion, and facilitate re-vegetation.
Seedbed Preparation
Re-contouring should include preparation of an adequate seedbed. This is accomplished by ripping or
disking compacted soils to a depth of at least 6 inches in rocky areas and at least 18 inches in less rocky
areas. This should be done following the contour of the land to limit erosion. All stockpiled settling pond
fines, and then topsoil, shall be spread evenly over the disturbed areas.
Appendices - 637
FEISfor the Revision of the Western Oregon RMPs
Fertilizer
Due to the generally poor nutrient value of mined soils, it may be necessary to use fertilizer to ensure
maximum yield from the seeding mixture. The fertilizer (16-16-16, or other approved mix) should be spread
at the rate of 200 lbs/acre, but not allowed to enter streams or bodies of water.
Seeding
The BLM approved seeding prescription must be used to provide adequate re-vegetation for erosion control,
wildlife habitat, and productive secondary uses of public lands. Seeding should be done in September or
October in the Roseburg District to ensure that seed is in the ground prior to the first significant winter
rains. If seeding fails, or is done at the wrong time, the operator may be asked to reseed the area at the
appropriate time, as determined by the Authorized Officer.
Broadcast seeding is preferable on smaller sites. When using a whirlybird type seed spreader, it is important
to keep the different seeds well mixed to achieve even seed distribution. For the best results, a drag harrow
should be pulled over the seeded area to cover the seed before mulching. The Authorized Officer may
recommend hydro-seeding on critical sites for rapid coverage and erosion control on cutbanks, fill slopes,
and any other disturbed areas.
Tree Replacement
Replacement of destroyed trees may be necessary with the planting of seedlings or container stock.
Mulch
As directed by the BLM, during review of the Notice or Plan of Operations, the disturbed area may require
mulching during interim or final reclamation procedures. Depending on site conditions, the mulch may need
to be punched, netted, or blown on with a tackifier to hold it in place. In some cases, erosion control blankets
may be cost effective for use.
Roads
After mining is completed, all new roads shall be reclaimed, unless otherwise specified by the BLM. High
walls and cutbanks are to be knocked down or backfilled to blend with the surrounding landscape. All
culverts shall be removed from drainage crossings and the fill shall be cut back to the original channel.
The roadbed should be ripped to a minimum depth of 18 inches to reduce compaction and provide a good
seedbed. The road must then be fertilized, seeded and mulched if necessary. When necessary, water bars are
to be used to block access and provide drainage.
Tailings Ponds
The ponds should be allowed to dry out and the sediments removed and spread with the topsoil, unless the
sediments contain toxic materials. If the ponds contain toxic materials, a plan will be developed to identify,
dispose, and mitigate effects of the toxic materials. If necessary, a monitoring plan will also be implemented.
The ponds should then be backfilled and reclaimed.
Visual Resources
To the extent practicable, the reclaimed landscape should have characteristics that approximate or are
compatible with the visual quality of the adjacent area.
Appendices - 638
Appendix Q - Energy and Minerals
Guidelines for Development of Salable Mineral Resources
Proposed Operations
All proposed salable mineral developments, and any exploration that involves surface disturbance, should
have operation and reclamation plans approved by the Authorized Officer. All proposals will undergo the
appropriate level of review and compliance with the National Environmental Policy Act.
Quarry Design
Due to steep terrain in the operating area, most quarry developments would require a series of benches to
effectively maximize the amount of mineral materials to be removed in a safe manner. In all cases, bench
height shall not exceed 40 feet. If the bench would be used by bulldozers to access other parts of the quarry,
the width of the bench should be at least 25 feet. If the bench won’t be used by equipment, then this width
can be reduced to approximately 10 feet.
Clearing of timber and brush should be planned at least 10 feet beyond the edge of the excavation limit.
Most often the brush would be piled and burned at the site, or scattered nearby.
If at all possible, all topsoil and overburden should be stockpiled and saved for eventual quarry site
reclamation. These piles may need to be stabilized by mulching or seeding in order to minimize erosion
during the winter months.
As a standard procedure, the excavation of the quarry floor should be designed with an outslope of
approximately two percent to provide for adequate drainage of the floor. Compliance with this design should
be made a requirement of all operators at the site.
Operating Procedures
Where practicable, the following requirements should be made a part of every contract or permit providing
for the use of mineral material sites on the district:
• Oversized boulders shall not be wasted, but shall be broken and utilized concurrently with the
excavated material unless otherwise specified.
• The operator shall comply with local and State safety codes covering quarry operations, warning
signs and traffic control. All necessary permits must be obtained from State and County agencies.
• Use of the site for equipment storage and stockpiling rock material is allowed for the duration of
the contract or permit. Use of the site beyond that time would be authorized under a temporary use
permit.
• All topsoil shall be stockpiled or windrowed as appropriate, for use in reclamation.
• Prior to abandonment, all material sites will be graded to conform with the surrounding
topography. Topsoil will be utilized to create a medium for re-vegetation. Reseeding and tree
planting, if necessary, will be done as prescribed by the Authorized Officer. Access roads no longer
needed by the BLM will be abandoned and reclaimed as directed by the Authorized Officer.
Appendices - 639
FEISfor the Revision of the Western Oregon RMPs
Appendices - 640
Appendix R
Vegetation Modeling
This appendix provides background on the vegetation modeling used to simulate the application of the land
use allocations, management action, and forest development assumptions to characterize forest conditions
into the future.
In this appendix:
Introduction 642
BLM Forest Inventory Data 643
Use of the Inventory Data in the Modeling 648
GIS - Defining the Land Base & Spatial Projections 664
Forest Growth and Yield Modeling 666
OPTIONS Modeling 683
OPTIONS Products 711
Appendices - 641
FEISfor the Revision of the Western Oregon RMPs
Introduction
The alternatives considered in the plan revisions outline a range of approaches for managing the BLM forest
lands by varying the land allocations and intensity with which these forests are managed. These different
management approaches result in a range of outcomes in terms of the structural stages of the forest over
time, types of habitat that are developed, and the sustainable harvest levels. Models allow simulation of
the development of the forest over time under these various management strategies. Models were used in
the plan revision to simulate the application of the land use allocations, management action, and forest
development assumptions to characterize forest conditions 10, 20, 30, 40, 50, and 100+ years into the
future. The models are also used to determine the level of harvest that can be produced and sustained over
time. The outputs from modeling form a factual basis for comparing and evaluating these different land
management strategies at the strategic level.
Two primary vegetation models were used for the plan revisions:
• ORGANON - Individual tree growth model that was utilized for the development of growth and
yield projections for the major species groups on the BLM lands. ORGANON was developed by
Oregon State University, http://www.cof.orst.edu/cof/fr/ research/ORGANON/. In this appendix,
ORGANON refers to the generic model available in the public domain. DBORGANON refers to
the version of the model specifically modified for BLM’s Western Oregon Plan Revision.
• OPTIONS - Spatially explicit strategic planning model that was utilized to project the forest
conditions over time by simulating the land allocations and management action of the alternatives.
OPTIONS is proprietary software created by DR Systems Inc. http:// www.drsystemsinc.com/
prod_options.html
Both of these models have been in use and under continued development for approximately 20 years, and
provide a framework to bring the data and assumptions together to simulate these management scenarios.
The extent of this modeling effort when looked at from an entire plan revision perspective can seem large
and complex. It is easier to understand the modeling by looking at the major components used in the
model formulation. These major components include; the GIS data that defines the land allocations and
spatial representation of numerous resources, the forest inventory data, growth and yield projections, the
definitions of habitats and structural stages, the assumptions on habitat and structural stage development,
and management assumptions to simulate the alternatives.
This appendix provides an overview of the key components that were used in formulating the models used
in the plan revision:
1. BLM Forest Inventory
2. Use of Inventory Data in Modeling
3. GIS - Defining the Land Base and Spatial Projections
4. Forest Growth and Yield Modeling
5. OPTIONS Modeling
6. OPTIONS Products
Appendices - 642
Appendix R - Vegetation Modeling
BLM Forest Inventory Data
Introduction
Three inventories of the BLM lands were used in the vegetation modeling for the plan revision:
• GIS Vegetation mapping with stand level attributes.
• Timber Productivity Capability Classification (TPCC)
• Current Vegetation Survey (CVS) - measured permanent plot data.
GIS Vegetation Mapping - Forest Operations Inventory &
Micro*Storms
The Forest Operations Inventory (FOI) is a GIS layer that delineates vegetation polygons across BLM lands
within the planning area. There are approximately 80,000 stands identified that average 32 acres in size. The
minimum mapping feature is generally five acres but some finer scale non forest and harvest features are
identified. Polygons are delineated based on vegetation attributes of cover condition, size class, density of
trees, and age. (See Figure R-l below for an FOI mapping example)
Figure R-i. Example
Of FOI Mapping For
Approximately A Three By
Three Mile Area
Appendices - 643
FEISfor the Revision of the Western Oregon RMPs
The Micro*Storms database contains the attributes for the FOI polygons. The vegetation classification
represents stand average characteristics that include:
• Cover Condition - Conifer, hardwood, mixed, or non forest.
• Single or Multi canopy stands.
• Species - Top five species with percent occupancy within a stand layer and listing of other species
present.
• Stocking Class.
• Size Class - Diameter of the trees species by layer in 10” diameter classes.
• Birthdate of the layer.
• Ten-year age class.
Land management treatment history is recorded in Micro*Storms for the FOI polygons. These
treatments include; timber harvest, site preparation, planting, stand maintenance / protection, pre-
commercial thinning, fertilization, pruning and a variety of other treatments.
The data is updated by the districts on a regular basis as treatments are implemented and as conditions
change. The data is updated by a variety of inventory methods. The FOI and its companion database,
Micro*Storms, are operational datasets that are in daily-use by the districts for planning and tracking
purposes.
The FOI and Micro*Storms data, as used in the plan revision, reflects the conditions of the BLM lands as
of October, 2005 (vintage 2006). The FOI data is the spatial representation of the forest conditions for the
OPTIONS vegetation modeling. The Micro*Storms data was used to develop modeling stratification for:
species groups, site productivity, existing stand conditions, and 10-year age class.
Timber Productivity Capability Classification
The Timber Productivity Capability Classification (TPCC) is a classification of BLM lands based on the
physical and biological capability of the site to support and produce commercial forest products on a
sustained yield basis. Each TPCC unit is classified based on four assessments.
1) Forest / Non Forest
• Forest - capable of 10% tree stocking
• Non forest
2) Commercial Forest Lands
• Commercial forest lands - capable of producing 20 cubic feet of wood per year of commercial
species.
• Non commercial forest lands - not capable of producing 20 cubic feet of wood per year of
commercial species.
• Suitable Woodland - Non Commercial Species or Low Site
3) Fragile Conditions
• Non Fragile - forest yield productivity is not expected to be reduced due to soil erosion, mass
wasting, reduction in nutrient levels, reduction in moisture supplying capacity, and or the rise of
ground water.
• Fragile - forest yield productivity may be expected to be reduced by soil erosion, mass wasting,
reduction in nutrient levels, reduction in moisture supplying capacity, and/or the rise of ground
water table.
Appendices - 644
Appendix R - Vegetation Modeling
Fragile sites are classified as:
— Restricted - Special harvest and or restricted measures are required.
— Non Suitable Woodland - Future production will be reduced even if special harvest and
or restricted measures are applied due to the inherent site factors. These lands are not
biologically and or environmentally capable of supporting a sustained yield of forest
products.
4) Reforestation
Reforestation problem sites are those where environmental, physical, and biological factors have the
potential to reduce the survival and or growth of commercial tree seedlings. These factors include light,
temperature, moisture, frost, surface rock, animals and disease.
• Non Problem - Sites that can be stocked to meet or exceed target stocking levels, of commercial
species, within 5 years of harvest, using standard practices.
• Restricted - Commercial forest land where operational reforestation practices in addition to
standard practices are necessary to meet or exceed the minimum stocking levels of commercial
species within 5 years of harvest.
• Suitable Woodland - Operational practices will not meet or exceed minimum stocking levels of
commercial species within 5 years of harvest. These sites are biologically capable of producing a
sustained yield of timber products.
The BLM handbook 5251-1 (1986) provides the standards for the TPCC classification.
There are approximately 66,000 TPCC units mapped in GIS on the BLM lands within the planning area.
The minimum mapping feature is generally five acres but some finer scale non forest features are identified
in the data. The TPCC initial classification of all BLM lands in the planning area was performed in
the late 1980s. The data is updated on an as needed basis as lands are acquired, and new information is
obtained through field examination.
The data, as used in the plan revision, reflects the classification of the BLM lands as of October, 2005. For
the Western Oregon Plan Revision the TPCC data is used to identify what portions of the BLM lands will
contribute to the Allowable Sale Quantity. The non forest, suitable woodlands, and non suitable woodland
categories are not included in the lands contributing to the Allowable Sale Quantity under the current plan.
In Figure R-2, the cross-hatched areas are examples of TPCC units withdrawn from the lands contributing to
the Allowable Sale Quantity. The Forest Operations Inventory units are outlined for approximately a four by
two mile area.
Appendices - 645
FEISfor the Revision of the Western Oregon RMPs
Figure R-2. Example Of TPCC Withdrawn Lands
Current Vegetation Survey - Measured Plot Inventory
The Current Vegetation Survey (Max, et al. 1996) provides comprehensive information on vegetative
resources on BLM lands within western Oregon. The information was collected during the years 1997 to
2001. It consists of four 3.4-mile grids of field plots that are off-set from one another to produce one 1.7 mile
grid across BLM lands for a total of 1,376 plots. The primary sampling unit is one hectare (approximately
2.5 acres) with five fixed-radius sets of subplots with trees 1.0 to 2.9 inches DBH measured on the 11.8 foot
radius subplot, 3.0 to 12.9 on a 24.0 foot, 13.0 to 47.9 on a 51.1 foot and trees 48.0 and larger on the 1/5
hectare (approximately Vi acres) nested subplots. There is one subplot located at the plot center and four
subplots each in a cardinal direction and 133.9 feet from the center of the plot (See Figure R-3). In addition,
at each subplot, potential natural vegetation is determined using plant indicator keys, and coarse woody
debris is measured along a transect. For specific information on the attributes that are collected refer to
USDI BLM 2001).
The location of most of the plot centers have differentially corrected GPS coordinates. Since each subplot
center was located at a precise distance from the plot center, the coordinates for the subplot centers were
calculated and included in a GIS layer. The CVS layer was overlain on the Forest Operation Inventory GIS
map. The CVS layer is independent of the FOI layer; consequently, the CVS data represents an unbiased
sampling of the FOI layer. In FigureR-3 below, the cross hair dot symbols are examples of CVS plot center
locations on a 1.7 mile grid. The Forest Operations Inventory units are outlined for approximately a 4.5 by 3
mile area as shown in Figure R-4.
Appendices - 646
Appendix R - Vegetation Modeling
Figure R-4. CVS Plot Overlain With Forest Operations Inventory
Appendices - 647
FEISfor the Revision of the Western Oregon RMPs
Use of the Inventory Data in the Modeling
Introduction
The Forest Operations Inventory (GIS vegetation units) and the Current Vegetation Survey data (measured
inventory plots) were divided into stratification units to identify groups of stands with like characteristics.
The stratification was based upon Existing Stand Conditions (ESC), site class, stand age, and species groups.
This stratification of the data carried forward into both the DBORGANON and OPTIONS modeling.
DBORGANON is a version of the ORGANON growth and yield model customized for BLM by FORsight
Resources. DBORGANON is discussed in more detail in the Growth and Yield section of this appendix.
Stratification of Forest Operation Inventory
Stand Age
For every Forest Operations Inventory unit there is a stand age recorded in the Micro*Storms database.
(See Figure R-5 and Table R-l ) The stand ages reflect the conditions of the forest as of 2006. A Ten-Year age
class was derived from these stand ages which served as the starting ages for the OPTIONS model. For
multi-storied stands the Ten-Year age class was assigned to the predominant layer being managed. Stand
ages over 200 years of age are in 50 year bands. All regeneration harvest timber sales sold by September
30, 2005 were considered depleted from the inventory and the stand ages were converted to year zero for
OPTIONS modeling. Stand ages were not assigned to the Klamath Falls eastside management lands. Update
instructions for the Forest Operations Inventory were issued to the districts through BLM Information
Bulletin No. OR-2005-142 http://web.or.blm.gov/ records/ib/2005/ib-or-2005- 142.pdf
Figure R-5. Western Oregon Age Class Distribution 2006 (Acres)
400.000
350.000
300.000
250.000
200.000
150.000
100.000
50,000
0
— — -
Appendices - 648
Appendix R - Vegetation Modeling
Table R-i. Western Oregon Age Class Distribution 2006 By Sustained Yield Unit (acres)
Age Class
Salem
Eugene
Roseburg
Coos Bay
Medford
Klamath
Total
0
273
110
1,374
1,311
3,654
0
6,722
10
13,172
12,108
23,079
16,176
24,742
969
90,247
20
32,098
30,163
37,483
31,292
56,403
3,483
190,922
30
34,395
31,666
39,203
32,757
20,328
1,595
159,944
40
35,946
32,071
32,483
37,476
38,329
2,578
178,883
50
23,067
27,581
29,673
28,794
30,865
1,731
141,710
60
41,409
41,547
13,198
12,676
20,213
1,913
130,956
70
30,922
29,659
8,997
15,946
28,680
2,699
116,902
80
22,908
12,567
5,387
9,272
26,627
3,905
80,667
90
13,738
6,701
5,584
3,519
35,325
5,365
70,232
100
12,047
4,423
5,607
4,161
42,860
3,421
72,519
110
12,393
6,021
12,661
3,576
62,101
4,216
100,968
120
20,751
7,949
6,573
9,223
44,948
1,908
91,353
130
20,598
6,204
7,679
10,557
43,225
1,048
89,311
140
9,165
1,623
11,233
5,528
62,066
2,797
92,412
150
7,502
1,223
25,360
8,570
30,226
2,046
74,927
160
1,876
2,073
2,310
7,321
39,218
455
53,253
170
2,756
400
8,285
3,810
49,008
396
64,655
180
429
424
1,552
635
17,796
70
20,906
190
201
3,952
2,497
1,739
9,969
92
18,450
200+
29,625
37,571
118,961
57,372
101,156
6,056
350,740
Total
365,272
296,036
399,180
301,710
787,740
46,742
2,136,679
Existing Stand Conditions (ESC)
The Existing Stand Condition coding aggregated Forest Operations inventory based on past management
history and similar stand conditions. The MicrcCStorms database was used to classify each of the Forest
Operations Inventory units into one of the existing stand condition codes. This stratification was done prior
to beginning the DBORGANON and OPTIONS modeling. Further collapsing of the ESC coding was done
to formulate the DBORGANON and OPTIONS modeling groups. (See Table R-2 )
Appendices
649
FEISfor the Revision of the Western Oregon RMPs
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Appendices - 653
FEISfor the Revision of the Western Oregon RMPs
Table R-3. No Action Alternative Existing Stand Condition Acres By Sustained Yield Unit
ESC
Salem
Eugene
Roseburg
Coos Bay
Medford
Klamath
E. Mgt. lands
Grand Total
1
83,348
60,695
57,832
31,920
92,475
6,635
398
333,303
2
14,241
11,706
32,549
29,367
9,614
97,476
3
30,299
31,441
28,320
29,331
18,634
138,026
4
1,662
6,464
6,502
16,663
5,269
36,559
5
2,004
222
644
8,383
6,012
17,266
6
14,057
1,269
23,182
6,899
1,811
47,218
7
4,034
13,481
2,158
6,615
26,288
8
338
487
2,037
2,862
9
1,132
231
870
4,576
539
7,348
10
18
380
15
413
11
43
314
1,023
910
211
2,501
12
2,789
1,346
3,443
7,578
13
512
1,983
342
153
2,989
14
13
154
167
16
672
557
778
2,007
17
200
1,135
157
12,178
13,670
18
37
152
20
5,717
19
5,946
19
19
2,254
2,273
20
275
218
424
917
21
62
430
491
22
250
250
24
86
37
123
25
18
19
617
189
2,750
3,592
26
3
225
228
27
77
77
28
46
212
258
30
908
7
683
1,598
31
72
201
1,853
206
2,214
4,547
32
39
676
507
1,139
229
1,437
112
4,138
33
1,123
990
845
809
149
1,362
782
6,059
34
297
754
102
316
839
2,384
629
5,321
35
330
822
3,485
1,183
5,820
36
49
148
9,473
18,482
9,811
37,962
37
458
52
159
313
105
1,087
38
35
131
98
264
39
3,277
851
2,218
992
145
7,483
40
16
283
956
1,255
41
8,935
4,163
3,154
1,919
238
18,408
42
1,766
856
9
2,633
5,265
43
8,201
5,683
2,023
843
204
16,955
44
824
1,049
831
2,704
Appendices - 654
Appendix R - Vegetation Modeling
ESC
Salem
Eugene
Roseburg
Coos Bay
Medford
Klamath
E. Mgt. lands
Grand Total
45
5,674
2,778
1,438
876
10,765
46
354
445
121
919
47
8,252
519
595
120
993
10,480
48
6,643
247
156
6
1,166
8,218
49
824
37
32
2,732
3,624
50
779
170
36
6,793
7,778
51
888
5,330
125
20,481
4,546
31,370
52
186,872
154,570
224,927
144,923
376,391
1,445
171
1,089,298
53
5,248
2,659
8,598
5,906
676
1,265
24,351
54
147
548
909
1,320
2,924
55
133
71
307
511
56
30
249
167
446
57
10,500
2,790
7,711
4,499
42,014
2,131
74,399
144,045
62
53
53
64
79
79
66
2,353
2,353
67
67,045
152
24
67,221
68
5,661
715
62
6,439
69
7
1,145
1,046
39,161
414
4,289
46,063
70
40,972
947
64
41,984
71
87,314
4,043
77,026
168,383
72
622
939
1,471
754
58
3,845
73
224
25
731
1,117
12
2,109
74
2,206
766
56
3,028
75
1,705
2,242
3,947
76
166
467
633
77
46
46
78
349
349
79
82
65
147
Total
402,184
312,261
423,589
321,167
866,694
51,306
172,903
2,550,103
Appendices
655
FEISfor the Revision of the Western Oregon RMPs
Species Groups
The Micro*Storms database has a listing of the top 5 species within each stand layer with a ranking of relative
abundance. This data was utilized to classify each Forest Operations Inventory Unit into one of the following
species groups for modeling purposes. The Micro*Storms species group stratification was a starting point.
For the OPTIONS and DBORGANON modeling some species groups were combined to attain adequate
representation by the Current Vegetation Survey plots. (See Figure R-6)
Douglas-fir (DF)
This species group includes stands with single species DF listed, and those stands with minor quantities of other
conifers or hardwoods. They would typically be “FCO” stands (forest conifer), and have either single or multiple sizes
and ages indicated.
Northern True Fir (N_TF)
Stands of Noble or Silver fir, including other species mixed in such as Douglas- fir, western hemlock, or western
red cedar, but where Silver or Noble are dominant.
Northern Mixed Conifer (N_MX_CON)
This species group includes stands with single species of western hemlock, western red cedar, Sitka spruce, or
mixed conifer stands where Douglas-fir would not be the dominant species. They would typically be “FCO”
stands (forest - conifer).
Northern Conifer / Hardwood Mix (N_CON_HWD)
These stands would have both conifer and hardwood species listed. Neither conifer nor hardwood would
dominate these stands. Conifers or hardwoods could be indicated in the dominant or secondary position.
Hardwoods would include big leaf maple and red alder mixed with conifer species. Many FMX stands
(forest - conifer and hardwoods) would be located here.
Northern Hardwood (N_HWD)
Maple/aider mixes and pure alder are here. Pure or nearly pure alder stands, with limited maple fractions.
FHD stand (forest - hardwoods) descriptions are here.
Southern Mixed Conifer (S_MX_CON)
Stands containing incense cedar, sugar pine, Ponderosa pine, Douglas-fir and white fir in varying fractions,
but not including pure types without any secondary species indicated. This type may include some
hardwood component but less than the southern conifer/hardwood mix. Hardwoods would not be listed as
the dominant species.
Southern Conifer / Hardwood Mix. (S_CON_HWD)
This type consists of stands with the mixed conifer species, but with southern hardwoods such as oak, madrone,
tanoak, myrtle, etc mixed in. The hardwoods may be in the majority or minority FMX types (forest - conifer and
hardwoods) are here.
Southern Hardwood (S_HWD)
This type consists primarily of southern hardwood species with limited mixed conifer component.
Hardwoods would comprise the dominant species, possibly FHD types (forest - conifer and hardwoods).
Appendices - 656
Appendix R - Vegetation Modeling
Southern True fir (S_TF)
This type includes Shasta red fir and white fir types. White fir types could have other secondary species such
as Douglas-fir.
Ponderosa Pine (PP)
These are stands with dominant Ponderosa pine. Stands with Douglas-fir or other species in the understory
would be here, if not the dominant species. This would include dryer types with juniper as long as the
Ponderosa pine was the dominant species.
Juniper (J)
This type is juniper dominant. This type would contain some limited pine on dryer lower site types.
Depending on the district and the DBORGANON variant used, lodge pole pine and knob cone pine types would go
into Northern Mixed Conifer or Southern Mixed Conifer Jeffery pine would go into a low site Ponderosa pine type.
Mountain hemlock would go into northern true fir. Port-Orford-cedar would go into Southern Mixed Conifer
Site Class
Site Class data in the Micro*Storms database / Forest Operation Inventory (FOI) come from a variety of
sources, including estimations, measured on site, and/or soils mapping. The site class data in FOI is adequate
for a general portrayal of productivity but due to the variety of sources it is of varying accuracy.
Site index data was measured on the CVS inventory at the plot level. Assignment of site index to the subplot
level was made at the time of data collection. Using a site index conversion routine created by Mark Hanus
(FORSight Resources), all measured site data for all species and base ages was converted to a Douglas-fir, 50-
year base index, using King (1966) for Northwest Oregon, and Plann-Scrivani (1987) for SW Oregon.
Figure R-6. Species Group By District - Forested Acres
Frozen Micro* Storms 4/7/2006
Species Group
Salem
Eugene
Roseburg
Coos Bay
Medford
Kfalls
W. Oregon
DF
284,856
247,212
300,796
250,087
396,459
1,479,41 1
64%
N CON HWD
54,316
40,127
8,883
27,751
131,076
6%
N HWD
12,506
4,473
596
5,929
23,504
1%
N MX CON
17,163
8,127
327
1,818
27,434
1%
N TF
9,935
9,935
0%
PP
1,437
57,445
33,544
92,426
4%
S CON HWD
28,341
11,206
159,802
2,125
201,474
9%
S HWD
2,768
2,214
39,740
44,722
2%
S MX CON
57,653
734
118,473
29,262
206,122
9%
S TF
21,170
8,277
29,446
1%
J
71,891
71,891
3%
Total
378,775
299,939
400,802
299,738
793,089
145,098
2,317,442
100%
—
Appendices - 657
FEISfor the Revision of the Western Oregon RMPs
It was assumed that the best representation for range of site productivity values and relative proportions of
these values are the CVS data for areas as large as those occupied by combined species group within an SYU.
The Measured CVS data was used to re-distribute the FOI site class data to reflect the profile of the measured
data. Assignment from the CVS to the FOI was based on a set of rules. These data were apportioned to
each sustained yield unit forest land base at the FOI unit level. Existing measured site index data from the
Micro*Storms / FOI were retained for individual FOI units. For the remaining FOI units, site productivity
values were assigned to all stands in the forest land base in such a manner to approximate the expanded CVS
distribution for species groups at the SYU level. These FOI unit-level productivity assignments were held
constant for the OPTIONS modeling of all alternatives.
Methodology for Site Class Re-Distribution - CVS to the FOI
The following methodology was applied at the district level to achieve a similar distribution of acres by
species group and site productivity in the inventory as was present within the CVS information.
Source Information
A Microsoft Excel spreadsheet, with the following information, was prepared for each district:
• CVS Plot Number - unique plot number
® CVS District - the district for the plot
• CVS Species Group - the super species group for the plot
« CVS Site Productivity - the site productive class for the plot
• FOI Number - unique inventory number
• FOI Site Index Conversion Code - the conversion method used to calculate the Douglas-fir, 50-
year base index
• FOI District - the district for the FOI
• FOI Species Group - the super species group for the FOI
• FOI Site Productivity - the site productivity class for the FOI
• FOI Acres - the acres for the FOI
. FO DBORGANON Variant - the DBORGANON Variant for the FOI
Assumptions
• FOI with measured site index information are not redistributed.
® FOI polygons are treated as whole units. An FOI polygon cannot be split in order to achieve
desired acre redistribution.
• Redistribution of acres cannot result in an excess of acres over the desired target.
• Species Groups identified as ‘NF’ (non-forest) were not redistributed
• If either CVS or FOI information was not available, then no redistribution would occur, i.e. both
CVS and FOI information must be available for redistribution to occur.
Methodology
1. Using the source CVS information, for each district (SYU) and species group (SSPG) combination,
determine the percent distribution of plots within each site productivity class (SP). (See Table R-4 )
2. Using the FOI information, for each district (SYU) and species group (SSPG) combination,
determine percent distribution of acres within each site productivity class (SP). (See Table R-5 )
Appendices - 658
Appendix R - Vegetation Modeling
3. Redistribute FOI acres between site productivity classes within the district species group to obtain
the same percent distribution as indicated by the CVS information. Beginning redistribution
starting with the highest site (1) and progress to the lowest site (5) as follows:
a) Identify initial acres based on FOI information for the desired site productivity class
b) Determine target acres based on percent distribution from CVS information for the desired site
productivity class.
c) If the initial acres are less then the target acres, then reassign acres from the next lowest site
productivity class to the desired site productivity class until the target acres are met (but not
exceeded). Acres from each subsequent site productivity class are reassigned until the target
acres are achieved.
In our example, for site productivity class 1, the initial 38,372 acres is less than the target acres
of 50,869. Therefore, approximately 12,500 acres from productivity class 2 are reassigned to site
productivity class 1. (See Tables R-5 and R-6 and Figure R-7)
d) If the initial acres are greater then the target acres, then reassign acres from the current site
productivity class to the next successively lower site productivity class until the target is met
(but not exceeded).
If our example was reversed and the initial acres for site productivity class were 50,869, then
approximately 12,500 acres would be reassigned to site productivity class 2.
Table R-4. Example Of Distribution Of Plots By Site Productivity Class
SYU.SSPG
SYU_SSPG_SP
# of Plots in
SYU_SSPG
# of Plots in
SYU_SSPG_SP
% Distribution
Coos Bay_NDF
Coos Bay_NDF_1
673
132
20
Coos Bay_NDF
Coos Bay_NDF_2
673
273
41
Coos Bay_NDF
Coos Bay_NDF_3
673
182
27
Coos Bay_NDF
Coos Bay_NDF_4
673
61
9
Coos Bay_NDF
Coos Bay_NDF_5
673
25
3
Table R-5. Example Of Percent Distribution Of Acres Within Site
Productivity Class
SYU_SSPG
SYU_SSPG_SP
Total Acres
Total Acres
SYILSSPG
SYU_SSPG_SP
% Distribution
Coos Bay_NDF
Coos Bay_NDF_1
254347
38372
15
Coos Bay_NDF
Coos Bay_NDF_2
254347
133575
53
Coos BayJMDF
Coos Bay_NDF_3
254347
68960
27
Coos Bay_NDF
Coos Bay_NDF_4
254347
13440
5
Coos Bay_NDF
Coos Bay_NDF_5
254347
0
0
Table R-6. Example Of Reassignment Of Productivity Class Acres To Match
Percent Of CVS Plot Distribution
SYU_SSPG_SP
Total Acres in
SYUJ5SPG
Target
%
Target
Acres
Resulting
Redistributed
Acres
Resulting
Redistributed
% Distribution
Coos Bay_NDFJ
254347
20
50869
50884
20
Coos Bay_NDF_2
254347
41
104282
104224
41
Coos Bay_NDF_3
254347
27
68674
68324
27
Coos Bay_NDF_4
254347
9
22891
22538
9
Coos Bay_NDF_5
254347
3
7630
8376
3
Appendices - 659
FEISfor the Revision of the Western Oregon RMPs
4. For each FOI, reassign the corresponding mid-point site index value based on the new site
productivity class and DBORGANON variant code. (See Table R-7)
a) Southwest Oregon (SWO)
b) Northwest Oregon (NWO)
Table R-7. Reassigning Mid-point Site Index Values
Site Productivity Class
Midpoints by DBORGANON
Variant Code
2
1
5
70
60
4
85
75
3
105
95
2
125
115
1
140
130
Figure R7. Salem District Site Class Re-Distribution Example (Species Groups NCM -
Northern Conifer Mixed, NDF - Northern Douglas-Fir, NHM - Northern Hardwood Mixed)
Salem District
□ FOI Species Group Representation
1
□ CVS Species Group Representation
1 FOI Re-Distributed Species Group
Rooms onfation
NCMJ NCM_2 NCM_3 NCM_4 NCM_5 NDF_1 NDF_2 NDF_3 NDF_4 NDF_5 NHIVM NHM_2 NHM_3 NHM_4 NHM_5
Species Group Site Productivity
Appendices - 660
—
Appendix R - Vegetation Modeling
Collapsing the Stratification into Modeling Groups
Both the Forest Operation Inventory (FOI) and Current Vegetation Survey (CVS) had an initial stratification
based on stand age, existing stand condition (ESC), site productivity class, and species groups. Modeling
Groups were developed to aggregate like types which represented significant quantities of the FOI acres and
to assure there was sufficient measured data from CVS for each group.
The modeling groups were developed to:
• Classify the CVS data for the development of growth and yield curves with the DBORGANON
model for each Modeling Group.
• Provide a consistent linkage between the growth and yield data from DBORGANON with the
Forest Operation Inventory (FOI) for configuration, projection and the OPTIONS modeling.
The first step in the process involved grouping the CVS subplots, by DBORGANON variant, into strata
of similar forest, past treatment, and productivity types. For each CVS subplot, the forest type and past
treatment data was extracted from the FOI. The forest type was an assignment of a species group which had
been derived by district personnel thru a series of queries on stand level information.
The past treatment groupings consisted of stands with similar management histories or trajectories. This
designation was based on their existing stand condition data which had been reviewed and brought up to
date (as of September 30, 2005) by district personnel. The third consideration used in this stratification
process was the productivity level (50-year Douglas-fir Site Class) assigned to each CVS subplot.
The DBORGANON variants for Northwest
(NWO) and Southwestern Oregon (SWO)
were split primarily on District boundaries.
(See Figure R-8 ) The Salem, Eugene and
Coos Bay districts are being assigned to
the NWO variant, with one exception.
The southern portion of Coos Bay District
which lies primarily in the Tanoak Zone
was assigned to SWO for modeling. The
Roseburg and Medford Districts and
The Klamath Falls Resource Area were
assigned to the SWO variant, again with one
exception. Within the northwest portion
of Roseburg district, some CVS subplots
and a companion set of FOI units were
within stands designated as species groups
modeled only in the NWO variant.
ORGANON Variants
The stratification process involved
partitioning the entire planning area;
sampled by the over 5,300 forested CVS
inventory plots, into logical modeling
groups. This process involved a multi-
day session with a workgroup of district
personnel including but not limited
to silviculture, timber and inventory
specialists. A majority of these same district
personnel were in a subsequent stage of
the project, involved in development of the
Figure R-8. Organon Variants
Appendices - 661
FEISfor the Revision of the Western Oregon RMPs
Guide and Treatment Curves modeling the grouped CVS data with DBORGANON. Through an iterative
process, the number of modeling groups with fewer than 30 subplots was minimized. Out of the final 53
existing-stand modeling groups, 22 for NWO and 31 for SWO, only 2 had fewer than 30 subplots.
Imputing Data from Current Vegetation Survey (CVS) to the
Forest Operation Inventory (FOI)
The objective was to create summary information for each Forest Operation Inventory (FOI) unit within the
forested land base and to mimic the natural variation that exists among the FOI units. There is information
to stratify each of the FOI units into Existing Stand Condition (ESC), Site Class, Age and Species Groups.
There is CVS data for nearly every combination of characteristics found on BLM lands but there are FOI
units without CVS data.
Information from the FOI: Existing Stand Condition (ESC), redistributed site productivity, stand age and
species group, were used to stratify both the FOI and CVS. The combination of ESC, site class, age and
species groups are non-overlapping strata. The resultant spatial relationship between the CVS plots and the
FOI creates a stratified random sample of the plots with unequal number of subplots per plot. The CVS data
within each of the characteristic combination represents an unbiased collection of data for that stratum.
In Figure R-9, the two plots on the right fall within the selected stratum (cross- hatched). These
represent stands with common ESC, site productivity class and species groups.
The collection of CVS subplots that fell within the same stratum (defined by ESC, site productivity class and
Figure R-9. Example Of CVS Plots And FOI Units With A Common Existing
Stand Condition
Appendices - 662
Appendix R - Vegetation Modeling
species groups but including different age categories) were projected with no future silvicultural treatments
applied. This produced a smooth empirical curve that borrowed strength from adjacent age categories with
more data to predict the current inventories for ages with less data.
To derive a set of stand attributes for each forested FOI unit, the subplots that fell within each stratum
(ESC, site class, species group and age) were pooled and the subplots were drawn with replacement equal
to the number of subplots within the category. If the number of subplots exceeded 30, then the summary
information was calculated using the tree lists associated with each selected subplot and the summary
information was assigned to an FOI unit. This process was repeated for each FOI unit within the stratum.
This technique imputes values into each FOI unit.
Figure R- 10 is an example of two FOI units that have been assigned 10 subplots with replacement from an
original list of subplots numbered from 1 to 10.
If the number of subplots within a stratum was less than 30, a shrinkage estimate was employed where
the predicted attributed associated with the category was combined with the imputed summary statistic
and combined estimate was assigned to the FOI unit. The shrinkage estimate can best be illustrated by an
example. If there were 20 CVS subplots within a category, the shrinkage estimate is:
20/30 x CVS statistics + (30-20)130 x modeled predicted values
As the number of subplots approach 30, most of the information comes from the CVS data. Conversely if
there were relatively few CVS subplots, then the majority of the information came from the DBORGANON
model. This method was repeated for each FOI unit with the category.
The stratification for the forested FOI units was the basis for applying the CVS derived values for basal
Figure R-io. Examples Of Subplot Data Imputed Into FOI Units
Appendices - 663
FEISfor the Revision of the Western Oregon RMPs
area, trees per acre, height, quadratic mean diameter, and board foot volume for the initial inventory in the
OPTIONS modeling. The imputed initial inventory dataset provided a consistent basis for the OPTIONS
modeling of all alternatives.
The use of the imputation provided attributes to the OPTIONS model that did not exist in the Forest
Operations Inventory. Attributes assigned through imputation will not match the characteristics of each
individual stand as measured on the ground but the statistics applied to the grouping of stands in the
population, is statistically sound. The use of imputation is an attempt to mimic the natural variation that
exists among the stands. Although, no process can accurately reflect the actual variation short of conducting
a 100 percent cruise, this process is seen as more realistic than assigning the mean value for these statistics
to all FOI units within a group.
Application of the Stratification in Growth and Yield Modeling
Each CVS subplot tree list within an existing stand modeling group was projected in the DBORGANON
growth and yield model individually to simulate future development with and without future silvicultural
treatments. Results from the simulations were averaged together to predict stand attributes at any point in
time and to define an average yield function. This method is based on the fact that the CVS data represents
a random sample of the modeling group hence the average of all projected curves for a modeling group
represents the average projection for the FOI units within the modeling group. In OPTIONS terminology
these average yield functions are the Guide Curves.
GIS - Defining the Land Base & Spatial Projections
Introduction
The Geographic Information System (GIS) data provides the OPTIONS model with a set of polygons with
unique identifiers (WPR_ID), covering BLM lands in the planning area. Each of these polygons has attribute
data which is used in defining the land base for application of modeling rules for simulation of the alternatives.
GIS is also used for mapping the OPTIONS projections results of the forest conditions over time. This section
provides an overview of the GIS process. The type of GIS data that was used for analyzing the alternatives and
how it was applied is covered in the OPTIONS modeling section. Details on the GIS processing and datasets
themselves are recorded with the GIS metadata.
Defining BLM Lands
The land lines theme (LLI) is the BLM’s corporate GIS
layer for land status - O&C, Public Domain, Coos Bay
Wagon Road. The Forest Operations Inventory (FOI)
is the spatial vegetation layer used for the OPTIONS
modeling. The Forest Operations Inventory and Land
Lines themes are not vertically integrated in GIS that
results in slivering in the areas of misalignment. (See
Figure R-ll and Table R-8 ) For analytical purposes,
BLM-administered lands are defined by the area in
which the FOI and LLI overlap. This FOI & LLI mask
was subsequently used to minimize the slivers from
all GIS layers used in the analysis.
Figure R- i i . Differences
Between The FOI And LLI Themes
Appendices - 664
Appendix R - Vegetation Modeling
Table R-8. Acres Of Misalignment Between The FOI And LLI
FOI or LLI
Acres
Percent
FOI and LLI
2,550,000
100%
FOI only
9,200
0.36%
LLI only
8,200
0.32%
Intersection/Majority Rules
Where the subdivision of the FOI was important for simulating different modeling rules within each stand,
within, the data layers were intersected in GIS to create unique areas. Riparian reserves and roads are good
examples of this within stand subdivision that was important for simulating different modeling rules.
Some data layers came from external sources which were captured at coarser scales than the FOI mapping
and do not align well with BLM checkerboard ownership. Northern Spotted Owl Critical Habitat Units
is an example of this disparity between GIS data layers. In these situations, a majority rules analysis was
performed where 50% or more of the FOI unit would need to coincide with the data theme, such as critical
habitat, to receive the designation. This majority rules process was also applied to themes where spatial
subdivision of FOI polygons was not needed and stand level designation was sufficient for the analysis.
Rasterizing and Unique ID Assignment
To facilitate GIS processing, all vector GIS data layers were converted to a 10 by 10 meter raster cell (1 cell
= .025 acres - UTM zone 10, NAD83) and the data was partitioned into tiles which were based on 24K
USGS Quads (~ 35,000 acres, 6 miles east/west by 8.5 miles north/south). Within each tile, every unique
combination of GIS data layers was intersected with the Forest Operations Inventory and received a unique
identifier (WPR_ID). The example in Table R-9 illustrates one FOI unit (840369) being subdivided into 4
unique areas based on how riparian reserves and roads intersected the forest stand. This GIS subdivision of
the forest stands allows the OPTIONS model to simulate how each portion of the stand would develop.
The unique ID (WPR_ID) carries through the OPTIONS modeling projections for the purpose of tracking
each spatial entity. OPTIONS classification of allocations or projections of forest conditions were returned
to GIS as attributes with the unique IDs which were linked back to the original grid to produce spatial
products.
Table R-9. Example of Subdivision Of An FOI Unit And Assignment Of Unique
Identifier
WPRJD
FOI#
GIS
ACRES
RIPARIAN
RESERVE
ROAD
BUFFER
DESCRIPTION
124000005
840369
28.84
N
N
Outside riparian reserve
Outside of road buffer
124000008
840369
0.99
N
Y
Outside riparian reserve
Within road buffer
124000004
840369
10.90
Y
N
Inside riparian reserve
Outside of road buffer
124000013
840369
0.49
Y
Y
Inside riparian reserve.
Within road buffer
Appendices - 665
FEISfor the Revision of the Western Oregon RMPs
Data Vintage
A snap shot of the Forest Operations Inventory (FOI), Land Use Allocation (LUA), Timber Production
Capability Classification (TPCC), Occupied Marbled Murrelet Sites (OMMS), and the Landlines (LLI)
data were captured for the Western Oregon Plan Revision (WOPR) analysis. The data represents the
conditions as of 10/1/2005 (vintage 2006). The guidance on capture of this data was issued in the 2005
Information Bulletin IB-OR- 2005-142. The other GIS datasets reflect the best available information at the
time of the analysis.
GIS Data Themes
See the modeling rules section for further description of the GIS data themes used in the modeling.
Forest Growth and Yield Modeling
Introduction
The purpose of simulating forest stand growth and development is to permit analysis of the effects of
different silvicultural systems and silvicultural practices on timber yield and stand structure. Modeling
estimates are not intended to describe the structures and volumes of current stands that may be
quite different (higher or lower in volume) than projected future stands depending on the kind of
management questions explored in the analysis.
The yield tables described in this section were used in the OPTIONS model to produce a series of
different Allowable Sale Quantity (ASQ) estimates for different management alternatives.
Silvicultural Systems, Practices and General Modeling
Approaches
Silvicultural Systems
A silvicultural system is a planned series of treatments for tending, harvesting, and re- establishing a
stand. The system name is based on the number of age classes managed within a stand. Three recognized
silvicultural systems are applicable to the land use allocations with a primary emphasis of timber
management. These are the even-aged, two-aged and uneven-aged systems (Helms 1998). Each of these
systems is applied depending on the alternatives and the land use allocations objectives. (See Figure R-12 )
These general silvicultural systems were modeled using CONIFERS young-stand model in concert with
DBORGANON
The even-aged system uses the clearcutting or shelterwood cutting method to regenerate existing stands.
Clearcutting essentially removes all trees from an area in a single harvest operation. Shelterwood harvest
initially retains a number of shelter trees and has a similar visual appearance to a regeneration harvest
using the two-aged silvicultural system (see Figure R-13). Unlike the two-aged system, the shelter trees are
only temporarily retained and are harvested when they no longer are required for protection of the new
regeneration.
Appendices - 666
Appendix R - Vegetation Modeling
The two-aged system uses a variable-retention harvest method to achieve the goal of establishing new
regeneraton. At regeneration harvest, live trees are retained long-term (reserved from harvest) to facilitate the
development of two-aged structure. The retained trees may be left in a dispersed, aggregated or combination of the
two (see Figure R-14). For modeling purposes, dispersed retention was assumed for regeneration harvests in the
No Action Alternative and Alternative 3. Aggregated retention was assumed for partial harvest in Alternative 3.
The uneven-aged system achieves regeneration through selection harvest. Trees are harvested singly or in
groups (See Figure R-15).
Timber harvests on land managed for purposes other than timber employ an approach commonly referred
to as variable -density thinning (USDA 2002). This approach combines elements of the two-aged and
uneven-aged approaches for the purpose of promoting stand heterogeneity through the development of
multi-layered canopies. Provision of conditions conducive to the initiation and growth of regeneration is
often an objective of variable-density thinning to encourage understory development to contribute to stand
heterogeneity. Variable-density thinning was modeled as a series of proportional commercial thinnings with
simulated regeneration following the thinning harvests.
Uneven-aged: a stand with frees
of three or more distinct age
classes, either intimately mixed or
in small groups.
Two-aged: a stand with trees of
two distinct age classes sep-
arated in age by more than plus
or minus 20% of the rotation
age.
Even-aged: a stand composed of a
single age class of trees in which
the range of tree ages is usually
plus or minus 20% of the rotation
age.
Figure R-12. Silvicultural Systems, Stand Structure Types
Appendices - 667
FEISfor the Revision of the Western Oregon RMPs
Figure R-13. Clearcut Regeneration Harvest Under Alternatives 1, 2, And The PRMP
And Shelterwood Regeneration Harvest Under The No Action Alternative And PRMP
Aggregate Retention
Figure R-14. Two-Aged
Regeneration Harvest, Retention
Tree Spatial Distribution Types
Under Alternative 3 And The No
Action Alternative
Appendices - 668
Appendix R - Vegetation Modeling
Figure R-15. Group Selection And Single-Tree Selection Regeneration
Harvests Under Alternative 3
Silvicultural Practices
For each silvicultural system, a variety of practices other than harvesting, may be planned for specific
periods in the life of the stand. These practices keep forest stands on desired developmental trajectories,
speed the development of desired habitat components, and maintain or improve stand vigor. Silvicultural
practices in this region have traditionally been applied to conifer stands, however, many of the same
principles and treatments have application for the growth and development of other desired vegetation.
While both the types of practices used and timing vary between systems, most silvicultural systems require
the full range of forest management tools and practices for their successful implementation. To predictably
direct forest stands so that structural and other objectives are met may require some level of intensive stand
tending practices whatever the system employed.
There are seven major silvicultural practices besides regeneration harvesting that affect forest stand
growth, value, and structure. These are site preparation, regeneration, stand maintenance and protection,
precommercial thinning and release, commercial thinning, fertilization, and pruning.
Site Preparation
If needed, site preparation procedures are used to prepare newly harvested or inadequately stocked areas for
planting, seeding, or natural regeneration. Site preparation methods are selected to provide physical access
to planting sites, control fire hazard, provide initial physical control of the site to channel limited resources
on the site into desired vegetation, influence the plant community that redevelops on the site, influence or
control animal populations, and ensure the retention of site productivity. Three types of site preparation
techniques will be used. These are prescribed burning, mechanical, and manual methods.
Future site preparation treatment needs were based on historical experience.
Regeneration
Silvicultural systems would utilize existing regeneration, natural seeding, and prompt planting of desired
conifer species to assure that regeneration targets and timeframes are met in timber emphasis land use
allocations. Where available, the planting of genetically improved seedlings is emphasized. Planting may
also be done in non-timber emphasis land use allocations to supplement, or in lieu of natural regeneration
Appendices - 669
FEISfor the Revision of the Western Oregon RMPs
to enhance development of complex stand structure. Existing vegetation would be used to the extent
possible in meeting management objectives dependent upon non-conifer vegetation. Where necessary to
meet objectives, non-conifer vegetation would be established through seeding or planting.
The species composition, size, density and age of trees for development of tree lists representing future
stands following a regeneration harvest were based on CVS subplots in the 20 years-old and younger age
classes. Plots were stratified so as to have each species group and site class represented where possible. A
basic modeling assumption was that future young stand species composition would be similar to current
young stand composition.
Stand Maintenance & Protection
Stand maintenance and protection treatments occur after planting or seeding and are designed to promote
the survival and establishment of trees and other vegetation by reducing competition from undesired plant
species. Maintenance and protection techniques include actions such as mulching, cutting or pulling of
unwanted species, placing plastic tubes/netting over seedlings to protect from animal damage, and animal
trapping.
The effects of past maintenance and protection treatments are reflected in the current condition of existing
young forest stands. It was assumed in the simulation of future regenerated stands that the same types and
level of treatments would occur as in the current young existing stands that were used to derive the initial
regeneration tree lists. Herbicides for stand maintenance were not available to BLM during the time period
in which the current young stands developed. Therefore the initial conditions of the future tree lists derived
from current stands attributes should exhibit the effects of non-herbicide treatment methods only.
Precommercial Thinning and Release
Precommercial thinning and release are treatments used to reduce the densities of tree and shrub densities,
manipulate species composition, or promote dominance and/or growth of selected species. Species
selection criteria can vary by vegetation zone and land use allocation management objectives. Treatments
are usually implemented during the mid-range of the stand establishment structural stage. These treatments
are used to influence stand developmental pathways so that desired stand and tree level characteristics result
in the future.
Precommercial thinning and release treatments may be done by completely severing and/or girdling the
stems of trees and shrubs with manual or mechanical tools.
Precommercial thinning enhances the growth and vigor of the residual trees by reducing inter-tree
competition for growing space. The primary goal of precommercial thinning is to maintain high growth
rates by effecting density control. This involves the removal of excess stocking which may consist of both
desirable and undesirable species. The average number of trees remaining following treatment varies by
alternative, land use allocation and species group as shown in Table R-10.
Release treatments are implemented to remove or reduce the competitive status of shrubs and undesirable
tree species competing with desirable tree species. Thinning and release may occur simultaneously or as
separate treatments.
Commercial Thinning
Commercial thinnings are implemented to recover anticipated mortality; control stand density for
maintenance of stand vigor, place or maintain stands on developmental paths so that desired stand
characteristics result in the future. Commercial thinnings are scheduled after developing stands reach
a combination of relative density stem diameter and timber volume to permit a harvest entry that is
economical. Generally, uniform tree spacing, more or less is implemented in stands on land use allocations
Appendices - 670
Appendix R - Vegetation Modeling
with a timber emphasis. Generally, a variable-density approach is used in stands on land use allocations
with a non-timber management emphasis as shown in Table R-ll and as described further in the “Treatment
Response Curves” section of this appendix.
Table R-io.
Precommercial Thinning (PCT) Modeling Assumptions8
Species Group
Alternatives
Land Use Allocation
Post-PCT TPA Target
No Action
Northern General Forest Mgt. Area
260
No Action
Southern General Forest Mgt. Area
260
No Action
Connectivity/Diversity Block
220
No Action
Late-successional Reserve
Variable15
All except
No Action
Riparian Reserve
Variable15
Pondersosa pine
1,2, PRMP
Timber Management Area
260
1,2, PRMP
Late-successional Mgt. Area
Variable15
1,2,3, PRMP
Riparian Management Area
Variable15
3
General Landscape Area
260
3, PRMP
Uneven-aged Management Area
Variable5
No Action
Northern General Forest Mgt. Area
200
No Action
Southern General Forest Mgt. Area
200
No Action
Connectivity/Diversity Block
150
No Action
Late-successional Reserve
Variable15
No Action
Riparian Reserve
Variable15
1,2, PRMP
Timber Management Area
200
1,2, PRMP
Late-successional Mgt. Area
Variable15
1,2, 3, PRMP
Riparian Management Area
Variable15
3
General Landscape Area
200
3, PRMP
Uneven-aged Management Area
Variable5
"These are broad based modeling assumptions. Targets are residual densities reflecting current and anticipated future treatment targets averaged for all districts for
particular species groups. Actual densities implemented may vary around the average by approximately 20±%.
bFor modeling purposes, existing and/or post-harvest natural or planted regeneration density levels are assumed to average approximately 75-150 trees. Actual
implementation target densities will vary depending on amount and spatial distribution of residual overstory trees, species mix and anticipated understory reduction due
to future timber harvest entries.
Table R-ii. Commercial Thinning (CT) Modeling Assumptions3
Species Group Alternatives
Land Use Allocation
Pre-CT RDb
Threshold
Post-CT RDb
Target
No Action
Northern General Forest Mgt. Area
55
35-40
No Action
Southern General Forest Mgt. Area
55
35-40
No Action
Connectivity/Diversity Block
55
35-40
No Action
Late-successional Reserve
45-50
25-35
All except No Action
Riparian Reserve
45-50
25-35
Pondersosa pine 1 , 2, & PRMP
Timber Management Area
55
35-40
1,2, & PRMP
Late-successional Mgt. Area
45-50
25-35
1,2, 3, & PRMP
Riparian Management Area
45-50
30-40
3
General Landscape Area
55
35-40
3 & PRMP
Uneven-aged Management Area
55c
15-255
No Action
Northern General Forest Mgt. Area
50-55
3540
No Action
Southern General Forest Mgt. Area
50-55
35-40
No Action
Connectivity/Diversity Block
50-55
3540
No Action
Late-successional Reserve
50-55
35-40
n , n. No Action
Ponderosa Pine 128pRMp
Riparian Reserve
50-55
3540
Timber Management Area
50-55
3540
1,2, & PRMP
Late-successional Mgt. Area
50-55
35-40
1,2, 3, & PRMP
Riparian Management Area
50-55
3040
3
General Landscape Area
50-55
3540
3 & PRMP
Uneven-aged Management Area
55c
1 5-25°
These are broad-based modeling assumptions. Targets represent stand level averages. Thinnings for late-successional, riparian and uneven-aged management
objectives may vary considerably on an acre-by-acre basis.
b Relative Density (RD) - The level of competition among trees or site occupancy in a stand relative to some theoretical maximum based on tree size and species
composition, The values in this table are Curtis relative density basis. (Curtis 1982)
'Alternative 3 is based on basal area guidelines, not relative density. The PRMP is based on relative density.
Appendices - 671
I LISJor the. Revision of the. Western^ Oregon. RMl'i
Fertilization
Stand growth in western Oregon is often limited by the supply of available nutrients, particularly by available
nitrogen. The supply of soil nutrients can be augmented through fertilization (Miller, Glendenen and Bruce
1988). Fertilization actions are usually designed to apply 200 pounds of available nitrogen with helicopters
in the form of urea based prill (46 percent available nitrogen) group. See this appendix “Treatment Response
Curves” section for additional information.
Occasionally, fertilizer may be applied in a liquid urea-ammonia form or with a mixture of other nutrient
elements in addition to nitrogen.
Pruning
The primary objective of pruning is usually the improvement of wood quality, i.e., “clear knot free” wood
for lumber and veneer production. Pruning for wood quality usually removes the live and dead limbs on
selected trees up to height of about 18 feet. Treatments are generally implemented as a two-phase process or
lifts between stand ages of approximately 15-40 years-old. Timing varies by site productivity, i.e. treatments
occur earlier on stands of higher site productivity. Pruning is also used for disease and fuels management
purposes.
Removal of up to one-third to one-half of the live tree crown at each lift is not expected to significantly affect
diameter growth at breast height or height growth (Staebler 1963; Stein 1955; BCMOF 1995). Since pruning
treatments are expected to be implemented within this range, no impact on growth and yield is assumed.
Therefore no treatment response curves were developed that incorporated a growth effect for pruning
treatments.
Modeling Assumptions by Alternative
Common to All Alternatives
An uneven-aged management system is assumed for the eastern portion of the Klamath Falls Resource
Area.
Fertilization is modeled only on land use allocations with a timber management emphasis.
Variable-density thinning is the form of timber harvest used on land use allocations with non-timber
management objectives.
No Action Alternative
The No Action Alternative employs a two-aged silvicultural system on the General Forest Management
Areas, Southern General Forest Management Area and Connectivity/Diversity Block land use allocations.
Regeneration harvests were modeled with the retention of a specific number of the largest overstory trees for
non-timber objectives. The number of retention trees per acre totaled 7, 16 or 12 respective of the Northern
General Forest Management Area, Southern General Forest Management Area, and Connectivity/Diversity
Blocks land use allocations. In addition, 0, 3 and 4 hardwood trees were retained respectively. The spatial
arrangement of retention trees was modeled as dispersed retention.
The OPTIONS model simulates retention trees by assuming that the retention trees continue to grow on
the pre-harvest existing stand guide curve generated by DBORGANON while the regenerated portion of
the stand follows a new DBORGANON generated future guide curve. The amount of green tree retention
is determined on the basis of pre-harvest basal area being retained. For each land use allocation a single
percent basal area was applied to all age groups, site classes, and modeling groups.
Appendices - 672
Appendix R - Vegetation Modeling
For The No Action Alternative the amount of retention tree basal area was determined by simulating
the growth of a young stand modeling group of average density and site productivity to age 100 years-
old, at which time a harvest treatment leaving the largest 7, 12 or 16 retention trees representing the
Northern General Forest Management Area, Connectivity/Diversity Blocks, and Southern General
Forest Management Area respectively is done. The percentage of the retention tree basal area divided
by the pre-harvest total stand basal area at age 100 years-old determines the appropriate allocation for
modeling green tree retention in OPTIONS.
Alternatives 1 and 2
Application of even-aged systems without green tree retention was modeled in the Timber Management
Area land use allocation.
Alternative 3
Alternative 3 employs a two-aged silvicultural system in the General Landscape Area generally north of
Grants Pass, Oregon. Depending on landscape structural stage criteria and vegetation zone, regeneration
harvests were modeled with varying amounts of retained overstory trees as dispersed retention or
aggregated retention. An uneven-aged management silvicultural system is applied in the zone south of
Grants Pass, Oregon on the Medford and Lakeview Districts.
The dispersed retention approach used the DBORGANON yield functions derived for the No Action
Alternative, Northern General Forest Management Area land use allocation which closely approximated
(seven trees per acre) the Alternative 3 retention tree requirements for regeneration harvests of six trees
per acre in the western hemlock zone or nine green trees per acre in the Douglas-fir and tanoak zones.
Aggregated retention is designated as partial harvest to further distinguish the difference in Alternative 3
with the dispersed retention harvest method. Partial harvests retained retention tree blocks constituting
18%, 33% or 37% of the existing stand in the Douglas-fir, tanoak, and western hemlock zones respectively.
The proportion of the pre-harvest stand basal area retained was determined using similar methodology
to that used for The No Action Alternative described above with the following exceptions. Simulated
harvest ages were 80 years-old for the Douglas- fir and tanoak zones, and 120 years-old for the western
hemlock zone. Also, the retention tree basal area was estimated using Alternative 3 retention tree minimum
size classes definitions, which varied by vegetation zone. The basal area calculations also included some
merchantable trees which did not meet the minimum retention tree size. Inclusion of these smaller trees
was done based on the assumption that little or no harvest would generally occur within the aggregated
retention blocks.
Future growth of the aggregated retention blocks was represented by their continued growth using the pre-
harvest existing stand guide curve. Growth of the harvested portion was represented by Alternative 1 even-
aged future stand guide curves with no retention. However, a reduction in timber yields is taken to account
for the “edge effects” from the aggregated retention blocks.
The uneven-aged management zone harvests consist of periodic selection cuttings applied to stands from
each representative modeling group. Harvest frequency ranged from 20 years to 60 years with harvests
generally occurring more frequently on higher sites. Selection cutting was modeled as a proportional
commercial thinning at regular intervals using residual basal area targets which varied by modeling group.
Predominantly Ponderosa pine stands were managed at lower residual basal area levels than mixed-conifer
groups. After each harvest a regeneration tree list was added to the simulation to rellect natural and artificial
reforestation occurring. Regeneration tree lists generally included a proportional representation of species
included in the stands original species mixture.
Appendices - 673
FEISfor the Revision of the Western Oregon RMPs
Special adaptations to cutting practices were applied to the various modeling groups. For example, in the
Ponderosa pine modeling groups, some stands were managed to reduce the proportion of Douglas-fir to
favor pine growth.
PRMP
Application of even-aged systems using clearcutting and shelterwood regeneration harvest methods were
modeled in Timber Management Area land use allocation.
Timber harvests on the Uneven-aged Timber Management Area land use allocation on the Medford District
and the westside of the Klamath Falls Resource Area consisted of periodic selection cuttings applied to
stands from each representative modeling group. Harvest and other silvicultural treatment frequency
generally ranged from 20 years to 60 years with harvests generally occurring more frequently on higher
sites. Selection cutting was modeled as proportional and low commercial thinnings at regular intervals using
residual relative density targets to maintain stand average relative density between 25-55.
After each timber harvest, a regeneration tree list was added to the simulation to reflect natural and artificial
reforestation occurring. Regeneration tree lists generally included a proportional representation of species
included in the stands original species mixture.
Special adaptations to cutting practices were applied to the various modeling groups. For example, in the
Ponderosa pine modeling groups, some stands were managed to reduce the proportion of Douglas-fir to
favor pine growth.
Stand Modeling Process
The prediction of forest stand development requires the growth projection of BLM’s existing forest stand
types into the future, with and without further silvicultural treatments, and the simulation of stands which
represent future stands, i.e., new stands created following timber harvest. Depending on the management
direction of the alternatives, both existing and future stands may be subject to different intensities of
silvicultural treatments.
The results of DBORGANON growth projections are used to develop guide and treatment response curves
for use in the OPTIONS modeled. See the “Types of Growth Curves” section in this appendix for more
detail.
Two computer growth and yield simulation models, DBORGANON and CONIFERS were used to project
the growth and development of forest stands under various silvicultural prescriptions.
Organon Model Description
ORGANON is an individual-tree, distance-independent model developed by Oregon State University
from data collected in western Oregon forest stands (Hann 2005). The architecture of the model makes it
applicable for simulations of traditional and non-traditional silviculture (Hann 1998).
Three variants of ORGANON are available for use in western Oregon. The northwest Oregon variant
(NWO-ORGANON) and southwest Oregon variant (SWO-ORGANON) were deemed appropriate for
modeling the stand types found on BLM-administered lands and the proposed management actions.
The standard ORGANON configuration is not conducive to the efficient processing of large numbers of
individual tree lists representing forest stands within a stratum. It is not configured to merge multiple
simulation results into average timber yield functions. Also, the standard model does not produce
Appendices - 674
Appendix R - Vegetation Modeling
specific stand structural characteristics that have utility for effects analysis on resources other than timber
production, or for the incorporation of factors to simulate growth improvement of trees due to genetic
improvement programs. FORsight Resources developed a version of ORGANON for the BLM, referred to as
DBORGANON, which incorporates all the basic ORGANON functions and equations and which meets the
additional BLM requirements. DBORGANON was used to project the growth of forest stands greater than
or equal to 15 years-old.
The BLM modified northwest Oregon variant (NWO-ORGANON) was used to project the growth of forest
stands located on the Salem, Eugene, Coos Bay and Roseburg Districts. The basic data underpinning of
this variant of the model is from predominantly conifer forest stands with ages ranging from about 10 to
120-years-old breast height age (Llann 2005).
The BLM modified southwest Oregon variant (SWO-ORGANON) was used to project forest stand growth
on the Roseburg, Coos Bay and Medford Districts and the Klamath Falls Resource Area. The original basic
data underpinning this variant of the model is from mixed-conifer forest stands with ages of the dominant
trees ranging from about 13 to 138-years-old breast height age (Ritchie and Hann 1987). Subsequently,
additional new data was collected and used to extend the applicability of the model to stands with older
trees (250+ years-old), with higher proportions of hardwoods and with more complex spatial structure
(Llann and Llanus 2001).
Simulations of stand growth of the WOPR silvicultural prescriptions extend beyond the ORGANON
model’s range of data for both variants. Flowever, the timing of harvests and other silvicultural treatments
generally occur within the range of the model’s validated height growth projection and volume prediction
capabilities. Height growth is the primary driving function in ORGANON (Ritchie 1999). Hann (1998)
found that the SWO-ORGANON height growth equations can be extended to up to 245 years without loss
of accuracy, or precision.
Conifers Model Description
The CONIFERS model is an individual-plant growth and yield simulator developed from young mixed-
conifer stands in southern Oregon and northern California by the U.S. Forest Service. CONIFERS provides
growth forecasts for young plantations of single or mixed- species growing with or without competition
from shrubs (Ritchie 2006). The growth of forest stands less than 15 years-old were simulated using the
CONIFERS young stand growth model. The tree lists were exported to DBORGANON at stand age 15
years-old for further simulation.
Existing Stands Modeling Groups Description
The land base consists of existing forest stands, the result of past harvests and natural disturbances, of
various ages, structures, past management histories and potential for forest management. Tree lists from
Current Vegetation Survey (CVS) inventory subplots were stratified into modeling groups as described
elsewhere in this appendix. Using DBORGANON, these modeling groups were used for depicting current
stand condition and simulating future development with and without future silvicultural treatments.
Each individual CVS subplot tree list within a modeling group was projected by DBORGANON subject to
a common silvicultural prescription to stand ages 200 or 400 years-old, depending on the initial range of
stand ages in the various modeling groups or the requirements of an alternative. Modeling groups consisting
of younger managed stands, generally less than 60 years-old, were projected to stand age of 200 years. Older
stand modeling groups were projected to a stand age of 400 years to insure that all CVS plots would be
incorporated into the simulation.
Appendices - 675
FEISfor the Revision of the Western Oregon RMPs
Each individual tree list
entered the simulation
at its current age. This
resulted in some stands
having a greater weight on
the overall group average
characteristics, depending
on the distribution of
plot ages in a particular
modeling group and
the length of the growth
projection. Figure R-16
shows a simplified example
of individual plot growth
trends and the modeling
group average.
DBORGANON Growth Simulation Example
Plots Start Simulation at Current Age & Are Projected to Common End Age
Total Age
rue DSOPGAMQn I'uf.p.vsou
Figure R-16. Example of DBORGANON Simulation
Future Stands Modeling Groups Description
Modeling groups and tree lists for forest stand types or silvicultural prescriptions for which little or no
specific CVS data existed, were developed from subsets of the CVS data and growth was modeled with
CONIFERS.
Initial stand attributes for the future stands tree lists were derived from the 10 and 20 years-old age
class CVS subplots, stratified by DBORGANON variant, species group and site class. It was assumed
that the future young stand management intensity and tools available would be similar to the past two
decades.
Review of the data indicated that the future stands could be represented by three basic modeling groups for
the northwestern Oregon and six groups for the southwestern Oregon. A single future stand tree list based
on the characteristics of existing CVS plots for each modeling group and site productivity was grown in
CONIFERS to age 15 years-old, at which time the tree lists were exported to DBORGANON for further
simulation. Projections were simulated to a stand age of 200 years-old, except for Alternative 3 where 400-
year projections were required.
These future stand projections formed the basis for initiating new stands following regeneration harvests in
all alternatives and the partial harvests in Alternative 3. The future stands category includes existing stand
types created as a result of regeneration harvest prescriptions with green-tree retention under the current
BLM Resource Management Plans. There were an insufficient number of CVS subplots with this type of
management for Guide Curve modeling. Therefore, it was necessary to create tree lists for simulating those
silvicultural prescriptions for existing and future stands under the No Action Alternative.
For all alternatives, a special subset of modeling groups was developed for modeling future stands within
geographic areas currently identified with a high incidence of Swiss needle cast disease on the Salem
District. Future tree lists species composition in the Swiss needle cast zone was based on an assumption of
higher proportions of disease resistant species being used for the reforestation of future harvested areas.
Appendix R - Vegetation Modeling
Types of Growth Curves
Two types of curves are produced from DBORGANON simulations for further use by the OPTIONS model.
The curves are referred to as guide and treatment response curves.
Guide Curves
Guide curves are used to provide guidance to the OPTIONS model with respect to the growth curve shape
and projection values. Simply stated, guide curves represent the growth projection of forest stands without
any additional silvicultural treatments. Individual guide curves are developed for each modeling group
which incorporates geographical province, species groups, current stand condition, and site productivity
class. Existing stand guide curves developed from CVS data were applicable to all alternatives. Future stand
guide curves were developed specific to the management direction of the various alternatives Two-aged
silvicultural prescriptions were developed for the No Action Alternative and Alternative 3. Even-aged curves
were developed for Alternatives 1, 2, 3 and the PRMP. Uneven-aged curves were developed for Alternatives
3 and the PRMP.
Treatment Response Curves
Treatment Response curves were used to adjust the guide curves to reflect the effects of various silvicultural
treatments (see discussion of Treatment Response). Growth projections were done to produce curves that
simulated commercial thinning, fertilization, and uneven-aged management treatments. Precommercial
thinning of future stands was incorporated into the initial ORGANON guide curve tree lists, so no growth
response curves were necessary for that treatment type.
Within the constraints of other modeling assumptions, all possible combinations of treatments were
simulated for each modeling group to allow a wide range of treatment timing, combination and flexibility
within the OPTIONS model.
Commercial Thinning
Silvicultural prescriptions incorporating commercial thinning were developed using the modeling groups
with stands less than 60 years-old. Guide curve simulations were examined for each modeling group to
determine the earliest average age when an initial commercial thinning was feasible.
Evaluation criteria included four factors:
1) stand relative density (Curtis 1982),
2) attainment of minimum average stand diameter,
3) minimum harvestable volumes, and
4) residual canopy cover or shade requirements (late-successional and riparian areas only).
Relative density thresholds were based on published recommendations, such as Curtis and Marshall
1986; Hayes et al. 1997; and Chan et al. 2006 and professional judgment. Minimum diameter and volume
thresholds were based on historical BLM timber sales.
For each modeling group, simulations were done to determine the appropriate timing of treatment based on
relative density rules. Thinning was simulated when minimum criteria were met.
Relative density rules can vary by land used allocation within alternatives. Silviculture prescriptions for
land use allocations with timber objectives including the Northern General Forest Management Area
under the No Action Alternative, the Timber Management Areas under Alternatives 1, 2, and the PRMP,
and the General Landscape Area under Alternative 3 were thinned to maintain relative densities between
approximately 35 and 55. The timing of the final thinning is designed so that relative density recovers to
Appendices - 677
FEISfor the Revision of the Western Oregon RMPs
a minimum of 55 at rotation age. Assumed rotation ages for treatment response simulations in land use
allocations with timber objectives were based on culmination of mean annual increment (CMAI) and range
from 100 to 125 years.
Commercial thinnings have been found to contribute to the establishment of conifer regeneration in
the understory of thinned stands (Bailey and Tappeiner 1998). Simulation of the recruitment of this
regeneration in the growth simulations was done to reflect expected stand dynamics following commercial
thinning harvests. The ORGANON growth and yield model (Hann 2005) does not recognize trees with
diameters less than 4.5 feet at breast height. Therefore, regeneration tree lists were developed using existing
CVS data and growth relationships from current published and unpublished studies. The regeneration trees
were added to DBORGANON simulations 20 to 25 years following any commercial thinning. The time lag
represented the estimated time for all trees in the regeneration tree list to reach 4.5 feet tall.
Silviculture prescriptions for land use allocations with objectives other than timber were thinned to
maintain relative densities between approximately 25 to 50 to a maximum age of 80 years-old in No Action
Alternative, or until minimum desired stand structural class is attained in Alternatives 1, 2, 3, and the PRMP.
Fertilization
Fertilization with 200 pounds of active nitrogen per acre is simulated to occur after thinning in all
alternatives. Fertilization was modeled for land use allocations with timber objectives where the stand was
even-aged, two-aged with low green tree retention (< 8 dispersed retention trees per acre), two-aged with
aggregated retention, i.e. partial harvested areas in Alternative 3, and when DBORGANON criteria were
met. DBORGANON criteria for treatment were when the stand contains 80% or more Douglas-fir by basal
area and total stand age is less than 70 years-old.
The fertilization equations in ORGANON were revised for the Final EIS growth simulations. A sensitivity
analysis was done to compare differences in outputs. Differences between the estimated yield and other
stand attributes varied by 1% or less from stand age 40 years-old and older. This level of change was not
considered substantial enough to warrant new growth and yield simulations.
Growth and Yield Adjustments
The DBORGANON model projections of timber yields needed to be adjusted to account for increased
growth due to genetic tree improvement and reduced to account for the effects of additional overstory
mortality in older and partial cut stands. Adjustments for factors which could substantially affect stand
dynamics including genetic tree improvement, Swiss needle cast disease, and other overstory mortality
were accomplished by means of factors applied within the DBORGANON model. Other factors affecting
recoverable commodity volumes were modeled as a percent reduction in volume. Timber defect and
breakage, endemic insects and disease, soil compaction, future snag creation, future coarse woody debris
creation, green tree retention were applied in the OPTIONS data preparation program to account for
guidance requirements specific to each alternative.
Tree Improvement
Conifer species such as Douglas-fir and western hemlock have been selected for genetically controlled
characteristics such as high growth rates and tree form. The BLM in cooperation with other landowners
have established field test sites using progeny from the selected trees. These progeny test sites have been
measured at regular intervals and the data collected has been used to select those parent trees which are
ranked highest in growth rates. Seed orchards have been established to produce locally adapted seed from
these selected trees for reforestation of harvested stands and natural deforestation.
Appendices - 678
Appendix R - Vegetation Modeling
The increased growth and yield effects from utilization of genetically improved seedlings was accomplished
by the use of a one-time growth increase to tree lists exported from CONIFERS and the application of
growth modifiers applied to future stand modeling groups in DBORGANON.
Height and diameter of genetically improved species exported from CONIFERS at age 15 years-old were
increased before importation into DBORGANON by 7% and 8% respectively based on the observed height
and diameter percentage increase of the top one-quarter trees in the progeny tests. After importation of the
tree lists into DBORGANON, growth modifiers were applied to future stand modeling groups to account
for incremental genetic gain expected to accrue beyond age 15 years-old. Growth modifiers have been found
to be an effective way to incorporate genetic gain from tree improvement programs into growth models
(Carson 2003).
Growth modifiers have not been publicly developed for Pacific Northwest tree improvement programs,
although work is currently underway (USDA 2006b). Finalized growth modifiers for regional growth and
yield models are expected within a year or perhaps more.
In the interim, growth modifiers were adapted from the preliminary feasibility work of Johnson and
Marshall (2005) by BLM personnel. These factors are used to modify growth and mortality rates of
genetically improved seedlings for simulations of the future stands modeling groups. The DBORGANON
model was specifically configured to allow the use of growth modifiers for simulation of genetic gain and
other purposes.
Growth modifiers are applied in DBORGANON as described below.
1) Growth modifiers apply to Douglas-fir within timber management land use allocations for all
alternatives, when stands are managed under even-aged silvicultural systems, two-aged systems
with aggregated overstory retention, or dispersed retention with low overstory density. No
increased growth from genetic improvement is simulated for lands managed using uneven-aged
silvicultural systems, or with high levels of dispersed retention overstory
2) Growth modifiers apply to western hemlock using the criteria as Douglas-fir except that it is
confined to area designated as the Swiss needle cast zone on the Salem District only (see Disease
section).
3) Growth modifiers were calculated for each BLM district, but since no significant difference was
observed, average westside BLM growth modifiers were used.
4) Existing BLM seed orchards have the biological capability to produce improved seed in excess of
probable BLM needs.
5) Growth modifiers were reduced to account for pollen contamination from non- genetically
improved trees adjacent to and within the BLM seed orchards.
6) Growth modifiers are applied from stand age 15 to 100 years-old.
Analyses were updated for the Final EIS growth simulations to produce revised genetic improvement
factors. A sensitivity analysis was done using five modeling groups representing both DBORGANON
variants and a range of site productivity classes to simulate guide curves incorporating the new genetics
factors. An additional simulation was done utilizing the new factors to test impacts on commercial
thinning.
Within the range of assumed rotation ages (80-120 years), the yield differences varied from less than 1 to
4%. Changing the genetic factors did not change the timing of potential commercial thinning opportunities
or result in a substantial change in yields or other stand attributes. In general, the magnitude of change in
yields from the revised genetics factors alone was not considered substantial enough to warrant new growth
and yield simulations. An exception to this was made for the Swiss needle cast disease zone on the Salem
District; where new simulations were necessary due to changes in the Swiss needle cast disease growth
adjustment factors (see the Swiss Needle Cast Disease section of this appendix).
Appendices - 679
FEISfor the Revision of the Western Oregon RMPs
Defect and breakage
A proportion of harvested trees can contain defects which reduce its utility from a commodity standpoint.
Also, damage can occur during harvesting, that results in breakage which reduces recoverable timber
volume. The proportion of volume which is not recoverable for commodity use generally increases with
stand age. DBORGANON generated timber volume yields were reduced by BLM district-specific factors
derived from historical timber sale cruise and scale data.
Soil Compaction
Districts with available data as to the extent and degree of soil compaction applied a yield reduction factor
to DBORGANON yields. The deductions were applied to the Medford and Salem Districts and the Klamath
Falls Resource Area.
Snag Retention
The yield impact of retaining varying amount of green trees for the creation of future snags was done
by leaving extra retention trees or applying a percent volume reduction to meet the minimum snag
requirements at the time of harvest. Retention requirements varied by alternative and by land use allocation.
Coarse Woody Debris Retention
The yield impact of retaining varying amounts for future down woody debris on timber yield was modeled
as a percent volume reduction at the time of harvest. Retention requirements were varied by alternative and
land use allocation.
Stocking Irregularity
For any level of stocking, a portion of a stand may consist of openings which do not contribute to stand
volume at any point in time, i.e., a stand may contain non-stocked openings of a size sufficient to affect
timber yield. These openings may be thought of in terms of less-than-perfect stocking or in terms of
variation in tree location and fall into two categories; permanently incapable of growing commercial tree
species, and those temporarily unoccupied by desirable trees.
Portions of stands may contain permanent areas of non-productive rock or other areas incapable of growing
commercial tree species. This condition is partially accounted for by reductions in the timber base through
the Timber Productivity Capability Classification.
Temporarily non-stocked areas occur due to variation in reforestation success from a variety of non-
permanent factors, such as vegetative competition or logging slash.
The ORGANON model accounts for stocking variation by assuming that the degree of local competition
experienced by a tree is reflected in its crown size. Trees growing next to openings have longer crowns and
poor growth reflected as stem taper which reduces the volume of a tree next to the opening, compared to
a similar size tree with shorter crown in an area with more uniform tree distribution. As long as the crown
characteristics of sample trees are measured, then any long-term spatial variation within the stand will be
modeled appropriately (Forsight 2006).
Since existing CVS data used for existing stands and the development of future stands modeling groups
contain the necessary crown measurement, no external adjustment for stocking irregularity was applied to
DBORGANON yields.
Green tree retention has two effects from a stand growth and yield standpoint. First, otherwise harvestable
volume is foregone for commodity use at the time of harvest. Methodology for determining this allowance
was described previously for each alternative. Second, retention trees compete for growing space with the
newly regenerated trees.
Appendices - 680
Appendix R - Vegetation Modeling
The first effect of retained trees on foregone harvest volume is modeled with the OPTIONS model as a
stand constraint. A proportion of the stand equating to the amount of basal area per acre of the uncut
stand retained is set aside and is simulated to continue to grow on the existing guide curve until the next
regeneration harvest. At that time a new set of retention trees would be set aside to grow for the subsequent
harvest cycle. The proportions ranged from approximately 10% to 20% for the No Action Alternative and
from 18% to 37% for Alternative 3 depending on land use allocation or vegetation zone.
The second effect was modeled using DBORGANON for the No Action Alternative and by using a fixed
percentage yield reduction for Alternative 3.
The No Action Alternative future modeling group tree lists included the required number of retained trees
as overstory. The retained trees slowed the growth of the new understory in roughly proportional to the
amount of retained overstory trees. The volume of the retention trees was not included in DBORGANON
estimates of potential timber yield, but included for evaluating overall stand characteristics and structural
stages.
Alternative 3 partial harvest yields from future stands were reduced by 5% percent to account for edge
effect, i.e., the effects of the aggregated retention blocks of overstory trees competing with the new tree
regeneration. The factor used is an average reduction observed from modeling work in British Columbia (Di
Lucca et al. 2004).
Disease
Two types of reductions were used to simulate the effects of endemic levels of insect and disease on timber
yields. The first method was through the DBORGANON model using a growth modifiers approach for areas
on the Salem District with moderate to severe levels of Swiss needle cast disease. The second method used a
percentage reduction in yield approach applied in OPTIONS data-prep program to the guide curves for all
districts to account for other insect and disease effects.
Swiss Needle Cast Disease
Portions of the Salem District are located in an area with a moderate to high occurrence of Swiss needle cast
disease. This disease infects Douglas-fir trees only and reduces growth rates. It does not affect the growth of
other tree species. A growth modifier approach similar to that used for modeling the growth of genetically
improved trees was employed in DBORGANON to reflect the estimated growth reductions for Douglas-fir
in the Swiss needle cast zone. Three Swiss needle cast (SNC) zones were developed for BLM land consistent
with Oregon Department of Forestry (ODF) criteria, a severe, moderate, and a no impact zone.
The BLM calculated mean foliage retention values for the severe and moderate zone using plot data from
ODF Swiss need cast surveys. The foliage retention values were used to calculate growth loss in height and
basal area by severity zone using ODF methodology (Oregon Department of Forestry 2005). The growth
loss modifiers were applied in DBORGANON to existing and future stand modeling groups in order to
simulate more realistic stand dynamics. New Swiss needle cast factors were calculated based on information
that became available after the growth simulations for the draft EIS were completed. The new factors are
a product of ongoing work to develop a Swiss needle cast disease module for the ORGANON model. The
difference in factors was considered substantial enough that new growth simulations for the PRMP were
done. Revised genetic tree improvement factors were also incorporated in the simulations.
As stands are regeneration harvested in the Swiss needle cast zones, an average mix of tree species will be used
for reforestation that is different than the current stand composition. Future tree lists reflecting tree lists with
a minority of Douglas- fir were generated using the process described above for the future stands modeling
groups. Tree lists with a single average species composition for both zones containing 28% Douglas-fir w'as
used. Examination of the simulation results for the moderate and severe Swiss needle cast zones showed no
substantial difference in predicted timber yields (<1%) so a single yield function was used.
Appendices - 681
FEISfor the Revision of the Western Oregon RMPs
Other Insects and Disease
Some of the effects of endemic levels of insects and disease other than Swiss needle cast on timber yields are
assumed to be reflected in the defect and breakage allowance described previously and the additional overstory
mortality factor described below. In addition to those factors, further allowance was deemed appropriate for
insects and diseases by adjusting timber yields down by a percent volume reduction. These factors generally
vary from about 1% to 3% increasing with stand age and are based on literature and professional judgment.
Additional Overstory Mortality Factor
The ORGANON model underestimates tree mortality from causes other than inter-tree competition, such
as insects, disease, windthrow and stem breakage, (Tappeiner et al. 1997). This type of mortality is often
irregular, or episodic in nature, and it is inherently difficult to predict the exact time period in which it will
occur (Franklin et al 1987). The ORGANON mortality equations predict that the risk of dying is very low for
trees over 20 inches in diameter or with crown ratios over 70% (Hann and Wang 1990). For mature stands,
mortality from inter-tree competition becomes less significant as stands age and mortality from other factors
becomes more substantial.
To account for mortality from these other factors, an irregular mortality adjustment of 1.4% per
DBORGANON growth cycle (five years) was determined from a review of ecological literature and
Continuous Forest Inventory data (Lewis and Pierle 1991).
The 1.4% factor was applied to existing and future stand modeling groups through a function in the
DBORGANON model. The factor applied only to trees greater than 20” diameter breast height in stands
aged 100 years-old and older, to simulate mortality of larger trees from causes other than inter-tree
competition.
In addition, partial cutting has been reported to significantly increase wind damage, especially during
the first few years after treatment. Amount and extent are dependent on individual site factors, landscape
conditions, and severity of the storm event (Strathers et al 1994). Average mortality for retained trees in
partial cut Douglas-fir stand during the first five years post harvest from non- suppression factors averages
about 1-2% (Williamson and Price 1973; McDonald 1976; Jull 2001). To account for this type of mortality,
the same 1.4% factor was applied to stands which represented regeneration harvests with dispersed green
tree retention. Model limitations allowed the use of only one additional mortality factor in a simulation.
Therefore, the additional mortality factor was applied at stand age of 20 years-old, corresponding to the end
of the first growth cycle in DBORGANON to trees greater than 20” diameter breast height.
Application of the additional 1.4% mortality rate during growth simulations produced modeling results
which more closely matched patterns of stand development supported by empirical data and ecological
theory than simulations done without the factor (Lewis and Pierle 1991).
A review of the green-tree retention mortality rate assumptions used in the Draft EIS was completed due to
the availability of new published information. Three previously unexamined publications were reviewed
(Buermeyer et al. 2002; Busby et al. 2006; Maguire et al. 2006) for applicability. Based on the review,
sensitivity analysis was done to determine if new growth simulations were warranted for the Final EIS. The
results of the analysis indicated that new growth simulations using revised mortality assumptions were
not necessary since the results were not expected to substantially affect predicted yields or structural class
changes in those alternatives that reserved live overstory trees for stand structural values.
Appendices - 682
Appendix R - Vegetation Modeling
OPTIONS Modeling
OPTIONS Model
Background
The OPTIONS model version V (OPTIONS or the model) is a spatially explicit, rules-based, land
management simulation model. OPTIONS, developed by D.R. systems inc. (DRSI), has been in use for
more than 20 years and is regularly updated and refined to reflect current knowledge, issues in land
management and modeling techniques. The model has been used to develop land management strategies
and operationally feasible plans on more than 500 million acres throughout North America, South
America, the South Pacific and Asia. Most of these projects involved complex, multi-resource objectives
and environmental regulations.
In the western United States, OPTIONS has been used for a wide range of industrial and government
analyses, including land trades, evaluation of lands for sale or purchase and the development of sustainable,
multi-resource management plans. The model was used in Plum Creek Timber Company’s 1997 Cascades
Habitat Conservation Plan for central Washington State. The Habitat Conservation Plan was the first
major, multi-species habitat conservation plan developed in the United States. The OPTIONS model was
also used in the Washington State Department of Natural Resources 2004 Sustainable Forest Management
Harvest Calculations. The Sustainable Forest Management Harvest Calculations applied an alternatives
based approach toward developing a long-term, sustainable, multi-resource forest management plan on
approximately 2.1 million acres of Washington State Trust Lands. The model was also recently used to
complete Pacific Lumber Company’s Long-term Sustainable Yield Calculations on approximately 217,000
acres of redwood forest land in northern California. The project set new standards for sustainable yield
calculations and planning in California.
Currently the model is also being used by the University of Georgia to analyze the impacts of proposed
regulations and policies on long-term timber supply, by the California Department of Forestry in a pilot
project investigating new approaches to the sustainable yield calculations, as well as numerous operational
analyses in Washington, Alaska and British Columbia, Canada. DR Systems’ expertise in partnership with
BLM staff was used in applying the OPTIONS model to analyze alternative management strategies for the
Western Oregon Plan Revision.
This analysis provided the basis for comparing alternatives in terms of the forest conditions / wildlife
habitats created over time as well as determining the sustainable harvest levels for the Western Oregon BLM
districts.
OPTIONS Model Overview
The OPTIONS model simulates the growth and management of individual land management units within
a BLM Sustained Yield Unit (SYU). Land management units are created in a GIS process that combines
multiple layers of resource information and objectives into a single resultant layer. Examples of these resource
layers would include Forest Operations Inventory units, administrative boundaries, riparian management
areas, Late-Successional Management Areas, Visual Resource Management areas, (See Figure R-17).
The model utilizes the resultant file to dynamically maintain all of the spatial identity across all contributing
layers enabling the model to apply spatially explicit growth projections and management rules to individual
resultant units (polygons), or groups of polygons throughout the Sustained Yield Unit.
Appendices - 683
FEISfor the Revision of the Western Oregon RMPs
The planning horizon of a simulation
can extend as far as 400 years. Inventory
information for each resultant unit is
used to initialize the model and for each
subsequent year in the planning horizon
growth projections forecast future
conditions for each polygon. However,
these growth projections are sensitive to
management activities and rules.
Management activities, such as silvicultural
treatments (for example site preparation,
fertilization or pre-commercial thinning)
and harvesting activities (for example
commercial thinnings, selection harvest
or regeneration harvest) are distinguished
from management objectives such as the
exclusion of harvesting activities within
riparian management areas. Activities are
applied to polygons individually, while
objectives may be applied to individual
polygons, portions of a polygon, or
collectively to a group of polygons.
Importantly, all objectives are implemented
before any management activity can be
applied, so harvest activities are simulated
only after all environmental and habitat
requirements have been satisfied.
Figure R-17. Graphic Example Of How A
Resultant Layer Is Created From Multiple
Resource Layers In GIS
age and types of
trees in 30,000 to
40,000 different
forest stand
inventory units
owl or murrelet
habitat,
unstable slopes
management
roads
rivers, streams,
wetlands and
buffers
basic
landscape
and
topography
Growth Projections
Throughout the planning horizon individual polygons are grown according to their individual forest
inventory characteristics and growth trends established from a set of generalized growth projections. For
this project, the growth projections were generated with the DBORGANON growth and yield model. These
projections are imported into OPTIONS and used to forecast the nominal growth trend of each polygon.
Within the model these growth projections are further refined to accommodate the unique characteristics
of each polygon, including any unique management objectives, environmental conditions or inventory
information. Growth projection attributes are tracked and reported including: stand height, diameter, basal
area, density, and volume.
Incorporating Existing Inventory Information into the Simulation
Spatially explicit forest inventory information reflects current forest conditions. Depicting current
conditions accurately is important in forecasting how alternative management strategies impact future forest
conditions.
Where available, OPTIONS incorporates existing forest inventory information into the simulation
analysis. Spatially explicit forest inventory information improves the analysis, but can create challenges
because resource inventory classification systems often do not coincide directly with modeled growth
projections. Although the generalized growth projections are accurate across a broad set of polygons, they
do not capture variations of current inventory conditions at the individual polygon level. Thus, projecting
the future growth of individual polygons requires an integration of existing inventory information with
Appendices - 684
Appendix R - Vegetation Modeling
the generalized growth model projection. This integration is accomplished by utilizing algorithms to
normalize future growth from the individual polygons current inventory condition towards the long-term
growth model projection. The rate of normalization is scaled according to the proximity of the inventory
value to the model prediction. The process, referred to as the “trend to normality” captures, with spatial
integrity, current conditions while accounting for the future growth within the polygon.
Treatment Adjustments and Responses
Growth projections are sensitive to management activities such as silvicultural treatments. Management
activities are applied to individual polygons only when a set of eligibility criteria are met. Polygons that do
not meet these criteria are not treated and their growth projection is uninterrupted. Stands that meet the
eligibility criteria, as well as all other management objectives, are treated and their growth projection is
adjusted. This adjustment is specific to stand age, species, site productivity level, as well as treatment type
and intensity. All of these treatment and adjustment variables are defined in the model based on experience
gained from the growth and yield modeling, professional judgment, research, and management objectives.
Figure R-18 provides an example of a volume growth projection and the adjustments applied for two stand
thinning treatments. Growth projection for a polygon without treatment following the guide curve and the
adjustments for two stand treatments at ages 40 and 60.
Figure R-18. Example Of A Volume Growth Projection Curve And
Adjustments For Thinning Treatments
Appendices - 685
FEISfor the Revision of the Western Oregon RMPs
Management Activities and Rules
Management Activities
Forest management often requires intervention activities such as silvicultural treatments or harvesting
activities. Silviculture treatments such as planting, pre-commercial thinning, pruning, fertilization,
commercial thinning and selection harvest are explicitly defined, that is; their timing, intensity, duration
and biological response are all defined in the model based on experience gained from the growth and yield
modeling, professional judgment, and research.
Additionally, treatments are subject to stand (polygon) level and landscape level eligibility criteria. An example
of a stand level eligibility rule would be a minimum age or basal area threshold. A landscape level eligibility
criteria would be an upper limit on the commercial thinning volume, within a Sustain Yield Unit. Silviculture
treatments were not applied unless all eligibility criteria were met.
Harvesting activities are also subject to stand level and landscape level rules. An example of a polygon
level harvest rule would be a minimum harvest age or a minimum residual volume per acre. There
can be a number of landscape level harvest rules that control the maximum and minimum harvest
levels by species type, species and wood-type priorities, polygon age and treatment type and landscape
management objectives.
Figure R-19 provides an example set of landscape level harvest rules requesting minimum and maximum
board foot volume level by species group.
Numerous management activities and silvicultural treatments can be developed and applied in various
combinations, each combination defines a unique management regime. Polygons within a Sustained Yield
Unit are assigned to a single, starting management regime. On completion of the management regime, or
because of a specific harvest treatment, the polygon may return to the same management regime or continue
under a new management regime.
Figure R-19. Landscape Level Harvest Rules Example
Appendices - 686
Appendix R - Vegetation Modeling
Land and Resource Management Rules
In OPTIONS, resource management objectives can be applied as targets or constraints.
Targets and constraints can be applied to individual polygons or collectively to a group of polygons.
Targets and constraints are applied for each year in the planning horizon, so all management objectives are
maintained for every year within the planning horizon.
Targets are used to control conditions at the landscape level. For example, a target may be used to ensure that at
any point in time 15% of the forested BLM -administered lands within a fifth field watershed will be in stands 80
years and older before regeneration harvest may occur. The model is flexible about which particular polygons
are reserved to satisfy the target criteria. If current stand conditions do not achieve the target criterion the
model will evaluate and recruit polygons that will contribute toward meeting the criterion soonest. Recruited
polygons are deferred from harvest ensuring that the target criterion is met as soon as possible. Each year
within the planning horizon, the model checks that sufficient polygons are available and deferred to meet
the target criteria. The model only defers enough polygons to meet the modeling targets, thus allowing non-
deferred polygons to contribute toward meeting other management objectives.
Constraints set explicit limitations on the amount, or kind, of activities permitted for an individual polygon,
portion of a polygon or across a group of polygons, for a defined period. The defined period can extend
through the entire planning horizon, or it can be defined for a shorter timeframe. For example, constraints
can be used to exclude regeneration harvest activities from a riparian area throughout the entire planning
horizon, while allowing commercial thinning activities until the stand reaches an age of 80, after which no
further treatments are permitted.
GIS-Based Modeling Rules
The attributes associated with the GIS spatial data are used in OPTIONS to identify areas where modeling
rules are applied to simulate the management action and land use allocations for the alternatives. This
section will describe, by topic area, the modeling rules and GIS data as they were applied to simulate the
alternatives with the OPTIONS model.
1) Sustained Yield Units (SYU)
The BLM lands are subdivided into Sustained Yield Units for the purpose of defining the area in
which the allowable sale quantity will be based. The Sustained Yield Units are based on the BLM-
administered lands within the District boundaries for Salem, Eugene, Roseburg, Coos Bay, and
Medford Districts. The western portion of the Klamath Falls Resource Area within the Lakeview
District is also a SYU. The eastern portion of the Klamath Falls Resource Area does not contain
any O&C lands and a sustained yield unit is not designated. The Forest Operations Inventory
(FOI) District attribute data was used as the basis for the Sustained Yield Units in the OPTIONS
modeling. The Land Use Allocation data segregated the Klamath Falls Resource into the Klamath
SYU and the eastside management lands. An estimate of the sustainable harvest level was done for
the eastside management lands under the No Action Alternative modeling assumptions. Allocations
and management direction did not vary across alternatives for the eastside management lands and
so they were not modeled in the action alternatives.
2) Non Forest
Non-forest areas in the OPTIONS model remain static in the projections and do not carry
vegetation attributes. Non forest information was derived from multiple sources of GIS data to
form the non forest class in the OPTIONS modeling.
Transportation data buffered by 22.5 feet to simulate the road network.
Appendices - 687
F£JS/or the Revision of the Western Oregon RMPs
Timber Productivity Capability Classification non forest classes.
Forest Operations Inventory Existing Stand Condition non forest class.
In Alternatives 2 and 3 - open water class from the streams data.
3) Timber Productivity Capability Classification (TPCC)
The TPCC inventory is described in detail in the Inventory Data section of this appendix. Common
to all alternatives, the non suitable woodlands and the suitable woodland categories of low site and
non commercial species had no harvest modeled and were not included in the ASQ.
In the No Action Alternative, the reforestation suitable woodlands had no harvest modeled and
were not included in the ASQ. In the Action Alternatives, these lands had harvest modeled and
did contribute to the ASQ.
4) Recreation Sites
In all Alternatives, the existing recreation sites had no harvest modeled and were not included
in the ASQ. In the Action Alternatives the proposed recreation sites had no harvest modeled and
were not included in the ASQ. In the No Action Alternative the proposed recreation sites lands had
harvest modeled and did contribute to the ASQ.
5) Wild and Scenic Rivers
In all alternatives, the existing Wild and Scenic Rivers had no harvest modeled and were not
included in the ASQ. In the Action Alternatives, the eligible Wild and Scenic Rivers had no harvest
modeled and were not included in the ASQ. In the No Action Alternative, the eligible Wild and
Scenic Rivers had harvest modeled and did contribute to the ASQ. In the No Action Alternative,
the existing recreation segments had harvest modeled and did contribute to the ASQ. (Note: not all
recreation segments were able to be identified and put in the harvest land base).
6) Visual Resource Management (VRM)
In all alternatives, the VRM class one had no harvest modeled and was not included in the ASQ.
Under Alternative 2 and the PRMP, on the PD or acquired lands, no regeneration harvest was
applied on VRM class two (Note: The VRM class one GIS data was only used in the No Action
Alternative and Alternative 2. In the other action alternatives, the combination of the Wild and
Scenic River and Congressionally Reserved covered this allocation.)
7) Areas of Critical Environmental Concern (ACEC)
In the No Action Alternative, all of the existing ACECs had no harvest modeled and were not
included in the ASQ. The proposed ACECs had harvest modeled and did contribute to the ASQ.
In the action alternatives, all of the existing and proposed ACECs which passed through the O&C
filter had no harvest modeled and were not included in the ASQ. Those ACECs that did not pass
through the O&C filter had harvest modeled and did contribute to the ASQ.
O&C Filter - Used the following evaluation to determine how the each ACEC was modeled.
a) All ACECs that were Research Natural Areas (RNAs) had no harvest modeled and were not
included in the ASQ.
b) For each of the action alternatives, the districts reviewed the existing and proposed ACECs and
designated them as:
• Whole ACEC does not conflict with the timber management objectives (On PD lands
or on non commercial forest lands). These areas had no harvest modeled and were not
included in the ASQ.
Appendices - 688
Appendix R - Vegetation Modeling
• A portion of the ACEC is in conflict with timber management but the portion of the
ACEC outside of the O&C lands would remain as a valid ACEC. These portions of the
ACECs that were not on O&C or CBWR lands had no harvest modeled and were not
included in the ASQ.
• The entire ACEC conflicts with timber management objectives and is not carried
forward under the alternative. These areas had harvest modeled and did contribute
to the ASQ.
8) Marbled Murrelet Sites
Existing occupied marbled murrelet sites.
• No Action Alternative, Alternative 1, and PRMP, these areas had no harvest modeled and
were not included in the ASQ.
• In Alternative 2, they became part of the Late-Successional Management Area which had
thinning harvest modeled but this volume does not contribute to the ASQ.
• Alternative 3 had no harvest modeled until the landscape targets were met. In the
modeling, one decade after the landscape target was met, these areas became available for
harvest and they contributed to the ASQ. See the Assessment Area description for further
information on the landscape targets and release dates.
The No Action Alternative Occupied Marbled Murrelet Site (OMMS) data was used to simulate the
existing sites.
Projected future marbled murrelet sites.
The Draft EIS alternatives had a management action to limit harvest around marbled murrelet sites
as they are identified. To simulate this in the modeling, the stands that are 120 years and older that
are within four townships from the coast were used as a surrogate.
The No Action Alternative and Alternative 1, for Coos Bay only, had no harvest modeled and were
not included in the ASQ. The LSR / LSMA in Salem and Eugene encompassed the majority of the
area within 4 townships of the coast so no simulation was needed.
Alternative 2 had no projection for future sites.
Alternative 3 had no harvest modeled until the landscape targets were met. In the modeling,
one decade after the landscape target was met, these areas became available for harvest and they
contributed to the ASQ. See the Assessment Area description for further information on the
landscape targets and release dates.
For the PRMP, marbled murrelet survey station data was used to determine the probability of
finding a murrelet site when a survey occurred in stands that were likely habitat. A combination of
District, Resource Area, and distance from the coast were used to subdivide the Marbled Murrelet
Range into zones to develop these probabilities based on district Biologist professional judgment.
Age breaks for each zone (generally 1 10 years) were used as a threshold for likely marbled murrelet
habitat. The land outside of the large block Late Successional Management Areas within each zone
and above the age threshold were identified as the population of potential sites. A random selection
of stands from this population was done based on the probability for that zone. The center point
of these stand was used to place a Vi mile buffer to select all stands meeting the likely habitat age
criteria plus all stand within 30 years of that age threshold (for recruitment within 25 years). Tire
selected stands within the half mile radius were used to simulate the future sites for the Marbled
Murrelet in the OPTIONS modeling. These areas were modeled as no harvest.
9) Northern Spotted Owl
lire No Action Alternative had 100 acres known owl activity centers identified which had no harvest
modeled and were not included in the ASQ.
Appendices - 689
FEISfor the Revision of the Western Oregon RMPs
The No Action Alternative had Reserve Pair Areas identified in the Salem District.
• The suitable and next best reserved areas had no harvest modeled and were not included
in the ASQ.
• The dispersal, next best, and non-habitat received thinning only with no regeneration
harvest. These lands had thinning harvest modeled but this volume did not contribute to
the ASQ.
Alternatives 1, 2, and the PRMP have no provisions for site management in the modeling.
Alternative 3 had 250-acre activity centers identified which had no harvest modeled until the
landscape targets were met. In the modeling, one decade after the landscape target was met, these
areas became available for harvest and they contributed to the ASQ. See the Assessment Area
description for further information on the landscape targets and release dates.
10) Special Status Species
For the No Action Alternative, survey and manage species sites had no harvest modeled and were
not included in the ASQ. Although the survey and manage mitigation was subsequently removed
from the No Action Alternative, the modeling had already been completed.
In Alternative 1, 2, and 3 special status species which were on Public Domain or Acquired lands
had no harvest modeled and were not included in the ASQ.
For the PRMP, all existing identified sites on all BLM lands were modeled as no harvest and were
not included in the ASQ.
11) Species Management Areas
In all alternatives, species management areas were identified for bald eagle and golden eagles sites.
These areas had no harvest modeled and were not included in the ASQ.
12) Riparian
GIS Modeling
The riparian reserves / riparian management areas vary across the alternatives based upon the
management action outlined in Chapter 2. The GIS modeling was employed to estimate the extent
of riparian areas so that management action could be simulated in the OPTIONS modeling.
The GIS modeling, depending on the alternative, had many factors to consider in estimating the
riparian area; presence/absence of fish, potential tree height adjusted specifically for each area,
perennial versus intermittent streams, wetlands, lakes, ponds, and the potential to deliver large
wood to streams. (See Table R-12) The description below is general in nature. The GIS metadata
contains the technical details of the GIS riparian modeling.
No Action Alternative, Alternative 1, and PRMP. The GIS modeling varied the application of the
site potential tree height based on district computed values usually by fifth-field watershed. To
determine the GIS buffering widths, the potential tree heights were adjusted for the average stream
side adjacent slope as determined by GIS analysis for each 5th field watershed. Attributes from
the hydrography data were used to determine the presence and absence of fish, if a stream was
intermittent or perennial, and the identification of ponds, wetlands and lakes. The GIS data for the
OPTIONS modeling identified those areas in the riparian reserves as a Y/N classification.
Alternative 2. Three riparian management area zones were identified with GIS buffering of the
hydrography data. All fish-bearing streams 0-25 feet (buf25). All non-fish-bearing intermittent
0-25 feet (shrub). Perennial and fish-bearing 25-100 feet (buflOO). The GIS modeling was done to
identify the areas likely to deliver large wood to streams which were identified in addition to the
GIS buffering of the hydrography data (WDFLOW).
Appendices - 690
Appendix R - Vegetation Modeling
Alternative 3. Four riparian management areas zones were identified with GIS buffering of the
hydrography data. 0-25 feet on all streams. Within the Coquille Tribal Management Area for all
perennial streams and all intermittent streams with fish 25-50 feet. Within the Coquille Tribal
Management Area for all fish bearing streams 50-100 feet. Outside the Coquille Tribal Management
Area for all perennial streams and all intermittent streams with fish 25-100 feet.
Alternative 2 and 3 riparian GIS analysis identified open water that was not recognized in the No
Action Alternative and Alternative 1 data. The open water was added to the other classes of non
forest and not included in the modeled riparian area in Alternatives 2 and 3.
OPTIONS Modeling Rules
In the OPTIONS modeling, any harvest coming from the riparian areas does not contribute to
the ASQ since the management action / modeling rules preclude continuous management. The
shrub riparian area in Alternative 2 does contribute to the ASQ, because these harvest practices
can continue over time. Harvest levels are determined for these lands along for the duration which
harvest can occur given the modeling rules.
Operability limitations were modeled by limiting thinning activities within each riparian polygon
to a maximum of 50% of the polygon area. Additionally, riparian stand that were commercially
thinned were then deferred from subsequent thinning treatments for 60 years. This deferral was
applied to the entire polygon.
Table R-ii. Riparian Modeling Rules By Alternative
Alternative
GIS Data
Riparian Modeling Rules
No Action
Y-Yes inside riparian
reserve
• No regeneration harvest
• Commercial thinning modeled up to age 80. In Salem
Adaptive Management Areas up to age 110
• 50% operability by polygon
Alternative 1 &
PRMP
Y-Yes, inside riparian
Management area
• No regeneration harvest
• Commercial thinning modeled up to age 80.
• 50% operability by polygon and 0-60’ no harvest (PRMP)
Alternative 2
0 to 25 feet
• No harvesting activities modeled
25 to 1 00 feet
• No harvest in stands 80 years and older.
• No regeneration harvest modeled
• Commercial thinning modeled up to age 80
• 50% operability by polygon
Shrub
• Regeneration harvest modeled with 10-15 conifer green
tree retention. (Contributes to ASQ.)
Wood Debris Flow Area
• No harvest activities modeled.
Alternative 3
0 to 25 feet
• No harvesting activities modeled
25 to 100 feet
• No harvest in stands 80 years and older
• No regeneration harvest modeled
• Commercial thinning modeled to age 80
• 50% operability by polygon
Coquille Management Area
25 to 50 feet
• No harvest in stands 80 years and older.
• No regeneration harvest modeled.
• Commercial thinning modeled to age 80
• 50% operability by polygon
Coquille Management Area
50 to 1 00 feet
• No regeneration harvest modeled
• 50% operability by polygon
Appendices - 691
FEISfor the Revision of the Western Oregon RMPs
13) Congressionally Reserved
Congressionally reserved areas had no harvest modeled and were not included in the ASQ for any
alternative. The Land Use Allocation GIS layer and Wild and Scenic Rivers GIS layer were used to
define these areas.
14) Late-Successional Reserves (LSR)
The Late-Successional Reserves had only thinning harvests modeled in those stands less than 80
years of age for the No Action Alternative. This volume estimate is not included in the ASQ since
the harvest would diminish over time as the stands eligible for thinning matured. The OPTIONS
modeling projected the duration and volume levels for this harvest as it stepped down over time.
The Land Use Allocation GIS theme was used to define this allocation. The other Northwest
Forest Plan LSR components, Occupied Marbled Murrelet Sites and Know Owl Activity Centers,
were modeled independently of the large block reserves. Also see the Adaptive Management Area
Reserve section.
15) Late-Successional Management Areas (LSMA)
Late-Successional Management Areas were defined for Alternatives 1 , 2, and the PRMP.
Alternative 1 LSMAs were based on the No Action Alternative Late-Successional Reserves.
Commercial thinning treatments within LSMA were consistent with the No Action LSR thinning
treatments. Thinning was modeled in stands less than 80 years of age.
Alternative 2 LSMAs were developed by BLM utilizing rules for size and spacing of large blocks
which was based on current science for the Northern Spotted Owl and discussions from the draff
Northern Spotted Owl recovery team. The initial GIS mapping of these large blocks was revised
in the OPTIONS data preparation program to designate whole BLM parcels/sections based on a
majority rule. In addition the existing Occupied Marbled Murrelet Sites were added to the LSMA.
Commercial thinning treatments within LSMA were consistent with the No Action LSR thinning
treatments. Thinning was modeled in stands less than 80 years of age.
For the PRMP, the Late-Successional Management Areas were developed from three components.
Northern Spotted Owl Managed Owl Conservation Areas from the proposed recovery plan
• Currently Occupied Marbled Murrelet Sites ( Occupied Marbled Murrelet Site - OMMS
GIS Data)
• A subset of existing Marbled Murrelet Critical Habitat.
— A MAMU zone that is 35 miles from the coast and extends inland 50 miles in
Medford.
— All stands 80 years and older (as currently mapped) within MAMU zone are part of
the LSMA.
Note: All stands less than 80 years old (as currently mapped) in the MAMU zone are in the Timber
Management Area and not include in the LSMA.
No harvest was simulated for the LSMAs associated with the occupied Marbled Murrelet Sites.
Since the other components of the LSMA were related to critical habitat designations it was
intended to have no thinning of stands 70 years and older. Although the model did not enforce this
cap, this was inconsequential because it resulted in a minor increase in the overall thinning.
Harvest projections for the LSMAs are not included in the ASQ estimates. With the absence of
regeneration harvest, timber production from commercial thinning would diminish over time as
the stands mature and become ineligible for thinning.
16) Adaptive Management Area and Late Successional Reserves
Appendices - 692
Appendix R - Vegetation Modeling
Under the No Action Alternative, there are Adaptive Management Area designations that overlap
the Late-Successional Reserves in the Salem and Medford Districts. The Medford area was modeled
the same as the Late-Successional Reserves, with thinning harvests limited to those stands less
than 80 years of age. For the Salem area, the thinning harvest was modeled up to age 110. Harvest
projections for the areas are not included in the ASQ estimates. With the absence of regeneration
harvest, timber production from commercial thinning would diminish over time as the stands
mature and become ineligible for thinning. The OPTIONS modeling projected the duration and
volume levels for this harvest as it stepped down over time. The Land Use Allocation GIS theme
was used to define this allocation.
17) Adaptive Management Areas (AM As)
Adaptive Management Areas applied to the No Action Alternative. These are the portions of the
AMA that exist outside Late-Successional Reserves.
The AMAs in the Eugene and Roseburg Districts were modeled the same as General Forest
Management Areas (GFMA).
The Medford AMA was modeled the same as Southern General Forest Management Areas (S_
GFMA).
The modeled harvest from these areas was included in the ASQ.
The Salem AMA was modeled under thinning only, up through age 110, with no regeneration
harvest. Since this harvest level would diminish over time the modeled volume was not included in
the Allowable Sale Quantity.
Modeling reductions to the harvest land base for administratively withdrawn and riparian reserves
within the AMAs was the same as within the surrounding matrix lands. The Land Use Allocation
GIS layer was used to define this allocation.
18) Connectivity Diversity Blocks
The connectivity diversity block allocations applied only to the No Action alternative. OPTIONS
modeling rules were established so regeneration harvest would not occur until at least 25% of the
forest area in the blocks was in stands 80 years or older. For each block a maximum of 1/1 SO1*1
of the forested area could be at age zero (regenerated) to simulate the area control requirement.
The modeling blocks were based on all of the connectivity diversity lands within a township and
Sustained Yield Unit. The Land Use Allocation GIS layer was used to define this allocation on a
gross basis. The net acreage modeled for harvest is the area remains after all other reductions to the
harvest land base have been made. The modeled harvest from these areas was included in the ASQ.
19) General Forest Management Areas (GFMA)
Tire GFMA allocation applied only to the No Action Alternative. The Southern GFMA in the Medford
District and the Klamath Falls SYU has older minimum harvest ages and higher green tree retention
than the GFMA allocations in the other SYUs. The Land Use Allocation GIS layer was used to define
this allocation on a gross basis. The net acreage modeled for harvest is the area remains after all other
reductions to the harvest land base. The modeled harvest from these areas was included in the ASQ.
20) Timber Management Area (TMA)
The TMA allocation applied to Alternatives 1, 2 and the PRMP On a gross basis, these are the lands
outside of the Late-Successional Management Area, Riparian Management Area, Congressionally
Reserved, and the Cascade-Siskiyou National Monument. The net acreage modeled for harvest is
the area which remains after all other reductions to the harvest land base. The modeled harvest
from these areas was included in the ASQ.
Appendices - 693
FEISfor the Revision of the Western Oregon RMPs
21) General Landscape Area (GLA)
The GLA allocation applied to Alternative 3. On a gross basis these are the lands outside of the
Riparian Management Area, Congressionally Reserved, and the Monument. The net acreage
modeled for harvest is the area which remains after all other reductions to the harvest land. The
modeled harvest from these areas was included in the ASQ.
22) District Defined Reserves
Under the No Action Alternative, there are district-defined reserves that were established in the
1995 RMR These lands are defined in the Land Use Allocation GIS layer. No harvest was modeled
for these areas and they were not included in the ASQ.
23) Miscellaneous District No Harvest Areas
Under all alternatives, individual OI units were earmarked by the districts to be excluded from the
harvest land base for modeling. These included communications sites, seed orchards, and some
omissions in the TPCC data for Klamath Falls. No harvest was modeled for these areas and they
were not included in the ASQ.
24) Wilderness Characteristics
Under the action alternatives, wilderness characteristics areas were identified in GIS. Only those
lands which fell on Public Domain were considered in the modeling. For those areas no harvest
was modeled and they were not included in the ASQ.
25) Medford Granitic Soils
For the No Action Alternative, the areas identified in GIS for the Medford District as granitic soils
in the Northern General Forest management Areas were modeled under the southern General
Forest Management Areas prescriptions.
26) Medford Frost Areas
For the No Action Alternative, the areas identified in GIS for the Medford district as frost areas
called for developing unique prescriptions to establish shelterwood prescriptions to retain trees for
30 years. The area was 8,000 acres in size. Due to the small size and complexity of modeling this no
specific modeling was done for this area. For the PRMP, a shelterwood prescription was applied to
the Medford frost areas.
27) Medford Deferred Watersheds
The Medford District 1995 RMP identified a set of monitoring watersheds which were deferred
from harvest for one decade.
• In the No Action Alternative, these areas had no harvest modeled for 1 decade. After that,
these areas would have harvest modeled according to the underlying land use allocation
and contribute to the ASQ. One watershed was included that was not intended to be
deferred and another was omitted. Overall, the modeling was 500 acres short on modeling
this deferral.
• In Alternative 1, these watersheds were modeled as completely deferred with no harvest
activities simulated. These lands did not contribute to the ASQ. The GIS data was
corrected from the No Action dataset.
28) 15% Standard and Guideline (15% S&G)
The 15% S&G was modeled in the No Action Alternative. The OPTIONS model did not conduct
any regeneration harvest until 15% of the forest area with in each fifth field (with in the SYU) was
Appendix R - Vegetation Modeling
in stands 80 years or older. This constraint was enforced annually, prohibiting watersheds from
going below the threshold. Thinning treatments were modeled irrespective of the 15% S&G status.
Harvest in these areas does or does not contribute to the ASQ depending on the underlying land use
allocation.
29) Swiss Needle Cast Area
The Salem District identified where the current extent of the Swiss needle cast infection exists. The
OPTIONS model used a unique set of species groups to reflect the reduced yields of existing stands
or the future growth and yields of disease resistant species mixes in the existing infection area.
30) Alt 3 Assessment Areas - Landscape Targets
A review of the age which the OPTIONS projection achieved Northern Spotted Owl habitat
(category 4) was conducted for each province / SYU. From this review, 90 year or 140 year
thresholds were established for each province / SYU for use as the landscape targets. (See Table
R-13) Assessment areas were established based on the combination of province / SYU which were
outside of the Uneven-aged Management Area in Medford and Klamath Falls and the Coquille
Tribal management area. In OPTIONS, regeneration harvest was not modeled until 50% of
the forest area in each assessment area was above the landscape target age. Partial harvest and
commercial thinning were modeled for the entire projection period independent of the landscape
targets and assessment areas. Marbled Murrelet Sites and Northern Spotted owl sites were modeled
as no harvest until one decade after the landscape targets were met. At that time those lands were
available for harvest.
Table R-13. Landscape Areas, Habitat Threshold Ages, and Assessment Area Names (Alternative 3)
Appendices - 695
FEISfor the Revision of the Western Oregon RMPs
31) Coquille Tribal Management Area
The Coquille Tribal Management Area was modeled in Alternatives 2 and 3. No northern spotted
owl site harvest constraints were applied in this area under both alternatives. Under Alternative 3,
the landscape targets were not applied which limited regeneration harvest. See Riparian section for
Alternative 3 modeling for the riparian area. The TMA/ GLA lands were modeled under the No
Action GFMA prescription.
32) PRMP Deferred Timber Management Area
The Northern Spotted Owl Recovery Plan Recovery Action 32 - “ Maintain substantially all of
the older and more structurally complex multi-layered conifer forests on Federal lands outside of
MOCAs.” BLM stalf met with the Interagency Support Team supporting the recovery team
to gain an understanding of how this could be defined. The BLM staff and the Interagency
Support Team agreed that the structurally complex forest classification approximates the types
of conditions they were describing. The BLM does not have an in place stand level classification
of structurally complex forest. A comparison was done with the BLM stand age data with the
modeled structurally complex classification. Stands with ages of 160 years and older reasonably
approximates the stands mapped currently as structurally complex (80% of structurally complex
stands are 160 years and older; 85% of the stands 160 years and older are structurally complex)
Stands currently mapped as 160 years and older were mapped as the Deferred Timber Management
Area land use allocation. These lands were deferred from harvest for 15 years in the modeling.
Recovery action 32 states - “ Land managers have made significant investments of time and resources
in planning projects that may have been developed prior to the approval of this Recovery Plan, thus
some forests meeting the described conditions might be harvested”. The planned timber sale areas for
the 2009 and 2010 were not included in the Deferred Timber Management Area allocation. The
modeling occurred before this adjustment was made so these lands were simulated as a 15 year
deferral in determining the harvest levels.
GIS Data - Modeling Harvest and Contribution to ASQ
Table R-14 provides a summary of how each category of GIS data was modeled and which
categories contribute to the Allowable Sale Quantity
Appendices - 696
Appendix R - Vegetation Modeling
Table R-14. GIS Modeling Data Layers
Alternative
Alternative
Alternative
PRMP
GIS Modeling Data Layers
No Action
1
2
3
Roads
X
X
X
X
X
TPCC Non Forest
X
X
X
X
X
TPCC Non Suitable Woodlands
N
N
N
N
N
TPCC Suitable Woodlands - Low Site and Non
Commercial Species
N
N
N
N
N
TPCC Suitable Woodlands - Reforestation
N
Y
Y
Y
Y
Recreation Sites Existing
N
N
N
N
N
Recreation Sites Proposed
Y
N
N
N
N
Wild and Scenic Rivers - Existing
N
N
N
N
N
Wild and Scenic Rivers - Eligible
Y
N
N
N
N
Visual Resource Management Class 1
N
N/A
N On PD Only
N/A
N On PD Only
Visual Resource Management Class 2
N/A
N/A
P On PD Only
N/A
P On PD Only
N - If
N - If
N - If
Areas Of Critical Environmental Concern - Existing
N
Passes O&C
N -If Passes
Passes O&C
Passes O&C
Filter
O&C Filter
Filter
Filter
N - If
N - If
N - If
N - If
Areas Of Critical Environmental Concern
Y
Passes O&C
Passes O&C
Passes O&C
Passes O&C
- Proposed
Filter
Filter
Filter
Filter
Occupied Marbled Murrelet Sites
N
N
N
D
N
Simulation Future Marbled Murrelet Sites
N
N
N
D
N
N - 100
D - 250
N/A
Known Owl Activity Centers
Acres
Y
Y
Acres
Reserve Pair Areas (Salem)
N
N/A
N/A
N/A
N/A
Survey and Manage Species
N
N/A
N/A
N/A
N/A
N
N-For
N-For
N-For
Special Status Species
N/A
Those On
PD Lands
Those On
PD Lands
Those On
PD Lands
N
Species ManagementAreas
N
N
N
N
N
Riparian Reserves
P
N/A
N/A
N/A
N/A
Riparian ManagementAreas
N/A
P
P
P
P
LUA- Congressional^ Reserved
N
N
N
N
N
LUA- Late-Successional Reserves
P
N/A
N/A
N/A
N/A
LUA - Late-Successional ManagementAreas
N/A
P
P
N/A
P
LUA -Adaptive ManagementAreas
Y/P
N/A
N/A
N/A
N/A
LUA - Adaptive Management Areas/Reserves
P
N/A
N/A
N/A
N/A
LUA - Connectivity Diversity Blocks
Y
N/A
N/A
N/A
N/A
LUA- General Forest ManagementAreas
Y
N/A
N/A
N/A
N/A
LUA- Southern General Forest ManagementAreas
Y
N/A
N/A
N/A
N/A
LUA- Timber Management Area
N/A
Y
Y
N/A
Y
LUA - Gen Landscape Area
N/A
N/A
N/A
Y
N/A
LUA - District Defined Reserves
N
N/A
N/A
N/A
N/A
Misc. District No Harvest Areas
N
N
N
N
N
Wilderness Characteristics on PD Lands
Y
N
N
N
N
Medford Deferred Watersheds
D
N
N/A
N/A
N/A
15% Standard & Guide
D
N/A
N/A
N/A
N/A
Deferred Timber Management Area (15 Years)
N/A
N/A
N/A
N/A
D
Y = Harvest is modeled and contributes to ASQ
P = Harvest is modeled but does not contribute to ASQ since the harvest can not be sustained continuously over time.
N = No harvest is modeled.
D = Harvest is deferred for 1 or more decades and contributes to ASQ.
X = Non Forest
N/A= Does not apply to the alternative
Appendices - 697
FEISfor the Revision of the Western Oregon RMPs
Reference Analysis Modeling Rules
1 ) Maximum Harvest
The Alternative 2 data was used for this analysis. All lands were made available for harvest with
the exception of TPCC Non Suitable Woodlands, TPCC Suitable Woodland (low site and non
commercial species), Wild and Scenic Rivers, existing recreation sites. 25’ buffer on streams
(buf_25), Congressionally Reserved lands, and the National Monument. CMAI was used in setting
the minimum harvest ages similar to Alternative 2.
2) No Harvest
No harvest was simulated.
Green Tree Retention
No Action Alternative
Green Tree Retention (GTR) was modeled as a stand level constraint in the No Action Alternative. Within each
polygon, a retention level was applied at the time of harvest. Retention levels varied by land use allocation as
presented in Table R-15.
Table R-15. Green Tree Retention Percent By Land Use Allocation For
The No Action Analysis
Land Use Allocation
Green Tree Retention
Percent
General Forest Management Area (GFMA), North
GFMA, Adaptive Management Areas, No Designation
11%
South General Forest Management Area (including
Granitic Soils Areas)
24%
Connectivity Diversity Blocks, District Defined Reserves,
Congressionally Reserved, National Monument
18%
Late-Successional Reserves, Adaptive Management
Area Reserves
Not Applicable
Eastside Management Lands
Not Applicable
Appendices - 698
Appendix R - Vegetation Modeling
The retained portions of the polygons were modeled as contiguous areas and reserved until a subsequent
rotation when the areas were made available for harvest and GTR retention was applied. Thus, in each
subsequent harvest a smaller portion of the original retention area was reserved while younger GTR areas
were also retained.
Figure R-20 provides a graphic example of modeling 11% green tree retention. In the model the retention
areas is not spatially defined with in the polygon but is tracked as a proportion of the area.
Figure R-20. Green Tree Retention Accounting Within The OPTIONS
Model
Polygon prior to first harvest. Stand age 100 years. Area 20 acres.
Polygon after first harvest. Retention stand age 101, area 2.2 acres;
regeneration age 1, area 17.8 acres.
Polygon prior to second harvest. Retention stand age 181, area 2.2 acres;
regeneration age 81, area 17.8 acres.
Polygon after second harvest. Oldest retention stand age 181, area 0.24 acres;
younger retention stand age 81, area 1.96 acres; regeneration age 1, area 17.8 acres.
—
Appendices - 699
FEISfor the Revision of the Western Oregon RMPs
Alternative 1 and PRMP
No green tree retention was applied.
Alternative 2
Management action for two trees per acre green tree retention was not simulated in the modeling since the
volume reduction would be minor. Green tree retention for the Coquille Management Area was modeled the
same as the No Action alternative General Forest Management Area.
Modeling of the tree retention levels for future snags and coarse woody debris in the Late-Successional
Management Areas varied individual SYUs and physiographic provinces. This retention was modeled as a
stand level constraint by reserving a percentage of each stand being thinned. (See Table R-16 below)
Table R-16. Late-Successional Management Areas Tree Retention Percent By
Sustained Yield Unit / Retention Zone
Retention Zone
Lakeview
Salem
Eugene
Roseburg
Medford
Coos Bay
Western Hemlock
0%
7%
8%
14%
0%
8%
Douglas-fir
9%
0%
0%
8%
12%
0%
Tan Oak
9%
0%
0%
0%
13%
5%
Alternative 3
Assessment areas were established based on the combination of province / SYU which were outside of
the Uneven-aged management area in Medford and Klamath Falls and the Coquille Tribal management
area. Age thresholds (90 yr or 140 yr) were established as landscape target for each assessment area. (See
GIS Based Modeling Rules - Assessment Areas) Regeneration harvests were not modeled until 50% of the
Assessment Area was in ages at or above the landscape target threshold.
After regeneration harvests, green tree retention was modeled in a similar manner as in the No Action and
Alternative 2. However, retention levels for Alternative 3 were based on species group. (See Table R-17 below)
Table R-17. Regeneration Harvest Prcent Volume Tree Retention For Green
Tree, Snag, And Coarse Woody Debris Creation By Species Group
Species Group
Green Tree
Retention Percent
Green Tree + Future
Snag and CWD
Northern Hardwood Mixed
7%
15%
Northern Mixed Conifer
6%
14%
Northern Douglas-fir
6%
14%
Southern Douglas-fir
7%
10%
Southern Mixed Conifer
8%
12%
Sothern Conifer Hardwood
10%
13%
Southern Hardwood
9%
13%
Southern True Fir
8%
11%
Ponderosa Pine
15%
24%
Appendices - 700
Appendix R - Vegetation Modeling
In Alternative 3, intermediate harvests, termed partial harvests, were permitted prior meeting the older
forest targets. For intermediate harvests, green tree retention was modeled as a partial harvest, and stand
attributes of the retained stems were incorporated into the blended yield curves. The blended yield curves
reduced the retained and regenerated components of the harvest unit proportionally, similar to the stand
level constraint method described above, however, the retained portions of the polygons are not reported
independently. (See Tables R-18 and R- 19 below)
The Coquille Management Area was modeled the same as the No Action General Forest Management Area.
Table R-18. Stand Treatment Age And Retention Used To Blend Yield Curves
For Intermediate Harvests
Zone
1st Intermediate
Harvest
2nd Intermediate
Harvest
3rd Intermediate
Harvest
4th Regeneration
Harvest
Age
%
Age
%
Age
%
Age
%
Hemlock
120
35
240
35
0
0
360
n/a
Douglas fir
80
19
160
19
0
0
240
n/a
Tanoak
60
35
120
35
180
35
240
n/a
Table R-19. Partial Harvest Retention Plus Supplemental Retention For Snag
And Coarse Woody Debris Creation
Zone
1st
Intermediate Harvest
2nd Intermediate
Harvest
3rd Intermediate
Harvest
4th
Regeneration Harvest
Age
%
Age
%
Age
%
Age
%
Hemlock
120
42
240
42
0
0
360
*
Douglas fir
80
22
160
22
0
0
240
*
Tanoak
60
39
120
39
180
39
240
★
* GTR levels by Species Group
Scribner Volume
For OPTIONS modeling, Scribner volumes were generated as a part of the guide curve modeling with the
ORGANON Shell. The equations for these volumes are based 16-foot BLM volume rules.
Volume Adjustments
Guide Curve Adjustments to volume were made for Defect and Breakage (D&B), Green Tree Retention
(GTR), Snags, Coarse Woody Debris (CWD), Insect and Disease, and Soil Compaction.
With the exception of GTR, all adjustments to the Guide Curves were compiled outside the OPTIONS
model as percent basal area reductions. Estimates for D&B, Insect and Disease, and Soil Compaction were
supplied by the districts or based on values derived for the most recent RMR The guidelines for Snags and
Coarse Woody Debris (CWD) varied by alternative. These adjustments were made to the Guide Curves with
the OPTIONS data preparation program and applied within the OPTIONS modeling as volume reductions.
Adjustments were compiled and applied by ORGANON variant, Species Group, stand type (managed,
unmanaged, or future) and harvest type where appropriate. For Alternative 3, these adjustments were
further stratified by Vegetation Zone; Western Hemlock, Douglas-fir and Tanoak to account for differences in
Snag and Coarse Woody Debris requirements. (See Figure R-21)
Appendices - 701
FEISfor the Revision of the Western Oregon RMPs
Figure R-21. An Example Of Adjustments Utilized For A Single Alternative And District
Alternative 3 Yield Adjustments - Factors Varying by Management Status and Retention Zone
District:
Roseburg
GTR Green Tree Retention
Snag CieationfRetention Y.BA
Altemath
Alt 3
ZBA Adj For Regen Harvest
Adj for Partial h Regen
CVD XBA Adj for Partial &
ESC/Modeling Groin MG11&15= Unmanaged
Only
Harvest
Regen Haiuest
Land Use Allocation
GLA
Final
Final
Cruise
Adjustment
Adjustment
WH
DF
TO
WH
DF
TO
WH
OF
TO
Regen
Soil
Gross to
GTR
Sum of
Factor
Factor
Retention
Retention
Retention
Retention
Retention
Retention
Retention
Retention
Retention
Harvest
Compac-
Insect &
Net
Edge
Adjust-
Managed &
Unmanaged
Zone GTR
Zone GTR
Zone GTR
Zone Snag
Zone Snag
Zone Snag
Zone CVD
Zone CWD
Zone CWD
Aqe
tion
Disease
[D&Bl
Effect
ments
Future
[wto Soil l&D)
y.BA
y.BA
y.BA
y.BA
Y.BA
y.BA
y.BA
y.BA
y.BA
30
0.00
0.005
0.050
0.050
0.105
0.885
0.800
0
0
0
0
0
0
0
0
0
40
0.00
0.007
0.050
0.050
0.107
0.883
0.800
0
0
0
0
0
0
0
0
0
50
0.00
0.008
0.050
0.050
0.108
0.882
0.800
0
0
0
0
0
0
0
0
0
60
0.00
0.010
0.050
0.050
0.110
0.880
0.800
0
0
0
0
0
0
0
0
0
70
0.00
0.011
0.050
0.050
0.111
0.888
0.900
0
0
0
0
0
0
0
0
0
80
0.00
0.012
0.050
0.050
0.112
0.888
0.900
0
0
0
_|N o
0
0
0
0
0
90
0.00
0.014
0.050
0.050
0.114
0.886
0.900
0
0
0
* 0
0
0
0
0
0
100
0.00
0.015
0.060
0.050
0.125
0.875
0.880
0
0
0
0
0|
0
0
0
0
110
0.00
0.016
0.070
0.050
0.136
0.864
0.830
0
0
0
0
0
0
0
0
0
120
0.00
0.018
0.080
0.050
0.148
0.852
0.870
0
0
0
0
0
0
0
0
0
130
0.00
0.018
0.080
0.050
0.158
0.841
0.860
0
0
0
0
0
0
0
0
0
140
0.00
0.020
0.080
0.050
0.160
0.340
0.860
0
0
0
0
0
0
0
0
0
150
0.00
0.022
0.090
0.050
0.162
0.833
0.860
0
0
0
0
0
0
0
0
0
160
0.00
0.023
0.100
0.050
0.173
0.827
0.850
0
0
0
0
0
0
0
0
0
170
0.00
0.024
0.110
0.050
0.184
0.816
0.840
0
0
0
0
0
0
0
0
0
180
0.00
0.026
0.120
0.050
0.186
0.804
0.330
0
0
0
0
0
0
0
0
0
190
0.00
0.027
0.130
0.050
0.207
0.733
0.820
0
0
0
0
0
0
0
0
0
200
0.00
0.028
0.200
0.050
0.278
0.722
0.750
0
0
0
0
0
0
0
0
0
210
0.00
0.023
0.200
0.050
0.278
0.722
0.750
0
0
0
0
0
0
0
0
0
220
0.00
0.028
0.200
0.050
0.278
0.722
0.750
0
0
0
0
0
0
0
0
0
230
0.00
0.028
0.200
0.050
0.278
0.722
0.750
0
0
0
0
0
0
0
0
0
240*
0.00
0.028
0.200
0.050
0.278
0.722
0.750
0
0.083
0.074
0
0.012
0.018
0
0.028
0.035
360.
0.00
0.028
0.200
0.050
0.278
0.722
0.750
0.065
0.083
0.074
0.030
0.012
0.018
0.043
0.028
0.035
Exceptions to these were limited to the modeling of GTR for Regeneration harvests in the No Action
Alternative and Alternative 3 and the Partial harvests in Alternative 3. These reductions were taken at time
of harvest within the OPTIONS model in the form of reduced harvest unit acreage.
Minimum Harvest Age
The OPTIONS model uses a minimum harvest age to control the lower limit where regeneration harvest
could occur.
In the No Action Alternative, the minimum harvest ages were set by direction in the existing plans. For
all districts, except Medford, the minimum regeneration harvest age was set to 60 years. For the Medford
District, the minimums were 100 years in the North General Forest Management Areas and 120 years in the
South General Forest Management Areas.
For Alternatives 1, 2, and the PRMP, minimum harvest ages were based on Culmination of Mean Annual
Increment (CMAI) for regeneration harvests.
Culmination of Mean Annual Increment (CMAI) results can vary widely depending on the unit of
measurement used, the utilization standards and whether net or gross growth is considered. It has been
a commonly accepted forestry theorem that even- aged stands should be harvested at CMAI in order to
maximize biological yields.
Current Annual Increment (CAI) is defined as the annual increment of wood grown for a particular stand,
or in this case a group of inventory plots representing similar growing conditions. Mean Annual Increment
(MAI) for a particular stand or set of plots is the total increment of wood at a given stand age divided by
that stand age. CMAI is the point when the CAI, sometimes termed Periodic Annual Increment (PAI) and
the MAI are equal. Culmination occurs when the maximum MAI is reached. From the ORGANON Guide
Appendices - 702
Appendix R - Vegetation Modeling
Curve runs, Total Stem Cubic Volume (TSCV) was used for CMAI determination. This approximates a
biological decision rule for the point of harvest. For this evaluation, the CMAI threshold was assumed to be
the first age (5-year ORGANON modeling cycle) at which the difference between PAI and MAI was zero or
negative. The gross volume CMAI statistics generated from ORGANON were adjusted to approximate net
volume CMAI and allow the OPTIONS modeling greater flexibility in harvest scheduling.
In Alternatives 1 and 2, the OPTIONS minimum harvest age was set at the 90% level of CMAI to give the
model a reasonable level to vary from the estimated values. (See Table R-20)
For Alternative 3, minimum both partial harvest and regeneration harvest minimum harvest ages were
established in the management action. (See Table R-21 )
Table R-20. Forest Maturity Criteria: Proposed Minimum Harvest Ages At
90% CMAI By Species Group And Site (Productivity) Class
Species
Group
Productivity Classes
SP5
(yrs)
SP4
(yrs)
SP3
(yrs)
SP2
(yrs)
SP1
(yrs)
NCM
110
105
95
95
85
NDF
110
95
85
85
75
NHM
95
95
85
80
80
SCH
155
120
110
110
110
SDF
140
120
110
105
100
SHW
155
120
110
110
110
SMC
155
120
110
110
110
STF
145
140
120
120
120
PP
140
115
115
115
115
SSCH
155
120
110
110
110
SSDF
140
120
110
105
100
SSHW
155
120
110
110
110
SSMC
155
120
110
110
110
SSTF
145
140
120
120
120
SPP
140
115
115
115
115
CNCM
130
110
95
90
85
CNDF
130
110
95
90
85
CNHM
130
110
95
90
85
Table R-21. Minimum Stand Treatment Ages For Partial And Regeneration
Harvests (Alternative 3)
1st Partial
2nd Partial
3rd Partial
Regeneration
Harvest
Harvest
Harvest
Harvest
Zone
Stand Age
Stand Age
Stand Age
Stand Age
(yrs)
(yr§)
(yrs)
(yrs)
Hemlock
120
240
0
360
Douqlas fir
80
160
0
240
Tanoak
60
120
180
240
Appendices - 703
FEISfor the Revision of the Western Oregon RMPs
Modeling Thinnings
Commercial thinning modeling criteria were derived from two sources.
1. Simulation rules for management action for an alternative.
Example - Modeling “caps’ were used to limit commercial thinning in Late- Successional Reserves to
stands less than 80 years to simulate the plan requirement to only apply treatments that would promote the
development of late-successional forest.
2. Growth and yield teams results for the ORGANON modeling of existing and future stands.
ORGANON modeling determined the timing, extent and number of treatments which were specific to
modeling groups. The lower and upper treatment ages, treatment intensity and the number of treatments
along with modeling criteria, targets and guidelines are documented under the Forest Growth and Yield
Modeling section.
The Treatment Response approach allowed the OPTIONS model to adjust for the total growth in the
thinned stand by modifying the growth rate (slope) of the Guide Curve for the untreated stand. The growth
rate was adjusted such that the ORGANON modeled growth response of the treated stand, i.e. the increase
in volume growth at the end of the treatment response period, was approximated within the OPTIONS
modeling for that particular stand type and a specific thinning treatment. For use in the OPTIONS model,
the commercial thinning treatment results, for each modeled combination of Species Group(s), Productivity
Class(es) and thinning entry number (1st, 2nd, 3rd...) were subsequently analyzed to determine a “Treatment
Response”. Treatment Response Period was defined as 30 years or the number of years between modeled
thinning entries, whichever was less.
Within the OPTIONS model, the thinning availability window was set in all alternatives to 5 years prior
and 15 years after the ORGANON modeled treatment age for a specific stand type. If, within the OPTIONS
model, a particular vegetation polygon was not thinned during a treatment window, the opportunity for
the model to apply that specific commercial thinning treatment was foregone. If that particular stand was
modeled for subsequent thinning treatments at older ages, it became available for treatment evaluation like
any other stand regardless of whether the previous treatment was applied.
Before the OPTIONS model could apply a commercial thinning treatment to a particular stand, the current
stand attributes were reviewed to ensure that the prescribed removal would meet the minimum per acre
harvest targets. The minimum targets were - Salem Roseburg, Coos Bay - 8,000 board feet per acre, Eugene
- 6,000 board feet per acre, Medford 4,000 board feet per acre, and Klamath Falls 2,000 board feet per
acre. If the residual stand criteria could not be met, the stand would be left to grow and be re-evaluated in
subsequent years as long as it remained within the treatment window or until the treatment was applied.
Since all the existing stands were assigned an imputed stand attributes, not the average guide curve values,
some lower-stocked stands which could not meet the minimum post-harvest criteria could be left to grow.
Depending on the stand, the priority for commercial thinning in a particular alternative and the harvest
related criteria described above, stands might or might not receive treatment.
Shelterwood Modeling
Shelterwood treatment areas were identified and mapped for the Medford District in areas with frost
problems or granitic soils. Within these areas, all stands classified as Ponderosa pine Species Group were
excluded from modeling under the Shelterwood Management Regime and modeled along with like stands
according to the rules of the underlying general LUA.
Shelterwood regeneration harvest levels used in OPTIONS modeling were computed using the basal area
difference between the existing stand pre- and the post-shelterwood treatment basal area levels. It was
Appendices - 704
Appendix R - Vegetation Modeling
assumed that the ORGANON cycle 3 (15-year) residual stand basal area statistics approximated that of the
post-shelterwood treatment stand.
Shelterwood treatments were modeled to occur approximately 30 years prior to 90% CMAI for Productivity
Class 5 Species Groups and approximately 20 years for Productivity Classes 1- 4.
Shelterwood stands, for modeling purposes were stratified into separate age-based grouping: Young, Mature,
Old and Very Old stands. (See Table R-22 ) These are identified with Species Group prefixes of S, M, O and V
respectively (e.g. SSDF represents Young Southern Douglas-fir, MSDF for Mature, OSDF for Old and VSDF
for Very Old). The partition of stands into these various modeling groups was based on initial ten-year age
class and varies by Species Group - Site Productivity combinations.
Table R-22. Initial Age Criteria For Shelterwood
Shelterwood Species Group Age Criteria
ies Group
Site
Productivity
Class
Maximum Group Age by Shelterwood Modeling Species Groups
Young
Mature
Old
Very Old
PP
SP1
115
SSPP
200
MPP
285
OPP
370
VPP
PP
SP2
115
SSPP
200
MPP
285
OPP
370
VPP
PP
SP3
115
SSPP
200
MPP
285
OPP
370
VPP
PP
SP4
115
SSPP
200
MPP
285
OPP
370
VPP
PP
SP5
140
SSPP
220
MPP
300
OPP
380
VPP
SCH
SP1
110
SSCH
195
MSCH
285
OSCH
370
VSCH
SCH
SP2
110
SSCH
195
MSCH
285
OSCH
370
VSCH
SCH
SP3
110
SSCH
195
MSCH
285
OSCH
370
VSCH
SCH
SP4
120
SSCH
205
MSCH
285
OSCH
370
VSCH
SCH
SP5
155
SSCH
230
MSCH
305
OSCH
380
VSCH
SDF
SP1
100
SSDF
190
MSDF
280
OSDF
370
VSDF
SDF
SP2
105
SSDF
195
MSDF
280
OSDF
370
VSDF
SDF
SP3
110
SSDF
195
MSDF
285
OSDF
370
VSDF
SDF
SP4
120
SSDF
205
MSDF
285
OSDF
370
VSDF
SDF
SP5
140
SSDF
220
MSDF
300
OSDF
380
VSDF
SHW
SP1
110
SSHW
195
MSHW
285
OSHW
370
VSHW
SHW
SP2
110
SSHW
195
MSHW
285
OSHW
370
VSHW
SHW
SP3
110
SSHW
195
MSHW
285
OSHW
370
VSHW
SHW
SP4
120
SSHW
205
MSHW
285
OSHW
370
VSHW
SHW
SP5
155
SSHW
230
MSHW
305
OSHW
380
VSHW
SMC
SP1
110
SSMC
195
MSMC
285
OSMC
370
VSMC
SMC
SP2
110
SSMC
195
MSMC
285
OSMC
370
VSMC
SMC
SP3
110
SSMC
195
MSMC
285
OSMC
370
VSMC
SMC
SP4
120
SSMC
205
MSMC
285
OSMC
370
VSMC
SMC
SP5
155
SSMC
230
MSMC
305
OSMC
380
VSMC
STF
SP1
120
SSTF
205
MSTF
285
OSTF
370
VSTF
STF
SP2
120
SSTF
205
MSTF
285
OSTF
370
VSTF
STF
SP3
120
SSTF
205
MSTF
285
OSTF
370
VSTF
STF
SP4
140
SSTF
215
MSTF
295
OSTF
370
VSTF
STF
SP5
145
SSTF
225
MSTF
300
OSTF
380
VSTF
Appendices - 705
FEISfor the Revision of the Western Oregon RMPs
Uneven-Age Management Modeling
To facilitate OPTIONS modeling, stands in the Uneven Age Management Area were stratified into three
separate Management Regimes; Young, Old and Future. (See Table R-23 )
Uneven-age modeling was applied to the Uneven-Age Management Area land use allocation in the Medford
District and to most of Klamath Falls Resource Area of the Lakeview District.
The sequence of 5 treatments was similar in all three OPTIONS Management Regimes and across all
combinations of Species Group and Site Productivity classes. Harvest entries were modeled at 20, 30 or 50-
year intervals, depending on Species Group, productivity level and stand type. The initial entry, at whatever
age, might be best termed a Preparatory or Fuels Hazard Reduction treatment. The ORGANON modeling
for this harvest entry focuses on thinning from below, concentrating on removal of smaller diameter trees.
The second and third treatments are more traditional proportional commercial thinnings, removing trees
across the range of diameters. The fourth treatment entry was, with a few exceptions, a non-commercial
thinning entry for reducing the number of smaller, younger trees and potential fuel ladders. The fifth and
final entry in this modeling sequence is another thinning entry which the OPTIONS model identifies as a
Selection Harvest. After the Selection Harvest entry, both the Young and Old modeling groups shift to the
Future stand Management Regime and follow another similar treatment sequence for the remainder of the
modeling cycle.
Table R-23. Old Versus Young Age Class Thresholds By Site Productivity Level
Species
Old Versus Young Age Class Threshold by Site Productivity Level
Group
SP5
SP4
SP3
SP2
SP1
Age
Age
Age
Age
Age
SCH
200
130
130
130
n/a
SDF
200
200
200
130
130
SHW
200
130
130
n/a
n/a
SMC
200
130
130
130
130
STF
130
130
130
130
130
SPP
70
70
70
70
70
Harvest Priorities
Within the OPTIONS model the source of harvest volume could be prioritized by three categories of “Wood
Type” defined and held constant across all alternatives.
• Older Forest - Regeneration harvest stands 200 years and older.
• Second Growth - Regeneration harvest of stands less than 200 years.
• Thinning - All thinning, intermediate, or partial harvests.
Within the model, Wood Types are assigned priorities 1 through 3, with 1 being the highest and 3 the lowest
priority for harvest.
Within each Wood Type a lower and an upper harvest request limit can be designated.
An overall harvest volume is established in the Model as a maximum harvest level for any one year. The
model will then attempt to satisfy the first priority Wood Type lower harvest request. Then do the same
Appendices - 706
Appendix R - Vegetation Modeling
with the other two Wood Type priorities. After the lower harvest limits have been, to the extent possible,
implemented across all three Wood Types, the model goes through the Wood Types by priority to satisfy any
upper limit of harvest requests. If the upper harvest limit can not be satisfied in the first wood type priority
then it proceeds to the next wood type priority until it attains the over all harvest level requested.
These lower and upper limits for each wood type can be modified for specific time periods of the projection.
These harvest priority controls can be used to control the rate of harvest in a particular Wood Type as well as
balancing the levels of harvest across wood types.
Establishing Harvest Levels
The OPTIONS modeling projections occurred in increments of one year. Thus, all management objectives were
maintained, and requested harvest levels met, in each year of the planning horizon. The planning horizon for all
analyses was 100 years, although the final ASQ harvest level for each alternative was tested at 400 years to ensure
its long-term sustainability. The sustainability analyses were subject to the same criteria as the 100 year analyses.
Harvest volume projections were based on the lands available for harvest, under the assumptions of the
alternative within each sustained yield unit. Those lands which contribute to the ASQ can be managed over
an extended period of time to provide a sustainable non declining level of harvest. Harvest from reserves
(Late-Successional Reserves / Late Successional Management Areas and or Riparian Reserves / Riparian
Management Areas) would diminish as stands grow past the conditions suitable for thinning and would not
produce a sustainable harvest over time.
The sustainable harvest level from the land base supporting the ASQ was modeled separately from that
harvest which can be derived from the reserves. Segregating the landbase and modeling of harvest volume
in this manner isolated the interaction of these two types of allocations.
For ASQ lands, a non-declining even flow (NDEF) strategy was applied. Based on this approach a single
maximum harvest level was modeled for the entire planning horizon and tested within a defined level of
precision (increments of 1 million board feet, 0.1 for Klamath Falls). The exception to this approach was
in the modeling of Alternative 3 where a future increase in the ASQ harvest levels were determined after
landscape targets were achieved for an entire Sustained Yield Unit.
Generally, reserve lands permit limited management activities and thus have a limited period of availability.
The NDEF strategy was not an appropriate method of modeling these areas so an uneven flow strategy
was applied. Reserve lands only provided timber within the short-term (within the first 80 to 100 years,
depending on the alternative), so a stair- stepped method was used to characterize and report partial harvest
volume. With this approach a maximum harvest volume for each 10-year period was determined.
A combined ASQ and reserve land OPTIONS run was performed for the production of the Ten -Year
Scenario, Northern Spotted Owl Habitat Projections, Structural Stage Projections and other post processing
reporting. A maximum harvest level of the larger combined harvest landbase was not modeled. The total
harvest volume modeled was the simple sum of the ASQ and reserve harvest volumes, although the reserve
harvest volume amount was first reduced by 20% to approximate operational fall down. A maximum harvest
volume level of the larger combined harvest levels landbase was not modeled. The overall thinning harvest
level in terms of acres and volume matched the combined request but the proportions coming from inside
and outside reserves was not controlled in the combined run. This appeared in Alternative 3 where a very
small amount of riparian thinning (2 MMBF out of 473 MMBF total) was requested in the combined run
but none if occurred in the riparian areas.
Appendices - 707
FEISfor the Revision of the Western Oregon RMPs
The sustainable harvest level for the PRMP was initially determined to be 523 MMBF. When the stands
in the deferred timber management area became available for harvest, there was a high proportion of the
volume coming from regeneration harvest of these stands and the thinning levels elsewhere were lower. The
sustainable harvest level of 502 MMBF was established to maintain a balanced level of regeneration harvest
and thinning over time.
Figure 22 is an example of non-declining ASQ harvest volume, stair-stepped reserve harvest volume and
combined harvest volumes.
Figure R-22. Reserve, ASQ, And Total Volume
CD
>
CD
160000
140000
120000
100000
~ 80000
</)
<D
>
k_
X 60000
40000 -
20000
l
10
l
20
_ _ _ _
Combined
ASQ Volume
Reserve Volume
60
70
80
30 40 50
Year
, : ' 1 ’ ~
90
100
Appendices - 708
Appendix R - Vegetation Modeling
Creating Blended Yield Curves for Alternative 3
Alternative 3 included rules that excluded regeneration harvests until older forest retention target thresholds
were achieved. Additionally, within each landscape unit intermediate harvests with high levels of green tree
retention were permitted prior to achieve the landscape target levels of older forests. (See Table R-24)
In the other alternatives, yield curves were developed by the growth and yield team with the Organon
model. However, the high retention levels of the intermediate harvests in Alternative 3 presented a modeling
challenge for Organon. Investigation by the growth and yield specialists revealed that in the ORGANON
model, it would be difficult to develop an appropriate set of tree data to represent the multi-storied character
of the intermediate harvests. As an alternative, a simple mathematical approach was considered a suitable
technique for developing the blended guide curves for the multi-storied stand conditions resulting from
intermediate harvests. It was recognized that this approach did not account for the treatment, competition,
or edge effects of the intermediate harvest. The blending process was applied to the Organon stand summary
table for the OPTIONS analysis, and for the Organon detailed stand tables for use with the Northern
Spotted Owl habitat index and structural stage classification.
This mathematical approach involved combining (or blending) the yield curve of the untreated portion
of the stand with the yield curve of the treated portion of the stand. Tire blending technique apportioned
basal area, volume and density based on the retention level of the intermediate harvest. Stand height and
diameter were not blended. These attributes were based wholly on the yield curves for the treated portion of
the stand.
Table R-25 provides an example of the pairing between the untreated overstory yield curve and the treated
understory yield curve that resulted in a blended yield curve. The values represent the Current Vegetation
Survey name prefix. A curve naming convention was established to identify the resulting blended yield curve
based on the zone and treatment age. For example, the generation of the 1st intermediate harvest at age 120
for the Hemlock Zone would result in the blended curves shown in Table R-25.
For example, if the intermediate harvest retained 40% of the original stand, the blended curve would include
Table R-24. Stand Treatment Age And Percent Retention Used To Blend Yield
Curves For Intermediate Harvests
Zone
1st Intermediate
Harvest
2nd Intermediate
Harvest
3rd Intermediate
Harvest
4th Intermediate
Harvest
Age
%
Age
%
Age
%
Age
%
Hemlock
120
35
240
35
0
0
0
0
Douglas-fir
80
19
160
19
240
19
0
0
Tanoak
60
35
120
35
180
35
240
35
Table R-25. Initial, Regeneration, And Resulting Blended Yield Curves
Overstory Curve
Understory Curve
Blended Curve
MG1_1_NCM_NONE
NDF_NO_OS_1_PCT260
ALT3_H120_MG1_1_NDF
MG1_2_NCM_NONE
NDF_NO_OS_2_PCT260
ALT3 _H 1 20_M G 1 _2_N D F
MG1_3_NCM_NONE
N DF_N O_OS_3_PCT260
ALT3 _H 1 20_MG1 _3_NDF
MG1_4_NCM_NONE
NDF_NO_OS_4_PCT260
ALT3_H120_MG1_4_NDF
MG1_5_NCM_NONE
N D F_N O_OS_5_PCT260
ALT3_H 1 20_MG 1 _5_N D F
Appendices - 709
FEISfor the Revision of the Western Oregon RMPs
40% of the stems from the original and 60% of the regenerated stand curve. The curves assigned to existing
stands differed from curves assigned to recently regenerated areas to reflect current and/or future regenerations
standards. In the model, the treated stand retains the age of the overstory which represents the initial age of
the blended curve. Figure R-23 compares a stands initial yield curve, the regeneration yield curve, the blended
curve, and how a stand progresses from its initial curve to the blended curve. In the example shown in Figure
23, a stand receives an intermediate harvest at age 80. At the time of treatment, the stand supports a volume of
approximately 70,000 board feet/ acre. Immediately after treatment, the stand retains its age of 80, and has a
residual volume of approximately 15,000 board feet/acre, or approximately 22% of the original stand volume.
After treatment, the stand is assigned to the blended yield curve and grows at the blended rate.
Within the various landscape units, multiple intermediate harvests were permitted, and for each possible
intermediate harvest an additional blended yield curve was required. Blended curves were applied after
intermediate harvest treatments. Where the blended curve of the first intermediate harvest was created
from the initial curve combined with a regeneration curve, each successive treatment combined the
previously blended curve with a regeneration curve. Once the landscape targets were achieved, stands were
regeneration harvested and then assigned to an unblended regeneration curve. The blended curves extended
to a stand age of 400 years. In OPTIONS, stands older than this were assigned the attributes of the 400 year
old stand.
Figure R-23. A Comparison Of An Initial Yield Curve, The Regenerated
(Future) Yield Curve And The Blended Curve
Appendices - 710
Appendix R - Vegetation Modeling
Alternative 3 Blended Curve Procedures
Create a blended curve for a stand within the Douglas-fir Zone (DF) with an intermediate harvest at age 80
years. This is the first intermediate harvest age and the green tree retention level is 19%.
Stand Summary Blending
1. Initialize the new blended yield curve with the stand characteristic from the overstory yield
curve beginning at the blending age and continuing to the end of the projection horizon.
2. Incorporate the stand characteristics from the understory yield curve, matching the blended
stand age with the initial understory age. In this example, the overstory stand characteristics at
age 80 are matched with the stand characteristics of the understory at age 0.
3. Calculate the blended stand characteristics through the simple mathematical approach of
summing the retention percent of the overstory stand and the remaining percent of the
understory stand. In this example, 19% of the overstory stand is combined with 81% of
the understory stand. This approach is applied to basal area, trees per acre and volume.
Quadratic Mean Diameter (QMD) and height are re-set to the understory levels. Relative
density (RD) is recalculated based on blended values for QMD and basal area.
Stand Table Blending
1. Initialize the new blended stand table with the overstory stand table values for each species and
diameter beginning at the blended stand age and continuing to the end of the projection horizon.
2. Incorporate the stand table values from the understory stand table by species and diameter,
matching the blended stand age with the initial understory age. In the case where there is no
matching understory species and diameter, incorporate these additional stand table values into to
the blended stand table.
3. Calculate the blended stand table values through the simple mathematical approach of summing
the retention percent of the overstory stand with the remaining percent of the understory stand.
This approach is applied to basal area, live trees per acre, dead trees per acre and board foot volume
and cubic foot volume. Height is re-set to the understory value.
In the case where there are only overstory stand values, the retention percent of the overstory stand
values are used. In our example, 19% of the overstory stand values would be used.
OPTIONS Products
Introduction
The projection of forest conditions with OPTIONS is based on the model tracking the change over time for
five basic attributes:
• Density - trees per acre
• \blume - board feet per acre
• Diameter
• Basal Area
• Height
Appendices - 71 1
FEISfor the Revision of the Western Oregon RMPs
The growth and yield curves coming from the ORGANON modeling can also be used as a source for forest
attribute information since each OPTIONS polygon has a relationship with a growth curve.
Additional modeling was performed to create look up tables for the presence and absence of dead wood
which could be related back to the OPTIONS projections.
Considering each alternative has between 400,000-600,000 polygons, each with 5 attributes, projected in
annual increments for 200-400 years the potential data array from OPTIONS alone is considerable. Drawing
data relationships from ORGANON or other models to derive forest attributes related to the OPTIONS
projections increase that potential data to draw upon. Many of the outputs for the modeling required
custom programming to extract and formulate the products for the ID team analysis.
Although OPTIONS performs projections in annual increments, only key projection reporting periods (0,
10, 20, 30, 40, 50, and 100 years) were established for the ID team analysis.
The following products from the OPTIONS modeling are described in this section.
. ASQ / NON ASQ Volume
• Ten-Year Scenario
• Projections
— Structural Stages Projection
— Northern Spotted Owl Habitat Projection.
— Age Projection
— Carbon Projection
— Large Wood Projections
— OPTIONS Projections - Technical Papers
• Economic Analysis Data
• Time Slice Report
• State of the Forest
• Net Down Report
• Attribute Data for GIS
ASQ / NON ASQ Volume
Harvest volumes are a direct output from the OPTIONS model. Volumes from OPTIONS for the plan
revisions are based upon scribner 16 foot short log volumes. Harvest volumes are based on the capabilities of
the forest lands in each individual Sustained Yield Unit given the management action and allocations of the
alternative. All volumes are rounded down to the nearest whole million board feet.
• ASQ Volume - ASQ is synonymous with the O&C Act term Annual Productive Capacity. For each
alternative, the non declining even flow volume that can be sustained from the harvest land base is
the basis for, determining the Allowable Sale Quantity. Under Alternative 3 a two tiered volume was
reported to account for the increased harvest level that can be attained after the landscape targets
are met (regeneration harvest begins) and the owl and murrelet sites are released, resulting in an
increase in the size of the harvest land base
• Non ASQ - Thinning harvest is simulated for the Riparian Reserves / Riparian Management Areas
and for the Late-Successional Reserves / Late Successional Management Areas as they apply to the
alternatives. The management actions for these allocations do not permit regeneration harvest and
there are modeling age caps on the thinning treatments, thus a sustainable source of harvest cannot
be expected from these lands. The OPTIONS modeling determined the amount of harvest volume
that could be produced from these lands and stepped down harvest levels as the stands aged and their
thinning treatment windows closed.
Appendices - 712
Appendix R - Vegetation Modeling
The ASQ and Non ASQ volumes were recorded by SYU for each alternative and reference analyses. The
duration of the Non ASQ volume and the long term increase in ASQ for Alternative 3 was summarized as well.
No ASQ was calculated with the OPTIONS model or declared for the East-side Forest Management Areas in
Klamath Falls since there are no O&C lands in that area.
Ten- Year Scenario
The Ten-Year Scenario selects polygon records that were harvested in the first ten years of the OPTIONS
projections. For each polygon, the acreage and volume harvested is reported by harvest type; regeneration,
commercial thinning or selection. The OPTIONS Ten-lfear Scenario report also identified a random 1/3
sample of BLM sections that were harvested in the first decade and identified all harvest units within those
sections.
The OPTIONS output of the polygons harvested by harvest type with acreages and volume were brought
back to GIS to make map products with these attributes. The Districts evaluated the harvest units in the
sample sections to identify the logging system, and road construction needs.
The Ten- Year Scenario reports were produced for the No Action and all action alternatives. A database
was created with the first decade polygons harvested, with acreage and volume by harvest type at the
SYU and District level. This data was linked to the vegetation polygons to make GIS coverages and map
products.
See the Timber Appendix for further description of the methodology of the Ten-Year scenario.
Projections
Post processing of the OPTIONS data created a classification of every OPTIONS vegetation polygon record
at year 0, 10, 20, 30, 40, 50, and 100 years for the structural stage classification, Northern Spotted Owl habitat
classification and age class distributions. Databases were created for the No Action, action alternatives, and
reference analysis. This data was linked to the vegetation polygons in GIS for further spatial analysis.
1) Structural Stage Projections
The following structural stage classifications were used in the modeling:
1) Stand Establishment
la. ) Without Structural Fegacies
lb. ) With Structural Legacies
2) Ymng
2a.) Young High Density
2a 1.) Without Structural Legacies
2a2.) With Structural Legacies
Appendices - 713
FEISfor the Revision of the Western Oregon RMPs
2b.) Young Low Density
2b 1.) Without Structural Legacies
2b2.) With Structural Legacies
3) Mature
3a.) Single Canopy
3b.) Multiple Canopy
4) Structurally Complex
4a.) Existing Structurally Complex
4al.) Existing Old Forest
4a2.) Existing Very Old Forest
4b.) Developed Structurally Complex
2) Northern Spotted Owl Habitat Projections
Three classes of habitat were determined based on diameter class, canopy cover, presence/ absence of snags
(10 snags per hectare greater than 25 centimeters), presence / absence of down woody debris (greater than
2% ground cover).
The classification used in the Draff EIS was revised for the Final EIS as follows:
• Exception for size 11-20, canopy cover 60-100 for the Salem District only.
• Dispersal habitat that was in mature multi canopy or structurally complex structural stages were
re-classified as suitable (tracked as code 2-ss).
Table R-26. Northern Spotted Owl Habitat Projections
Diameter Class
(Inches)
Canopy
Cover (%)
Snag
Presence (p)
/ Absence (a)
Down Woody Debris
Presence (p) Habitat Code Value3
/ Absence (a)
aHabitat Code values: 1
-non-habitat, 2
- dispersal, 4 - suitable and dispersal (Finalized 10/18/2006)
11-20
0-40
a
a
1
11-20
0-40
P
a
1
11-20
0-40
a
P
1
11-20
0-40
P
P
1
0-11
0-100
n/a
n/a
1
20-30
0-40
a
a
1
20-30
0-40
P
a
1
20-30
0-40
a
a
1
20-30
0-40
P
a
1
20-30
0-40
a
P
1
20-30
0-40
P
P
1
20-30
0-40
a
P
1
20-30
0-40
P
P
1
30-100
0-40
a
a
1
30-100
0-40
P
a
1
30-100
0-40
a
a
1
Appendices - 714
Appendix R - Vegetation Modeling
Diameter Class
(Inches)
Canopy
Cover (%)
Snag
Presence (p)
/ Absence (a)
Down Woody Debris
Presence (p)
/ Absence (a)
Habitat Code Value3
aHabitat Code values:
1 ■ non-habitat, 2
- dispersal, 4 - suitable and dispersal (Finalized 10/18/2006)
30-100
0-40
P
a
1
30-100
0-40
a
P
1
30-100
0-40
P
P
1
30-100
0-40
a
P
1
30-100
0-40
P
P
1
11-20
40-60
a
a
2
11-20
40-60
P
a
2
11-20
40-60
a
P
2
11-20
60-100
a
a
2
11-20
60-100
P
a
2
20-30
40-60
a
a
2
20-30
40-60
P
a
2
20-30
40-60
a
a
2
20-30
40-60
a
P
2
20-30
60-100
a
a
2
20-30
60-100
a
a
2
30-100
40-60
a
a
2
30-100
40-60
P
a
2
30-100
40-60
a
a
2
30-100
40-60
P
a
2
30-100
60-100
a
a
2
30-100
60-100
a
a
2
11-20
40-60
P
P
2
11-20
60-100
a
P
4/2 Salem
11-20
60-100
P
P
4/2 Salem
20-30
40-60
P
a
2
20-30
40-60
P
P
2
20-30
40-60
a
P
2
20-30
60-100
P
a
4
20-30
60-100
P
a
4
20-30
60-100
a
P
4
20-30
60-100
P
P
4
30-100
40-60
a
P
2
30-100
40-60
P
P
2
30-100
60-100
P
a
4
30-100
60-100
a
P
4
20-30
40-60
P
P
4
20-30
60-100
a
P
4
20-30
60-100
P
P
4
30-100
40-60
a
P
4
30-100
40-60
P
P
4
30-100
60-100
P
a
4
30-100
60-100
P
P
4
30-100
60-100
a
P
4
30-100
60-100
P
P
4
Appendices - 715
- hllSfur tlic Revision^ of the. Western. Oregon^ KMJ't
3) Age Class Projections
Starting age classes derived from the Forest Operations Inventory (see inventory data section of this
appendix) increment forward on an annual basis with the OPTIONS projections until regeneration harvest
treatments reset the age. The stand ages under Alternative 3 should be treated as broad age groups since the
yield curves and the progression of stands over time reflect multi storied stand conditions in which a single
age does not well represent a multi storied stand.
4) Carbon Projections
The carbon sequestration projection forecasts the total-unit standing inventory volume of carbon within
each forest stand at the reporting point (report date years 0, 10, 20, 30, 40, 50, 100)). This carbon volume
(metric tonnes) is based on individual forest stand volume which reflects the management activities
(treatments) scheduled in the OPTIONS model and the volume projections (ASQ and non-ASQ) derived
from the ORGANON model. A series of factors are then applied to convert the stand volumes (per acre) to
total carbon volume for each forest stand
See Appendix C, (Carbon Storage Modeling) for further details on the carbon projection.
5) Large Wood Projections
The Large Wood projection provides statistics for each forest stand on the number of stems, density, height
and diameter of the live and standing dead trees by 10 inch diameter class for conifer and hardwood at each
reporting point (0, 10, 20, 30, 40, 50, 100 years). The reports account for management activities and stand
growth and mortality.
See Appendix J, (Fish) for further details on the large wood projections.
6) OPTIONS Projections (Technical Papers Spotted Owl Habitat / Structural
Stage, Carbon, Large Wood)
Northern Spotted OwS (NSO) Habitat and Structural Stage Classification
ORGANON Stand Tables for NSO Habitat and Structural Stage Classification Data
The NSO dispersal habitat and structural stage classifications are based on a number of stand averages and
stand table statistics. Stand height is an example of stand average information, the number of stems greater
than a threshold diameter, or the number of snags of a particular decay class, are examples of stand table
information. The OPTIONS model utilized and reports stand average data but did not provide the detailed
stand table information required in the dispersal habitat and structural stage classifications. To project
habitat and structural stage conditions throughout the planning horizon, ORGANON stand tables were
required.
In the modeling environment, each WOPR unit may receive a number of possible treatment combinations
throughout the planning horizon. The number of possible treatments varies by management regime (a
series of treatments), species group, site productivity and alternative. The actual sequence of treatments a
WOPR unit receives is a dynamic modeling process, dependent upon stand and landscape level targets and
rules; it cannot be forecast outside of the OPTIONS model. However, it is possible to describe all possible
combinations of treatments, and from this all inclusive set, select the actual scenario of treatments as
reported by OPTIONS. Thus, an ORGANON stand table was created for each possible unique combination
of treatment, species group and site productivity, for each management regime and for each alternative.
A crosswalk table was defined to provide a reference between the treatment combinations and the
corresponding stand table.
Appendices - 716
Appendix R - Vegetation Modeling
Modeling Process
There are a number of stand attributes to be considered in the habitat and structural stage classification
for an individual WOPR unit, at a particular point in time. The ORGANON treatment stand tables were
pre-processed, and then further analyzed to calculate specific habitat and structural stage statistics. These
statistics, referred to as ‘index values’, are reference values in a look-up table; the Index Table. The index
values for every modeling group, stand group, site index and treatment are stored in the Index Table.
One of the key steps in the pre-processing of the stand tables for northern spotted owl habitat classification
was to generate index values for snags and down woody debris. The CWDM model was used to generate this
information based on input from the stand table dead trees. Together, the stand tables and snag and downed
woody debris information provided the detailed information necessary to complete the habitat. Information
from the CWDM is also reported within the Index Table.
The OPTIONS model records for each WOPR unit and for all years in the planning horizon, all silvicultural
and harvest treatments performed. Also recorded are details of the treatments such as: the area treated, the
type of treatment, the volume removed, as well as stand attribute information after treatment. Based on
this information it is possible to compile a complete history of activities for each WOPR unit for the entire
planning horizon.
Based on the information from the WOPR unit activity history provided by OPTIONS, the appropriate
stand table reference is identified in the crosswalk table. This stand table reference is used to locate the index
values in the Index table that will be evaluated to define the NSO dispersal habitat and structural stage
classification.
Methodology
The following methodology was applied to generate the NSO Habitat and Structural Stage Index Report.
Source Information
NSO Dispersal Habitat Classification
An NSO Dispersal Habitat definition table was used to define the stand conditions required to meet
dispersal habitat. These included:
• Diameter Range- average stand diameter from summary table
• Canopy Closure - based on relative density as follows:
Canopy Closure = -12.298 + 2.375(RD) - 0.014(RD)^2
• Snag presence: 10 snags/acre greater than 10”
• Down woody debris presence: 2% ground cover. The percent ground cover was approximated
using a conversion factor and volume by retention plant zones
(\folume (cu ft/ac)/X var = % cover) (see Table R-27)
Table R-27. Plant Zone and Down Woody Debris Volume
Retention Plant Zone
DWD Volume (ft3/ac)
Ponderosa Pine/Douglas Fir
362.648
Southwest Oregon conifer
465.179
Westside conifer
62.771
Note: TanOak and DF = SW Oregon, and W. hemlock = West side conifer
Note: Species Group of R Pine for the p.pine/d.fir in SW Oregon
Appendices - 717
FEISfor the Revision of the Western Oregon RMPs
• Canopy (single/multi-story): A diameter diversity index (DDI) of 60 was used to determine the
distinction between single and multi-story canopy, with single-story canopy having a DDI greater
than 60 and multi-story canopy having a DDI less than or equal to 60.
Structural Stage Classification
Structural Stage Classification definitions were provided based on the following stand characteristics:
• Age: stand age from summary table
• Height: average stand height from summary table
• TPA: number of trees per acre by diameter from the stand table
• Relative Density: average stand relative density from the summary table
• Legacy Presence: the presence of legacy as an initial condition (based on MicroStorms structure
stage classification) as well as the future creation of legacy based on alternative harvest
prescriptions.
• CVgt( 10): from summary table coefficient of variation of tree diameters greater than 10” dbh.
All Possible Treatment Yield Curve Crosswalk Table
This table (ACT2CVS_XWALK) identifies which treatment yield curve to use for the required stand
characteristics and index values to determine the NSO Dispersal Habitat and Structural Stage Classifications.
The treatment yield curve is identified based on the current alternative, management regime, species, site
productivity class, and treatment age. Below is an example of the crosswalk table.
Index Value Lookup Table
This table, (INDX_LKUP) is an alternative-based lookup table containing projected stand characteristics
and index values for each treatment yield curve. Some of the index values available include:
• Stand characteristics: age, basal area, TPA, QMD, height, volume, crown ratio, canopy closure,
relative density, SDI, CY DDI,
• TPA by 10” diameter classes: # of trees in 0” to 9”, 10” to 19”, 20” to 29”, 30” to 39”, greater than or
equal to 40”
• Snags by 10” diameter classes: # of snag in 0” to 10”, 11” to 20”, 21” to 30”, 31” to 40”, greater than
40”
• Snag TPA: # of snags greater than 10” dbh
• CWD by 10” diameter classes: sum of volume in 0” to 10”, 11” to 20”, 21” to 30”, 31” to 40”, greater
than 40”
• CWD vpa: sum of volume greater than 10”
• Calculated canopy closure: canopy closure calculated based on relative density
• Overstory stand characteristics: available for Alternative 3 blended curves, based on the untreated
yield curve (basal area, tpa, qmd, height, volume relative density, tpa by 1 0” diameter class, CY
DDI)
• Understory stand characteristics: available for Alliterative 3 blended curves, based on the treated
yield curve (basal area, tpa, qmd, height, volume relative density, tpa by 10” diameter class, CY
DDI)
OPTIONS Run Files
To post-process an OPTIONS run, the following OPTIONS run files are required:
. OPTIONS data files (.DBF, .DBS, .SPG, .SIC)
. OPTIONS run files (.DEF, .DEY -RUN, .1, .II., .V)
Appendices - 718
Appendix R - Vegetation Modeling
Procedure
For each Alternative:
1. Using ORGANON, generate the possible treatment stand tables based on the Alternatives
management regime definitions. Create the Crosswalk Table to identify which stand table to
reference for a particular treatment combination.
2. Based on the Crosswalk Table, pre-process each treatment stand table to generate the index values
that will be used to define the habitat and structural stage classifications. This includes projecting
snag and CWD using stand table attributes. Create the Index Table to identify which index values
to use for a particular treatment stand table.
3. Initialize a Habitat Report Table by listing for each WOPR unit the OPTIONS inventory values for
forest type (forest, non-forest, road), initial management regime, species group, site productivity class
and area.
For each forested WOPR unit in the Habitat Report Table:
4. Set initial conditions:
• Initial Structural Stage and legacy (based on OPTIONS inventory structural stage)
• Plant Series/Retention Zone (based on OPTIONS inventory)
• NSO Variance: based on plant series, species group and habitat definition
• Alternative 2 GTR (green tree retention) flag for MOCA and SHRUB areas
5. Based on the OPTIONS run results, build the WOPR unit Activity History Table including harvest
activities and state of the forest years in chronological order. Also record the stand management
regime, species group, site productivity and age at which these actives occur. This history table
represents the changes in stand characteristics over time.
For each Activity in the Activity History:
6. Determine the current thinning treatment combination, partial harvest condition and legacy based
on the type of activity completed.
For Regeneration Harvest: reset thinning treatment combination, reset partial harvest
conditions, re-evaluate legacy:
• No Action Alternative (modeled tree retention), legacy is present (WL)
• Alternative 1 (no modeled tree retention), then legacy is not present (WOL)
• Alternative 2 (no modeled tree retention), then legacy is not present (WOL).
• Alternative 2, MOCA and SHRUB area (modeled tree retention), then legacy is present
(WL)
• Alternative 3 (modeled tree retention), legacy is present (WL)
• PRMP, area with GTR the legacy is present (Snag retention in LSMA - WL) otherwise
legacy is not present (WOL)
For Selection Harvest: reset thinning treatment combination, set partial harvest condition, re-
evaluate legacy:
• No Action Alternative, Alternative 1 and Alternative 2 there is no modeled selection
harvest
• Alternative 3 and PRMP has modeled selection harvest, so legacy is present (WL)
Appendices - 719
FEISfor the Revision of the Western Oregon RMPs
For Commercial Thinning: set thinning treatment combination based on thinning age and
thinning sequence, no change to partial harvest condition or legacy.
7. Set activity stand table reference from Crosswalk Table based on the treatment combination.
8. Retrieve stand characteristics and index values from Index Table based on stand table reference.
9. Calculate Structure Stage Classification based on index values and structural stage definition.
• For Alternative 3 with partial harvest conditions, if height is <50’ Structural Stage is based
on understory values. Otherwise Structural Stage is based on stand values.
• For Alternative 3 with partial harvest conditions, if Structural Stage is calculated as
Mature-Single-Story, then canopy is reset to multi-story.
10. Calculate NSO Dispersal Habitat Classification based on index values and dispersal habitat
definition.
• For Alternative 3 with partial harvest conditions, canopy is set to multi- story. Otherwise,
canopy is set based on DDI values.
• The NSO Classification is then re-evaluated for Dispersal Classifications (class 2) that are
within Mature Multiple Canopy or are Structurally Complex. These are re-classified as
Dispersal with Structural Stage (class 2-SS)
11. Update Report Table with Structural Stage and NSO Dispersal Habitat Classification values for
reporting years
See Figure R-24 for a data flow diagram of this procedure.
Appendices - 720
Appendix R - Vegetation Modeling
11 JJ|
Figure R-24. Data Flow Diagram For Owl FFabitat And Structural Stage Classification
Appendices - 721
FEISfor the Revision of the Western Oregon RMPs
Carbon Sequestration Projection
The carbon sequestration projection forecasts the total-unit standing inventory volume of carbon within
each WOPR unit at the reporting point (report date). This carbon volume (metric tonnes) is based on
individual WOPR unit stand volume which reflects the management activities (treatments) scheduled in the
OPTIONS model and the volume projections (ASQ and non-ASQ) derived from the ORGANON model.
A series of factors are then applied to convert the stand volumes (per acre) to total carbon volume for each
WOPR unit.
Modeling Process Overview
The calculation of total carbon volume requires information about the stand volume per acre, including
both ASQ and non-ASQ species. However, because OPTIONS utilizes and reports stand information for
ASQ species only, it was necessary to adopt a method to determine the total (ASQ and non-ASQ) stand
volume for each WOPR unit at each reporting point.
In the OPTIONS model, each WOPR unit is uniquely managed based on the hierarchy of management
assumptions and objectives. The application of these assumptions and objectives create a dynamic modeling
process that affects the sequence and timing of stand level treatments, this sequence cannot be forecast
outside of the OPTIONS model. However, based on the OPTIONS modeling framework it was possible
to define the entire range of possible treatment combination based on modeling group, site index and
treatment timing and intensity, which were then modeled in ORGANON to create stand tables with total
stand volume (ASQ and non-ASQ species).
For modeling convenience this large set of ORGANON volume data was consolidated into a single Index
Table that contained the volume information to represent every combination of modeling group, species
group, site index and treatment timing and intensity. This volume information was expressed as the total
board foot volume per acre unit. The per acre stand inventory volume was determined for each WOPR
unit by reviewing the sequence of OPTIONS treatment details and then referring to the corresponding
ORGANON volume data from the Index Table.
Board foot volumes were then converted to cubic foot volumes and then to dry wood weight by applying
species sensitive conversion factors. An expansion factor was then applied to the dry wood weight to
account for non-merchantable biomass including roots and branches. The dry wood weight was further
converted to carbon volume and then multiplied by the WOPR unit area to derive a total carbon volume
within the WOPR unit.
Methodology
The following methodology was applied to generate the Carbon Credit Report.
Source Information
Carbon Factor Lookup Table:
A Carbon Factor Lookup table was provided that defines the board foot to cubic foot conversion
factor by species. Also included in this table are various prices for carbon by cubic ton.
All Possible Treatment Yield Curve Crosswalk Table (ACT2CVS_XWALK):
Appendices - 722
This table identifies which treatment yield curve to use for the required stand characteristics to
calculate available carbon. The treatment yield curve is identified based on the current alternative,
management regime, species, site productivity class, and treatment age.
Appendix R - Vegetation Modeling
Index Value Lookup Table (INDX_LKUP):
This table is an alternative-based lookup table containing projected stand characteristics and index
values for each treatment yield curve. Some of the index values available include:
• Stand characteristics: age, basal area, TPA, QMD, height, total volume, crown ratio,
canopy closure, relative density, SDI, CV, DDI,
• TPA by 10” diameter classes: # of trees in 0” to 9”, 10” to 19”, 20” to 29”, 30” to 39”, greater
than or equal to 40”
• Snags by 10” diameter classes: # of snag in 0” to 10”, 11” to 20”, 21” to 30”, 31” to 40”,
greater than 40”
• Snag TPA: # of snags greater than 10” dbh
• CWD by 10” diameter classes: sum of volume in 0” to 10”, 1 1” to 20”, 21” to 30”, 31” to 40”,
greater than 40”
• CWD vpa: sum of volume greater than 10”
• Calculated canopy closure: canopy closure calculated based on relative density
• Overstory stand characteristics: available for Alternative 3 blended curves, based on the
untreated yield curve (basal area, tpa, qmd, height, volume relative density, tpa by 10”
diameter class, CV, DDI)
• Understory stand characteristics: available for Alliterative 3 blended curves, based on
the treated yield curve (basal area, tpa, qmd, height, volume relative density, tpa by 10”
diameter class, CV, DDI)
OPTIONS Run Files
To post-process an OPTIONS run, the following OPTIONS run files are required:
— OPTIONS data files (.DBF, .DBS, .SPG, .SIC)
— OPTIONS run files (.DEF, .DEV, .RUN, .1, .II., .V)
Procedure
For each Alternative:
1. Using Organon, generate the possible treatment stand tables based on the management direction
for each Alternative. Create the Crosswalk Table to identify which stand table to reference for a
particular treatment combination.
2. Based on the Crosswalk Table, pre-process each treatment stand table to generate the index values
that will be used to define the habitat and structural stage classifications. This includes projecting
snag and CWD using stand table attributes. Create the Index Table to identify which index values
to use for a particular treatment stand table.
3. Initialize a Carbon Report Table by listing for each WOPR unit the OPTIONS inventory values for
forest type (forest, non-forest, road), initial management regime, species group, site productivity
class and area.
For each forested WOPR unit in the Carbon Report Table:
4. Set initial conditions:
— Initial Structural Stage and legacy (based on OPTIONS inventory structural stage)
— Plant Series/Retention Zone (based on OPTIONS inventory)
— NSO Variance: based on plant series, species group and habitat definition
— Alternative 2 GTR (green tree retention) flag for MOCA and SHRUB areas
5. Based on the OPTIONS run results, build the WOPR unit Activity History Table including harvest
activities and state of the forest years in chronological order. Also record the stand management
regime, species group, site productivity and age at which these actives occur. This history table
represents the changes in stand characteristics over time.
For each Activity in the Activity History:
6. Determine the current thinning treatment combination, partial harvest condition and legacy based
on the type of activity completed.
Appendices - 723
FEISfor the Revision of the Western Oregon RMPs
For Regeneration Harvest: reset thinning treatment combination, reset partial harvest conditions,
re-evaluate legacy:
• No Action Alternative (modeled tree retention), legacy is present (WL)
• Alternative 1 (no modeled tree retention), then legacy is not present (WOL)
• Alternative 2 (no modeled tree retention), then legacy is not present (WOL).
• Alternative 2 - MOCA and SHRUB area (modeled tree retention), then legacy is present (WL)
• Alternative 3 (modeled tree retention), legacy is present (WL)
• PRMP area with GTR the legacy is present (Snag retention in LSMA -WL) otherwise legacy is
not present (WOL)
For Selection Harvest: reset thinning treatment combination, set partial harvest condition, re-evaluate
legacy:
• No Action Alternative, Alternative 1 and Alternative 2 there is no modeled selection harvest
• Alternative 3 and PRMP has modeled selection harvest, so legacy is present (WL)
For Commercial Thinning: set thinning treatment combination based on thinning age and thinning
sequence, no change to partial harvest condition or legacy.
7. Set activity stand table reference from Crosswalk Table based on the treatment combination.
8. Retrieve stand characteristics and index values from Index Table based on stand table reference.
9. Calculate the total number of metric tons of carbon dioxide OPTIONS reports volume in board
foot per acre. Convert this volume to merchantable cubic feet per acre. For this report, we used a
factor of 6.00.
MERCH_CUFT = BDFT volume /6.00
A. Initialize the conversion factor (LBS_CUFT) for calculating the number of pounds of dry weight
of a cubic foot of wood based on the species group. This conversion factor is located in the
CARBON FACTOR Lookup table.
B. Calculate the number of pounds of dry weight (MERCH_LBS) per acre using the corresponding
species conversion factor.
MERCH_LBS = MERCH_CUFT * LBS_CUFT
C. Calculate the total dry biomass in trees (TOT_LBS) per acre. The expansion factor is set to
1.85 for all units, meaning that total tree biomass (including tops and roots) is 1.85 times
merchantable dry weight.
“ TOTJLBS = MERCH_LBS * 1.85
D. Calculate the number of pounds of carbon (LBS_C) per acre.
LBS_C = TOT_LBS * 0.50
E. Calculate the number of metric tons of carbon (TONS_C) per acre.
TONS_C = LBS_C/ 2200.0
F. Calculate the number of metric tons of carbon dioxide (TONS_C02E) per acre.
TONS_C02E = TONS_C * 3.667
G. Calculate the total number of metric tons of carbon dioxide
TOT_C02E = TONS_C02E * unit area.
10. Update Report Table with carbon values for reporting years.
See Figure R-25 for a data flow diagram of this procedure.
Appendices - 724
Appendix R - Vegetation Modeling
Figure R-25. Data Flow Diagram For Carbon Projection
;
_
Appendices - 725
FF.IS for the. Revision. 0/ the Western. Oregon^ RMPs.
Large Wood Projection
The Large Wood projection provides statistics for each forest stand (WPR_ID) on the number of stems,
density, height and diameter of the live and standing dead trees by 10 inch diameter class for conifer and
hardwood at each reporting point (report date). The reports account for management activities and stand
growth and mortality.
Modeling Process
The Large Wood Report requires stand table information on live and dead trees by species type. The
abundance of live and dead trees is sensitive to management activities. Detailed information about these
activities is provided by WOPR unit from the OPTIONS model. However, since OPTIONS utilizes
and reports stand average information, it was necessary to adopt a method to determine the stand table
information for each WOPR unit at each reporting period.
In the OPTIONS model, each WOPR unit is uniquely managed based on the hierarchy of management
assumptions and objectives. The application of these assumptions and objectives create a dynamic modeling
process that affects the sequence and timing of stand level treatments, this sequence cannot be forecast
outside of the OPTIONS model. However, based on the OPTIONS modeling framework it was possible
to define the entire range of possible treatment combination based on modeling group, site index and
treatment timing and intensity, which were modeled in ORGANON to create to create individual stand
tables
For modeling convenience, this large set of ORGANON stand tables was consolidated into a single
Index Table for every combination of modeling group, species group, site index and treatment timing
and intensity. In creating the Large Wood Report this detailed stand table information for each WOPR
unit was determined by reviewing the sequence of OPTIONS treatment details and then referring to the
corresponding ORGANON data in the Index Table.
Methodology
The following methodology was applied to generate the Large Wood Analysis Report.
Source Information:
All Possible Treatment Yield Curve Crosswalk Table (ACT2CVS_XWALK)
This table identifies which treatment yield curve to use to obtain the required stand characteristics
and index values for the large wood analysis report. The treatment yield curve is identified based
on the current alternative, management regime, species, site productivity class, and treatment age.
Index Value Lookup Table (INDX_LKUP)
This table is an Alternative based lookup table containing projected stand characteristics and index
values for each treatment yield curve. Some of the index values available include:
— Stand characteristics: age, basal area, TPA, QMD, height, volume, crown ratio, canopy
closure, relative density, SDI, CV, DDI,
— TPA by 10” diameter classes for live and dead trees by Conifer and hardwood: # of trees in
0” to 9”, 10” to 19”, 20” to 29”, 30” to 39”, greater than or equal to 40”
— Average height by 10” diameter classes for live and dead trees by Conifer and hardwood:
weighed height by TPA in 0” to 10”, 1 1” to 20”, 21” to 30”, 31” to 40”, greater than 40”
— Average diameter by 10” diameter classes for live and dead tree by conifer and hardwood:
weighted diameter by TPA in 0” to 10”, 1 1” to 20”, 21” to 30”, 31” to 40”, greater than 40”
Appendices - 726
Appendix R - Vegetation Modeling
OPTIONS Run Files
To post-process an OPTIONS run, the following OPTIONS run files are required:
- OPTIONS data files (.DBF, .DBS, .SPG, .SIC)
- OPTIONS run files (.DEF, .DEV, .RUN, .1, .II., .V)
Procedure
For each Alternative:
1. Using Organon, generate the possible treatment stand tables based on the management direction
for each alternative. Create the Crosswalk Table to identify which stand table to reference for a
particular treatment combination.
2. Based on the Crosswalk Table, pre-process each treatment stand table to generate the index values
that will be used to in the large wood analysis. Create the Index Table to identify which index
values to use for a particular treatment stand table.
3. Initialize a Large Wood Report Table by listing for each WOPR unit the OPTIONS inventory
values for forest type (forest, non-forest, road), initial management regime, species group, site
productivity class and area.
For each forested WOPR unit in the Large Wood Report Table:
4. Set initial conditions:
— Initial Structural Stage and legacy (based on OPTIONS inventory structural stage)
— Plant Series/Retention Zone (based on OPTIONS inventory)
— NSO Variance: based on plant series, species group and habitat definition
— Alternative 2 GTR (green tree retention) flag for MOCA and SFIRUB areas
5. Based on the OPTIONS run results, build the WOPR unit Activity History Table including harvest
activities and state of the forest years in chronological order. Also record the stand management
regime, species group, site productivity and age at which these actives occur. This history table
represents the changes in stand characteristics over time.
For each Activity in the Activity History:
6. Determine the current thinning treatment combination, partial harvest condition and legacy based
on the type of activity completed.
For Regen Harvest: reset thinning treatment combination, reset partial harvest conditions, re-
evaluate legacy:
• No Action Alternative (modeled tree retention), legacy is present (WL)
• Alternative 1 (no modeled tree retention), then legacy is not present (WOL)
• Alternative 2 (no modeled tree retention), then legacy is not present (WOL).
• Alternative 2 - MOCA and SHRUB area (modeled tree retention), then legacy is present
(WL)
• Alternative 3 (modeled tree retention), legacy is present (WL)
• PRMP area with GTR the legacy is present (Snag retention in LSMA -WL) otherwise legacy
is not present (WOL)
For Selection Harvest: reset thinning treatment combination, set partial harvest condition, re-
evaluate legacy:
• No Action Alternative, Alternative 1 and Alternative 2 there is no modeled selection harvest
• Alternative 3 and PRMP has modeled selection harvest, so legacy is present (WL)
Appendices - 727
FEISfor the Revision of the Western Oregon RMPs
For Commercial Thinning: set thinning treatment combination based on thinning age and
thinning sequence, no change to partial harvest condition or legacy.
7. Set activity stand table reference from Crosswalk Table based on the treatment combination.
8. Retrieve stand characteristics and index values from Index Table based on stand table reference.
9. Calculate Structure Stage Classification based on index values and structural stage definition.
• For Alternative 3 with partial harvest conditions, if height is <50’ Structural Stage is based on
understory values. Otherwise Structural Stage is based on stand values.
• For Alternative 3 with partial harvest conditions, if Structural Stage is calculated as Mature-
Single-Story, then canopy is reset to multi-story.
10. Update Report Table with Structural Stage and stand table values such as TPA, average HT and DBH
for live and dead trees by conifer and hardwood in 10” diameter classes for each reporting year
See Figure R-26 for a data flow diagram of this procedure.
Appendices - 728
Appendix R - Vegetation Modeling
Figure R-26. Data Flow Diagram For Large Wood Projection
flPlPlSPPSBi illlls
-J
Appendices - 729
F£fS/or the Revision of the Western Oregon RMPs
Economic Analysis Data
Two inputs were provided for post processing of the OPTIONS data for the calculation of timber harvest
value.
• Costs necessary for harvesting were computed using an historical basis of timber sales from FY
1996 thru FY 2006 (part). Costs were brought to 2005 dollars and expressed in $/MBF. Thinning
and partial harvest for Alternative 3 were separated from regeneration harvests and costs averaged
by harvest method for each district. See Appendix E, Timber, for additional information.
• The weighted pond value was calculated for each district for each structural stage and harvest
method. This weighted pond value included both a weighting for the level of expected species
from each district and additionally weighted for grades expected from each structural stage. See
Appendix E, Timber, for additional information
OPTIONS post processing produced a report by each SYU with the attributes listed below. This data is in
excel spreadsheet by sustained yield unit for the No Action alternative, Action alternatives, and reference
analyses.
• Projection year - Annual for first ten years.
• Harvest Land Base - distinguish ASQ from non ASQ volume sources.
• County, Name, Resource Area
• Harvest Type
• Volume in MBF 16' scribner for the action
• Weighted pond value of timber for action X (totvol)
• Average stump to truck cost - falling, yarding and loading, $/MBF X totvol Average road
construction, improvement and renovation cost/MBF X totvol Average hauling cost to mill, $/MBF
X totvol
• Average road maintenance and road use fees X totvol
• Average misc. cost, includes slash disposal, special requirements, etc X tot vol
• Sum (stump, roads, transport, maintain, misc.)
• Revenue-(tot cost), estimate of value of action, (Stumpage in MBF X tot vol)
Time Slice Report
For 10-year increments, spanning 200 years, this report summarizes the acres and volume harvested for the
combination of data elements listed below.
• Sustained Yield Unit
• County
• Resource Area
• Harvest Land Base - Distinguish ASQ from Non ASQ volume
• Harvest type
• Ten-Year age class at time of treatment
• Treatment area
• Harvest volume
This report was generated for the No Action and Action Alternatives. The data is compiled in Access
databases.
Appendices - 730
Appendix R - Vegetation Modeling
State of the Forest
The state of the forest contains the attributes tracked in OPTIONS for each vegetation polygon record at the
time of the projections periods - year 0, 10, 20, 30, 40, 50, and 100. These attributes include
• Management regime
• Species group
• Volume
• Trees per acre
• Height Basal Area
• Harvest Land Base
• Age Class
• Sustained Yield Unit.
This report was generated for the No Action and action alternatives. The data is compiled in Access
databases.
Attribute Data for GIS
A GIS input file was created for each alternative. This spatial analysis dissected the vegetation polygons by
all of the GIS layers which formed an allocation, modeling rule, or reporting unit needed for the OPTIONS
modeling. The OPTIONS data prep program utilized this GIS file to further classify and format the data for
OPTIONS modeling. Harvest Land Base coding is an example for this reclassification of the data. The data
from the OPTIONS data preparation program is returned to GIS so selected attributes can then be linked
and used for subsequent spatial analysis. This provides a common data set used in both the OPTIONS
analysis and the resulting GIS spatial analysis. Access databases with the data going to the OPTIONS model
and data returned to GIS were generated for the No Action and action alternatives.
Vegetation Modeling Team Members
OPTIONS Team
Kristine Allen
Chris Cadwell
Joe Graham
Mark Perdue
Don Reimer
OPTIONS Programming / Modeling
Director of Operations
D. R. Systems Inc.
Forester / Vegetation Modeling Coordinator
WOPR Core Team
BLM Oregon State Office.
Inventory Forester / Senior Modeling Specialist
WOPR Core Team
BLM Oregon State Office.
OPTIONS Modeling
Manager of Consulting Services
D. R. Systems Inc.
OPTIONS Modeling
CEO, D. R. Systems Inc.
Appendices - 731
FEISfor the Revision of the Western Oregon RMPs
Growth and Yield Team
Craig Kintop
Forester (Silviculturist) /
Growth & Yield Modeling Coordinator
BLM Roseburg District Office
Michael Oxford
Forester (Inventory Specialist) BLM Coos Bay District Office
Robert Pierle
Forester (Inventory Specialist) BLM Medford District Office
Steve Brownfield
Forester (Inventory Specialist) BLM Salem District Office
Robert Ohrn
Forester (Silviculturist)
BLM Eugene District Office
Daniel Schlottmann
Forester (Silviculturist) BLM Salem District Office
Carolina Hooper
Forester
BLM Salem District Office
Richard Kelly
Forester (Silviculturist)
BLM Eugene District Office
Art Emmons
Forester (Inventory Specialist)
BLM Eugene District Office
Kevin Carson
Forester (Silviculturist)
BLM Roseburg District Office
Walter Kastner
Forester (Silviculturist)
BLM Salem District Office
Alan Bergstrom
Forester
BLM Medford District Office
Douglas Stewart
Forester
BLM Medford District Office
Mark Stephen
Forester
BLM Eugene District Office
Frank Hoeper
Forester
BLM Medford District Office
Mark Hanus
Biometrician
ORGANON Shell Developer / ORGANON Advisor
FORSight Resources, Vancouver WA.
William Johnson
Forester (Silviculturist)
BLM Lakeview District Office
Gregory Reddell
Forester (Inventory Specialist)
BLM Lakeview District Office
Appendices - 732
Appendix R - Vegetation Modeling
CVS / Statistical Team
Carol Apple
Mathematical Statistician
FS PNW Region Regional Office
Jim Alegria
Biometrician
BLM Oregon State Office
GIS Team
Duane Dippon
GIS Lead
WOPR Core Team
BLM Oregon State Office
Thomas Jackson
GIS Specialists
Eugene District Office
Arthur Miller
GIS Specialist
BLM Oregon State Office
Appendices - 733
Appendices - 734
Appendix S
Wood River
Wetland and West
Eugene Wetlands
Management Plans
This appendix includes two documents: (1) the record of decision and resource management plan for
the Upper Klamath River and Wood River Wetland, which is in the Klamath Falls Resource Area of the
Lakeview BLM District; and (2) a summary of the wetlands plan for the West Eugene Wetlands, a portion of
which are in the Eugene BLM District.
In this appendix:
Wood River Wetland Plan 736
Summary of the West Eugene Wetlands Plan 758
Appendices - 735
FEISfor the Revision of the Western Oregon RMPs
Wood River Wetland Plan
The following pages contain a consolidated document (including the record of decision and resource
management plan) of the Upper Klamath Basin and Wood River Wetland. The document is tiered to and
references the Klamath Falls Proposed Resource Management Plan/Final Environmental Impact Statement
(PRMP/FEIS), which is available from:
BLM Klamath Falls Resource Area Office
2795 Anderson Ave., Bldg. #25
Klamath Falls, OR 97603
The Klamath Falls Proposed Resource Management Plan was approved by the Oregon/Washington State
Director in November 1995. The Record of Decision approves the BLM decisions for managing 3,220 acres
in Klamath County, Oregon.
The Record of Decision conforms with 40 CFR 1505.2, which requires a concise document linking the
manager's decision to the analysis presented in the Upper Klamath Basin and Wood River Wetland Final
Environmental Impact Statement (FEIS), dated July 1995.
Appendices - 736
Appendix S - Wood River Wetlands and West Eugene Wetlands Management Plans
Record of Decision for the Upper Klamath Basin
and Wood River Wetland
Resource Management Plan
Prepared by the Bureau of Land Management
Klamath Falls Resource Area
Lakeview District, Oregon
February 1996
Introduction
In this Record of Decision we adopt and approve for immediate implementation the following Upper
Klamath Basin and Wood River Wetland Resource Management Plan, based on the combination of this
office's March 1994 draff environmental impact statement and the fuly 1995 final environmental impact
statement. The resource management plan addresses resource management on approximately 3,220 acres
of federal land administered by the Bureau of Land Management (BLM) located within Klamath County,
Oregon.
The approved resource management plan responds to the need for a healthy aquatic ecosystem associated
with the Upper Klamath Basin that will contribute toward improved water quality and support stable
populations of native species, particularly those associated with wetland and riparian communities. It
also responds to the need for monitoring the results of implementing the plan and the use of adaptive
management based on those monitoring results.
Alternatives Considered
Four alternatives for management of the BLM-administered lands and resources on the Wood River
property were analyzed in the final environmental impact statement. A brief description of each alternative
analyzed in the final environmental impact statement follows below.
Alternative A (No Action). This alternative would emphasize a continuation of the management direction
in place at the time of the BLM's purchase of the Wood River property. The management objective would be
to maintain irrigated pastureland for livestock grazing.
Alternative B. This alternative would emphasize restoring the property to a functioning wetland with
diverse and healthy plant communities. This would be accomplished by restoring historic stream channel
meanders on the property. Few water control structures, minimal hydrologic control, long-term low
maintenance, and no livestock grazing are features of this alternative.
Alternative C. This alternative would emphasize the restoration of a functioning wetland through the use
of highly engineered techniques, complex designs, and/or numerous research pilot projects to meet the
long-term goal of improving water quality entering Agency Lake from the property. Research would be
emphasized in this alternative. Vegetation management could be done through the use of water level and
flow manipulations, livestock grazing, prescribed fire, mechanical and chemical treatments. Recreation use
would be maximized, with an emphasis on outdoor education and interpretation.
Alternative D (Proposed Action). This alternative would restore the property to its previous function as a
wetland community. Emphasis would be given to long-term improvement in the quality of water entering
Appendices - 737
FEISfor the Revision of the Western Oregon RMPs
Agency Lake from the property. In addition, improving and increasing the wetland and riparian habitat
for federally listed fish and other wildlife species would be emphasized. Vegetation management could be
accomplished through the use of water level and flow fluctuations, livestock grazing, fire, chemical and
mechanical treatments. A combination of new structures to improve hydrologic control, and utilization of
natural processes would be emphasized in this alternative. Adaptive management, the process of changing
land management as a result of monitoring or research, would be used. Recreation resources would be
managed for low to moderate use levels, with non-motorized access being featured.
Rationale for Decision
The Congressionally directed purposes for managing the Bureau of Land Management-administered lands
include both conserving the ecosystems upon which plant and wildlife species depend, and at the same time
providing raw materials and other resources that are needed to sustain the health and economic well-being
of the people of this country. The Proposed Resource Management Plan alternative best meets these criteria.
We have reviewed the alternatives discussed in the Proposed Resource Management Plan/Final
Environmental Impact Statement and their predicted environmental, economic, and social consequences,
and the risks and safeguards inherent in them. The Proposed Resource Management Plan alternative in the
Proposed Resource Management Plan/Final Environmental Impact Statement is the best alternative for
providing a sustainable level of human use of the aquatic/wetland resource while still meeting the need to
restore and maintain the wetland ecosystem. We therefore select the Proposed Management Plan alternative
as the management direction that best responds to the purpose and need for the proposed action as
expressed in the Proposed Resource Management Plan/Final Environmental Impact Statement.
We base our conclusion on a number of factors. Management under Alternative A (No Action), would
provide the least amount of water quality, water retention, and endangered species habitat improvements.
Management under Alternative B would provide the least amount of hydrologic control, and the lowest
long-term maintenance costs. It would likely provide the least improvement in water quality of the
action alternatives, the fewest acres of emergent marsh habitat, and the most water retention capability.
Management under Alternative C would provide the most hydrologic control, the most potential for
improved water quality, the greatest construction and long-term maintenance costs. It would provide greater
capability for water storage than Alternative A, but less than Alternative B. Management under Alternative
D (the Proposed Resource Management Plan) would provide more hydrologic control and potential water
quality improvements than Alternatives A and B, but less than C. This alternative would provide more
potential water retention than alternatives A and C but less than B. This alternative would require more
initial and long term maintenance costs than alternatives A and B, but less than C. Alternatives B, C, and D
(the Proposed Resource Management Plan) would all have beneficial effects on Lost River and Shortnose
sucker habitat. The Proposed Resource Management Plan alternative has the greatest potential to provide
improved habitat for these species. The Proposed Resource Management Plan alternative would have a
beneficial impact on more Special Status Animal Species than any other alternative. See Proposed Resource
Management Plan/Final Environmental Impact Statement.
All alternatives follow current BLM policies, initiatives, and emphasis on restoration and maintenance of
wetland resource conditions, including riparian and aquatic conditions, that perpetuate fully functioning
ecosystems while still providing for societal needs. The primary goals of water quality improvement,
increased water retention and improved habitat for the Lost River and Shortnose suckers were used to
develop all action alternatives. Alternatives A (No Action), and B would make achieving these objectives
more difficult. Alternatives C and D (the Proposed Resource Management Plan) make it easier to
accomplish.
The No Action alternative is based on the previous use of this property for irrigated pasture land that existed
prior to acquisition. In addition, it does not emphasize the primary goals stated for the management of this
property.
Appendices - 738
Appendix S - Wood River Wetlands and West Eugene Wetlands Management Plans
The impacts to many species, and groups of species, of fish, wildlife, and plants are complex and difficult to
summarize in this Record of Decision. They are described in detail in the Proposed Resource Management
Plant Final Environmental Impact Statement. Based upon the Proposed Resource Management Plan/
Final Environmental Impact Statement and all of the information in the record, we have determined that
Proposed Resource Management Plan alternative will continue to meet the needs of species influenced by
federal land management activities. We find it meets the requirements of the Endangered Species Act for
the conservation of listed species. Moreover, it meets the requirements of acts that protect elements of the
environment, and requirements for coordinated planning and consultation.
Environmental Preferability of the Alternatives
Environmental preferability is judged using the criteria suggested in the National Environmental Policy Act
of 1969 (NEPA), which is guided by the Council on Environmental Quality (CEQ). The CEQ has stated that
"The environmentally preferable alternative is the alternative that will promote the national environmental
policy as expressed in NEPA's Section 101. Generally this means the alternative that causes the least damage
to the biological and physical environment; it also means the alternative which best protects, preserves, and
enhances historic, cultural, and natural resources." (Council on Environmental Quality, "Forty Most Asked
Questions Concerning CEQ's National Environmental Policy Act Regulations [40 CFR 1500-1598], Federal
Register Vol. 46, No. 55, 18026-18038, March 23,1981:Question 6a.)
NEPA's Section 101 establishes the following goals:
• Fulfills the responsibility of this generation as trustee of the environment for succeeding
generations (NEPA 101 [b] [1] ),
• Assures for all Americans productive and aesthetically and culturally pleasing surroundings (NEPA
101 [b] [2]),
• Attains the widest range of beneficial uses of the environment without degradation or other
undesirable and unintended consequences (NEPA 101 [b] [3]),
• Preserves important natural aspects of our national heritage and maintains an environment which
supports diversity and variety of individual choice (NEPA 101 [b] [4]),
• Achieves a balance between population and resource use, which permits high standards ofliving
and a wide sharing of life 's amenities (NEPA 101 [b] [5]) , and
• Enhances the quality of renewable resources and approach the maximum attainable recycling of
depletable resources (NEPA 101 [b] [6]) .
The Proposed Resource Management Plan alternative allows for the hydrologic control necessary to restore
the property to a fully functioning wetland ecosystem. Hydrologic control will also allow for recovery of the
site from subsidence at an accelerated rate.
Recovery from subsidence is necessary before a wetland driven by natural processes and requiring little
maintenance is possible. This alternative would also allow more acres of woody riparian habitat and flood
plain to be restored along the Wood River. Because of this, the Proposed Resource Management Plan
alternative affords the most potential for improved habitat conditions for the Lost River and Shortnose
suckers. Based on these factors, we conclude that the Proposed Resource Management Plan alternative is the
"environmentally preferable alternative."
Implementation
Decisions in this plan will be implemented over a period of years. The rate of implementation is tied to the
BLM's budgeting process. General priorities for overall management will be developed through long-term
budgeting processes and in consultation with other agencies, tribes, and government units. Those priorities
will be reviewed annually to help develop work plan commitments for the coming years. Although the
Resource Management Plan implementing actions are described by individual resources, most activities will
be consolidated and considered in an interdisciplinary, multi-resource process.
Appendices - 739
FEISfor the Revision of the Western Oregon RMPs
Valid Existing Rights
This plan will not repeal valid existing rights on public lands. Valid existing rights are those rights or claims
to rights that take precedence over the actions contained in this plan. Valid existing rights may be held by
other federal, state or local government agencies or by private individuals or companies. Valid existing rights
may pertain to reserved mineral rights mining claims; mineral or energy leases; and easements or rights-of-
way; reciprocal rights-of-way and water rights.
Administrative Actions
Various types of administrative actions will require special attention beyond the scope of this plan.
Administrative actions are the day-to-day transactions required to serve the public and to provide optimum
use of the resources. These actions are in conformance with the plan. They include, but are not limited to;
permits or sales for traditional or special forest products; competitive and commercial recreation activities;
lands and realty actions, including issuance of grants, leases, and permits and resolution of trespass;
facility maintenance; law enforcement and hazardous material removal or mitigation; enforcement and
monitoring of permit stipulations; cadastral surveys to determine legal land or mineral estate ownership;
and engineering support to assist in mapping, designing, and implementing projects. These and other
administrative actions will be conducted at the resource area, district or state level, sometimes in
partnership with other landowner or agencies or entities. The degree to which these actions are carried out
will depend upon BLM policies, available personnel, funding levels, and further environmental analysis and
decision making, as appropriate.
Mitigation and Monitoring
All protective measures and other management direction identified in the plan will be taken to avoid or
mitigate adverse impacts. These measures will be taken throughout implementation. All practical means to
avoid or reduce environmental harm will be adopted, monitored, and evaluated, as appropriate.
Monitoring will be conducted, as identified in the approved plan. Monitoring and evaluations will be
utilized to ensure that decisions and priorities conveyed by the plan are being implemented, that progress
toward identified resource objectives is occurring, that mitigating measures and other management
direction are effective in avoiding or reducing adverse environmental impacts, and that the plan is
maintained and consistent with the ongoing development of BLM state office, regional, and national
guidance.
Public Involvement
Scoping of the Upper Klamath Basin and Wood River Wetland Resource Management Plan/Environmental
Impact Statement began in January 1993, with a public meeting and the formation of the Wood River
Wetland Team. Anyone who participated in the development of the plan was considered a team member.
Active public involvement has been stressed throughout the plan development process. Public involvement
has included information mailers, public meetings, field trips, distribution of planning documents,
document review, comment periods, informal contacts, and group presentations to share information. The
Wood River Wetland Team had 18 meetings open to the public between January 1993 and May 1995. The
team reviewed all portions of the draff and final Resource Management Plan /EIS, and provided comments
that were considered throughout the development of these documents. The Bureau of Land Management
has been careful to inform this group that all management decisions for this property will be made by the
Bureau. The team will continue to meet and provide comments on project implementation and monitoring.
Appendices - 740
Appendix S - Wood River Wetlands and West Eugene Wetlands Management Plans
On March 11, 1994, a Notice of Availability of the Draft Resource Management Plan/Environmental Impact
Statement was published in the Federal Register by the BLM, in addition to a Notice of Availability by
the Environmental Protection Agency. Newspaper and other media were also notified of the document
availability, the length of the comment period, and the dates, times, and locations of public meetings. The
Draft Resource Management Plan/Environmental Impact Statement was sent to a list of approximately 250
individuals, organizations, and agencies.
On July 28, 1995, the Environmental Protection Agency published a Notice of Availability in the Federal
Register, which initiated the official protest and public comment period for the Upper Klamath Basin
Proposed Resource Management Plan/Final Environmental Impact Statement. In addition, on July 18,
1995, a Notice of Availability was also published in the Federal Register by the BLM. Newspaper and other
media were also notified of the document availability, the length of the protest period, and the date, time,
and location of public meetings. The Proposed Resource Management Plan/Final Environmental Impact
Statement or summary were sent to a list of approximately 300 individuals, organizations, and agencies.
Approximately 20 people attended meetings. The district manager received no comment letters. There were
no objections or recommendations by the Governor on behalf of any state or local government entity. There
are no known inconsistencies with officially approved or adopted natural resource related plans, policies, or
programs of applicable state or local governments or Indian tribes.
The official period to protest the proposed plan closed on September 18, 1995. No valid protests were
received. A few non-substantive changes have been made in the text of the approved plan to reflect
typographical corrections, improve clarity, or demonstrate consistency with various regulatory procedures
or policies.
Recommendation
With full knowledge of the commitment to resource and ecosystem management represented by the plan,
I recommend the adoption of the Upper Klamath Basin and Wood River Wetland Resource Management
Plan.
/s/ Edwin T. Singleton 10/25/95
Date
Edwin J. Singleton
District Manager, Lakeview District, Lakeview, Oregon
State Director Approval
I approve the Upper Klamath Basin and Wood River Wetland Resource Management Plan as recommended.
This document meets the requirements for a Record of Decision as provided in 40 Code of Federal
Regulations 1505.2.
/ s/ William L. Bradley 1 1/21/95
Date
for
Elaine Zielinski
State Director, Oregon/Washington
Bureau of Land Management
Appendices - 741
FEISfor the Revision of the Western Oregon RMPs
Appendices - 742
Appendix S - Wood River Wetlands and West Eugene Wetlands Management Plans
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Appendices - 743
Summary of Effects Tabie - Comparison of Alternatives
FEISfor the Revision of the Western Oregon RMPs
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Appendices - 744
Appendix S - Wood River Wetlands and West Eugene Wetlands Management Plans
The Resource Management Plan
Introduction
This document contains the basic information needed to implement the Upper Klamath Basin and Wood
River Wetland Approved Resource Management Plan. The text included in this Approved Resource
Management Plan replaces the text of Alternative D of the Upper Klamath Basin and Wood River Wetland
Proposed Resource Management Plan/Final Environmental Impact Statement (PRMP/FEIS). However,
this document should be used in conjunction with that PRMP/FEIS for topics such as a discussion of the
Planning Area; Purpose and Need for the Action; Relationship of the RMP to BLM Policies, Programs,
and Other Plans; Coordination and Consultation; Use of the Completed Plan; Adaptive Management;
Requirement for Further Environmental Analysis; The Budget Link; and Research. The appendices of that
PRMP/FEIS have not been reprinted here and also apply to this plan.
There were no changes made between the proposed plan and the approval of this plan as a result of protests
since no protests were received. Some minor changes were made as a result of on-going internal review to
adjust the language of the plan to fit its approved status.
The appendices contained in the PRMP/FEIS contain detail that was deemed non-essential for the purposes
of this document. Based on the lack of changes needed it was felt that a portable approved plan usable by the
public while actually on the property would be better than reprinting all of the details. This is particularly
true for the appendices covering wetland and stream restoration options and the monitoring plan. Those
appendices contain details that will be considered during implementation of this plan. This plan is expected
to be implemented over a period of years. Readers should keep both this document and the Proposed
Resource Management Plan/Final Environmental Impact Statement for future reference.
The text and maps included with this document are sufficient to give the average reader a good idea of
what will happen on the property. For those readers interested in more details, using this document in
conjunction with the Upper Klamath Basin and Wood River Wetland Proposed Resource Management
Plan/Final Environmental Impact Statement will give a complete picture of what is expected to occur on the
property.
Plan Objectives
Restore the Wood River property to its previous function as a wetland community, within unalterable
constraints (such as water rights, land ownership patterns, and available funding). Long-term improvement
in water quality entering Agency Lake is a goal; however, localized decreases in water quality could occur in
the short term. Emphasize improving and increasing wetland and riparian habitats for federally listed fish
and other wildlife. Allow labor-intensive, highly engineered wetland restoration methods using complex
designs; however, the preference would be to use wetland restoration systems and methods that were
designed with less labor-intensive practices using the existing landscape features (such as topography) and
natural energies (such as stream flows) of the property. Use vegetation management (including water level
and flow fluctuations, livestock grazing, fire, chemical and mechanical manipulation) to develop desired
plant communities. Allow pilot studies for research purposes. Use adaptive management, the process of
changing land management as a result of monitoring or research. Manage recreation resources for low to
moderate use levels.
Appendices - 745
FEISfor the Revision of the Western Oregon RMPs
Water Resources
Objective: Improve the quality and quantity of water entering Agency Lake from this property.
Restore the majority of the property to a wetland community dominated by native species to the extent
that it would not adversely impact adjacent landowners. Improvement in water quality entering Agency
and Klamath Lakes would occur through changes in current management practices and passive filtration.
The current drainage/irrigation system could be used or modified to manipulate water levels and/or soil
moisture conditions to maintain a wetland in properly functioning condition. The BLM will cooperate in
studies to determine the effectiveness of the wetland system(s) in improving water quality and storage. The
BLM will comply with all applicable Oregon State water laws and cooperate with the Meadows Drainage
District in its operation and use of the Wood River property's irrigation system.
The techniques used for wetland restoration will be a combination of existing and constructed water control
structures (berms, ditches, screwgates, and flashboard darns), and the encouragement of natural processes
(plant succession, channel meandering). Several likely restoration scenarios are summarized in Table 6 of
the Proposed Resource Management Plan/Final Environmental Impact Statement (PRMP/FEIS, see also
Appendix F of the PRMP/FEIS for a more detailed description). Actual wetland restoration methods would
not vary significantly from methods described in the PRMP/FEIS. A site specific engineering design will be
completed prior to construction. The BLM will coordinate with the Oregon Department of Environmental
Quality, US Fish and Wildlife Service, and the Army Corps of Engineers (among others) to obtain any
permits necessary prior to constructing stream channel or wetland restoration projects.
Stream Channel Restoration Options
Objective: Provide a wider riparian area and floodplain along Wood River and Sevenmile Creek to allow
meandering flow patterns to develop. Encourage vegetation diversity, channel sinuosity, and complexity.
This restoration will only occur within BLM- administered lands, will be consistent with Oregon State water
laws, and will be designed to not adversely affect water use or rights of other landowners.
Stream channel restoration will be accomplished initially as described in the Summary of Channel and
Wetland Restoration Actions Table, located at the end of this appendix (see also Table 6 of the PRMP/
FEIS). New levees will be constructed 50 to 400 meters toward the interior of the property from the current
locations. New channel meanders could be constructed between the new levee and the old levee along
the west side of the Wood River. Restoration of meandering flow patterns would then be accomplished
by removing portions of the existing levees along the streams. Other portions of the existing levees could
be left in place or used to encourage meanders in the existing dredged channels. A wider riparian area
and floodplain will be created along these streams. Natural processes would then be relied on to establish
overflow channels, backwater areas, and to increase the sinuosity and complexity of the Wood River and
Sevenmile Creek. This approach will allow the streams to establish their own courses across the floodplains
over time. The long-term goal is to have narrower, deeper, and more sinuous channels within wider riparian
areas. Because the Wood River channel has been less altered, and has the greatest potential to respond to
restoration activities in the shortest period of time, restoration of the Wood River channel will be a higher
priority than Sevenmile Creek. Therefore, restoration activities will be implemented first along the Wood
River.
Wetland Restoration
Objective: Restore the majority of the Wood River property to a wetland in properly functioning condition
dominated by a native plant community. Vegetation management could occur using several methods,
including but not limited to water level fluctuations, livestock grazing, haying, planting and seeding,
Appendices - 746
Appendix S - Wood River Wetlands and West Eugene Wetlands Management Plans
prescribed fire, and mechanical or chemical methods. Vegetation manipulation will be designed to develop
species diversity and to maintain healthy and productive communities of native riparian and wetland
vegetation. One or two small-scale, reversible pilot projects could be constructed to provide additional
information on effects on water quality, effects on wetland habitat, or for other research purposes; however
these projects will only take up a very small portion (less than 5 acres) of the property.
Wetland restoration will be accomplished as described in the Summary of Channel and Wetland Restoration
Actions Table, located at the end of this appendix (see also Table 6 of the PRMP/FEIS). Option I will be
applied to the restoration of the entire property. Internal wetland cells will be designed in such a way that
Option 2 could be incorporated on a portion of the south half of the property.
Wetland restoration through the use of a system of 4 to 8 cells, water control structures, and pumps will
allow hydrologic control to be maintained on the property. This hydrologic control will allow for greater
biological diversity to develop. This system of cells and structures will facilitate a wide array of management
options (for example maintaining different water levels in different cells), including periodic aeration of the
soil surface. Intermixing of waters from the wetland with those of Agency Lake could still be incorporated
using this approach on a portion of the wetland.
Special Status Species Habitat
Objective: Manage for a diversity of habitats for special status species (see Table 3 of the PRMP/FEIS).
Maintain a viable population of spotted frogs on the property. Protect habitats of federally listed or
proposed threatened or endangered species; to avoid contributing: to the need to list category I and 2 federal
candidate, state listed, and Bureau sensitive species.
Management of special status species habitats will also be consistent with the Klamath Falls Resource
Area s Approved RMP. If any special status species (federally or state listed as threatened or endangered,
federally proposed as threatened or endangered, category I and 2 federal candidate, and Bureau sensitive)
are suspected in an area proposed for a management activity, field surveys would focus on those species
. If populations of these species are found, then the plants or animals and their habitats will be protected
through modification or abandonment of management actions as appropriate to eliminate impacts to
federally listed or proposed species and to not contribute to the need to list category I and 2 federal
candidate, state listed, or Bureau sensitive species.
It a project could not be altered or abandoned to eliminate a potential effect on a federally listed or proposed
threatened or endangered species, then consultation with the U.S. Fish and Wildlife Service would be
initiated under section 7 of the Endangered Species Act.
For state listed and state proposed species, the BLM will coordinate with the appropriate state agency to
develop policies that would assist the state in achieving its management objectives for those species.
Fish and Wildlife. Management actions for special status fish species will include removal and movement
of portions of existing levees and dikes. Encourage natural processes to form a more sinuous channel with
greater habitat complexity in the Wood River and in portions of Sevenmile Creek. The placement of natural
structures such as logs and boulders will be considered to achieve desired channel conditions and increase
the amount of cover for fish.
Plants. Inventories will be conducted if appropriate habitat is identified. Coordinate and cooperate with the
Oregon Department of Agriculture regarding management activities with potentially adverse effects on a
state listed or proposed plant species.
Appendices - 747
in') for lire Revision^ of the Western^ Oregtm l/Ml’t
Fish and Wildlife Habitat
Objective: Improve habitat conditions for suckers and salmonids; improve habitat for raptors and
neotropical migratory birds; and optimize waterfowl habitat within the constraints of other resource
objectives.
Native tree species will be planted in clumps along major dikes for cover and future nest and perch sites,
as well as to mitigate dike erosion. Portions of levees will be planted with native shrubs to provide nesting
and roosting areas for neotropical migrant birds. Vegetation management (using water fluctuations,
livestock grazing, prescribed fires, mechanical or chemical manipulation, or other methods) could be
used to maintain, enhance, or create diverse habitats within the wetland. Riparian habitat along the Wood
River and Sevenmile Creek will be restored and maintained by planting riparian vegetation and protection
from grazing. River meanders will be encouraged to improve fisheries habitat. Channel morphology and
substrate will be studied as they relate to factors limiting fish production, and will be modified as necessary
to encourage natural sinuosity and narrow, deep channels.
Nest islands, upland areas, and other structures could be developed to provide wildlife habitat.
Vegetation
Fire Management
Objective: Suppress all wildfires, and reintroduce fire as an ecosystem process by using prescribed burning
as a management tool to support the primary goal of wetland restoration.
An initial attack agreement for suppression of wildfires will be established with the Winema National Forest,
U.S. Fish and Wildlife Service, and/or the Oregon Department of Forestry. Parameters will be developed
under which fire could be introduced as an ecosystem process to achieve resource management objectives.
Prescribed burning could be implemented through planned ignition, as determined by wetland restoration
methods; by meeting the other objectives of improving water quality and quantity, and restoring wetland
habitat for endangered suckers and waterfowl; and to further research objectives. To mitigate air quality
problems, all burning will be conducted during unstable atmospheric conditions and with favorable
transport winds.
Noxious Weed Management
Objective: Manage noxious weed species to facilitate restoration and maintenance of desirable plant
communities and healthy ecosystems; prevent introduction, reproduction, and spread of noxious weeds
into and within the property; and manage existing populations of noxious weeds to levels that minimize the
negative impacts of noxious weed invasions.
Federal agencies are directed to control noxious weeds on federal lands by the Carlson-Foley Act (Public
Law [PL] 90-583) and the Federal Noxious Weed Act of 1974 (PL 93-629). Noxious weed management on
the Wood River property will be part of an integrated noxious weed management program as described
in the Integrated Weed Control Plan and Environmental Assessment (EA) for the Klamath Falls Resource
Area (OR-014-93-09). An appropriate combination of manual, mechanical, chemical, and biological
methods, and water level manipulation will be used to control noxious weed species. Seasonal timing will
be considered in any control program. Herbicide use will be in accordance with the program design features
outlined in the KFRA Integrated Weed Control Plan and EA.
Appendices - 748
Appendix S - Wood River Wetlands and West Eugene Wetlands Management Plans
All chemical and some mechanical treatments for noxious weeds will be accomplished through a contract
with Klamath County or other appropriate contractors, if populations of these species are identified for
control. Appropriate herbicides will be used for treatment of noxious weeds in or adjacent to wetlands.
Biological control organisms are supplied and/or distributed by the Oregon Department of Agriculture
(ODA) through a memorandum of understanding between the ODA and the BLM's Oregon State Office.
Livestock Grazing
Objective: If and where appropriate, use livestock grazing as a vegetation management tool to support the
primary goal of wetland restoration.
Use livestock grazing mainly as a management tool to support the primary goal of wetland restoration.
Livestock grazing could be allowed if needed to create or maintain wildlife habitat. No long term grazing
lease will be issued. Levels and duration of grazing, as well as maintenance and construction of range
improvement projects, will be dependent on the need to meet management objectives. It is expected that
the amount of grazing will be significantly less than that allowed under Alternative A of the PRMP/FEIS,
and it is possible that no grazing will occur. It is estimated that grazing use will not exceed 1,500 animal unit
months in any given year. Any livestock use could be authorized and allowed via a competitive bid contract
for the purposes of vegetative management and evaluated on a year by year basis. In lieu of or in addition
to livestock grazing, haying ot portions of the property will be considered as an alternative if vegetative
removal was necessary to meet the wetland restoration goals. The allotment is initially categorized as an
"M" or maintain category allotment. The same planning (RMP/EIS) constraints and direction listed under
Alternative A of the PRMP/FEIS would also apply to this alternative.
Cultural Resources
Objective: Protect known cultural resources (including both historic and prehistoric resources). A class
1 inventory will be conducted on the property. A class 1 inventory is a comprehensive literature search to
determine the existence of cultural remains within the project area. A class 3 survey, which is an intensive
survey of the ground to identify and record all cultural resource sites within a specific location, will be
completed prior to commencing any surface-disturbing activities. An archaeologist (from the BLM and/or
Klamath Tribes) will be on-site during these activities to monitor the site. Testing for artifacts could be done,
based on surface or stream bank indicators.
Consultation with the Klamath Tribes will occur during the regular monthly BLM\Klamath Tribes meetings
on cultural resources, or at other times, if deemed necessary. This consultation will include updates on
existing projects and discussion on new projects anticipated on the Wood River property. Consensus will be
sought on all projects.
Recreation
Objectives: Provide opportunities for roaded natural and semi-primitive recreation experiences
(opportunities to have a high degree of interaction with the natural environment, to have moderate
challenge and risk and to use outdoor skills). Manage the area for low (6 to 10 parties per day) to moderate
(10 to 50 parties per day) recreation use levels (moderate near developed sites and roads, and low to
moderate in other areas). Manage for day use only.
Recreation use and facilities will be secondary to the overall objective of wetland restoration and water
quality improvement. Based on informal recreation use monitoring during calendar year 1994, some trends
in recreation use levels have been identified (See Chapter 2, Recreation section of the PRMP/FEIS). The
property has been designated closed to off-highway vehicles, except for designated roads and trails and for
Appendices - 749
FEISfor the Revision of the Western Oregon RMPs
administrative use. An improved parking area (graveled or paved) at or near the entrance to the Wood River
property, sufficient to hold 20 to 25 vehicles (for peak use periods) will be provided. The facilities provided
will meet the roaded natural and semi-primitive recreation opportunity objectives.
In addition to use levels, the BLM will consider user convenience, safety, and resource protection when
determining what recreation facilities to provide. Such facilities could include, but are not limited to,
improved (graveled or paved) parking areas and roads, toilets, interpretive signing, nature trails (canoe,
foot, mountain bike, horseback, and/or ski trails), and a boat ramp to access Wood River (see Map 7
of the PRMP/FEIS). The BLM will coordinate construction activities with the Oregon Department of
Environmental Quality, U.S. Fish and Wildlife Service, and the Army Corps of Engineers (among others)
when designing and constructing recreation facilities.
Maintain current recreation use levels during waterfowl hunting season and allow for greater motorized
access and increased use levels during the rest of the year. A likely development scenario includes the
previously mentioned improved parking area at or near the entrance to the Wood River property, sufficient
to hold 20 to 25 cars. A toilet, 1 to 2 picnic tables, garbage cans, and interpretive signs could also be provided
at the parking area.
During the non-hunting season, better access to the property could be permitted. An improved (graveled)
parking area (approximately one quarter acre in size) near the Wood River bridge, along with a primitive
boat ramp (suitable for launching a small boat or canoe) and toilet could be provided. Nature trails could be
provided in the vicinity of the Wood River bridge (including canoe trails, interpretive trails along the dikes
and newly constructed trails using construction techniques similar to dikes).
The area is closed to overnight use. No campfires, fireworks, or smoking will be permitted. Off-highway
vehicles will be limited to designated, signed roads (this will also include seasonal closures), as determined
by use levels and needs.
The location and type of facilities, as well as which roads will be open or closed to motorized vehicles, will
be determined as recreation use levels are established and the design and location of stream and wetland
restoration projects are defined. Because of the increased recreation management and investment, the
area is identified as a special recreation management area, as required in BLM Manual 1623. Hunting,
fishing, sightseeing, and wildlife viewing will be supported by providing facilities. Hunting regulations on
motorized vehicles, such as motorboats, and fishing use will be monitored and coordinated with the Oregon
Department of Fish and Wildlife (ODFW); hunting and fishing policies could be developed and/or adjusted
based on results of the monitoring data. Safety zones will be established if needed for user safety and
wildlife viewing, and shooting will be prohibited in these zones. Jet boats and air boats will be prohibited
in the existing Wood River Marsh and in other wetland areas as they are constructed. Limits on speed and
wakes will be coordinated with the Oregon State Marine Board and could be recommended to mitigate
environmental degradation. Small motorized boats could be allowed to enter the wetland areas, during
times when waterfowl nesting is not occurring. The area will be identified as a Watchable Wildlife site in
cooperation with the ODFW.
Visual Resources
Objective: Ensure management actions meet VRM Class II objectives.
The property will be managed to meet Visual Resource Management (VRM) Class II objectives, which is
to retain the natural character of the landscape, which is a wetland. Changes in any of the basic elements
(form, line, color, texture) caused by a management activity should be low. Contrasts are seen, but must not
attract attention of the casual observer. Changes must repeat the basic elements found in the predominant
natural features of the characteristic landscape. Projects or management actions will be evaluated using
Appendices - 750
Appendix S - Wood River Wetlands and West Eugene Wetlands Management Plans
the BLM's contrast rating system to measure the degree of contrast between the proposed activity and the
natural features of the landscape, and will meet or exceed VRM Class II objectives (BLM Manual Handbook
H-8431-1).
Special Areas
Objective: Manage the property as an area of critical environmental concern (ACEC); and protect and
restore the area’s relevant and important values, which are cultural, fish and wildlife values, and natural
processes and systems.
The Wood River property has been designated an ACEC (through this plan process). The Wood River
property was evaluated for designation as an ACEC and found to meet the relevance and importance criteria
and evaluation process as described in Appendix G in the PRMP/FEIS. This approved Upper Klamath Basin
Resource Management Plan/Record of Decision serves as the management plan for the area.
Mineral and Energy Resources
Objective: Ensure mineral and other activities do not conflict with other management goals, the lands will
be withdrawn from (closed to) settlement, sale, location, and entry under the general land laws, including
the United States Mining Laws (30 USC Ch. 2 [1988]) , but not the mineral leasing laws, subject to valid
existing rights. Energy and mineral leases will be subject to a "no surface occupancy" stipulation. The
"no surface occupancy" stipulation could be waived if it was demonstrated that the mineral activity was
consistent with other management goals. Mineral or energy activity also would be subject to other federal
and state regulations, such as the Clean Water Act, Endangered Species Act, etc.
Soil Resources
Objective: Ensure that undue degradation of soils does not occur. Encourage and/or allow the natural
accumulation of peat.
Management activities will be designed and monitored to meet the soils objective. Studies that determine
the potential of peat and peaty soils as pollutant and nutrient filters will be encouraged.
Air Resources
Objective: Meet the goals of the Federal Clean Air Act, as amended; the Oregon Implementation Plan; the
Oregon Smoke Management Plan; and prevent the deterioration of air quality within the Klamath Falls
Special Protection Zone (described in the Oregon Smoke Management Plan).
Monitoring of air quality will be conducted as required by regulation and peer practice. Emissions of
fugitive dust and smoke will be limited to operations associated with maintenance and restoration activities.
Roads and Facilities
Objective: Provide adequate roads and facilities (quality and quantity) to support management objectives.
Existing easements with adjacent property owners are recognized and the BLM will follow the terms and
conditions of those easements. Roads could be improved (graveled or paved), consistent with overall
Appendices - 751
FEISfor the Revision of the Western Oregon RMPs
i >bjec 1 1 ves of this alternative and as determined by use levels and needs. Motorized vehicle use is limited to
improved, designated, and signed roads (this could also include seasonal closures; see Map 7 of the PRMP/
FEIS and the recreation section for more details). Exceptions to this will be for people with administrative
access or existing easements. Dike maintenance (such as rip-rapping, and planting trees and shrubs) will
be accomplished to provide safety to vehicle users and to maintain the integrity of the dikes. The bridge
over Wood River will be inspected and maintained according to BLM bridge maintenance schedules (BLM
Manual 9112.4).
If necessary to be consistent with overall management objectives, existing facilities, including cattle guards,
fences, gates, ditches, bunkhouse shack, corral, and livestock handling facilities could be removed and
disposed of in accordance with BLM property procedures (BLM Manual 1527.2 and 1533.2). The pumps
and pump house will be maintained, and improved if necessary (see Map 7 of the PRMP/FEIS).
Plan Monitoring
The BLM planning regulations (43 CFR 1610.4-9) call for monitoring and evaluating resource management
plans at appropriate intervals. The purposes of monitoring and evaluating the Upper Klamath Basin and
Wood River Wetland Resource Management Plan/Environmental Impact Statement (RMP/EIS) are to:
• Track progress of RMP implementation and assure that activities are occurring in conformance
with the plan (implementation monitoring);
• Determine if activities are producing the expected results and meeting stated objectives
(effectiveness monitoring); and
• Determine if activities are causing the effects identified in the EIS (validation).
• Ensure that research results are well documented and shared with the community.
Implementation of the RMP will be monitored to ensure that management actions are being implemented
and are meeting their intended purposes. Specific management actions will be compared with RMP
objectives to ensure consistency with the intent of the plan.
Monitoring will be conducted as specified in the following sections, and the results will be reported in
an Annual Program Summary, along with monitoring results from the RMP for the rest of the Klamath
Falls Resource Area. This annual summary will be published starting the second year following initial
implementation of the RMP. The Annual Program Summary will serve as a report to the public, track and
assess the progress of plan implementation, and state the findings made through monitoring. For the Upper
Klamath Basin portion of the program summary, the BLM will determine if:
• management actions are resulting in satisfactory progress toward achieving RMP objectives;
• management actions are consistent with current policy ;
• original assumptions are valid and impacts are within the range predicted, given the reliability of
the predictions;
• mitigation and corrective measures are satisfactory and serving their purposes;
• the RMP is still consistent with the plans and policies of state or local government, other federal
• agencies, and the Klamath Tribes;
• new data are available that could result in alteration or amendment of the plan;
• requirements of the National Environmental Policy Act are being met; and
• compliance is being achieved on actions authorized by the BLM.
Monitoring will occur for the following resources:
® Air Quality
• Cultural Resources, Including American Indian Values
Appendices - 752
Appendix S - Wood River Wetlands and West Eugene Wetlands Management Plans
• Water Resources
• Vegetation
• Riparian Areas
• Wildlife Habitat
• Fish Habitat
• Special Status Species
• Areas of Critical Environmental Concern
• Visual Resources
• Recreation
• Grazing Management
The Upper Klamath Basin and Wood River Wetland Proposed Resource Management Plan/Final
Environmental Impact Statement contains the complete details on when and how monitoring will take
place.
Summary of Stream Channel and Wetland Restoration Actions Table
Stream Channel Restoration:
Restore meandering flow patterns for the Wood River and Sevenmile Creek by relocating portions of the existing levees along these streams.
Prior to relocating the existing levees, new channel meanders could be constructed along the west bank of the Wood River. New levees would be
constructed 50 to 400 meters interior to the existing levees. Portions of the existing levees could be left in place as islands or used to construct point
bars. Natural hydrologic processes would then be allowed to establish wider riparian areas, and to enhance channel sinuosity.
Wetland Restoration:
Restore wetland by operating the existing canal and pump system. The wetland would be restored and maintained by manipulating water levels within a
system of berms and water control structures. Water levels would be manipulated to manage wetland vegetation within 4 to 8 created cells. This system
would be designed so that option 2 could be incorporated at some point in the future.
Restore wetland by re-establishing the lake-wetland interface (opening the property's interior to prevailing water levels in Agency Lake). This could
be accomplished by installing pipes or culverts through the dike along the north shore of Agency Lake, allowing lake water passage between the lake
and the south half of the property. Culverts or other water-control structures could also be installed in the east and west dikes, and in the interior
containment dike separating the north and south halves of the property. This would allow for movement offish, wildlife, and plant species between
Agency Lake, Wood River, Sevenmile Creek, and the main property, as well as restoring wetland habitat to the majority of the Wood River parcel.
See Table 6 of the PRMP/FEIS for a comparison of these actions against the other alternatives analyzed in that EIS. See also Appendix F of the PRMP/FEIS for
a more complete description of these options.
Appendices - 753
FEIS for the Revision of the Western Oregon RMPs
Map i. Vicinity And Project Location Map, Klamath River Watershed
Wood River Wetland
Project Location '
Agency
Lake
River
JAg*nc*L \
Lake if -fe. \
Medford
v ©rookifia*
» Cl OREGON
U T " — - ——
O j CALIFORNIA
m*r
Lake
Klamath Pulls
i
Vv
X Vicinity and Project
3 Location Map
Ttmtr
Latte
v <4r/ Klamath River Watershed
) f Wee*erwflle ^ /
ft C 'V^\o //
t Rfd$n$
X
X
v^s* i
U j
% %y
V ^
d id 2-t 50 so
KJIcnnsters
—
Appendices - 754
— — — —
Appendix S - Wood River Wetlands and West Eugene Wetlands Management Plans
Map 2. Existing Conditions As Of 11/95
1995
0.5. Department of the interior
Bureau of Land Management
WOOD RIVER WETLAND
Lakevlftw District, Oregon
Existing Conditions as of 11/95
LEGEND
J Privola Property
Col*
XVAWW
mm p<lrt,in«
1000 0 1000 2000 JOOO *000 5000 fEET
Appendices - 755
FE1S for the Revision of the Western Oregon RMPs
Appendices - 756
Appendix S - Wood River Wetlands and West Eugene Wetlands Management Plans
Figure S-i. Wildlife Species Checklist
Wildlife
Species
Checklist
5*.
59-
ftsfasjMe
Coyote
60, Wadt Brsar
61,
BtrfXitei
Ii2. Klngiwek Sunt*
long-tert Mwmndrr
feu*-i-$ter>ned Neat
PftSfic Oram® Frag
BnSfrc®
Sfi£®«S F»g
Western W
WaSSfttti Ptrad TMle
Shon-hattred Lizsftl
Negfbnjsfi Lmrt
Wa&ra-n Fence Ltkard
Wssaa stiat
YeUWbfflisd&ie*'
Onplua Snake □
Cnfnmon Carter Snake O
Wwim TwreKfial Garter Snake D
Wtsiern Rattlesnake O
RuMsw Sea □
Mwsniii
£3
»
21
33-
23
24
25
26
ll
29
30
31
32-
33
34
33
36
37
3B
38
4I>
41
VigfttaS SihMW
Trawhrirfge Shrew
StaSrem Water Shrew
Water Shrew
Memm Shrew
Broad-footed Mote
Myutis
rlia
yurts
Unary ®a»
Ptfed Bat
TcwbmmTs i&g-eared But
Big Brawn Sat
Saawfdije® Hare
Wtiite-iailed lackrnbbiL
Bterk-iaik-d tetoabtet
Cattail's Oattcmtasl
Lew* Qiiprowk
Yellow Rue CMpitsak
Adding GrousS Squirrel
CnUfbrsaa Ground Sniteral
Western desy Seated
42.. Yel|aw-he|las3Manrol
43. Northern Pocket Gopher
44. fafaa*™ Packet Gopher
4 3 . Western Ehrwt Mesne
46. Dear Moure
*7. Bushy-tailed Wcrodnri
46 . Dusky- Tooted WaodM
49. Bssflref Vote
Sft Mountain We
51. -California. Vole
52, Long-Mid Vole
5 9 Townsend's- Vole
54. Musks*
35, Beaver
56. Bn use Moms®
57. WMtimJuajtofMoaK
WsgtaJl
62. fe.ci.-noa
63. Mink
64 Long-saiUd WNuwi
65. aawt-t«M Weasel
66. Norway Rat
67. Spotted Skunk
6#- Striped Stank
69. River Otter
TO. 'Mger
71- Mountain lion
72. Bobcat
72 Grey Fox
73. Efed Fox
75 Ell
7k Mai* Dm
Mrds
77 Eared Grebe
71. Pied-billed Grebe
79 KeaM Grebe
80- Cl mV* O-rh-r
a I. WfeHisrfi Gf«be
42 Amman White Palkao
33. PotAltMracted Cormorant
Aasahtaa Blttea
Least Bittern
Blsck-ctawacd Ntffrd Heron
Gres! feel
Snowy Epd
Gr®4 Blue Here*
'Wtofe-tajed IbB
Sandhill Cmm
Tuadffit Swsa
Greater White, feinted
SmwChtffi*
r«b" Qsma
Canada <3oos®
Common Loon
Malted
Green, waged Teal
AttMfieM wlpott
North em Pfeteit
Northern Shavtdtff
Slw- winged T»S
Ctomron Teal
ItejiMy Dyek
Wbndduck
CtaratMfc
Redhead
Kint-iioEtod Puck
Lesstt- Seatip
Bwm't Gnltoey©
ComaBn. OeMsaep
ftufitehsad
Common MagSMer
Hooded Mergarcur
GMWill
Virginia Rail
WmSkd
Sum Rail
American Awnoa
Blact-®ckedStell
Long-btlW Dnwtehor
Killdes
Willed
C>*:i!«r Y-il tea 1 1 ».»:
IjftiSKr Y«Hgw1m8
Lon g-Mted Cesrfew
] §28. Spatted Sattfipipar
] 129, Lewd Snafaper
3 3 ML Wilson's Phnianype
3 131, Cotainea Snij*
!1 3®. Dunlin
133. Atawfoa* Coot
134. Ring-hilled Gull
9135- Cfflftrfdia <Ml
i 136, MnfUffte's G4I
J 137. Forster's Torn
3 13*. llaefcftn
3 139. Caspian Tern
i] 40. CtoMfifl iSsale,
141 Bald Eagle
] 142: Nailham Harriet
3 149, Sb*p-s3trfnn*i5 Hawk
3 144. CwptfrkMrt
i!4S. Red-tailffl Hawk
146 Rough-legged Hwk
147. Osprey
14*. Amen-sas Rerael
3 149, PWrieFalron
1 150. Peregrine Falcon
I 141. fin-toy Vulture-
1 1SJ- OdifwwiaQuaa
3 1 53. fettg-ti«crl»3 Phufflaiit
I 154. IrskDov*
3 155, Mtofliiki Dhte
il56. -Stet-esned O#]
1 57 , Ljjsii -«»ed OwS
J 15* <3rHMHMaad.(MI
] 159. Walerr, Screech Cnsl
P 160. Nfiflfeera Ssw-whst Owl
□ 161. Coroiroa Bern CM
8162. Viutt's Swift
163. Common ^TlgMswi
D 164. Anna's IluisiiianjdMid
GeDBe □ 165. tJfc li-npe Bunnnanghird
□ 1 66. RliTous Hufflaninghtrd
O 167, Nwttest ;Ricfca
p 168. Red-raped Sa^ IJCter
O 169. fed- re-tasted Sapsucker
P 170. ftew-nv WaodpeekAf
□ 171, Hniry W«>:d pecker
D 172. Wtaterc iSn^siri
BI73. Asb-lhnwfid Flyc*e&»
174, Otive-fided RycUdrer
p ITS. WMtsai W0iid-«*«
0 ITS. fey'sPInwte
P 177. CordiGiwifl Hyi*aiCf
Q 178, WSlktw Rycsieher
B m. Hcenedlirk
ISA. Tre* Swallow
□ 181, Vimles-green Swallow
D l S3- atllSwallM-
B183. iantSwallw
184. ttetten Rctigh- winged Sw®£«
D 185, Bam Swallow
O T8S. BeltftgKjngfirfbtt
□ 187, SirthTay
□ 188. Rlack-bilted l^it*
D 1®, Common Saves
□ 190. jVmeftiin Cm*
p! 191. Bl®ck-capp«d Qhlcksds*
O 192, Moustait! Cfaudbidfe
□ 193. Bushiis
P 194, How Wren
Cl 195. Mnnth Wren
Q 196, fowlck’t Wren
□ 197. Wls-'CT Wrm
Q 198. Ruhy^rnwnbd Kijjglet
O 199. Gol<kn-«n*Ded Kinglrj
I 2i)0, Blue-gray Gjjt catcher
| 2BI. Anserkan Robin
I 201, VWed'Ttasfe
I 3631- Western Btaebard
I 294, Ltsggafoeal Shfll*
I 205. Nwiresm Shrike
I 206. Cefor WaKwiarg
I m Solr-aryVir™
I 20S. Etarepean Swriisg
I 2D9, Warbling Vlr*o
| 210, OnHSgJf*«Wtted Warbler
'311. Nashville Watof
I 212, ¥eltowjrH«fiKi Warbles
' 213, YeUaw W»ts9«
1214. M*5Llltvrf,y'i. Warbler
I 2 IS. Wikan’s Warbler
1 316. Tansmsa Ifellowlhral
1 217. Btedk-toied CjmatoA
1 211. Lftsttill Btttttina
I 219. Gfifirttdl*! Tcwlwe
i 230. Rufnus-sided Tcwhee
I 221. . OtlifmrEia Toute
1222. Vstpef Spamtw
I 22'J. Brewer’s Sparrow
I 214. Savfimfi-ih ilp-jr-row
I '225, Scmg Spsmn*'
I 216. Chipping Spatow
I 227. W.M»-cf owned Spanow
] 231. indeTi-cnreivned Spurts*'
229, Psx Sparrow
I 230 . Dot kTyed lun e*
I 231 , LLaiola'4 Sprrmr
!m Lart Sparrow
I 233. Wtasteirti MtettSjwlat
!' 234, YeBsw-tesfed B.lac4felpi
I 235. Brewer's Bhidelbifd
j 276- fed-wlaged Blackbird
I 237. mnotored Blackbird
| 23#. Brawn., headed Cowbird
I 239. NiMha-n Gttolc
I 240- Wesaera Tanker
I 24 L Hs>js« Spm&w
1242. Pine Sis Idn
I 343, Affie&ea CtoMflscfc
I 244, Lesser Goldfinch
124$. Purple Finch
1 346, CMSiit’f Pinch.
I 2.47, Hc®se Finch,
I 248. Evening Qtes&esk
I 249. New
I 250, New
Help us keep an accurate tel 0i SjHtdes
m the Wcicd Ri vcf property, For any new
tp«#S Identified, please nnte ahe place,
Em*, and tecfflori on the parpen? and
t K«n At* thing co tfic BLM office in
| Kiamath FaJ, Is at (5»3> 88 3.69 16. Thank
Too.
Appendices - 757
ItISJor llw Revision t>/ 1 he Western Oregon. RM /'■'
Summary of the West Eugene Wetlands Plan
The West Eugene Wetlands area encompasses about 3,000 acres, including numerous wetlands that wind
along major waterways through the Eugene area. Approximately 1,340 acres of the wetlands are BLM
land. Management of these wetlands is guided by the West Eugene Wetlands Plan (WEWP) through a
unique partnership of state and federal agencies, including the Bureau of Land Management, and private
organizations.
The West Eugene Wetlands Partnership currently has nine member organizations. Each signed a “Statement
of Partnership” that outlines a mission and broad goals and objectives. Collaboration and cooperation
comprise the heart of the partnership. The nine members are:
• City of Eugene
• U.S. Bureau of Land Management
• The Nature Conservancy
• U.S. Army Corps of Engineers
• Oregon Youth Conservation Corps
• U.S. Fish and Wildlife Service
• McKenzie River Trust
• Willamette Resources and Educational Network
• Long Tom Watershed Council
The West Eugene Wetlands Plan was the result of coordinated efforts that involved property owners,
interested citizens, and representatives of the development community, environmental groups, and state and
federal agencies. These various entities:
• Held community outreach meetings.
• Conducted inventories of wetlands habitat value.
• Mapped wetland boundaries.
• Determined functions of the different wetlands.
Based on the information gathered, the partners identified specific goals and developed policies important
for a system of restored and enhanced wetlands. Of major importance was designing a collaborative plan
that would strike a balance between development needs and environmental values. These goals and policies
provided the framework for the West Eugene Wetlands Plan. The partners dedicate resources within their
respective budgets, and with attention to their own missions and legal requirements, to carry out this plan.
An overall goal for the West Eugene Wetlands is to:
• Protect rare plants.
• Provide an open space greenway along the area’s major streams.
• Provide for water quality improvements that meet increased federal requirements.
• Help protect people and property from flooding.
The West Eugene Wetlands Partnership collaborates to implement the goals and policies originally
established by the West Eugene Wetlands Plan, including:
• Plans and implements wetland and stream restoration and enhance projects.
• Coordinates the West Eugene Wetlands Mitigation Bank to provide certified wetland mitigation
bank credits to satisfy mitigation requirements for local development projects.
• Maintains a native seed collection program to provide seed of locally native wetland, riparian and
upland species to use in restoration projects.
Appendices - 758
Appendix S - Wood River Wetlands and West Eugene Wetlands Management Plans
• Conducts vegetation and hydrological monitoring of restoration sites.
• Plans and implements land acquisition.
• Plans recreational facilities, such as multi-use paths, overlooks, and parking structures to access the
wetlands.
• Implements recreation and educational programming about the wetlands.
• Fosters scientific research.
Besides the goals and policies, the West Eugene Wetlands Plan identifies individual wetland sites and
recommended actions for each. Basically, the recommended actions are ideas on how to implement the
policies, and therefore are not land management actions nor are they mandatory, but serve as guidance.
Among the recommended actions are some for creating wetlands that filter pollution from storm run-
off, ways to purify storm water, and mitigation opportunities to compensate for the loss of lower-valued
wetlands displaced by development. Recommendations are reviewed, studied, and revised over time, giving
the Plan a dynamic structure. The recommended actions may or may not be implemented in the form stated
in the West Eugene Wetlands Plan. Rather, they are evaluated in light of their ability to address the plan’s
goal and policy direction while considering consistency with community aspirations, financial options, and
legal requirements. Additionally, the West Eugene Wetlands Plan lists future public improvement projects
that directly and indirectly affect the study area.
In general, the West Eugene Wetlands Plan:
• Strives to integrate environmental protection with economic development, within the framework
of state and federal wetland programs.
• Proposes a variety of techniques for spreading the costs of recommendations out among several
funding sources, over a period of time, to make the system affordable to the Eugene community.
• Facilitates addressing Federal and state requirements at the local level, which reduces time in the
permitting process.
• Provides for coordination of community resources to assist in development of lower- value
wetlands, while combining federal, state, and local resources to protect, restore and enhance the
remaining wetlands.
The complete West Eugene Wetlands Plan, with implementation details, is available online at
www.eugene-or.gov.
Appendices - 759
FEISfor the Revision of the Western Oregon RMPs
Appendices - 760
Appendix T
Responses to Public
Comments and
Comment Letters
from Congressional
Representatives; Indian Tribes;
and Federal, State, and Local
Government Agencies
This appendix provides responses to public comments received during the comment period for the Draft
EIS and copies of comment letters received from Congressional representatives; Indian Tribes; and Federal,
state, and local government agencies.
In this appendix:
Responses to Public Comments 763
Comment Letters Received from Congressional Representatives; Indian Tribes;
and Government Agencies 857
Appendices - 761
FEISfor the Revision of the Western Oregon RMPs
Appendices - 762
Appendix T - Responses to Public Comments and Comment Letters
Introduction and Background
The five-month public comment period on the Draft Environmental Impact Statement/Resource
Management Plan (DEIS/RMP) for the Western Oregon Plan Revision began on August 10, 2007 and
closed on January 11, 2008. Comments were received from private citizens; interest groups; organizations;
businesses; elected officials; state, local, and other federal agencies; and Indian Tribes.
More than 30,000 submissions were received in the form of letters, postcards, facsimiles, emails, and
electronic postings to the plan revision website. Many of the submissions were highly repetitive e-mails,
form letters, and postcards. Some submissions contained only a few lines, others contained hundreds of
pages. The submissions varied widely in their desires, their scope, and their specificity. Most expressed
opinions and suggestions but did not offer specifics.
Common themes were heard in the submitted comments. They included: don’t abandon the Northwest
Forest Plan; stop cutting old- growth; don’t clear-cut; increase harvest to provide funding for county services
and jobs for residents; these highly productive lands should be intensively managed for timber; increase
opportunities for off-highway vehicle use, and do what you can to decrease off-highway vehicle use.
The processing of the submissions should not be thought of as a tally of votes. All submissions were
treated equally and were not given weight by number, organizational affiliation, or other status of the
respondents. All of the submissions received during the public comment period were reviewed. Comments
in the submissions that identified, with a reasonable basis, errors in the analysis that would substantively
alter analytical conclusions, provide new or missing information that would substantively alter the
analytical conclusions, or proposed a new alternative that would meet the purpose and need were labeled
as substantive comments. These substantive comments were summarized into “comment statements.”
Comment statements are summary statements that identify and describe specific issues or concerns. Similar
concerns voiced in multiple letters were summarized into one comment statement.
The remainder of this appendix presents summarized comment statements and responses by issue topic.
The comments and responses are intended to be explanatory in nature; if there are any inadvertent
contradictions between this appendix and the main chapters of the final environmental impact statement,
the main chapters of the final environmental impact state. Copies of letters received during the comment
period from federal, state, and local governments and from Indian Tribes are included at the end of this
appendix.
Response to Comments
Purpose and Need
1. Comment: The EIS should be revised to analyze impacts over the life of the plan (15 to 20 years). The
assumption that the plan will be in effect for 100 years is unreasonable, because no plan adopted by the BLM
will be implemented longer than 15 to 20 years before it is amended or revised.
Response: Limiting the analytical scope to 15 to 20 years would not address the long-term effects of the
agency action, which is required by the Council on Environmental Quality regulations for implementing
the National Environmental Policy Act (40 CFR 1502.16). The BLM NEPA Handbook instructs that the
timeframes for analysis should be based on the duration of the direct and indirect effects of the proposed
action and alternatives, rather than the duration of the action itself (BLM NEPA Handbook, H- 1790-1, p. 58).
Appendices - 763
** PBISfor the Revision of the Western Oregon RMPs
2. Comment: The EIS purpose and need should be revised, because it unreasonably restricts the range of
alternatives. By focusing the purpose and need on a narrow, unreasonable interpretation of the Oregon and
California (O&C) Act, the BLM restricts the range of alternatives to actions that increase the extent and the
impacts of timber harvest, road building, and other associated activities to old-growth forests, the northern
spotted owl, the marbled murrelet, ESA listed salmon and steelhead, other special status species, and
important recreational species including big game, fish, and birds.
Response: The purpose and need articulated in the Draft EIS cannot be considered unreasonably
restrictive, because it reflects the legal mandates under which the BLM must manage, including the O&C
Act, the Endangered Species Act, and the Clean Water Act. The interpretation of the O&C Act presented in
the Draft EIS is consistent with the plain language of the O&C Act, the legislative history of the O&C Act,
and the Ninth Circuit ruling in Headwaters v. BLM, 914 F.2d 1174 (9th Cir. 1990), and therefore cannot
be considered unreasonable. As explained in Chapter 1, the Northwest Forest Plan elected to use criteria
for the management of habitat from the National Forest Management Act on both United States Forest
Service and BLM-administered lands, even though the National Forest Management Act does not apply to
BLM-administered lands. The action alternatives increase the extent of timber harvest from the levels in
the No Action Alternative, in part because the purpose and need for this action does not include applying
these National Forest Management Act criteria to BLM-administered lands. The range of alternatives covers
the full spectrum of alternatives that would address the purpose and need for the action. There are also
numerous and varied alternatives that were considered, but not analyzed in detail, as explained in Chapter 2
of the EIS.
3. Comment: The EIS should be revised to acknowledge that the O&C Act does not relieve the BLM of
its responsibility to comply with applicable environmental laws. In Portland Audubon Society v. Lujan, 998
F.2d 705 (9th Cir. 1993), the BLM argued that a court injunction barring logging from spotted owl habitat
would violate the O&C Act. The court rejected this argument, declaring: “We find that the plain language
of the Act supports the district courts conclusion that the Act has not deprived the BLM of all discretion
with regard to either the volume requirements of the Act or the management of the lands entrusted to its
care. Because there does not appear to be a clear and un-avoidable conflict between statutory directives,
we cannot allow the Secretary to “utilize an excessively narrow construction of its existing statutory
authorizations to avoid compliance [with NEPA].”
Response: The purpose and need in the Draft EIS clearly stated that part of the purpose of the agency
action includes compliance with not only the O&C Act, but with all applicable laws, including the
Endangered Species Act and Clean Water Act. The Draft EIS specifically detailed the major laws affecting
the management of O&C lands and acknowledged the applicability of environmental laws to O&C lands.
The construction of the O&C Act that the Court in Portland Audubon Society v. Lujan found too narrow
was an interpretation that the O&C Act required that a minimum of 500 MMBF of timber be offered on an
annual basis. The government argued that the injunction issued by the District Court was in conflict with
that statutory duty. The Court in Portland Audubon Society v. Lujan merely pointed out that the procedural
requirements of NEPA did not inherently conflict with the BLM’s substantive duties in the O&C Act. That
ruling is not in conflict with the Ninth Circuits interpretation of those substantive duties under the O&C
Act which were at issue in Headwaters v. BLM.
4. Comment: The EIS purpose and need should be revised to disclose that the revision is mandated by a
lawsuit filed by timber industry groups, ( AFRC v. Clarke, Civil No. 94-1031-TPJ [D.D.C.]). This lawsuit was
settled out of court on August 28, 2003. Under this agreement with the timber industry, the BLM agreed
to revise its resource management plans (RMPs) in Western Oregon and in this revision, the BLM would
consider an alternative that would not create any reserves on the O&C lands, except those mandated by the
ESA.
Appendices - 764
Appendix T - Responses to Public Comments and Comment Letters
Response: The Draft EIS acknowledged in Chapter 1 that the RMP revision will satisfy a settlement
agreement in AFRC v. Clarke , Civil No. 94-1031-TPJ (D.D.C). The Draft EIS also provided detailed
discussion of the settlement agreement in Appendix A - Legal Authorities.
5. Comment: The EIS purpose and need should be revised because not meeting the Allowable Sale
Quantity (ASQ) of 21 1 million board feet (mmbf) is not a valid reason to revise the plans. The ASQ of 21 1
mmbf is a limit, not a minimum standard. The courts ruled in Portland Audubon Society v. Babbit , 998 F.2d
705 (9th Cir. 1993) that the O&C Act did not establish a minimum volume that must be offered every year
notwithstanding any other law.
Response: The ruling in Portland Audubon Society v. Lujan was that the O&C Act did not establish 500
MMBF as a minimum standard. The Court said that this initial minimum was no longer applicable once
the Secretary determined the annual sustained yield capacity of the land, and from that time forward
the minimum to be offered was derived from the Secretary’s determination. Since there was no inherent
conflict between the duty to offer the determined amount annually and compliance with NEPA procedures
in making that determination, the injunction against timber sale offerings until the agency complied with
those procedures was within the jurisdictional authority of the Court. The ruling in Portland Audubon
Society v. Lujan should not be read as eliminating the requirement of the O&C Act that the Secretary
annually offer the declared sustained yield capacity for the O&C lands. The O&C Act requires the BLM to
declare the annual productive capacity of the O&C lands, and the 1995 RMPs declared an allowable sale
quantity that represents the annual productive capacity.
The O&C Act also requires that “the timber thereon shall be sold, cut and removed in conformity to the
principle {sic) of sustained yield.” The 1995 RMPs explained that the allowable sale quantity is an estimate
of annual average timber sale volume likely to be achieved from lands allocated to planned, sustainable
harvest. The allowable sale quantity represents neither a minimum level that must be met nor a maximum
level that cannot be exceeded, but it represents BLM s best assessment of the average amount of timber likely
to be awarded annually in the planning area over the life of the plan. As explained in the Draft EIS, plan
evaluations found that the actual level of timber harvest was 40 to 70 percent of the anticipated annual sale
quality, which represents a failure to meet the RMP objective of providing a sustainable supply of timber.
Failure to meet some plan objectives and new information that increases opportunities to improve the
performance of other plan objectives necessitates revisions to resource management plans.
Laws and Court Rulings Affecting Management of O&C Lands
6. Comment: The EIS should be revised on page 12 where it states, “Based on the language of the O&C Act,
the O&C Act’s legislative history, and the decision by the Ninth Circuit County in Headwaters v. BLM, (914
F.2d 1174 (9TH Cir. 1990), it is clear that the management of timber (including harvesting) is the dominant
use of the O&C lands . . .” to indicate that timber is dominant over wildlife, not all other uses.
Response: The Ninth Circuit ruling in Headwaters v. BLM, 914 F.2d 1174 (9th Cir. 1990) established that
timber production is the primary use and the dominant use of the O&C lands. To interpret this ruling as
concluding that timber production is dominant over some uses but not other uses on the O&C lands is
inconsistent with the plain language of the O&C Act and the Ninth Circuit ruling.
7. Comment: The EIS should be revised to discuss the 1939 law governing the Coos Bay Wagon Road lands
and its tax-equivalence basis for calculating payments to the counties.
Appendices - 765
FEISfor the Revision of the Western Oregon RMPs
Response: Additional discussion has been added to the final EIS describing the distribution of receipts from
Coos Bay Wagon Road lands.
8. Comment: The EIS should be revised to include more background on the O&C Act, as the discussion on
page 10 provides limited information. While the Act provides 50% to the counties, it provides an additional
25% “after back taxes and reimbursements to the U.S. Treasury are settled.” Thus, for some time after the
late 1950’s, the counties received 75% of timber sale receipts. Eventually, these receipts became so high
that they approached “windfall” status, and there was talk outside of Oregon about changing the O&C Act.
The counties opted to voluntarily return 25% back to the BLM. These “plowback” funds were to be used
for recreation developments, reforestation, and other forest development activities. The plowback funding
represented a unique Federal/County partnership, and facilitated intensive timber management on the O&C
lands.
Response: Additional information on the history of the payments to counties under the O&C Act would not
clarify the purpose and need for the action or how the O&C Act affects the RMP revision.
9. Comment: The EIS should be revised to be consistent with the Home builders case. The Supreme
Court’s ruling in National Association of Home Builders limits the ESA’s application to discretionary
agency actions, and takes the performance of non-discretionary actions outside ESA reach. This ruling has
applicability to the O&C Act. The non- discretionary language of the O&C Act means the BLM “does not
have the discretion” to manage O&C lands classified as timberlands for any purpose except permanent forest
production; it “does not have the discretion” to fail to determine and declare the annual productive capacity
of those timberlands; it “does not have the discretion” to fail to sell, cut and remove the timber from those
timberlands in conformity with the principle of sustained yield; and it “does not have the discretion” to sell
annually from those timberlands less than one-half billion feet board of timber or their determined annual
sustained yield capacity.
Response: The BLM management of O&C lands is different from the federal action at issue in National
Association of Homebuilders v. Defenders of Wildlife, 551 U.S. (2007), and that ruling is therefore not
applicable to this plan revision. At issue in National Association of Homebuilders v. Defenders of Wildlife was
legislative direction to the Environmental Protection Agency to transfer permitting authority to a State upon
application and a showing that a State has met nine specified criteria. The O&C Act provides a mandate for
BLM to manage the O&C lands for permanent forest production, but this mandate does not make BLM
management of these lands a non-discretionary action similar to the transfer of permitting authority by
the Environmental Protection Agency. The BLM has reasonable alternatives to accomplish the purpose of
“permanent forest production.” Because BLM has discretion in the management of these lands -- regardless
of the limits on that discretion — this plan revision is a discretionary action and is therefore subject to
section 7(a)(2) of the Endangered Species Act.
10. Comment: Management of all O&C lands, including the National Landscape Conservation System,
must be included in sustained yield timber production unless specific areas have received a Congressional
designation that precludes such timber management.
Response: Under each of the alternatives, O&C lands are withdrawn from timber harvest for a variety of
reasons other than a Congressional designation that precludes timber management. The Cascade-Siskiyou
National Monument, which would be withdrawn from timber harvest under all alternatives, was established
by proclamation of the President. Section 2 of the American Antiquities Act of 1906 (34 Stat. 225, 16 U.S.C.
431), authorizes the President, in his discretion, to declare by public proclamation historic landmarks,
Appendices - 766
Appendix T - Responses to Public Comments and Comment Letters
historic and prehistoric structures, and other objects of historic or scientific interest that are situated upon
the lands owned or controlled by the Government of the United States to be national monuments, and to
reserve as a part thereof parcels of land.
All alternatives include riparian management areas to ensure compliance with the Clean Water Act and
the Endangered Species Act. All alternatives withdraw O&C lands that are classified under the Timber
Productivity Capability Classification as not capable of supporting a sustained yield of forest products.
None of these O&C lands have received a Congressional designation that precludes timber harvest, yet
they are properly withdrawn from timber harvest under all of the alternatives. To include these lands in the
determination of the annual productive capacity would overstate the sustained yield harvest level.
11. Comment: The EIS should be revised to consider Executive Order 13443 of August 16, 2007,
“Facilitation of Hunting Heritage and Wildlife Conservation,” because it pertains to recreation and wildlife
on public lands and it is not discussed in the EIS.
Response: The appendix listing legal authorities has been updated to include Executive Order 13443
“Facilitation of Hunting Heritage and Wildlife Conservation.” Although the Draft EIS did not explicitly
identify Executive Order 13443 (which was issued after the publication of the Draft EIS), it was consistent
with the direction in the order, which included evaluating the effects of the alternatives on game species
and their habitats, working collaboratively with State governments, and seeking the advice of State fish and
wildlife agencies.
12. Comment: The EIS should be revised to include an explanation of how applicable provisions located in
the Healthy Forests Initiative and the Healthy Forests Restoration Act would be addressed by WOPR.
Response: Text has been added to the Final EIS describing the provisions of the Healthy Forests Restoration
Act.
13. Comment: The EIS should be revised to consider that relevant case law indicates that, to the extent
BLM chooses management actions which do not maximize species conservation, that it should be prepared
to describe its rationale for doing so.
Response: The Draff EIS described a range of alternatives that provide different contributions to species
conservation. The record of decision will provide the rationale for selection among the alternatives. If the
selected alternative does not maximize species conservation, the rationale for selection will provide an
explanation for the decision.
14. Comment: The EIS (Preferred Alternative) should be revised because withdrawing 52 percent of
suitable timberland to aid in achieving the “survival and recovery” of the northern spotted owl and other
federally listed species is in direct conflict with the Ninth Circuits Headwaters decision and the 1986 Legal
Opinion.
Response: The Ninth Circuit ruling in Headwaters v. BLM, 914 F.2d 1174 (9th Cir. 1990) concluded that
withdrawing O&C lands from timber harvest to serve as habitat for the northern spotted owl violated
the O&C Act. However, the Court did not explore in that opinion or in its response to the request for
reconsideration in Headwaters v. BLM , 940 F.2d 435 (9th Cir. 1991), the extent to which the BLM could
utilize its authorities under the O&C Act to further the purposes of the Endangered Species Act or what
actions the BLM would be allowed to take under the O&C Act to avoid jeopardizing a species listed under
the ESA or to avoid adversely modifying designated critical habitat. The EIS analyzed a range of alternatives
Appendices - 767
*-• FEISfor the Revision of the Western Oregon RMPs
to accomplish the purpose and need of managing these lands under the direction provided in the O&C
Act, while also complying with all other applicable laws, which includes compliance with the Endangered
Species Act and coordination with recovery planning for species listed under the Endangered Species Act.
The PRMP withdraws lands from timber harvest to provide habitat for species listed under the Endangered
Species Act and to ensure compliance with other environmental laws.
The commenter does not attach the “1986 Legal Opinion” or provide a complete citation. The “1986 Legal
Opinion” is presumably a memorandum signed jointly by Gale Norton, who was the Associate Solicitor for
the Division of Conservation and Wildlife, and Constance Harriman, the Associate Solicitor for the Division
of Energy and Resources, dated October 20, 1986, which addressed the interaction between the O&C Act
and other statutes, including the Endangered Species Act. This memorandum recognized that the O&C
Act made timber production the dominant use, but not the sole use, for the O&C lands, and that the BLM
has the discretion under the O&C Act necessary for compliance with other statutes. The purpose and need
described in the EIS is consistent with the 1986 memorandum.
Management of Public Domain Lands in Relation to O&C
Lands
15. Comment: The EIS should be revised to clearly state that the O&C Act does not govern public domain
lands, and develop separate management for public domain lands as it is not appropriate to propose the
same management actions on public domain lands and lands governed by the O&C Act. Along with this
clarification, the EIS should disclose the distribution of the roughly 400,000 acres of Public Domain lands
and consider the requirements of FLPMA for these lands. These lands should be identified in the EIS and
the BLM’s interpretation of the O&C Act should not be applied to these non-O&C Act lands. The BLM
should consider an alternative that provides a high level of conservation emphasis on Public Domain lands.
Response: The EIS acknowledges that Public Domain lands are to be managed for a multitude of values
under the Federal Land Policy Management Act. The alternatives include a range of uses and management
objectives for Public Domain lands in the planning area, which permits the BLM to consider multiple
uses for the Public Domain lands. Additional discussion has been added to the final EIS to explain the
management of public domain lands in this RMP revision. The Draft EIS described the acreage and location
of Public Domain lands. A map showing the location of Public Domain lands has been added to the final
EIS.
Hie Alternatives
16. Comment: The EIS should be revised to consider a full range of alternatives that meet the agency’s
legal obligations including at least one alternative that will not create any reserves on O&C lands except
as required to avoid jeopardy under the ESA. In addition, all alternatives must be consistent with the
O&C Act as interpreted by the 9th Circuit Court of Appeals. By only considering action alternatives that
cannot meet BLM’s legal duties, BLM is violating the requirement that National Environmental Policy Act
(NEPA) documents discuss alternatives to the proposed action, to “providje] a clear basis for choice among
options by the decision maker and the public.” 40 C.F.R. 1502.14; see also 42 U.S.C. § 4332(2)(E); 40 C.F.R.
1507.2(d), 1508.9(b). The Council on Environmental Quality, which wrote the NEPA regulations, describes
the alternatives requirement as the “heart” of any EIS. 40 C.F.R. 1502.14. “The existence of a viable, but
unexamined alternative renders an EIS inadequate.” Alaska Wilderness Recreation & Tourism v. Morrison , 67
F.3d 723, 729 (9th Cir. 1995).
Response: The EIS considered a range of alternatives that are designed to meet BLM’s legal duties. The
purpose and need in the Draft EIS clearly stated that the purpose of the agency action includes compliance
Appendices - 768
Appendix T - Responses to Public Comments and Comment Letters
with not only the O&C Act, but with all applicable laws. The commenter does not articulate which legal
duties the alternatives cannot meet nor which viable alternatives were not examined.
17. Comment: The EIS should be revised to include a restoration alternative because there is a growing
consensus among decision makers, scientists, foresters, and others that aggressive thinning and other
management activities are needed to restore forests historically characterized by frequent low and mixed
severity fire regimes, such as those of the Medford District.
Response: The Proposed Resource Management Plan (PRMP) Alternative in the Final EIS includes uneven-
aged management in forests that were historically characterized by frequent low and mixed severity fire
regimes in the Medford District and Klamath Falls Resource Area. Alternative 3 includes a partial harvest
forest management regime in these forests. More generally, all alternatives analyzed in detail include some
level of thinning. The acreage of thinning would vary among the alternatives, both in the harvest land
base and the nonharvest land base. This variation provides a comparison of the effects of different levels of
thinning and a basis for a reasoned choice among the alternatives.
18. Comment: The EIS should be revised to include a maximum timber alternative and maximum
environmental alternative to set the spectrum or outer limits of alternatives within which a rigorous and
documented search for a preferred alternative could take place.
Response: The EIS analyzed in detail a range of alternatives that respond to the purpose and need for
action. The alternatives vary the strategy for managing land and resources for threatened and endangered
species, wildlife, water quality, fish, and timber production within the context of meeting the purpose and
need for action. In addition, the EIS included analysis of two reference analyses: allow no harvesting, and
manage most commercial forest lands for timber production. These reference analyses provided additional
information that is useful to more fully understand the effects of the alternatives. However, these reference
analyses are not reasonable alternatives, because they do not meet the purpose and need for action.
1 9. Comment: The EIS graphs for comparing the alternatives should be revised to provide comparable
data across the alternatives. For example, old growth and late successional forests are not included in
the Alternative 3 graph resulting in non-comparable data across the alternatives. It is understood that
Alternative 3 doesn’t provide that data directly, but when asked for a comparison, an estimate based on the
plan would be more appropriate. The BLM should update the graphs to make sure they each measure the
same set of data, in order to allow viewers to make accurate comparisons.
Response: The Draft EIS provided comparable data across the alternatives for the abundance of structural
stages. Table 150 of the Draft EIS disclosed the abundance of each structural stage over time for each
alternative, including Alternative 3. Table 151 disclosed the outcome of existing old forest by 2106 under
each alternative, including Alternative 3. More generally, Table 40 in the Draft EIS provided a comparison
of the key impacts of the alternatives. These tables are included in the final EIS with the addition of data on
the PRMP (see Tables 4-4, 4-5, and 2-63, respectively). Tables 188 and 189 in the Draft EIS did not include
Alternative 3, because these tables described the amount of northern spotted owl suitable habitat within
late-successional reserves or late-successional management areas, and Alternative 3 did not allocate any late-
successional management areas.
20. Comment: The EIS should be revised on pages 43-44 (National Landscape Conservation System
section) to include only those management actions that are consistent with the O&C Act or specific
Congressional designation. For example, on Congressionally designated Wild and Scenic rivers with a
scenic or recreation classification, timber harvest is allowed, and lands with such classifications should be
Appendices - 769
FEISfor the Revision of the Western Oregon RMPs
a part of the timber base for sustained yield calculations. Only sections of rivers with Congressional wild
classifications are properly withdrawn from timber harvest. The BLM lacks authority to withdraw O&C
and CBWR lands from timber production on an interim basis while Congress is considering eligibility of
candidate areas for inclusion in the Wild and Scenic system.
Response: The EIS explains the application of the O&C Act to Wilderness Study Areas and visual resources,
including Wild and Scenic Rivers, and describes generally that protection on O&C lands would be provided
if required by Congressional designation or where protection would not conflict with sustained yield forest
management.
21. Comment: The EIS should be revised to include a description of the No Action Alternative. The EIS
must describe the No Action Alternative in sufficient detail to provide a baseline for the reader to make
comparisons to the action alternatives and assess the validity of the environmental effects section.
Response: The No Action Alternative has an important and vital role in effects analysis, because it provides
context for comparing the environmental effects of the alternatives and demonstrates the consequences of
not meeting the need for the action. The EIS summarizes the features of the No Action Alternative, provides
a map of the land use allocations, and incorporates by reference the detailed descriptions in the 1995 RMPs.
In preparing NEPA documents, agencies are directed by the Council on Environmental Quality regulations
to incorporate by reference to reduce excessive paperwork. The 1995 RMPs contain the detailed descriptions
of the No Action Alternative and are readily available.
22. Comment: The EIS should be revised to include a true No Action Alternative that continues current
management as is outlined in the existing plans. The addition of new management under the No Action
Alternative violates a primary tenant [szc] of NEPA to examine a No Action Alternative along with
action alternatives. Therefore, the reduction of riparian reserves from 522,000 acres to 364,000 acres and
subsequent increase of the ASQ by 32 percent (page 566 of the Draff EIS) should be considered under a
separate alternative.
Response: The No Action Alternative would continue current management direction as outlined in the
existing 1995 RMPs. There is no new management added to the No Action Alternative. The management
objectives and management direction for riparian reserves (including the riparian reserve widths)
are unchanged. The acreage of riparian reserves was estimated in the 1995 RMP/EISs based on the
information available at that time. New information based on improved mapping of hydrologic features has
demonstrated that the acreage of riparian reserves is actually smaller than estimated in the 1995 RMPs/EISs.
To analyze the No Action Alternative using the estimation of riparian reserve extent from the 1995 RMPs/
EISs would ignore this new information on the actual acreage that was allocated to Riparian Reserves by the
1995 RMPs and, therefore, would be inconsistent with the Council on Environmental Quality regulations.
23. Comment: The EIS should be revised to correct deficiencies in the alternatives. This can be achieved by
modifying Alternative 2 to incorporate the U.S. Supreme Court’s limitations on the reach of the ESA, and
correcting certain other existing inconsistencies with the O&C Act. All information and data necessary for
FEIS analysis is currently available in the Draff EIS. The following are suggested changes for Alternative 2:
1. Maintain existing LSMA allocation boundaries identified in Alternative 2, but do not withdraw
or reserve these lands from sustained timber production. Instead, develop long-term rotation age
strategies within the LSMA boundaries that would contribute to the conservation and recovery of
federally listed species, while also providing for regeneration harvesting on a sustained yield basis. We
Appendices - 770
Appendix T - Responses to Public Comments and Comment Letters
suggest using the long rotation ages contained in Alternative 3 within the areas currently identified
as LSMAs, and using landscape targets for regeneration harvest within LSMA boundaries similar to
requirements in Alternative 3.
2. Develop timber management objectives within LSMA boundaries that maintain and promote the
development of suitable habitat for federally listed ESA species. Examples include thinnings and partial
harvests that would hasten development of structurally complex forests within the LSMA boundaries.
All timber harvested within the LSMAs is in the timber harvest base and the volume should be included
in ASQ calculations.
3. The Secretary, apart from the WOPR process, should eliminate critical habitat designations on O&C
and CBWR lands. The BLM cannot participate in a system of reserves on O&C and CBWR lands.
The USFW, at the direction of the Secretary, should revise its proposed critical habitat designation to
account for the BLM’s non-discretionary mandates under the O&C Act.
5. Establish continuous field survey and monitoring systems within LSMAs for all federally listed species.
Determine whether a location is “actually occupied” based on confirmation of the physical presence
of species using the site for nesting, roosting, or foraging (owls) or nesting (murrelets), but excluding
locations where there are sightings of transient, dispersing birds.
6. Protect all sites (inside and outside of LSMAs) that are actually occupied by listed species by delaying
regeneration harvest of sites for so long as sites are actually occupied. See definition of “actually
occupied” in comment 5.
8. In areas south of Grants Pass and in the Klamath Falls Resource Area of the Lakeview District, apply
uneven-aged timber management principles where feasible to all BLM lands. This practice would
reduce fire hazard and the acres of high severity fire when wildfires occur in these areas. It could also
benefit suitable habitat conditions for ESA-listed species.
9. Include in the sustained yield timber management base all Congressionally designated Wild and Scenic
Rivers that have a scenic or recreation classification. Exclude only those rivers with a Congressional
wild classification from the timber base. Include in the timber management base all rivers that have
not been Congressionally designated. Any protections for riparian areas along Wild and Scenic rivers
included within the timber base would be those riparian protections generally applicable for the land
use allocation of the surrounding lands.
10. Withdraw O&C and CBWR lands located in the National Landscape System from sustained yield
timber management only if they have a Congressional designation requiring protection.
11. Include all lands adjacent to the Coquille Tribal Forest in the sustained yield timber management base.
13. Develop a sub-alternative for Alternative 2 that eliminates LSMA boundaries and establishes the
maximum harvest that can be maintained in these areas without exceeding the amount of new growth.
Response: Taken together, these proposed modifications are so substantial as to constitute a different
alternative. Such an alternative would not accomplish the purpose and need for action, because it would not
comply with the Endangered Species Act and would not coordinate with recovery planning by the U.S. Fish
and Wildlife Service. Furthermore, such an alternative would be beyond the scope of the action, because it
would require the Secretary of Interior to eliminate critical habitat designations.
Several component elements of the commenter s proposed alternative have been considered in the Draft EIS
or are included in the PRMP in the FEIS. Management within Late-Successional Management Areas using
the forest management strategies of Alternative 3 would have the same effects in these areas as Alternative
3. The Draft EIS analysis demonstrated that Alternative 3 would not create large blocks of habitat for the
northern spotted owl and would decrease the abundance of nesting habitat for the marbled murrelet in the
first 50 years. Protection of known sites of northern spotted owls and marbled murrelets was included in
the No Action Alternative and Alternatives 1 and 3; also, the PRMP includes protection of known marbled
murrelet sites.
The PRMP includes uneven-aged management in forests that were historically characterized by frequent
low and mixed severity fire regimes in the Medford District and Klamath Falls Resource Area. The PRMP
would not establish a unique land use allocation for land adjacent to the Coquille Tribal Forest and would
Appendices - 771
^ F£fS/or the Revision^ of, the Western^ Oregon, RMPs^
include those lands in the harvest land base similar to surrounding lands. The Draft EIS included a reference
analysis of “manage most commercial forest lands for timber production,” which established a maximum
harvest level that could be maintained without exceeding the amount of new growth.
Two of the component elements of the commenter s proposed alternative are contradictory. Regeneration
harvest on a sustained-yield basis within Late-Successional Management Areas would not be consistent with
an objective to maintain and promote development of suitable habitat for federally listed ESA species.
Under each of the alternatives, O&C lands are properly withdrawn from timber harvest for a variety of
reasons other than a Congressional designation that precludes timber management. To include these lands
in the determination of the annual productive capacity would overstate the sustained yield harvest level.
The Draft EIS explained the application of the O&C Act to Wilderness Study Areas and visual resources,
including Wild and Scenic Rivers, and described generally that protection would be provided to these
areas on O&C lands if required by Congressional designation, or where protection would not conflict with
sustained yield forest management.
24. Comment: The analysis of Alternative 1, Subalternative 3 should be reevaluated because it is
unreasonably constrained and it fails to consider the potential for ecologically appropriate thinning to
provide for a predicable [sic] supply of timber. Rather than calculating and disclosing potential volume
directly, the analysis is limited to estimating the number of years that harvest near the level of Alternative
1 could be sustained with thinning volume. By failing to fully analyze this subalternative for its effects on
recreation, water quantity and quality, soils, invasive plants, fish, wildlife, and other resources the BLM fails
to disclose the significant benefits of this approach and the significant impacts of the preferred alternative. In
particular, this subalternative could provide for stable communities and a predictable level of production.
Response: The analysis of the subalternative for Alternative 1 that would allow no regeneration harvesting
until thinning opportunities are exhausted did calculate the potential volume directly, but was constrained
by the requirement for a sustained yield of timber production, as were all alternatives and subalternatives.
The estimate of the number of years that harvest near the level of Alternative 1 could be sustained with
thinning volume is an outcome of the analysis, not a constraint on the subalternative. The Draft EIS
explained that the analysis of the subalternative was focused and limited to specific analytical questions. The
commenter does not specify the unreasonable constraints that were placed on this subalternative.
25. Comment: The EIS should be revised on page 107 to clarify why the Naturally Selected Dead and
Dying Trees Alternative was removed from consideration. It is interpreted that BLM rejected the alternative
because DCA did not determine and declare the annual productive capacity of BLM lands. However, NSA
has declared that it takes the dead and dying, conditional upon meeting the needs of other species. The
NSA would produce not less than the annual sustained yield capacity as it would retain the net worth of the
forest ecosystem which is necessary to retain maximum productivity over the long term. At the BLM WOPR
technology presentation in Oct 2007 a specialist working with the models indicated that BLM has the
ability to model natural tree mortality. If this is not the case, it should be clarified as this is part of the NEPA
requirement placed on BLM. It appears that that the NSA was eliminated because it did not receive rigorous
exploration and objective evaluation that is part of the BLM EIS process.
Response: The Draft EIS disclosed that the alternative of Harvest Only Naturally Selected Dead and
Dying Trees was eliminated from detailed study, because it would not be consistent with the O&C Act and
would not meet the purpose and need for action. The O&C Act requires the BLM to determine the annual
productive capacity of the O&C lands and to sell that amount of timber annually. Harvest of only dead and
dying trees would not reflect the annual productive capacity of the O&C lands and, therefore, would not
meet the purpose and need for the action.
Appendices - 772
Appendix T - Responses to Public Comments and Comment Letters
26. Comment: The EIS should be revised to provide meaningful response to the NSA issues raised during
scoping regarding fire hazard, where 57 different supporting studies were cited, and objectively evaluate and
disclose the extent and scientific basis for the controversy.
Response: The commenter does not identify the scientific controversy that the Draft EIS did not disclose.
The scoping comments were considered in the development of the Draft EIS, and the Draft EIS summarized
the science regarding fire hazard and fire resiliency. The alternatives in the Draft EIS considered different
forest management strategies to address fire hazard and fire resiliency. Specifically, the Draft EIS identified
the increasing fire resiliency as a topic to be explored in the preparation of the Final EIS. The PRMP in the
FEIS includes uneven-aged management in forests that were historically characterized by frequent low and
mixed severity fire regimes in the Medford District and Klamath Falls Resource Area specifically to mitigate
the fire hazard that would result from the preferred alternative identified in the Draft EIS.
Natural Disturbance and Salvage
27. Comment: The EIS should be revised to acknowledge that even with enlightened management on
federal lands for the next 100 years, we will reach only 75% of the historic large snag abundance measured
across the interior Columbia Basin, and most of the increase in large snags will occur in roadless and
wilderness areas.
Response: Projected changes in snag abundance under different management strategies in the interior
Columbia Basin are not directly relevant to changes in snag abundance in the planning area because of
fundamental differences in vegetation characteristics, disturbance regimes, and tree growth and mortality.
The Draft EIS described future changes in habitat for snag-dependent species, but did not identify any
threshold or target related to historic large snag abundance. Restoring the historic abundance of snags is not
identified as a management objective under any of the alternatives.
28. Comment: The EIS should be revised to include a delay in salvage logging after a fire, because beetle
dung helps forests recover from fire and immediate salvage logging disrupts the beetles and does not allow
them to complete their life cycle.
Response: The alternatives in the Draft EIS varied in whether they would allow salvage logging after
disturbances in the Late-Successional Management Areas. This allowed consideration in the development
of the PRMP in the FEIS of whether salvage logging in the Late-Successional Management Areas should be
allowed. None of the alternatives considered a delay in salvage logging after disturbance, because a delay
to allow bark beetles to complete their life cycle would result in a loss of the economic value of the logs.
Therefore, to delay salvage logging would have the same effect as not allowing salvage logging, which was
considered in the Draft EIS.
Climate Change
29. Comment: The EIS should be revised to consider Oregon House Bill 3543, and whether the proposed
alternatives’ impacts to climate change adhere to this State law.
Response: Oregon House Bill 3543 provides no authority for management of BLM-administered lands.
Nevertheless, none of the alternatives are inconsistent with this State law. The bill directs the State to stop
the growth of greenhouse gas emissions by 2010 and to reduce greenhouse gas emissions to 10 percent
below 1990 levels by 2020 and to 75 percent below 1990 levels by 2050. The bill creates the Oregon Global
Warming Commission, which will evaluate among other things, the carbon sequestration potential of
Oregon’s forests, alternative methods of forest management that can increase carbon sequestration and
Appendices - 773
FEISfor the Revision of the Western Oregon RMPs
reduce the loss of carbon sequestration to wildfire, changes in the mortality and distribution of tree and
other plant species, and the extent to which carbon is stored in tree-based building materials. The final EIS
includes an analysis of carbon storage and concludes that each alternative would result in an increase in net
storage of carbon in forests on BLM-administered lands and wood harvested from BLM-administered lands.
30. Comment: The EIS should be revised to include a thorough discussion of the proposed alternatives’
impacts on climate change.
Response: The greatest influence of forest management on climate change is through changes in carbon
storage. An analysis of the effects of the alternatives on carbon storage has been added to the final EIS.
Carbon Sequestration
31. Comment: The EIS should be revised to include estimates of decreased tons of carbon sequestration
and increased tons of atmospheric carbon from various amounts oflogging.
Response: An analysis of the effects of the alternatives on carbon storage has been added to the final EIS.
Vegetation Modeling
32. Comment: The methodology in Appendix Q of the EIS should be revised. On page Q-1512, the DEIS
describes a decision to use stand age for multi-storied stands assigned to the predominant layer that is being
managed. This leads to the misidentification of the stand, and underestimates the acres that could be readily
restored to old-growth. On BLM’s Medford District and on dry, fire-prone settings found in other districts,
a large percentage of multistory stands are assigned an age of the young cohorts that have filled in between
older legacy trees that are more widely spaced due to past fire, or past partial thinning. Many such stands
could meet the age requirements for old-growth if a percentage of the young cohort was thinned out and
contribute to improved fire regime condition class in many sub-watersheds. As a result of this methodology,
the description of the current condition of stands has been misrepresented, and thus skewed the degree
of impact in the Environmental Consequences. We recommend that age class definitions that recognize
restoration opportunities for old-growth stands.
Response: The cited passage of the Draft EIS described the existing inventory data available on BLM-
administered lands. It was not describing a decision or choice in the analytical methodology. There is no
available inventory data based on different age class definitions.
Forest Structural Stages and Spatial Pattern
(Note: This section was titled “Ecology” in the Draft Environmental Impact Statement.)
33. Comment: The EIS should be revised to cite references for the data on historic conditions, because
statements regarding the percent of mature and old forest (75%) in the Cascade and Klamath provinces is
contrary to other references (the Lieberg report from 1900 and the Osborne photos from the 1930 s) that
indicate that between 1860 and 1900 much of the land was dominated by brush and that most townships
had experienced high severity fires.
Response: The Draff EIS cited references for the data on historic conditions: the estimate of 70% mature
& structurally complex forest in the Klamath Province was derived from Rapid Assessment Reference
Condition Models, which derive average historic conditions by modeling disturbance probabilities. These
estimates are generally consistent with other descriptions of average historic conditions, as detailed in the
Appendices - 774
Appendix T - Responses to Public Comments and Comment Letters
Draft EIS. The Draft EIS also acknowledged the variability within the Klamath province and the difficulty
in deriving a province-wide characterization. The commenter did not attach the cited references or include
complete citations, which do not appear to be readily available. However, these references presumably
describe or portray the conditions in the late 1800s and early 1900s, after Euro- American settlement. The
average historic conditions described in the Draft EIS characterize conditions prior to Euro-American
settlement. Additional discussion has been added to the final EIS to clarify the estimates of average historic
conditions.
34. Comment: The EIS should be revised to acknowledge that while disturbance is essential to how forest
ecosystems function, long periods of growth and recovery between disturbances are equally important.
Response: The Draft EIS described the continued structural development of forests during long periods
without disturbance and described some functions that differ in older forests. More detailed explorations of
the changing ecosystem function over time in the absence of disturbance would not improve the description
of the affected environment, which includes citations to relevant scientific research that address this topic
(see, for example, Franklin et al. 2006, Spies 2006, Franklin and Van Pelt 2004, Spies 2004, Franklin et al.
2002, Spies and Franklin 1991). The description of the affected environment is not intended to be a primer
on forest ecology; it should be no longer than necessary to understand the effects of the alternatives.
35. Comment: The EIS should be revised on page 510 to cite Daniel Sarr, NPS Klamath Network Inventory
and Monitoring Coordinator, and others on the increase in salmonberry dominated areas in highly
productive riparian areas in our region.
Response: The Draft EIS at the cited page described uncertainty about the future development of riparian
red alder stands and described a likely future successional pathway. The commenter did not provide any
specific citations or attach any references to Dr. Sarr’s work, but recent research from Dr. Sarr described
current conditions of riparian forests (Sarr and Hibbs 2007a and 2007b). This research would not provide
a basis for describing future development of riparian forests. Therefore, including these citations would not
improve the analysis or clarify the uncertainty described in the Draft EIS.
Socioeconomics
36. Comment: The EIS should be revised to include an analysis of tourism within the socioeconomic
analysis section.
Response: The DEIS (page 535) describes the economic contribution of tourism in the planning area. There
are no measurable differences between alternatives with respect to visitor use patterns within the planning
area. A more detailed analysis of tourism for each alternative, therefore, would not change the analytical
conclusions or ranking of the alternatives.
37. Comment: Table 154 of the DEIS should be revised to correct apparent calculation errors. Revenues
under Alternative 2 should be $214.67 not $215.80 and revenues under the No Action Alternative should be
$83.07 not $83.90.
Response: Refinement of the harvest projections during successive iterations of analyses reduced the
average harvest levels by about 0.5%. The projected revenues, therefore, are overstated by about 0.5%. This
difference is inconsequential and within the precision of the projection methods; therefore, no adjustments
have been made.
Appendices - 775
FEISfor the Revision of the Western Oregon RMPs
38. Comment: The DEIS summary, page LII, Figure 2 should be revised to correct for inflation and show
constant 2005 dollars. Correcting this oversight would alter the graph in such a way that it would show that
payments under SRSA were at an average level of timber receipts between 1985 and 2000 instead of equaling
or exceeding the peak levels.
Response: The EIS shows the payments as they were actually made and as they are recorded in financial
records at the time of the payment. Performing an inflation adjustment would show that the payments in the
early 1990s were higher than during the 2001-2005 period, in terms of constant dollars. This adjustment,
however, would not change the analytical conclusions, the ranking of the alternatives, nor the relationship
between the alternatives and the recent county payments.
39. Comment: The EIS should be revised on page 549 to clarify the statement that a 17% budget increase
would be necessary to implement the No Action Alternative. The No Action Alternative is current
management and is currently being implemented. The budget increase is needed to continue current
management.
Response: The No Action Alternative is not currently being implemented at the levels anticipated in the
1995 western Oregon resource management plans. The No Action Alternative would harvest 266 mmbf
annually, whereas recent harvests have averaged 117 mmbf (DEIS, page 540, Table 156). Increasing harvest
from levels currently being implemented would require a budget increase.
40. Comment: The EIS should be revised to provide documentation on how BLM determined the increased
budget numbers for the various alternatives. Without this information, it is impossible to validate the 60
percent increase identified for Alternative 2.
Response: The DEIS in Appendix C documents the assumptions used to calculate the BLM timber budget
for the alternatives. A fixed + variable approach was used with the marginal cost of an additional MMBF at
$159, based on historical budget information, and 78% of the 2006 budget assumed to be fixed costs held
constant for all alternatives.
41. Comment: The EIS should be revised to assign economic values to recreational activities such as
hunting, fishing, wildlife viewing and tourism. The EIS should also assign economic values to the ecological
importance of old growth in addition to timber value of old growth.
Response: The DEIS (page 535) describes the economic contribution of tourism in the planning area. There
are no measurable differences between alternatives with respect to visitor use patterns or recreation levels
within the planning area. Therefore, a detailed analysis of contribution to the local economies of hunting,
fishing, wildlife viewing, and tourism would not change analytical conclusions, or the relative ranking of the
alternatives. Assigning an economic or market place value to the ecological importance of old growth would
be speculative since it does not trade in a marketplace and the price cannot be observed. (See page 783 of
the DEIS)
42. Comment: The EIS should be revised to: (1) include a definition of economic stability that is consistent
with economic theory, (2) describe the current status and basis of economic stability of local communities
and industries, (3) describe how additional logging contributes to economic stability of communities in
relationship to other socioeconomic factors, and (4) address the evidence indicating that increased logging
is not associated with greater economic stability.
Appendices - 776
Appendix T - Responses to Public Comments and Comment Letters
Response: The EIS does not claim that any of the alternatives would provide “economic stability” in any
absolute sense. Increased timber harvest, however, would generate additional economic activity: in the
wood products sector where primary processing jobs would be created: in the local government sector that
relies on O&C revenues; and in other sectors economically linked to these sectors. The DEIS describes the
potential economic contribution of each alternative in Chapter 4.
43. Comment: The EIS should be revised to show how timber receipts will be calculated and shared within
the six districts for each alternative.
Response: Stumpage price computation is documented in Appendix D of the DEIS. For each combination
of district, structural stage, and harvest type, stumpages are constant across alternatives. The total stumpage
value and the average stumpage price/mbf change by alternative due to the different quantities and types of
harvest that occur under each alternative.
The BTM is funded by appropriation and each BLM district’s allocation is determined through a budgeting
process that recognizes the amount of activity on each district. Each districts projected budget is shown in
Table 163 (see DEIS, page 550). In addition, the DEIS describes how BLM receipts and O&C revenues are
allocated between counties based on an acre-weighted proration formula (DEIS, pages 230-231).
44. Comment: More complete comment: The BLM has failed to explain how these international markets
have been accounted for in its economic models. BLM has not reported its implied assumptions about
international conditions, export and import restrictions, and the value of the U.S. dollar. BLM needs
to report specifically the assumptions it has employed in its economic models to account for salient
international events.
Response: The prices bid for BLM timber sales reflect market values that are driven by a number of
factors, including international and domestic demand for timber. These factors, however, would affect
all alternatives equally and, therefore, would not change the ranking of alternatives nor the fundamental
conclusions.
45. Comment: The DEIS models for economic analysis is inadequate and flawed because it ignores the
effect of harvest of late-successional forest on recreation and because of its use of IMPLAN output Studies
suggest that IMPLAN is inadequate for evaluating overall economic impacts of changes in regional natural
resources. See T. Hoekstra, G. Alward, A. Dyer, J. Hof, D. Jones, L. Joyce, B. Kent, R. Lee, R. Sheffield, R.
Williams. Analytical Tools and Information. Critiques of Land Management Planning. U.S. Department
of Agriculture. Forest Service. FS-455. (1990) 47 pp., and Office of Technology Assessment. Forest Service
Planning: Accommodating Uses, Producing Outputs, and Sustaining Ecosystems. OTA-F-505. U.S.
Congress. Washington, DC (1992).
Response: The EIS economic effects analysis does not use IMPLAN. The 18 county-level input-output
(I/O) models are constructed specifically for the Western Oregon Plan Revision EIS analysis. They are
based on the most recent secondary data from the same data sources typically used in IMPLAN, but this is
augmented and calibrated with primary (survey) data for key economic sectors in each county.
Secondary data is modified to increase local scale modeling accuracy. For example, industrial output is
adjusted to survey data provided by the Oregon Department of Forestry, the Ehinger Mill Survey (Ehinger
2006a), and the Western Oregon Model (Adams and Latta 2007). Employment and earnings data for major
manufacturers and other key components of the economic base is also updated to correspond with the
Oregon Department of Employment ES-202 data (national data), plus proprietors employment data.
Appendices - 777
FEISfor the Revision of the Western Oregon RMPs
An Economic Analysis Systems (EAS) team of staff economist and resource sociologist spent months on site
collecting supplementary primary data. This local conditions data set includes county-by-county surveys
of local government, forest products sectors and indicators of the roles of amenity migration, recreation
and tourism in local service sectors. The logic and structure of the WOPR I/O models, as well as the survey
process, are documented. The supplemental report is not printed in the Draff EIS, but is included in the
official record.
The I/O analysis is based on a static view (snapshot) of the economy that allows for detailed representation
of contemporary inter-sectoral transactions. Multipliers are very stable over time (Miller and Blair 1985,
1998; Trevz 1993). Although I/O models can be sensitive to changes in direct inputs or first round impacts,
it usually takes a very significant amount of structural change in an economy to change multipliers. The
multipliers used in WOPR I/O models tested as stable. Even the most changed county economy (Coos
County) met stable multiplier criteria between 1994 and the new 2004 baseline.
The WOPR I/O models project 2009 job and income responses to three significant perturbations of the
2004-2005 baseline economies. In addition to the forest management alternatives considered by BLM, local
government incomes from federal secure rural school funds terminate and long-run declines in the plywood
sector continue. The direct effects of the WOPR alternatives and the plywood sector decline are projected
by the Western Oregon Model (WOR), an econometric model of the wood products sectors’ responses
to harvest changes. Including three simultaneous perturbations ensured that the I/O models realistically
describe likely 2009 county economies and sectors of immediate interest.
Unlike IMPLAN, the 18 WOPR I/O models do include unearned income (non-labor income) such as
transfer payments, investment income, business profits, and retirement income (pensions). These are
important income sources in O&C counties, typically accounting for half of the residents’ income. In coastal
counties, retirement and investment income is prevalent, so unearned income is a major driver of local
economies. These models also account for income flows from commuting, a major factor near metropolitan
areas. Survey data shows that coastal counties have already experienced permanent shifts away from
natural resources extraction (wood, fishing, and agriculture) to economies more dependent on retirement
and tourism. So the WOPR baseline already includes the most recent non-commodity and recreation job
interactions with current BLM forest management patterns.
Although harvest levels vary among the alternatives, levels of recreation do not vary among the alternatives.
Typically, dispersed recreation demand on BLM-administered lands changes primarily in response to
external factors: demographics (population and age structure changes) or changes in recreation technology,
such as the popularity of off-highway vehicles. On the supply side, the most important factor tends to be
in recreation spending responses to new facilities such as campgrounds, trails and interpretive centers. The
Western Oregon Plan Revision does not include any proposed changes in developed recreation facilities. The
harvest of late-successional forests was reduced by 80% on Forest Service and BLM-administered lands in
1994 under the Northwest Forest Plan. In the 14 years since that 80% reduction in harvest level, recreation
activities have not materially increased. Since there are no projected changes in recreation activities on BLM
administered lands, the WOPR I/O models does not include any new 2009 multiplier effects of these types.
46. Comment: More complete comment: The EIS discusses multiplier effects without disclosing that there
are credible opposing viewpoints about the economic base model that multipliers are derived from. Krone,
Elaynes, Reyna. 1999. Different Perspectives on Economic Base. Research Note PNW-RN-538. April 1999.
http://www.fs.fed.us/pnw/pubs/rn_538.pdf
Response: The article by Crones et al. (1999) cites various shortcoming of an economic base approach. The
six major criticisms listed by these authors are followed by a synopsis of how the WOPR I/O models deal
with each point.
Appendices - 778
Appendix T - Responses to Public Comments and Comment Letters
1. Author’s Criticism: The concept of basis employment places a premium on jobs in sectors such as
logging and agriculture that are dangerous jobs. It does not include qualitative aspects of employment.
Response: The value an economy places on any particular job is best expressed by the wages paid to it. Both
job safety and specialized skills affect wage rates. The analyses in the Western Oregon Plan Revision includes
wage and salary impacts, which incorporate some qualitative aspects of employment. Other issues related to
job safety and specialized training are general societal issues beyond the scope of BLM planning.
2. Author’ Criticism: Export base analysis only captures exports from primary goods-producing industries
and does not capture exports from service and information sectors.
Response: The Western Oregon Plan Revision I/O models are individually adjusted to include exports from
all sectors. Examples include tourist services from motels, eating, and drinking that are important export
sales for most coastal counties. Most of the construction industry, a major employer in coastal counties, is
attributed to export sales because the construction is financed by investment and retirement income earned
outside local areas.
3. Author’s criticism: The role of non-basic sectors in leakage of trade from the local economy is not given
adequate consideration in base analysis.
Response: The multiplier or re-spending effect is included in WOPR models. The magnitude of the
multiplier effect is directly proportion to the “openness” of a local economy. Coastal economies are fairly
open economies. Dollars spent on the coast leak out to metropolitan areas such as Eugene-Springfield and
Portland. Trade leakage is estimated by separately modeling the Southwest Oregon economy (counties
with trade leakage to Eugene-Springfield) and the Portland area economy (counties with trade linkage to
the Portland area). These models demonstrated that the metropolitan areas could see significant secondary
impacts associated with their role as central cities. Impacts up and down the trade hierarchy can be
significant, but are typically ignored by other impact analysis approaches.
4. Author’s Criticism: The importance of non-labor income is not considered in base analysis.
Response: This criticism is valid for other input-output modeling programs, such as IMPLAN. The WOPR
models specifically include non-labor or unearned income in each model. In most coastal counties,
non-labor income accounts for over half of all disposable income. For example, Curry County is heavily
dependent on retirement income, investment income, and other types of non-labor income. These types of
income are more important than basic industries in understanding their export base. Commuting income
is also included, as it accounts for significant portions of the economic base in several counties. For example,
Columbia County residents earn more income from commuting than they earn from working within the
county.
5. Author’s Criticism: The economic base model assumes that people follow employment and that changes
in basic employment correspond to changes in population. This ignores the quality of life factor in
migration.
Response: Commuting and non-labor income accounts for two primary factors driving migration in western
Oregon. Quality of life migration is, in most circumstances, made possible by either outside income (non-
labor income) or income from commuting. Additional survey data supported the argument that quality of
life is increasingly important in residence choices. Western Oregon residents are commuting long distances
to find desired quality of life and living circumstances. Coastal communities report that many seasonal
residents are taking up permanent residence. Non-labor income is also playing an important role in the
migration to areas such as Florence, Seaside, and Gold Beach.
Appendices - 779
FEISfor the Revision of the Western Oregon RMPs
6. Author’s Criticism: The externalities associated with primary goods-producing industries are not
accounted for in the economic base model.
Response : Externalities of increased timber harvest are described in detail in other sections of the EIS.
Watershed, wildlife, aesthetics, fishery impacts, and related externalities of timber harvest play an integral
part in BLM planning. These are valuation questions, not I/O questions. The I/O models are not capable of
placing values on these non-market effects (externalities).
47. Comment: The DEIS fails to evaluate the contribution its proposals would make to the economic
stability of the local communities and industries in the context of the evolving regionalization of the log
market and the price effect on the regional log market.
Response: The DEIS states that the BLM anticipates a price effect and that under all alternatives, log prices
and harvests from price-sensitive private lands would fall as the BLM sells more timber into the log market.
As manufacturing capacity adjusts to absorb the increased BLM timber, prices and harvests from other
owners would adjust to previous levels (see DEIS, page 535).
Projections of harvest revenues under all alternatives assume a price impact of negative 3.5% in the first
decade, after which prices rise to historic levels. This price impact was based on analysis using the TAMM
model and WOR model. This information has been included in the FEIS.
48. Comment: The EIS should be revised to analyze the impacts of the alternatives on property value.
Response: There is no information that indicates property values would be affected under any alternative.
49. Comment: The economic analysis of the plan is flawed, inaccurate, and ignorant of the importance
of an intact ecosystem in both local economies and as a taxable base. A 1997 study by Haynes and Horne
found that in an intact roadless area, 89% of the revenue is connected to tourism and human industry. Only
11% of the revenue is connected to timber harvest. Not only does the BLM WOPR fail to recognize this
reality and how it plays out in Oregon economy, the BLM analysis relies on statistics from peak economic
times, over-inflated timber prices, and a lack of consideration for the economic climate such as the impact
of flooding the market with timber, and the effect of logging from WOPR on local businesses and private
timber owners. The fact that the BLM offers different prices for board feet in two different alternatives shows
a distortion of economic facts.
Response: None of the alternatives propose changes to roadless areas. The economic analysis described
in detail in Chapters 3 and 4 of the EIS is based on historic stumpage prices. Stumpage prices differ among
alternatives, because the alternatives differ with respect to factors that affect the type of harvest and the cost
of harvest. These differences translate into differences in projected stumpage.
50. Comment: A recent report by the Sonoran Institute (2004) found that: “Protected lands have the
greatest influence on the economic growth of rural isolated counties that lack easy access to larger markets.
From 1970 to 2000, real per capita income in isolated rural counties with protected land grew more than 60
percent faster than isolated counties without any protected lands.” Recent survey results also indicate that
many firms decide to locate or stay in an area because of scenic amenities and wildlife-based recreation,
both of which are strongly supported by wilderness areas (Morton 2000). In a study to determine the
economic value of federal lands in the Interior Columbia Basin, Haynes and Home (1997) concluded that
the services derived from roadless areas constitute 89 percent of the economic value of federal land. Timber
constitutes only 1 1 percent of the total value.
Appendices - 780
Appendix T - Responses to Public Comments and Comment Letters
Response None of the alternatives change the status of any wilderness or permanently protected lands.
Neither scenic amenities nor wildlife-based recreation would differ among alternatives.
51. Comment: There is empirical evidence that counties containing a higher proportion of land restricted
from timber harvests in order to promote biodiversity (late-successional old-growth or riparian reserves)
actually experienced faster employment growth than counties with a greater proportion of matrix land
available for harvest (Kerkvliet et al. 2007a). This evidence suggests that implementing the Northwest Forest
Plan and restricting timber harvesting on public land in order to promote biodiversity conservation actually
led to increased numbers of jobs, not the decrease in employment claimed by BLM.
Response: The Northwest Forest Plan monitoring of the socioeconomic effects of the plan have
indicated that the adverse economic impacts anticipated in the Northwest Forest Plan FSEIS, such as job
losses, actually occurred. The monitoring found that although some communities in close proximity to
federal forests were doing quite well, on the whole, however, these communities were not doing as well
as communities less associated with federal forests (Northwest Forest Plan, The First Ten Years Rural
Communities and Economics 2004). There is no evidence that counties in western Oregon with a higher
portion of land restricted from harvest (e.g., Douglas and Coos Counties) experience faster employment
growth than counties with a greater portion of matrix lands. More than 80 percent of BLM lands in all
counties in western Oregon have been reserved, and less than 20 percent have consisted of matrix lands
for the past 14 years (1994). The economic growth of these counties has not appreciably changed from that
experienced prior to 1994.
52. Comment: Recent research indicates that the economies of many areas of the West, including Oregon,
are no longer much dependent on resource extraction, including logging (Rasker et al. 2004) Research
indicates that economic growth in rural Oregon counties is associated with protected areas on federal land.
Response: Chapter 3 in the EIS describes the relative importance of BLM activities and revenues for each
of the 18 O&C counties. The Socioeconomics Appendix includes an analysis from the counties showing that
growth from recreation and tourism cannot be reasonably expected to oifset economic losses from the loss
of Secure Rural School Funding. The EIS acknowledges that certain rural counties have diversified; however,
the EIS analysis indicates that many rural county governments rely on timber revenues for a variety of
services, and that change in harvest levels will result in changes to local economies.
53. Comment: The EIS should clarify why data presented in Figure 161 illustrates that BLM payments to
counties totaled $65-69 Million, while 1981 data stated the figure was $18.6 Million.
Response: The EIS does not show payment to county data for 1981.
54. Comment: The EIS should explain why the stumpage prices differ between alternatives, particularly the
highest price assumed under Alternative 2. The EIS analysis should address the fact that finding markets for
large logs at reasonable stumpage prices is difficult.
Response: Stumpage price computation is documented in the Timber Appendix of the EIS. For each
combination of district, structural stage, and harvest type, stumpages are constant across alternatives.
The total stumpage value and the average stumpage price/ mbf change by alternative due to the different
quantities and types of harvest that occur under each alternative. The commenter presents no evidence
that the more limited number of mills which process large logs is negatively affecting their marketability.
Appendices - 781
FE/S/or the Revision of the Western Oregon RMPs
To presume the future demise of these mills such that current demands for such a timber supply would
disappear is speculative. The fact that there is a reasonable market for such large logs is evidenced by the fact
that such logs sell at a reasonable rates when offered.
55. Comment: The EIS should conduct a sensitivity analysis based on several scenarios reflecting the
historical range of variability in the market for wood products, including prices, volumes, and legal
impediments to harvests, and report the results of the analysis for timber volume, stumpage price, revenue,
O&C payments, and employment.
Response: A sensitivity analysis would add little to the analysis, where there is no conceptual hypothesis
that would suggest the relative effects among the alternatives would vary depending on the assumed
scenario. To suggest varying the assumed economic returns among alternatives on the presumption that
some would be more likely “legally impeded” would be inappropriate since it suggests that courts would be
biased by the types of harvest made under the alternatives. Any of the alternatives would be based on the
same NEPA document, and presumably all would be equally vulnerable.
To make assumptions about relative likely outcomes of litigation among the alternatives would be highly
speculative. Even if there were differential risks in legal vulnerability among the alternatives, to base an
analysis on such differences would necessarily involve legal analysis of such varying risk that it would force
the agency to forego the right to confidential attorney client communications. This, in turn, could adversely
affect the ability of the agency to get frank and unfettered advice from its legal counsel. As the commenter
notes, log prices have shown considerable variability over time. To anticipate future price changes that are
sensitive to the general economic level of activity is speculative and would only serve to raise or lower all
alternatives in a similar manner. To present a variety of futures, all depending on the price assumptions
used, would confuse rather than clarify.
56. Comment: The EIS should consider ecosystem services in its analysis, as BLM has numerous well-
established methodologies that it could use to provide a more complete estimate of ecosystem values.
Response: The EIS focuses on the economic impacts of the outputs that vary between alternatives and that
directly impact jobs and income. Ecosystem services do not affect economic outputs that vary between
alternatives.
57. Comment: The EIS should consider “existence value” of timber, the value of simply having, but not
using wilderness and other unroaded areas.
Response: None of the alternatives propose any differences in creating or maintaining wilderness areas
or unroaded areas from those already in existence. It is not feasible to assign an economic or market value
to the existence of timber. Qualitative and highly subjective descriptions of non-economic or non-market
value of the existence of timber would be so speculative as to not inform a choice among the alternatives,
particularly when none of the alternatives propose any differential treatment to those areas.
58. Comment: The EIS should evaluate the costs of sedimentation caused by clearcutting forested areas.
Response: Under all alternatives, BLM lands would be managed under Best Management Practices
designed to minimize sediment delivery from harvest units (DEIS, page 761). The EIS analysis concludes
that the amount of sediment delivered to streams as a result of timber harvest is inconsequential and does
Appendices - 782
Appendix T - Responses to Public Comments and Comment Letters
not materially vary among the alternatives. Therefore, any hypothetical economic impacts associated with
sedimentation from timber harvest would be minimal and would not affect analytical conclusions or the
ranking of alternatives.
59. Comment: The EIS should be revised to reflect that national macroeconomic variables that influence
wood products demand are the cause of forest sector employment in Oregon, and studies show that forest
timber cut or sold would not stabilize wood product employment.
Response: The O&C Act and the purpose and need are to manage BLM-administered lands for permanent
forest production in conformity with the principles of sustained yield. The O&C Act states the purposes of
permanent forest production in conformity with sustained yield include “a permanent timber supply” and
“contributing to economic stability of local communities and industries.” All BLM management needs to do
is contribute to economic stability, not be solely responsible for that outcome, which is obviously dependent
on factors other than a permanent timber supply.
The O&C lands managed by BLM have more impact than USFS lands, because of differences in how
revenues are shared with and used by county governments. Conclusions based on research in areas
dominated by USFS ownership would not be directly applicable to the O&C counties.
Demand for wood products creates demand for raw material (logs) and the factors (e.g., employees and
capital investments) that convert raw material into finished products. Management of BLM land is not
intended to create demand for wood products, but rather respond to demand through supplying raw
material. The BLM timber sales will generate revenues that are shared with the counties; the sales also will
create employment and income across many sectors of the economy.
60. Comment: The EIS should be revised to show the total number of jobs in each county, the net/loss gain
for jobs for each alternative, and the percentage of total jobs that the net loss/gain represents in each county,
in order to better illustrate the perspective of the potential impacts.
Response: Table 69 (DEIS, page 219) shows total jobs in each county. Tables 158 and 159 (DEIS, pages 543-
544) shows net changes in jobs by county for each alternative. The FEIS shows the changes graphically (see
FEIS, Socioeconomics Appendix , Figures 4-25 through 4-29). Information about employment by sector by
county have been added to the Socioeconomics Appendix.
61. Comment: The EIS should be revised to take into account the demographic characteristics of the
region, as in-migration is probably the single biggest driver of social and economic change in rural western
Oregon at this time. The EIS should include consideration of: the variation across counties and within
counties, how in-migration patterns are likely to affect demand for various types of stand structures, types
of recreational infrastructure, and how the different alternatives are likely to affect communities differently
depending on their demographic characteristics, amenity values migration, and the expanding role of Latino
immigration in the forest sector labor force.
Response: The 18 county-level models used to project employment and income impacts were individually
calibrated to take into account some demographic parameters such as retirement income. In the EIS
analysis, the economic conditions of the individual counties in the planning area were carefully assessed and
compared. The economic condition of the various counties is a result of many complex factors including:
proximity to major population centers, proximity to 1-5, education level, and population growth (in-
migration). The role of population growth as a factor in the economy of western Oregon was included in
the economic analysis in the EIS. The economic assessment of the counties included an acknowledgement
of the importance of population growth in the metropolitan counties and the in-migration of retirees to
Appendices - 783
FEISfor the Revision of the Western Oregon RMPs
certain rural counties (e.g., Curry County) and how that in-migration places demands on government
services. The population in many rural counties has not changed appreciably in the past 15 years (e.g., Coos
County, Douglas County). The alternatives are not expected to differ substantially with respect to recreation
opportunities or recreation use.
62. Comment: The EIS should be revised to provide complete descriptions of the input/output model
assumptions and limitations, including each county’s model assumptions and inputs.
Response: Complete specification of the 18 county-level models that project employment and income
impacts is too voluminous for the EIS and is available in the administrative record. Much additional
information and detail, however, has been added to the Socioeconomics Appendix of the FEIS regarding
county information used in the economic modeling.
63. Comment: The EIS should be revised to include adequate documentation to justify the stumpage price
differences between alternatives, especially the highest price assumed under Alternative 2. For example,
there is not a reference cited for BLM’s claim that additional investment is being made in large log capacity
(page 237). The BLM should address the possibility that it will have a difficult time finding markets for large
logs at reasonable stumpage prices.
Response: The Timber Appendix describes the method for calculating the stumpage price. The price under
Alternative 2 is a result of the higher level of regeneration harvest and higher level of harvest of structurally
complex forest. Within each combination of harvest type, district, and structural stage harvested, the
stumpage price for that combination is constant across alternatives. It is the different quantities harvested,
the different types of structural stages harvested, and the different harvest methods (thinning or
regeneration) that cause the stumpage prices to vary both in total and on a per MBF basis. The EIS provides
a citation (Ehinger 2006a) to support the assumption regarding large log capacity. The commenter asserts,
but does not provide evidence, that there is a shortage of manufacturing capacity for large logs. As shown in
the DEIS (page 576), even under Alternative 2, peeler logs > 24 inches in diameter comprise only about 8%
of harvested volume.
64. Comment: The EIS economic analysis should be revised to use a range of stumpage prices to forecast
O&C county payments, with the range determined by the historic range of variability of stumpage and
lumber prices. Given the projected continual recessed state of the real estate market over at least the next five
years, it is not likely that the high stumpage prices projected by BLM will be realized. If these high prices are
not maintained, BLM projections for O&C county payments are overly optimistic.
Response: An analysis using a variety of prices would add little clarity. Although the overall forecasted
receipt levels would vary if prices were changed, the results for the alternatives would move nearly in unison.
Even when pond values change, log grade premiums between grades (DF) change little. Log prices as of the
current time (2008) are below the 10-year average. The commenter asserts that prices will remain low, but
that is speculative and dependent on a variety of economic factors. Comparisons between alternatives would
change little in response to variations in price assumptions for pond values of logs.
Timber
65. Comment: The EIS should be revised to reconsider the conflation of sustained yield with ecological
sustainability. The calculus of extracting a maximum volume of timber in a rotation that theoretically will
never dip below a maximum volume ignores the qualitative difference between a thriving ecosystem and an
intensely managed rotation of cash crops.
Appendices - 784
Appendix T - Responses to Public Comments and Comment Letters
Response: The Draft EIS did not conflate sustained yield with ecological sustainability. The Draft EIS
defined sustained yield as the volume of timber that a forest can produce continuously at a given intensity of
management. The identification of the sustained yield level under each alternative described only the timber
harvest level. The Draft EIS presented the analysis of the effects of different forest management strategies on
the ecosystem in the various chapter sections, including wildlife, botany, fish, water, and soils.
66. Comment: The EIS should be revised to provide documentation on how BLM determined the increased
budget numbers for the various alternatives. Without this information, it is impossible to validate the 60
percent increase identified for Alternative 2.
Response: The FEIS Socioeconomics Appendix documents the assumptions used to calculate the BLM
timber budget for the alternatives.
67. Comment: The EIS should be revised to incorporate a more realistic implementation schedule. For
example, under Alternative 2, it is assumed the BLM will receive enough funding to sell 767 mmbf by
either the first or third year of the plan. This equates to an increase of 551 mmbf over the 2007 level and an
increase in the Forest Management Budget of $132.2 million assuming a cost of $240/mbf. This scenario is
unlikely to occur.
Response: Consistent analysis of the alternatives requires the assumption of similar implementation
schedules for all alternatives. To presume specific appropriations for any year is speculative, and in addition
would mask the environmental differences between alternatives, since it then would be the budget level
that would dictate environmental consequences, not the differences in management approach and intensity
between the alternatives. Knowing the actual funding levels the BLM will receive in the future is not
necessary in choosing among the alternatives, since in making that choice it is not the absolute numbers,
but the relative differences among the alternatives that is important. The periodic plan evaluations provide
opportunities to make adjustments based on the actual experience in implementing the plan.
68. Comment: The EIS should be revised to clearly explain how Alternative 2, with the greatest amount of
timber cutting, can have the lowest projected miles of new roads.
Response: Alternative 2 has a higher level of new road construction than the No Action Alternative, and
Alternatives 1 and 3. The projected miles of new road construction under the alternatives results from an
interaction of the harvest land base, the harvest type, topography, and the existing road level adjacent to
harvest units, among other factors. The amount of road construction would not necessarily relate simply
to the volume harvested. For example, thinnings have nearly three times the road construction required
compared to regeneration harvest on an equal volume basis.
69. Comment: The EIS should be revised to reflect the correct number of mmbf/year that would come from
non-ASQ (riparian reserves and late-successional reserves) thinning in the Medford District under the No
Action Alternative. Three mmbf/year is clearly too low based on sales like California Gulch, Rum Creek,
Rich and Rocky, and Deer Willy.
Response: Three mmbf per year is the level modeled on the Medford District under the No Action
Alternative. This level of non-harvest land base volume is the highest of all the alternatives. The sales
shown in the comment were sold under the current RMR Over the past 7 years, FY2000 through FY2007,
auctioned sales within Late-Successional Reserves and Riparian Reserves on the Medford District have been
Appendices - 785
F£IS/or the Revision of the Western Oregon RAlPs
1.6 mmbf per year under the current RMP, excluding fire salvage. For example, California Gulch and Rum
Creek together total 451 mbf of thinning within the Late-Successional Reserve, or about 15% of the yearly
modeled total, but were sold in two separate years.
70. Comment: The EIS should explain why the stumpage prices differ between alternatives, particularly the
highest price assumed under Alternative #2. The EIS analysis should address the fact that finding markets
for large logs at reasonable stumpage prices is difficult.
Response: Stumpage price computation is documented in the Timber Appendix of the EIS. For each
combination of district, structural stage, and harvest type, stumpages are constant across alternatives.
The total stumpage value and the average stumpage price/mbf change by alternative due to the different
quantities and types of harvest that occur under each alternative. The prices of logs at a manufacturing
facility used in our analysis came from Log Lines Log Price Reporting Service as shown in the Timber
Appendix, which publishes prices actually paid in the market monthly. The average price for 2005 was used.
The commenter presents no evidence that the more limited number of mills which process large logs is
negatively affecting their marketability.
71. Comment: The EIS should conduct a sensitivity analysis based on several scenarios reflecting the
historical range of variability in the market for wood products, including prices, volumes, and legal
impediments to harvests, and report the results of the analysis for timber volume, stumpage price, revenue,
O&C payments, and employment.
Response: A sensitivity analysis would add little to the analysis. As the commenter notes, log prices have
shown considerable variability over time. To anticipate future price changes that are sensitive to the general
economic level of activity is speculative and would only serve to raise or lower all alternatives in a similar
manner. To present a variety of futures, all depending on the price assumptions used, would confuse rather
than clarify the effects and differences of the various management strategies of the alternatives. The purpose
of NEPA analysis is to assist the agency in making a choice among alternatives for a decision. Therefore,
it is the relative differences among the alternatives that is important in making this choice, rather than
making the most accurate prediction on the actual prices that will be received by the government during
implementation.
72. Comment: The EIS should be revised to ensure that the estimated cost of preparing timber sales under
the proposed action and alternatives is consistent when compared to the actual costs incurred for similar
BLM activities in 2006.
Response: The estimated cost of timber sales was prepared from historical costs including FY2006. The
marginal cost/mbf is disclosed in the EIS.
73. Comment: The EIS should be revised to ensure alternatives conform to the O&C Act. It appears that
Alternative 2 has a declining, even if slightly, not sustained production. The same appears to be the case
for Alternative 1 and the No Action Alternative. These results need to be reexamined to ensure O&C Act
conformity.
Response: As disclosed in the EIS, the total harvest volume is comprised of both the sustained allowable
sale quantity from the harvest land base, and thinnings that are undertaken to improve habitat development
within the Late-Successional Management Areas and Riparian Management Areas. This non-harvest land
base volume from within the Late-Successional Management Areas declines over time and is identified
as not part of the sustained allowable sale quantity. The EIS discloses the sum of both volume types. The
Appendices - 786
Appendix T - Responses to Public Comments and Comment Letters
total volume level declines to the Allowable Sale Quantity at the end of the period when these habitat
development thinnings are completed.
74. Comment: The EIS should be revised to include adequate documentation to justify the stumpage price
differences between alternatives, especially the highest price assumed under Alternative 2. For example,
there is not a reference cited for BLM’s claim that additional investment is being made in large log capacity
(page 237). The BLM should address the possibility that it will have a difficult time finding markets for large
logs at reasonable stumpage prices.
Response: The Timber Appendix of the EIS describes the method for calculating the stumpage price.
The price under Alternative 2 is a result of the higher level of regeneration harvest and higher level of
harvest of structurally complex forest. Within each combination of harvest type, district, and structural
stage harvested, the stumpage price for that combination is constant across alternatives. It is the different
quantities harvested, the different types of structural stages harvested, and the different harvest methods
(thinning or regeneration) that cause the stumpage prices to vary both in total and on a per MBF basis.
The EIS provides a citation (Ehinger 2006) to support the assumption regarding large log capacity. The
commenter asserts, but does not provide evidence, that there is a shortage of manufacturing capacity for
large logs. As disclosed in the EIS, even under Alternative 2, peeler logs > 24 inches in diameter comprise
only about 8% of harvested volume.
75. Comment: The EIS economic analysis should be revised to use a range of stumpage prices to forecast
O&C county payments, with the range determined by the historic range of variability of stumpage and
lumber prices. Given the projected continual recessed state of the real estate market over at least the next five
years, it is not likely that the high stumpage prices projected by BLM will be realized. If these high prices are
not maintained, BLM projections for O&C county payments are overly optimistic.
Response: An analysis using a variety of prices would add little clarity. Although the overall forecasted
receipt levels would vary if prices were changed, the results for the alternatives would move nearly in
unison, and therefore maintain their relative differences in effects on the O&C county payments. Even when
pond values change, log grade premiums between grades (DF) change little. Log prices as of the current
time (2008) are below the 10-year average. The commenter asserts that prices will remain low, but that
is speculative and dependent on a variety of economic factors. Comparisons between alternatives would
change little in response to variations in price assumptions for pond values of logs.
76. Comment: The EIS should be revised to include a reference citation for the “improved genetics”
assumption, because several published articles suggest that “improved genetics” for faster growth may also
make trees more vulnerable to insect and fungal infestations.
Response: The basis and methods for analyzing the effects of genetic tree improvement are described in the
Vegetation Modeling Appendix of the FEIS.
The principal tree species genetically selected for faster growth within the planning area are Douglas-fir and
western hemlock. There is no documented evidence that genetically improved Douglas-fir and western
hemlock are more vulnerable to insect and fungal infestations. If anything, the opposite is true. “In Douglas-
fir, favorable genetic associations have been shown for growth and resistance to Swiss needle cast, and for
growth and terpine content, a deterrent to bear damage” (Johnson 2000; pages 29-34). To minimize the
chance of inadvertently favoring these or any other unintended consequence of genetic selection, a broad
genetic base is maintained, resistance/tolerance to known insect and disease problems is kept neutral or
improved, and only locally adapted planting stock is used for reforestation.
Appendices - 787
FEIS for the Revision of the Western Oregon RMPs
77. Comment: "Hie EIS should be revised to identify and reference surveys and modeling used to justify
anticipated growth of plantations, as they currently are not provided. Previous research in the Medford
District (on file at Medford BLM) indicates that the ORGANON modeling program used by BLM to
estimate future growth of plantations grossly overestimated tree growth while underestimating negative
impacts such as dumpiness, non-stocked openings, and animal damage.
Response: The methods used for estimating the growth of plantations, as well as natural forest stands and
the application of those growth projections, are described in the Vegetation Modeling Appendix of the FEIS.
The basic data used were the BLM Current Vegetation Survey (CVS) inventory plots stratified by geographic
region (southwest and northwest Oregon), age, site productivity class, species group, and existing stand
condition (current density, past treatment history). This modeling approach partially compensates for the
negative effects on growth and yield due to dumpiness, non-stocked openings, and animal damage. Further
growth reductions are applied to the simulated yield projections to account for the effects of defect and
breakage, soil compaction, snag and coarse woody debris retention, Swiss needle cast disease (Salem District
only), other diseases, and insects.
The modeling approach used for the Western Oregon Plan Revision differs from that used for the Medford
BLM analyses, and also that used by the BLM for the current (1995) resource management plans. The data
used for the Western Oregon Plan Revision is stratified to a much higher degree than previous BLM analyses
providing for more reliable estimates. In addition, each CVS subplot in a stratum is simulated separately.
This stratification ensures representation of the full range of actual conditions for a forest stratum (modeling
group), not just an optimum condition. Instead, the simulation results of each subplot in a modeling group
are averaged together. This method is based on the fact that the CVS data presents a random sample of the
forest stratum modeled. Therefore, the average of all projected curves for a modeling group represents the
average projection for the forested land base represented by the modeling group.
78. Comment: The EIS should be revised to use valid “net ingrowth” conclusions, because the conclusions
from the 10-year LSOG monitoring report are flawed. The modeled growth of trees from 18 or 19 inches
dbh in 1994 to cross an arbitrary 20 inch dbh threshold in 2004 is merely an incremental change that cannot
be compared on an acre-to-acre basis with regeneration harvest of old forests that is visible from space.
Response: The EIS acknowledges that the change occurs primarily in the lower end of the diameter range
for older forest. The 20-inch diameter threshold is not arbitrary. The rationale for this and other diameter
thresholds is described in the Late-Successional Old-Growth monitoring report (Moeur et al. 2005, pages
9-13).
79. Comment: The EIS should be revised to include discussion of increased exposure to herbicides that
forest dwellers will experience if clear-cutting is increased on BLM lands, especially in light of the recent
changes in BLM Lferbicide policies as announced in the September, 2007, Record of Decision (ROD) on
Vegetation Treatments Using Herbicides.
Response: The current western Oregon BLM vegetation management techniques employed in clearcuts for
forest management goals do not employ herbicides. Analysis of effects in the EIS is based on the assumption
of no herbicide use for reforestation and timber stand improvement purposes. The new vegetation
management EIS and ROD (USDI 2007a, 2007b) does not alter the status quo in that regard. The vegetation
management EIS specifically states: “Thus, this PEIS does not evaluate vegetation management that is
primarily focused on commercial timber or other forest product enhancement or use activities that are not
related to improving forest or rangeland health or work authorized under the Healthy Forests Restoration Act
of 2003” (USDI 2007a, pages 1-5).
Any future use of herbicides for commercial forestry purposes would be done only after additional
environmental analysis was completed.
Appendices - 788
Appendix T - Responses to Public Comments and Comment Letters
80. Comment: The EIS should be revised to include an analysis of the impacts to endangered species from
the use of herbicides, in particular impacts to salmon and the northern spotted owl.
Response: The BLM consulted with the U.S. Fish and Wildlife Service and the National Marine Fisheries
Service, as required under Section 7 of the ESA, as part of the vegetation management Programmatic
EIS (USDI 2007a) involving the use herbicides for other than commercial timber or other forest product
enhancement or use of activities that are not related to improving forest or rangeland health. The effects of
herbicide use on the northern spotted owl and various salmonid species were included in that assessment
(USDI 2007c). Further analysis and consultation at the state and local levels tiered to the vegetation
management PEIS would be undertaken before implementation occurred.
81. Comment: The EIS should be revised to address the apparent inconsistency with reporting that only
one southwestern Oregon site is currently infected with Sudden Oak Death. Other studies report that at
least 53 other localities are infected with Sudden Oak Death.
Response: The text in the final EIS has been revised and additional citations provided.
82. Comment: The EIS should be revised to include a definition for common silvicultural treatments and
these definitions should include examples of these management styles.
Response: Descriptions of common silvicultural treatments have been added to the Vegetation Modeling
Appendix of the FEIS.
Special Forest Products
83. Comment: The EIS should be revised to account for the diversity in special forest products, because the
current analysis is too generic and does not acknowledge that variation exists across products and across
species for the same types of products. Therefore the analysis is flawed.
Response: The EIS analysis describes 10 categories comprising 84 special forest products and the
anticipated effects of management activities to special forest products over 10 years. There is variability
of special forest products that occurs at local spatial scales and by management activities. However, the
availability, abundance, quality, and distribution of most special forest products would not vary under all of
the alternatives. Other special forest products would be affected by increased forest management activities
at the local scale, but to what extent is speculative. Little difference is expected at the regional scale. Special
forest products are collected and harvested from common species with broad distribution. Changes in
the level of forest management activities under the alternatives would not result in substantial changes to
current harvesting and collecting levels of special forest products.
84. Comment: The EIS should be revised to incorporate a range of existing scientific literature in the Special
Forest Products analysis, because the analysis lacks sufficient documentation. Existing literature includes:
Institute for Culture and Ecology, http://www.ifcae.org/ntfp/pubs/index.html. We have posted numerous
reports and links to articles on SFP issues at this site. One that might be particularly useful for the FEIS
is: Lynch, Kathryn A.; McLain, Rebecca J. 2003. Access, Labor, and Wild Floral Greens Management in
Western Washingtons Forests. PNWGTR-585. Portland: Pacific Northwest Research Station USDA Forest
Service. Another key publication is: Jones, Eric T. Rebecca J. McLain, and James Weigand. eds. 2002. Non
Timber Forest Products in the United States. Lawrence: University of Kansas Press. Center for Nontimber
Resources at Royal Roads University in Victoria, British Columbia.
http://www.royalroads.ca/programs/faculties-schools-centres/non-timber-resources/.
Appendices - 789
FEIS for the Revision of the Western Oregon RMPs
Response: The special forest product literature cited provides reference information to assist in drawing
conclusions for management of specific forest products and species on BLM-administered lands in response
to forest management activities and habitat changes anticipated over the next 10 years at the site scale and
regional scales. There is a growing body of scientific literature that provides regional perspectives of the
special forest product trade. However, much of the scientific literature acknowledges, as does the BLM, the
lack of information and knowledge of the distribution and abundance of these generally common, wide
ranging species (Jones et al. 2007, Muir 2004, Pilz et al. 2001) and the BLM contribution within the context
of the broader forested landscape. Much of the current information remains anecdotal. No studies have been
conducted that attempt to segregate the portion of the harvest that occurs on BLM-administered lands from
that of other landowners. Inventories of special forest products or spatially explicit habitat types associated
with individual special forest products are unavailable on BLM-administered lands, as well as the amount
and location of actual harvests.
Botany
85. Comment: The EIS should be revised to provide management direction for deciduous oaks. Currently,
these species are combined with “hardwoods” in the vegetation section. Deciduous oaks are much different
than broadleaf evergreen trees (e.g. tanoak) because deciduous oaks are shade intolerant and relatively low
growing (as compared to conifers). Deciduous oaks are easily shaded out by the faster growing and taller
Douglas-fir.
Response: The Draft EIS included a management objective common to all action alternatives to support
natural species composition and vegetation on noncommercial areas, including: noncommercial forests,
oak woodlands, shrublands, grasslands, cliffs, rock outcrops, talus slopes, meadows, wetlands, springs,
fens, ponds, and vernal pools. The Draft EIS described the following management actions common to
all action alternatives: natural processes, native species composition, and vegetation structure that would
be maintained or restored. Management would include the use of prescribed burns; retention of legacy
components (e.g., large trees, snags, and down logs); and removal of encroaching vegetation in meadows,
grasslands, or oak woodlands in a manner consistent with natural or historic processes and conditions.
Providing more detailed and site-specific management actions would be beyond the scope of this RMP
revision and may be developed through implementation actions.
86. Comment: The EIS should be revised to address the apparent inconsistency with reporting that only
one southwestern Oregon site is currently infected with Sudden Oak Death. Other studies report that at
least 53 other localities are infected with Sudden Oak Death.
Response: The text in the final EIS has been revised and additional citations provided.
87. Comment: The EIS should be revised by removing the statement “However, because future spread of
the disease and subsequent tree mortality in the planning area is speculative, there is no basis on which this
analysis can assume future changes to forest composition, structure, and process as a result of Sudden Oak
Death.” This statement is contrary to the General Technical Report cited in the EIS which notes that a model
for Sudden Oak Death created by the USDA Forest Service’s Pacific Southwest Research Station, found that
all five models examined “were consistent in their prediction of some SOD risk in coastal CA, OR and WA.”
Three of the five models predict high risk for almost all of the WOPR area and a 57 composite model placed
most of the WOPR area in the highest two risk categories.
Response: The cited models identified various levels of potential risk, rather than predicting spread of
Sudden Oak Death in the planning area. Whether Sudden Oak Disease actually spreads in the planning area
will be influenced by many variables other than the potential risk identified in these models, including the
Appendices - 790
Appendix T - Responses to Public Comments and Comment Letters
effectiveness of quarantine and eradication measures currently being implemented (Kanaskie 2007, Palmieri
and Frankel 2006). Regardless of the level of potential risk in the planning area, the future spread of the
disease and subsequent tree mortality remains speculative.
88. Comment: The EIS should be revised on page 46, Table 19 to remove Kincaid’s lupine from the list of
completed recovery plans. The completed plan is not expected until summer of 2008.
Response: The Final EIS has been revised to reflect this information.
89. Comment: The EIS should be revised to acknowledge that the health of individual special status
species populations, the threats to those populations, as well as the total number of populations need to be
examined when considering whether to provide conservation measures, as species persistence may be a
concern even when more than 20 populations exist.
Response: In the Final EIS, the term “occurrence” is used rather than “population,” which was used in the
Draft EIS. Each occurrence represents a record in the database as defined by the database entry standards.
The BLM GeoBob and Oregon Heritage data base standards differ, but in general represent distinct field
occurrences as part of a meta-population.
The BLM would apply conservation measures to Bureau special status species on all BLM-administered
lands under the PRMP Alternative in the FEIS consistent with BLM National and Oregon/Washington
State special status species policy. The 20 occurrence (population) threshold would not apply under the
PRMP Alternative. Consequently, there is no need to undertake a detailed species by species analysis of
health, threats, and total populations of the 296 special status plant and fungi species to determine species
persistence.
90. Comment: The EIS should be revised to provide more information on which recovery plan actions in
Appendix E would be implemented in relation to management commitments, especially for listed plants that
do not have completed recovery plans. As currently presented, it is unclear how these recovery plan actions
relate to management commitments.
Response: Management actions under the alternatives would direct implementation of recovery plans and
conservation measures of federally listed plant species on all BLM-administered lands. The BLM would
assess existing data (e.g., suitable habit, previous surveys, and known locations) for each plant species
prior to planned activities and determine if additional field data is necessary, consistent with existing
recovery plans, biological opinions, and BLM policy (Oregon/Washington policy and BLM national policy).
Consultation between the BLM and the U.S. Fish and Wildlife Service would occur for all federally listed
species without recovery plans to determine adequate species conservation measures.
91. Comment: Appendix E in the EIS should be revised to include the findings of last year’s monitoring
report that indicated g. Fritelaria populations are declining all over the district.
Response: Information regarding Bureau special status species has been revised in the final EIS as a result
of a new species list and updated field data entries into both the BLM GeoBob data base and the Oregon
Natural Heritage Information Center data base (see FEIS, Botany Appendix). Recent monitoring results
of Gentner’s fritillary have shown a decrease in the number of flowering plants, but the cause of this trend
is unclear and there is no direct correlation with recent management activities. The summary description
in the 2007 Gentner’s fritillary monitoring report is apt; “In general, the usual pattern of ‘no real pattern’
prevailed” (Siskiyou BioSurvey 2007).
Appendices - 791
FEISfor the Revision of the Western Oregon RMPs
Invasive Plants
92. Comment: The EIS should be revised to include mitigation measures that could be used in the event of
an introduction as apposed to focusing only on reducing the risk of introduction. The EIS should provide
information on the cost and effectiveness of the measures identified.
Response: Management of invasive plant infestations are addressed in the EIS. The EIS also incorporates
the analyses and decisions of the final environmental impact statement and records of decision for the
Northwest Area Noxious Weed Control Program (1987) and the Vegetation Treatments Using Herbicides
on Bureau of Land Management Lands in 17 Western States (2007). In addition to the discussions presented
in the FEIS, these other EISs and records of decision address measures that could be used in event of an
introduction and also provide information regarding cost effectiveness.
93. Comment: The EIS should be revised to include a thorough analysis of all 1 1 representative invasive
species, as apposed to the current analysis that briefly discusses 6 of the 1 1 species and lacks analysis of
economic and ecosystem consequences. In addition, the analysis should correspond to the temporal horizon
of the plan.
Response: All 1 1 species are addressed in Chapter 3 (Affected Environment) of the FEIS. The analysis of
environmental consequences in Chapter 4 is based on a pooled data set of the distribution of all 1 1 species.
The analysis in the FEIS addresses both the short-term and long-term risks of introduction and spread of
invasive plants.
Wildlife
94. Comment: The last sentence on page 685, Volume II of the EIS includes the assumption that private
forest lands will provide early serai forage if the BLM did not do so on its lands, and that the private lands
would provide more of it. The BLM is required under FLPMA to provide adequate wildlife forage and cover
on its lands. The assumption that private lands can provide the early serai stage habitat that happens to be
under represented on the federal lands is refuted by information located on pages 196 and 206 of Volume I.
Response: The analysis in the Draff EIS demonstrated that the abundance of stand establishment forests,
which provide early-seral forage for deer, is well above the average historic abundance on non-federal lands
and will continue to be abundant in the future. The cited statements in the Draff EIS qualified that these
stand establishment forests on non-federal lands generally have a homogeneous structure, uniform tree
composition, and high tree density. As noted in the Draff EIS, this stand condition would limit the habitat
value of these stands to some species, such as snag-dependent birds. However, these stands would provide
deer forage. The Draff EIS disclosed that the BLM-administered lands would continue to provide forage for
deer at levels that would vary over time and among alternatives.
The Federal Land Policy and Management Act requires that BLM-administered lands be managed
in a manner that will provide food and habitat for wildlife, but does not stipulate that this provision
be “adequate” or otherwise set any specific level or amount of food or habitat that must be provided.
Nevertheless, the O&C Act prevails over the Federal Land Policy and Management Act insofar as they relate
to management of timber resources on O&C lands, and there is no requirement specified in the O&C Act to
provide for wildlife. See Headwaters v. BLM, 914 F.2d 1174 (9th Cir. 1990).
95. Comment: The EIS should be revised to address the apparent inconsistency concerning the analysis and
conclusions of foraging habitat and the projected 50% increase in deer population at the end of 50 years.
Appendices - 792
Appendix T - Responses to Public Comments and Comment Letters
Response: The FEIS has been revised to clarify the analysis and conclusions of foraging habitat and also
the increases in populations. The analysis predicting a population response as a result of increased foraging
habitat has been dropped in the final EIS.
96. Comment: Table 5 of the EIS should be revised to explain why connectivity habitat for the No Action
Alternative, Alternative 1, and Alternative 2 is being compared to suitable habitat for Alternative 3 within
the table.
Response: This table does not discuss connectivity, but simply describes the amount of spotted owl suitable
habitat on those lands not contained within Late-Successional Management Areas. Connectivity is the
ability of the northern spotted owl to move across the landscape. Neither Table 5 in the DEIS, nor the
preceding text that references the table, make a presumption to describe the connectivity of the landscape
for the northern spotted owl.
97. Comment: The EIS figures and tables for Riparian Management Area should be clarified to resolve the
apparent contradictions.
Response: Table 207 in the DEIS) (which is Table 4-83 in the FEIS)(Riparian Management Areas Across
All Land Use Allocations Under the Alternatives) and the figure showing land use allocations under the
alternatives (Figure 1 in the DEIS) express Riparian Management Areas as a percentage of two different
base numbers and, therefore, are not comparable. The table expresses Riparian Management Areas as a
percentage of total BLM-administered lands, whereas the figure expresses Riparian Management Areas
as a percentage of the gross Timber Management Area. The analysis in the final EIS has been clarified to
eliminate the perceived conflict.
98. Comment: The figures in the EIS should be revised to include the percentage of both landscape and
land base current and future conditions of Mature and Existing Structurally Complex conditions. Including
this information would help determine whether or not the alternatives meet land bird conservation
objectives.
Response: In the Draff EIS analysis, the mature multi-canopy and structurally complex forests were
combined for analytical purposes. This grouping of structural stages failed to provide adequate analysis for
evaluating the Partners’-in-Flight objective of “[Mjaintain existing old-growth forests....” and “[Mjaintain
existing mature forests...” (Altman 1999). The land bird analysis has been restructured in the final EIS to
analyze impacts to structurally complex forests that approximate Partners’-in-Flight “old growth” and to
separately analyze impacts to mature multi-canopied forest for BLM-administered west-side conifer forests.
The analysis for all landowners has required the coupling of BLM data with data from the Interagency
Vegetation Mapping Project, and also the simplification of the overall data to three structural stages: stand
establishment, young, and mature & structurally complex. A discussion of the limitations on the ability to
address the Partners’-in-Flight habitat objectives has been added to the final EIS.
99. Comment: The EIS should be revised to address Oregon Department of Fish and Wildlife’s (ODFW)
assessment that blacktail and mule deer populations are in decline throughout the planning area, in part due
to the loss of early serai habitat. A discussion of habitat needs found in both the ODFW Mule and Blacktail
Deer Management Plans should be added. This section should also address how BLM’s management actions
will assist ODFW to stop the decline in forage habitat quantity and quality.
Appendices - 793
FEISfor the Revision of the Western Oregon RMPs
Response: The final EIS has been revised to reflect the declines in mule deer, black-tailed deer, and elk
across western Oregon. The Oregon Department of Fish and Wildlife’s elk and mule deer management plans
were reviewed and referenced in development of Chapter 3. (The black-tailed deer management plan is still
undergoing internal review by the department and is not available for referencing.) Neither the elk nor the
mule deer management plan provide habitat targets to guide BLM in accurately assessing the value of its
habitat contribution to the overall needs of these species. The BLM has ongoing efforts to coordinate with
the Oregon Department of Fish and Wildlife in meeting wildlife management objectives where they are
consistent with BLM land use plans. These administrative processes and intergovernmental relationships are
generally not detailed in land use plans.
100. Comment: The EIS should be revised to include new significant information on pileated woodpeckers
including pileated woodpeckers need for more and larger trees than nesting trees. They may use only
one nesting tree a year, but use seven or more roosting trees. These management requirements should be
included in the EIS.
Response: The BLM has incorporated or considered all available current information that is pertinent to
the analysis in the EIS.
101. Comment: The EIS should analyze the State of Oregon’s Comprehensive Wildlife Conservation
Strategy that identifies strategy species’ for the Coast Range, Klamath Mountains, and West Cascades
ecoregions. This conservation strategy instructs that special attention may need to be given to certain
species within late successional forests. In order to avoid trends toward listing, BLM should adopt measures
to conserve these species.
Response: The Final EIS includes a review of the PRMP Alternative for consistency with the State of
Oregon’s Comprehensive Wildlife Conservation Strategy.
102. Comment: The EIS should strongly consider the fact that the U.S. Fish and Wildlife Service (USFWS)
issued a decision on April 8, 2004 that the listing of the Pacific fisher is warranted under the ESA, but action
is being deferred due to workload constraints. Actions that would be detrimental to the Pacific fisher may
need to be reevaluated within the EIS due to its imminent listing.
Response: The EIS analyzed the effects of the alternatives on the Pacific fisher. The PRMP Alternative in
the FEIS was crafted to best meet the purpose and need of the plan revision while complying with the
requirements of the Endangered Species Act and Special Status Policy. There is no present requirement to
consult on a species that for whatever reason is not listed for protection under the Endangered Species Act.
If the U.S. Fish and Wildlife Service lists the Pacific fisher, the BLM will consider whether it has actions with
remaining discretion that have potentially adverse effects on the Pacific fisher, and also determine whether
consultation is required at that time. Not all of the alternatives being considered have adverse consequences
on this species. Furthermore, BLM will consult with the U.S. Fish and Wildlife Service on any implementing
projects of the revised plan that have likely adverse effects to threatened and endangered species.
103. Comment: The EIS should be revised to answer Analytical Question Number 7 on page 83 of the
Planning Criteria, “What levels of elk habitat will be available under each alternative?” because it is not
answered in the DEIS.
Response: The Proposed Planning Criteria and State Director Guidance was written early in the planning
process with the purpose of helping to guide development of alternatives and to ensure focused data
collection and analysis. It was meant to be a dynamic document, responding to changes in data availability
and analytical techniques. Re-evaluation of the issues led the BLM to evaluate the habitat management
Appendices - 794
Appendix T - Responses to Public Comments and Comment Letters
areas only, versus the entire landscape, as the key areas of BLM-administered lands on the landscape.
Coincidently, it was pointed out to the BLM that the western Oregon version of the Wisdom model was
dated and its validity for western Oregon may be questionable; therefore, it was dropped from the final EIS.
A brief discussion of the overall forage habitat and cover availability in the planning area was added to the
final EIS to frame the habitat management area analysis into a larger context.
104. Comment: The EIS should be revised to explain how elk populations will be protected from expected
detrimental effects of new roads being built and increased vehicle use on existing and new roads with the
implementation of WOPR. Roads fragment elk habitat and increase elk take due to increased traffic.
Response: The EIS discusses impacts of vehicle traffic to both deer and elk. The EIS discussion indicated
that unregulated road use causes an increased vulnerability to both legal and illegal harvest and disturbs the
use of adjacent foraging, fawning/calving, breeding, and resting habitat. The EIS discusses the benefits of
controlling road use: (1) decrease energy expenditure responding to vehicle disturbance and (2) increase in
the availability of cover and forage that would occur with road closure. Additional discussions were added to
the final EIS to categorize the relative value of habitat within 150 meters of roads open to vehicle use, versus
those habitats more than 150 meters away.
105. Comment: The EIS should include further analysis on the expected effects of habitat fragmentation
that would be caused by the implementation of the action alternatives, especially with regard to the reduced
riparian reserves and lack of green tree retention in some alternatives.
Response: The effects of the alternatives on landscape connectivity are quantitatively evaluated for BLM-
administered lands in the EIS using the northern spotted owl as the target species, in the Ecology section.
Additionally, the landscape connectivity of riparian-associated species is qualitatively addressed in the
special status species section of the EIS. The effect of green tree retention, or the lack of green tree retention,
is clearly analyzed and discussed in the Forest Structural Stages and Spatial Pattern section of Chapter 4 in
the EIS.
106. Comment: The EIS should consider including an analysis on the effects of the proposed changes
to land management on Survey and Manage instead of simply relying on an assertion that the effects are
similar to those experienced by the northern spotted owl. The 9th Circuit court has found that this type of
assertion does not meet the requirement of NEPA to analyze and disclose the effects of proposed actions.
Response: The EIS analyzes species effects for those wildlife species listed under the Endangered Species
Act, deer, elk, bald eagle, fisher, land birds in general, western snowy plover, sage grouse, and special status
species. For wildlife species that are listed as Special Status Species, many of which were formerly listed as
“Survey and Manage,” analysis was done by grouping species by habitat association. For plants and fungi,
those species that were formerly listed as “Survey and Manage” were included in the analysis of special status
species and other plants and fungi under various habitat groups. Survey and Manage is not a component
of the No Action Alternative or the action alternatives and, therefore, those species are not analyzed
individually.
107. Comment: The EIS should be revised to include a more in-depth analysis of the effects of the proposed
actions on the Siskiyou Mountains salamander, the Larch Mountain salamander, and the Inland tailed frog.
A discussion of salamander and frog biology, habitat requirements, distribution, conservation status, and
existing conservation plans need to be included in the EIS.
Appendices - 795
FEISfor the Revision of the Western Oregon RMPs
Response: Individual special status species were not addressed for several key reasons:
• The vegetative data available to the EIS does not contain adequate information to conduct an
detailed analysis of available habitat for each individual species and would result in analysis based
on more generalized habitat conditions.
• Generalized habitat descriptions for each species would result in similar analysis and results being
repeated for multiple individual species.
• Individual species will be addressed at the project scale where onsite mitigation would be applied,
as necessary, to meet the goals and objectives of the Special Status Species policy.
108. Comment: The EIS should explain that if the habitat needs of species associated with intermittent
streams would not be met under Alternatives 2 and 3, then this would violate the Clean Water Act
requirements to maintain water quality for aquatic organisms.
Response: There was inconsistency between the summary text and main text of the DEIS regarding
this issue. The summary has been clarified in the final EIS. The analysis in the EIS describes the adjacent
vegetative communities, not in-stream water temperatures. Increasing temperatures and decreased relative
humidity would be expected to occur during the summer months when intermittent stream channels are
typically dry and would, therefore, not contribute to water quality issues.
109. Comment: The EIS does not adequately analyze the effects of decreased habitat and increased
fragmentation of habitat under Alternative 3 to fisher and does not address the ESA requirement that federal
agencies not conduct activities that lead towards listing?
Response: The analysis in the EIS discusses the effects of all alternatives to the Pacific fisher, including the
increases and decreases to the available fisher natal and foraging habitat and the long-term changes in patch
size and connectance measure of mature & structurally complex forests (a surrogate for fisher natal habitat).
1 10. Comment: The EIS should be revised to include the Migratory Bird Treaty Act as a Major Legal
Authority in Appendix A, as well as a discussion of how WOPR will address Executive Order 13186,
Responsibilities of Federal Agencies to Protect Migratory Birds and the Migratory Bird Treaty Act.
Response: The Migratory Bird Treaty Act and Executive Order have been added to Appendix A in the
FEIS, under Major Legal Authorities. It is the purpose of an EIS to evaluate the environmental effects of a
proposed management action and to provide that information to a decision maker. A discussion of the plan’s
consistency with existing policy and laws will be included in the Record of Decision.
111. Comment: The EIS should be revised to strongly consider direction to conduct marbled murrelet
surveys prior to timber harvests that may destroy suitable habitat. Furthermore, the USFWS recommends
that BLM protect areas where occupied behaviors are observed.
Response: The requirement to conduct pre-disturbance surveys for all projects that degrade or remove
suitable marbled murrelet habitat has been added to the PRMP Alternative in the FEIS. Areas that exhibit
occupying behaviors would be protected under the PRMP Alternative.
112. Comment: The EIS is inconsistent with the recovery plan for the marbled murrelet
Response: The BLM management will be consistent with approved recovery plans. Although the BLM will
be consistent with the overall intent of recovery plans, the plan may not implement all aspects of the plan
verbatim.
Appendices - 796
Appendix T - Responses to Public Comments and Comment Letters
113. Comment: The DEIS analysis of effects on the marbled murrelet is flawed because it
habitat. By not relating marbled murrelet habitat availability to effects on marbled murrelet populations, the
DEIS is unable to quantitatively or qualitatively integrate habitat changes with other observed effects on the
species, such as changes in marine conditions.
Response: No relationships between amount of habitat and the number of murrelets were revealed during
a review of the scientific literature. Without any relationship it was not possible to determine population
change due to habitat modification other than in the most basic way. The complexities of integrating changes
in at-sea foraging habitat and changes in at-sea mortality due to by-catch and oil spills make forecasting
population effects problematic. Without models to forecast these factors, the BLM chose to analyze only
those factors influencing murrelet biology that the BLM controlled, which is available forest habitat. The
BLM has received no new information that would allow the prediction of marine conditions, or to relate
population levels to habitat amounts in western Oregon forests.
1 14. Comment: The DEIS uses a flawed analytical assumption in modeling marbled murrelet nesting
habitat as all patches classified as mature and Structurally Complex forest. This modeling assumption
encompasses too broad of a range of structural conditions, including some that are inconsistent with
empirically derived descriptions of nesting habitat. Therefore, the DEIS habitat estimations are inaccurate
and probably overestimate nesting habitat.
Response: Marbled murrelet nesting habitat definitions were based on nesting habitat definition for nesting
habitat suitability 4 found in the “expert opinion” model presented in Rapheal et al. (2006). These stands
had a minimum quadratic mean diameter of 20 inches. Quadratic mean diameter was calculated for the
trees in the “uppermost canopy” (Moeur et al. 2005). This diameter was not comparable to the quadratic
mean diameter derived from the ORGANON projects, which averaged all trees in the stand, over 8 inches in
diameter. Such averaging of trees would tend to underestimate the quadratic mean diameter of older, multi-
layered stands compared to the techniques employed by Moeur et al. (2005). The mature, multi-layered
structural stage (which is defined as 23 or more trees per acre greater than 20 inches in diameter at breast
height in the western hemlock zone; and 1 1 or more in the Douglas-fir zone) was used to be an adequate
approximation of the Raphael et al. (2006) definition. The BLM has not found, or received, any information
that this approach is invalid. Habitat analysis in the final EIS was revised to address effects to the structurally
complex old forest and very old forest separate from overall gross murrelet nesting habitat.
115. Comment: The DEIS analysis of marbled murrelet habitat based on the Forest Operation Inventory is
flawed because it does not consider minimum patch size, and habitat within individual polygons may not
be suitable if the patch is small and isolated. In addition, the metric used to quantify edge-depth may not be
biologically relevant to marbled murrelets (Ripple et al. 2003, Meyer and Miller 2002).
Response: The EIS acknowledges that patch size is positively correlated to the potential for murrelet
occupancy. None of the studies referenced in the comment cite a minimum patch size below which a stand
is no longer suitable. In fact, Nelson and Wilson (2002) note that murrelets will use habitat patches < 5 acres
surrounded by large areas of unsuitable habitat. Raphael et al. (2006) summarized all habitat down to a
patch size of 2.5 acres in Washington and Oregon and 2.0 acres in California.
The edge-depth used for fragmentation analysis is 164 feet (50 meters), which is consistent with analysis
used in Meyer and Miller (2002) and data summarized in McShane et al. (2004).
1 16. Comment: The results from the DEIS analysis suggesting 373,000 acres of marbled murrelet habitat is
inconsistent with the Northwest Forest Plan 10-year analysis which reported 289,000 acres which has been
validated with empirical data (Huff et al. 2006).
Appendices - 797
FEISfor the Revision of the Western Oregon RMPs
Response: The actual amount of high quality marbled murrelet nesting habitat on federal lands within
Zone 1 of the marbled murrelet range is 289,000 acres. The EIS identifies 244,000 acres of marbled murrelet
nesting habitat within Zone 1, and 129,000 acres of marbled murrelet habitat in Zone 2, for a total of
373,000 acres. McShane et al. (2004), citing U.S. Fish and Wildlife data, showed the BLM reporting a total
of 350,000 acres of marbled murrelet habitat, which is comparable to the 373,000 acres reported in the EIS.
Marbled murrelet occupancy was not analyzed because it is not possible to accurately predict its response to
habitat changes.
117. Comment: It is not possible to assess the accuracy of the DEIS marbled murrelet analysis because
it lacks validation. The assumption between coarse habitat availability (mature and structurally complex
forest) should be tested using available occupancy data for marbled murrelet.
Response: This analysis was meant to provide decision makers with a picture of the relative amounts
and changes that would be expected to occur to available marbled murrelet nesting habitat under each
alternative. Using different data and evaluation techniques would make comparison of alternatives difficult.
Validation with known occupied sites is difficult because murrelet surveys were not randomly located.
Murrelets tend to be biased either towards the best habitat because that is where regeneration harvests were
planned, or towards the worst nesting habitat because of planning management actions designed to avoid
murrelets. There is no evidence that the analysis in the EIS fails to provide decision makers with the ability
to make an informed decision on the relative merits of each alternative as it relates to the marbled murrelet.
Although the comment points out an information need that could help establish some relationship between
habitat availability and the species’ response, it is not information currently existing nor needed to establish
a relative ranking among alternatives for their potential effects to this species.
118. Comment: The DEIS analysis of marbled murrelet habitat focuses solely on patch-scale habitat
measures which is far less accurate than multi-scale models (Meyer 2007).
Response: Meyer (2007) describes a model that can assist in predicting the distribution of marbled
murrelet habitat across a geographical area, and also the relative likelihood of occupancy of individual
stands by marbled murrelets, by utilizing parameters calculated at four different scales. In terms of Meyer
(2007), the analysis in the EIS uses a single scale (i.e., the patch, which is the smallest scale in Meyer’s [2007]
hierarchy).
The analysis in the EIS does not redefine the distribution of this species, nor does it treat stands of suitable
murrelet nesting habitat differently based on the likelihood that they may be occupied. The analysis
in the EIS simply looks at the change in the relative abundance of potential nesting habitat within a
given geographical area (marbled murrelet Zones 1 and 2). This habitat model is then combined with
a quantitative analysis of the landscape patterns to describe to the decision maker whether conditions
on BLM-administered lands are getting relatively better or worse for the marbled murrelet under each
alternative. Compared to Meyer (2007) and Meyer and Miller (2002), this is a simplified review of habitat
conditions and their potential to change but it still provides an adequate basis for an informed choice
among the alternatives regarding marbled murrelets. Utilizing the full modeling technique in Meyer (2007)
would not change the overall conclusions or ranking of the alternatives.
119. Comment: Marbled murrelet, a raffing species, are tied to very specific marine habitats, often strongly
associated with large bays and river mouths (Meyer and Miller 2002). The alternatives would have very
different effects across the Plan area, and it appears (based on changes in habitat availability in DEIS, Fig.
234) that marbled murrelet populations in southern Oregon would be differentially impacted. In addition,
the DEIS fails to analyze the differential, geographically bounded effect (Meyer and Miller 2002) at both the
population and meta-population scale.
Appendices - 798
Appendix T - Responses to Public Comments and Comment Letters
Response: The analysis within the EIS does evaluate potential marbled murrelet nesting habitat at two
scales: (1) the entire planning area, and (2) district and marbled murrelet zones. This provides for an
evaluation of the entire population of marbled murrelet habitat as a whole, as well as pinpointing specific
districts and zones that may exhibit localized problems.
120. Comment: The DEIS assumption that “developed structurally complex” stands in one part of the plan
area can replace harvested old-growth stands in another area as marbled murrelet nesting habitat is not
supported by available data and is not supported by analysis in the DEIS.
Response: The EIS makes no such assumption. The EIS simply summarizes the marbled murrelet nesting
habitat available at each time interval. The analysis has been revised to analyze the changes to structurally
complex old and very old forest separately from the overall habitat analysis. The EIS makes no statement
relating to the relative value of each structural stage to another.
Wildlife - Northern Spotted Owl
121. Comment: Because down wood is a critical component of spotted owl habitat and there are no down
wood requirements for Alternative 1 and 2 in timber management areas other than leaving noncommercial
wood, the BLM should set a minimum standard for post-treatment down wood.
Response: Under all alternatives, BLM management would be consistent with the Final Recovery Plan for
the Northern Spotted Owl and the Final Rule on northern spotted owl critical habitat (DEIS, page 60). Under
Alternatives 1 and 2, the BLM chose not to establish a specific minimum standard for downed wood.
122. Comment: The EIS should be revised to consider the importance of Red tree voles in the northern
spotted owl recovery efforts. Red tree voles are important prey to the northern spotted owl and therefore,
surveys should be done to determine the presence or absence of Red tree voles within the study area.
Response: The red tree vole is mentioned only once in the Final Recovery Plan for the Northern Spotted
Owl (USFWS 2008a:49), and then only as one of several species that, collectively, “comprise a small portion
of the spotted owl diet.” However, even if the red tree vole were one of the principal spotted owl prey
items, the Recovery Plan does not recommend pre-project survey for any prey species. The presence or
absence of prey species in specific areas that would be revealed through surveys is not necessary to inform
implementation of management actions that are related to the recovery of the northern spotted owl under
the alternatives. The PRMP Alternative in the FEIS addresses recovery of the northern spotted owl through
land use allocations (e.g., Late-Successional Management Areas) and various management actions that are
independent of the localized presence or absence of red tree voles.
123. Comment: The EIS should be revised to consider not only the effects of habitat conditions on northern
spotted owls, but also non-habitat factors such as impacts from barred owls which are currently being
studied by the USFWS. The EIS should acknowledge that uncertainty exists concerning the effects of barred
owls on northern spotted owl populations and describe the manner in which BLM intends to respond to
future changes in spotted owl numbers.
Response: The PRMP Alternative in the FEIS is consistent with the Final Recovery Plan for the Northern
Spotted Owl (USFWS 2008a). Even though the Endangered Species Act does not require the BLM to comply
with a recovery plan, BLM management will comply with recovery actions in the Recovery Plan and the
Appendices - 799
FE IS for the Revision of the Western Oregon RMPs
Final Rule on northern spotted owl critical habitat. If additional measures are needed to respond to future
situations, BLM management will evaluate information at appropriate times and continue to comply with
the Endangered Species Act.
124. Comment: Page 282 of the EIS should be revised to include citation information for population
information as well as include the basis for the apparent data extrapolation and indicate which demographic
study areas are being used in this portion of the document.
Response: The BLM has corrected this shortcoming in the final EIS. The citation is Anthony et al. (2004)
who found that, within the six demographic study areas in western Oregon, populations declined in
three areas between 1983 and 2003 and were stationary in three, with an average population decline in
all six of 2.8% per year. However, within Oregon, population declines in the northern demographic study
areas (Warm Springs, H J. Andrews, and Oregon Coast Range), which averaged 4.9% per year, were more
pronounced than in the southern demographic study areas (Tyee, South Oregon Cascades, and Klamath),
where declines averaged less than 1% per year and populations statistically were stable.
125. Comment: The EIS should be revised to acknowledge the Final Draft Recovery Plan for the Northern
Spotted Owl and the 20-inch cap for snag removal. The 20-inch diameter cap is described as a “starting
point” for developing province-specific Standards & Guidelines. The final draft recovery plan also provides
a clear methodology to help managers develop provincial Standards & Guidelines based on the general
guidance in the recovery plan. The methodology is based a scientifically derived estimates of which logs
(size and species) will persist for 70 years or more.
Response: The alternatives considered a variety of options for the management of snags in spotted owl
habitats. The PRMP Alternative in the FEIS does not include a 20-inch diameter cap for snag removal,
because it is not part of the conservation strategy in the Final Recovery Plan for the Northern Spotted Owl
(USFWS 2008a). Also, nothing in the BLM analysis indicated that such a cap was needed to promote owl
conservation. Although the PRMP Alternative in the FEIS does not contain any such cap, the PRMP is
consistent with the provisions of the Recovery Plan and the Final Rule on northern spotted owl critical
habitat that the U.S. Fish and Wildlife Service has determined are necessary for species conservation.
126. Comment: The EIS analytical assumption that replacing existing older forest with younger habitat
provides equal benefits is flawed and therefore the EIS has underestimated the adverse impacts of the
alternatives to NSO.
Response: The DEIS did not make this assumption. The BLM acknowledges that not all habitat conditions
contribute equally to owl conservation and that, in general, older forest supports owl conservation better
than does younger forest. However, the DEIS was confined to those analyses needed for land use planning.
Not only did the scientific literature lack consensuses on the definitions and relative benefits of “old forest”
and “younger habitat,” but recent studies in the California Klamath and Oregon Coast Range provinces (e.g.,
Dugger et al. 2005) found that habitat comprised of a mixture of older and younger forests supported owl
reproduction better than habitat comprised almost exclusively of older forest.
To evaluate the alternatives, the EIS classified owl habitats according to Thomas et al. (1990:164) as refined
by Courtney et al. (2004:Chapter 5); i.e., (1) habitats that support nesting, roosting and foraging, (2) habitats
that support roosting and foraging but generally do not support nesting, and (3) habitats that generally
do not support nesting, roosting or foraging. The EIS analysis also relied on several studies to define the
metrics of a potential nest territory and to design the analysis to evaluate the development of such potential
Appendices - 800
Appendix T - Responses to Public Comments and Comment Letters
territories over time by alternative. The BLM, in collaboration with owl scientists, determined that this
approach would generate the most detailed and credible evaluation of how each alternative would affect owl
habitats at the scale needed for land use planning.
127. Comment: The EIS is flawed because it fails to address how the NSO population in the Klamath
Province will remain stable with the elimination of late-successional reserves under Alternative 3 or how
Alternative 3 will contribute to recovery.
Response: The DEIS (pages 640 and 641) states that Alternative 3 would not support the formation of
large blocks of northern spotted owl suitable habitat and would increasingly fragment that habitat over
time. Since large blocks of suitable habitat are needed to maintain population stability (Thomas et al. 1990),
Alternative 3, as was stated, would not contribute adequately to spotted owl conservation (which includes
recovery).
128. Comment: The index of the EIS should be revised to include a listing for the connectivity corridor that
links the Coast Range with the Cascades at the very southern end of the Willamette Valley.
Response: The EIS was revised to more fully address the South Willamette-North Umpqua Area of
Concern. The augmentation of a Late-Successional Management Area in this area, under the PRMP
Alternative in the FEIS, conforms to the conservation strategy contained in the Final Recovery Plan for the
Northern Spotted Owl to help address the issue of owl connectivity in this area.
129. Comment: The EIS should be revised to consider the legal decision in Gifford Pinchot Task Force v.
United States Fish & Wildlife Service, 378 F.3d 1059 (9th Cir. 2004). Specifically, the EIS should more closely
analyze actions that may modify critical habitat in terms of whether the modification actually promotes the
conservation of the owl and not simply whether the modification puts the species in jeopardy.
Response: The Endangered Species Act applies different thresholds to species and critical habitat. The
jeopardy threshold applies only to species, whereas the threshold of destruction and adverse modification
applies to critical habitat. The PRMP Alternative in the FEIS allocates areas expected to be designated as
critical habitat in the Final Rule to the Late-Successional Management Area land allocation. Directions for
management of the lands in this allocation are designed so as not to destroy or adversely modify critical
habitat. In the PRMP Alternative in the FEIS, the BLM is using its authorities to further the purposes of
the Act, and to manage the designated critical habitat of the northern spotted owl for the conservation and
recovery of the species.
130. Comment: The EIS should be revised to consider its heavy reliance on the USFWS’s 2007 Draft
Recovery Plan for the Northern Spotted Owl because this plan has recently been the subject of intense
criticism and negative scientific peer reviews due, in part, because the plan would lower habitat protection.
Response: Since the issuance of the DEIS, the U.S. Fish and Wildlife Service made significant changes to its
spotted owl recovery strategy. These changes were incorporated into the Service’s Final Recovery Plan for the
Northern Spotted Owl. The BLM’s PRMP Alternative in the FEIS incorporates the applicable changes.
131. Comment: The EIS should be revised to include northern spotted owl population estimates and rates
of change that have been reported or assessed. The BLM should use its extensive spotted owl data bases
more extensively within the EIS.
Appendices - 801
FEISfor the Revision of the Western Oregon RMPs
Response: The final EIS was revised to more fully discuss the results of the range-wide northern spotted owl
demography studies, which are ongoing and in which the BLM participates as a cooperator. Relevant data
from the BLM’s spotted owl data base were included in those analyses.
132. Comment: The classification system used in the DEIS for the northern spotted owl is flawed because
the separation of analytical results into quantity and quality of suitable habitat, dispersal habitat, large
blocks and suitable habitat outside of large blocks (DEIS 6733) fails to provide a single integrated measure
of habitat availability for the northern spotted owl, making it difficult to interpret overall impacts to owl
populations.
Response: The habitat classification used by the BLM is well supported by science (e.g., Thomas et al.
1990:164 as refined by Courtney et al. 2004:Chapter 5) and is essentially the same habitat classification
that has been used to evaluate the potential impacts of management actions to spotted owl habitat since
1994. The EIS analysis also relied on several studies to define the metrics of a potential nest territory and
to evaluate the development of such potential territories over time by alternative. Given the myriad of
non-habitat-related variables that are suspected to influence spotted owl populations (such as barred owls
and west Nile virus, and our current inability to separate or quantify the effects of those influences on
owl populations), there is no single variable that would show how habitat management alone would affect
regional populations. To better portray how the alternatives might affect spotted owl habitat at the landscape
scale, the analyses in the final EIS were augmented to evaluate how each of the alternatives would contribute
to the conservation needs of the northern spotted owl.
133. Comment: The gross classification of patches (BLM Forest Operations Inventory (FOI) polygons)
used in the DEIS ignores the fact that use of habitat by northern spotted owl varies across the planning area.
Several studies have shown fundamentally different niches for northern spotted owl from the southern to
the northern parts of the planning area (Zabel et al. 1995).
Response: The BLM acknowledges that northern spotted owls form variable niches in the planning area.
The BLM also considered a variety of studies that documented these variations but determined that many
of the findings were localized, inconsistent, or in other ways insufficiently determinant to allow the BLM
to further refine habitat classifications in most portions of the planning area. Accordingly, it is incorrect to
characterize the habitat parameters used by the BLM as a “gross classification.” Considering the landscape
scale of the analyses, the BLM used the best habitat data available, even though these data did not include
metrics for all spotted owl niche variables.
134. Comment: The DEIS overestimates suitable habitat because it does not adequately address minimum
patch size (or size of contiguous habitat patches). If minimum patch size was included as a mapping rule for
owl habitat, the outcomes for the alternatives would be differentially affected.
Response: This assessment is correct, and the BLM revised the EIS to more accurately evaluate the potential
affects of the alternatives to northern spotted owl suitable habitat. Revisions included the application of
minimum standards for the quantity and spatial arrangement of nesting, roosting, and foraging habitat
needed to support both individual breeding pairs and clusters of breeding pairs. Using these standards, the
BLM evaluated each alternative in terms of its contribution to potential spotted owl nest territories and
blocks of suitable habitat that would be capable of supporting stable spotted owl subpopulations. The BLM,
based on the recommendation of its owl working group, determined that these standards would yield more
accurate assessments of future habitat conditions and owl responses than would a reliance on minimum
patch size.
Appendices - 802
Appendix T - Responses to Public Comments and Comment Letters
135. Comment: The DEIS analysis of dispersal habitat is flawed because it does not appropriately address
disjunct isolated patches that are unlikely to function as dispersal habitat. In addition, the DEIS sums
dispersal habitat at the sixth field scale which is an unsupported metric for assessing effects on northern
spotted owl and obscures some landscape-level driving factors.
Response: The science on the northern spotted owl does not support defining a minimum quantity or
spatial arrangement of habitat needed for owl dispersal. Therefore, there is no valid means to define, map, or
exclude “disjunct, isolated patches.” Nevertheless, in response to this and other comments, the BLM revised
the scale of its analysis based on the recommendation of its spotted owl working group, which included
owl scientists. Instead of using the sixth-field watershed, the final EIS evaluates dispersal habitat at the scale
of the fifth-field watershed, jim Thrailkill (2007) believed, and the other members of the working group
concurred, that this larger scale would better indicate potential problems with owl movement and survival
than the scale of the sixth-field watershed. This belief is based on a sixth-field watershed being typically
closer to the size of a single northern spotted owl home range, whereas the issue to be addressed pertained
to owl movement between home ranges.
136. Comment: Model parameterization used for assessing northern spotted owl habitat in the DEIS would
be more tenable if it were validated with existing species data from the region. Several examples of validation
of northern spotted owl models exist (McComb et al. 2002, Lint 2005).
Response: The DEIS did not represent research and the BLM was not defining new habitat parameters for
the spotted owl, so there were no new habitat definitions that required validation. Instead, the BLM based
its evaluations on habitat parameters that have been developed and validated by researchers during the
past two decades. The final EIS was revised to more fully utilize regional habitat data and to evaluate owl
habitat on all land ownerships. The revised model also incorporated the isopleths mask developed by Lint
(2005:Figure 3-7).
137. Comment: The DEIS overestimates the projections of northern spotted owl habitat under the
alternatives because it does not assume any losses during 100 years to wildfire or other disturbances.
Response: In response to this and other comments, the BLM revised the final EIS to discuss how the
alternatives would affect northern spotted owl habitat, in terms of changes in fire severity and fire resiliency,
through 2106. However, the BLM can make no claim as to whether its analysis over- or under-estimates the
potential impact of wildfire on those habitats because no one fully understands how northern spotted owls
respond to wildfire. This is due in part to limited data, different methods of data collection, and differences
between expected and observed owl uses of burned habitat (for example, see Courtney et al. 2004:Chapter
6; 4.7). This is especially true of fires that are less severe (i.e., are not stand-replacement fires), or occur in
northern spotted owl habitats that are not yet suitable, or both.
In addition, our ability to predict the occurrence of fire is limited. According to the fire regime classification
for western Oregon, the Coast Range and West Cascades Provinces, which fall primarily within fire regimes
III and V, should experience infrequent (every 35 to 200+ years) but severe (stand-replacement) fires; the
Klamath Province, which falls primarily within fire regime I, should experience more frequent (every 0 to 35
years) but less-severe (surface) fires. However, in somewhat of a contrast to this expectation, between 1994
and 2003, Lint (2005:56-63) found that, on all federally administered lands in western Oregon, the Klamath
Province lost an unexpectedly high 6.6% of its northern spotted owl nesting habitat to stand-replacement
wildfire, compared to a 0.8% loss in the West Cascades Province and no measurable loss in the Coast Range
Province.
Appendices - 803
FEISfor the Revision of the Western Oregon RMPs
138. Comment: The DEIS analysis of effects to northern spotted owl is flawed because it only considers
habitat and thus is unable to integrate the effects of disturbance or other species (e.g. barred owl) on spotted
owl population trends. Without consideration of population change, it is impossible to consider latitudinal
gradients in northern spotted owl population trends across the planning area.
Response: It is incorrect to characterize the analysis as flawed because it does not address owl population
trends or suspected influences on population trends that are not directly related to habitat. Although the
habitat-based analyses in the final EIS do not predict population changes, they do predict changes in the
number of potential spotted owl territories over time. This is the most credible and useful method to predict
the relative effect of the alternatives on the reasonable assumption that the spotted owl would respond
to the management alternatives relative to the quality of habitat conditions. No one, in any venue, has
predicted how implementation of a regional habitat management plan would affect the northern spotted
owl population. Even at the time the Northwest Forest Plan was implemented, the single attempt to predict
an owl population response to plan implementation was limited to predicting an overall trend (without
population numbers) during an unspecified time period — and it turned out to be inaccurate.
Currently, with the myriad of variables that are known or suspected to affect spotted owl fecundity and
survival (for example, see Courtney et al. 2003:8-13), the science on the spotted owl does not allow the
BLM to estimate how disturbances such as wildfire, or other species such as the barred owl, would affect
the spotted owl population to the degree of accuracy needed to distinguish the effects of the management
alternatives on that population. Although the BLM recognizes that improving owl habitat conditions would
not necessarily change the population trends due to factors beyond our control or to factors not fully
revealed by current research, it is reasonable for the BLM to believe that the owl population would respond
better to alternatives with a higher quantity and quality of those habitat conditions. The BLM analyses were
designed to help the decision maker choose among the alternatives based on the relative benefits to spotted
owl habitat.
Fish
139. Comment: The EIS should explain how endangered anadromous fish species recovery plans that are
completed after WOPR implementation begins would be incorporated into land management actions.
Response: Completion of a recovery plan for a listed species would constitute new information that BLM
would evaluate. Because of the speculative nature and unknown requirements of possible future recovery
plans, it is not possible to make a reasonable conclusion regarding the process by which it would be
integrated into the RMP, or whether an RMP amendment or revision and a new National Environmental
Policy Act analysis would be required.
140. Comment: The EIS should be revised to more clearly differentiate work that was conducted by the
CLAMS project (pages H- 1082- 1083) and what work was done by the Bureau of Land Management (BLM)
EIS team. Citations should be altered to reflect previously published work.
Response: Kelly Burnett (of the Pacific Northwest Research Station) expanded the intrinsic potential model
from the initial modeling completed for the Coastal Landscape Analysis and Modeling Study (CLAMS)
project, to the extent of the Western Oregon Plan Revision planning area for coho, chinook, and steelhead.
Because the modeling for the Western Oregon Plan Revision was completed by Kelly Burnett using the
methods described in Burnett et al. (2007), this reference is appropriate. The text in the DEIS and FEIS are
not long multi-page quotes, but rather explanations of the modeling methods completed for the Western
Oregon Plan Revision. However, the FEIS has been revised to clarify which modeling was completed for the
FEIS.
Appendices - 804
Appendix T - Responses to Public Comments and Comment Letters
141. Comment: The EIS should be revised to clarify if fish distribution or critical habitat were analyzed, and
to describe how range and/or critical habitat play a role in the Wood/Intrinsic Potential/Fish Productivity
model analysis.
Response: Critical habitat designations were identified in the DEIS analysis. The DEIS and FEIS analyze
the effects of the alternatives on aquatic habitat for all fish species in the plan area, including critical habitat.
For this reason, the effects to critical habitat were not analyzed separately or as a subset. The FEIS has
been clarified to reflect this. Additionally, because of concerns by scientists regarding the reliability of the
productivity model, the fish productivity index has been removed from the FEIS analysis.
142. Comment: Hie EIS should clarify if all fish populations are cyclic by nature, and provide a reference
for the statement.
Response: All fish populations are cyclic by nature. This is the fundamental basis of fish population
dynamics and does not necessitate a reference.
143. Comment: The EIS should be revised to provide a better description of the survival traits of fish and
why they are relevant, as the current context is unclear.
Response: The description of survival traits is taken directly from Reeves (1995); it describes populations,
not individuals, and is the most recent and well accepted list from published literature. Providing additional
descriptions of survival traits is unnecessary. Additionally, the FEIS does provide a logical connection
to these survival traits as it describes the context of BLM’s role in contributing to the survival of fish
populations; including an example of how the BLM can contribute to survival traits (i.e., mobility) by
improving fish passage.
144. Comment: The EIS should clarify whether or not high intrinsic potential streams have been
determined for Oregon chub and special status fish species
Response: The DEIS and FEIS clearly state for which species the intrinsic potential model was modeled and
for which fish it was not.
145. Comment: The DEIS analysis of fish is flawed because it relied on the analysis of intrinsic potential
and failed to analyze or disclose the effects of the alternatives on bull trout, Lost River suckers, shortnose
suckers, Oregon chub and special status fish species.
Response: The analysis in the DEIS and FEIS fully analyze and disclose the effects of the alternatives on
all fish habitat for all fish species within the WOPR planning area. The analysis in the DEIS and FEIS does
not rely on the analysis of intrinsic potential to determine the effects on fish species. Rather, the DEIS and
FEIS analyze the effects under each alternative on those ecosystem processes (wood delivery, fine sediment
delivery, stream shade/temperature, nutrient input, and peak flows) that have the greatest influence on fish
habitat for all fish species, including bull trout and suckers. Intrinsic potential was used in the DEIS only
as a tool to show the inherent value of the habitat where those effects would occur. In the FEIS, intrinsic
potential is used as one tool to compare the effectiveness of aquatic restoration on fish habitat between
alternatives. Additionally, none of the alternatives vary the level of protection based on intrinsic potential.
The level of protection under the PRMP Alternative in the FEIS is applied to all stream segments regardless
of the level of their intrinsic potential.
Appendices - 805
FEISfor the Revision of the Western Oregon RMPs
146. Comment: The EIS should better describe how BLM used the CLAMS project (Burnett et al. 2007)
data, including the fact that the CLAMS study only assessed fish in a specific project area and what this
means in the context of the EIS analysis.
Response: Kelly Burnett, Pacific Northwest Research Station, expanded the intrinsic potential model from
the initial modeling completed for the CLAMS project to the extent of the Western Oregon Plan Revision
planning area for coho, chinook, and steelhead. The PEIS has been revised to clarify what modeling was
completed for the PEIS.
147. Comment: The EIS should be revised to clarify what method was used to determine fish productivity
for coho salmon, as the text in Section 7.9 and Appendix H are unclear.
Response: Because of concerns by scientists regarding the accuracy of the productivity model, the fish
productivity index has been removed from the FEIS analysis. The FEIS has been revised to provide
considerably more information on wood model outputs and the effects to fish populations without
summarizing the results into a single value, as was previously done with the fish productivity index.
148. Comment: The EIS should be revised to include more information about the effects of water
temperature on fish, including expansion on Oregon’s numeric water temperature criteria and a more
extensive discussion of the extensive literature on effects of water temperature on listed salmonid fish found
in the plan area.
Response: The FEIS has been revised to include more information about the effects of water temperature
on fish, including expansion of the water temperature criteria to include the Oregon Department of
Environmental Quality’s core cold water habitat criterion and designation. Oregon’s state- wide narrative and
numeric criteria for water quality are listed in the DEIS and also the FEIS ( Appendix I- Water, in the Best
Management Practices section).
149. Comment: The effects of roads are not modeled or considered, even though they often contribute to
increased peak flow responses (Johnson 2000, Grant et al. 2008). The EIS should be revised to model or
consider the effects that roads have on anadromous fish habitat at the stream reach scale.
Response: The effects of roads on peak flows were included in the analysis for water and fisheries. Refer to
the FEIS, Chapters 3 and 4 (Water sections) and Appendix I-Water (Analytical questions #1 and #2).
Land use activities can generate cumulative watershed effects dispersed through space and time. Various
interactions can occur, such as responses acting independently, sequentially, or synergistically, over an
increasing watershed area. Researchers (Reid 1993, Megahan et al. 1992) suggest that watersheds of 10-200
square kilometers are an appropriate scale for non-point source pollution assessments. The EIS analysis
conducted a peak flow cumulative effects analysis from the effects of forest management (harvest units and
roads) across BLM-administered and all other lands at a sub- watershed scale of 10,000-40,000 acres, (15 to
62 square kilometers). This scale of analysis was purposeful, and was based on research recommendations
from Thomas and Megahan (1988) and others.
The peak flow methodologies in the EIS for the rain and rain-on-snow hydroregions rigorously analyzed
1,192 different subwatersheds within a larger watershed context. Based on the peak flow analysis, the EIS
analysis found less than 1% of the subwatersheds at risk for peak flow increase. The effects of these increases
on fish habitat are dependent on the channel types at the reach-scale (as discussed in Chapter 4-Fish section
and Chapter 4-Water section). Therefore, reach scale assessments are more appropriate at the project scale
Appendices - 806
Appendix T - Responses to Public Comments and Comment Letters
to evaluate the effects of these increases on the stream channel and fish habitat. Additionally, because
hydrologic recovery occurs within a relatively short time period, the reach-specific analysis is better done at
the time of the project using the methods suggested by Grant et al. (2008).
150. Comment: The DEIS assumes that channels with low geomorphic intrinsic potential (IP) for
rearing habitat require less protection than channels with high intrinsic potential. This assumption is also
unwarranted in that channels with low IP for juvenile salmonid fish may be important sources of water,
sediment, organic matter or nutrients to channels with high intrinsic potential (Rice et al. 2001, Kiffney
et al. 2006). In other words, the intrinsic potential of a river network is likely a result of habitat attributes
as defined in the IP model, but also a result of important connections between habitat types and basal
productivity. Therefore, conserving, restoring and protecting linkages among habitat and channel types may
be a key action needed to increase populations of these fish species.
Response: The EIS does not assume that channels with low intrinsic potential require "less protection” than
high intrinsic potential (HIP) channels. Also, the EIS does not discount the contribution of water, sediment,
and organic matter from lower intrinsic stream channels to higher intrinsic potential streams. The FEIS
provides comprehensive information on the location of stream reaches with the greatest potential to provide
high-quality habitat for salmonids, which was generally missing within the Western Oregon Plan Revision
planning area. Additionally, none of the alternatives vary the level of protection based on intrinsic potential.
The level of protection under the PRMP Alternative in the FEIS, applies to all stream segments regardless of
the level of their intrinsic potential.
The FEIS uses the intrinsic potential model to evaluate the location of the high intrinsic streams relative
to BLM landownership patterns; the BLM’s ability to influence the intrinsic potential stream channels that
have a greater intrinsic potential to provide high-quality habitat for salmonids (Burnett et al. 2007); and
the potential and feasibility of aquatic restoration relative to landscape characteristics. The FEIS wood
recruitment rates are reported in terms of channel width classes, rather than in terms of a habitat index that
included dependence on calculated intrinsic potential values. The analysis in the FEIS of environmental
consequences for the PRMP Alternative demonstrates that the PRMP conserves, restores, and protects
aquatic habitat and fish populations in the planning area.
151. Comment: The DEIS definition of large wood is not the same as the definition of large wood used
in the literature cited by the DEIS (Beechie and Sibley 1997) to estimate frequency of pool formation. By
excluding all pieces of wood less than 20 inches DBH from their analyses, the DEIS grossly underestimates
the importance of wood to the formation of pool habitat, and by extension the importance of riparian forests
with trees less than 20 inches DBH to instream habitat. Alternatives 2 and 3 will substantially decrease the
large wood contribution to fish bearing streams relative to the No Action Alternative, and the decreases
will be long-term. This is because thinning will remove wood large enough to form pools from the riparian
zone (if the term large wood is defined by its ability to form pools rather than the arbitrary value of greater
than 20 inches diameter) (Beechie et al.. 2000). Alternative 1 will substantially decrease the large wood
contribution to fish-bearing streams from non-fish bearing streams relative to the No Action Alternative.
Response: The wood delivery model has been expanded for the FEIS to also determine the contribution of
smaller wood to both non-fish-bearing and fish-bearing stream channels for the FEIS.
152. Comment: The DEIS assumes that standing stock of wood accumulates without consideration of the
reduction of wood from decay, floods, and other processes. Proper modeling of wood balance would include
balance of inputs vs. outputs, such as decomposition, recognition of (bedrock) bed characteristics making
reaches more porous to wood (May and Gresswell 1996, Montgomery 1996), and shifts between hardwoods
Appendices - 807
FEISfor the Revision of the Western Oregon RMPs
( i a s t decomposition) and conifers (slower decomposition), to quantify changes in standing crop of wood in
comparison to natural abundances of wood in streams.
Response: The EIS analyses does not consider accumulation of instream wood since differences in
recruitment rates and stand conditions are the most reliable measure of management effects on wood
availability. Modeling a comprehensive and complete wood budget to estimate the standing stock of wood
involves many poorly constrained and stochastic processes, and would not be feasible with available models.
153. Comment: There is a problem in assigning equal value to wood delivered to fish-bearing streams from
debris flows as wood is delivered to streams from direct riparian recruitment or channel migration. Since
large wood delivered to fish bearing streams from debris flows occurs infrequently and tends to deposit
large piles of wood in and around streams, most of which contributes little to important functions such as
pool formation, it may not be appropriate to consider a piece of debris-flow derived wood as functionally
equivalent to wood entering streams from other sources. Because the DEIS treats all sources of large wood
equally, and estimates long term annual averages, it exaggerates the average amount of functional large wood
that will be in streams. For example, a stream could have very little functional wood most years, but a debris
flow that deposited a large pile of wood to the stream in a single year would then boost the annual average
and potentially make it appear that there was, on average, substantial amounts of functional wood in the
stream, when in fact that was not the case.
Response: The FEIS has been revised to determine the potential wood contribution from each source
(riparian and debris flow) separately, rather than a combined annual average, in order to evaluate the
management effects on these two processes independently. The wood delivery model has also been
expanded to include a sensitivity analysis on a subset of watersheds to analyze how the inclusion of stand-
type dependent debris flow probabilities affect the potential wood contribution from debris flow sources.
This sensitivity analysis integrates the effect of forest cover on the debris flow frequency and recurrence
interval at different time periods to better capture the temporal and episodic nature of debris flow wood
contribution and to demonstrate how the magnitude of large wood input, when triggered by storm events,
would differ between processes (riparian vs. debris flow) for each alternative.
There is some scientific evidence that wood from different sources provide different geomorphic and habitat
functions. However, the assumption that wood delivered to stream channels from debris flows contributes
little to important stream functions is unsupported. This idea was challenged by Benda and others (Benda
et al. 2003, 2005) who document that wood deposited from debris flow sources has a prominent role in:
forming pools, wide channels, floodplains, and gravel deposits; creation of complex habitats; and increasing
habitat heterogeneity. For many streams, landslides and debris flows provide a large portion of the instream
wood (Reeves et al. 2003) that contributes to the habitat heterogeneity in fish-bearing streams (Miller et
al. 2007) and creates complex productive stream habitats (Reeves et al. 2005, Bilby and Bisson 1998). For
macroinvertebrates and fish, increasing the heterogeneity of habitat conditions (including channel width
and depth, stream substrate, wood storage, and water velocity) can increase total species richness (Allan
1995). This has been documented in the Oregon Coast Range, where increased wood storage and pool
formation at low-order confluences resulted in increased salmonid rearing (Benda et al. 2004).
154. Comment: The fish productivity model should be revised to include: (1) more valid assumptions about
functional wood sizes, value of wood from different sources, and wood longevity; (2) the correct equation
for the number of pools per channel width; (3) a more realistic view of the totality of factors that may limit
fish productivity; and (4) better disclosure of assumptions and methods used to estimate fish response to
stream channel changes.
Response: (1) The FEIS considers woody material to be functional if it is pool forming, based on
correlations between functional piece size and stream channel width from Beechie et al. (2000). The
wood delivery model has been revised for the FEIS to also determine the contribution of smaller wood to
Appendices - 808
Appendix T - Responses to Public Comments and Comment Letters
both non-fish-bearing and fish-bearing stream channels. (2) The correct pool equation was used for fish
productivity index in the DEIS analysis. The fish productivity index was not included in the FEIS; however,
the FEIS has been revised to provide considerably more information on wood model outputs and the
effects to fish populations without summarizing the results into a single value, as was previously done with
the fish productivity index. (3) Each component (wood, sediment, temperature, hydrology) is modeled
independently; and the effects of each component for fish habitat and consequent productivity are evaluated
independently. The FEIS acknowledges that these processes do not act independently, but existing models
cannot accommodate interactions between these processes at the spatial scale of the Western Oregon Plan
Revision. (4) Additional information regarding the analytical assumptions and methods has been included
in the FEIS.
155. Comment: The EIS should include more clarity and specificity on how the reduced buffer widths in
the action alternatives adequately address the conservation and recovery needs of listed and sensitive aquatic
and riparian species.
Response: The PRMP Alternative and other action alternatives in the FEIS are designed to contribute to
the recovery of ESA-listed species and to provide for conservation of sensitive fish and wildlife species that
would preclude the need to list under ESA. The DEIS analysis adequately addressed the environmental
consequences that would occur to aquatic species. The effects of different management actions on
headwater-dwelling aquatic species has not been well addressed by past research. Therefore, there is
currently little available information to assist in defining habitat needs for these species, particularly in
determining the spatial extent and degree of connectivity for different forest types and the effect of different
riparian management area widths on these species. However, the FEIS analyzes the effects of the alternatives
on aquatic habitat in both fish-bearing and non-fish-bearing streams. This provides a basis for evaluating
the impact of the alternatives to headwater-dwelling species. Additionally, the PRMP Alternative in the
FEIS includes wider Riparian Management Areas than those in Alternative 2, the alternative identified as
“preferred” in the DEIS.
156. Comment: The EIS should disclose the current condition of habitats and populations for fish including
both special status and ESA listed species to allow an interpretation of the magnitude of projected effects, an
assessment of cumulative impacts and a comparison of alternatives.
Response: The DEIS and FEIS analysis focuses on those ecosystem processes that affect aquatic habitat, and
also includes a description of the current aquatic habitat condition for fish species in the plan area; including
ESA and Special Status fish populations. The DEIS and FEIS analysis utilized sophisticated models, GIS
mapping, and the most relevant scientific information to describe the current condition of aquatic habitats
and fish populations in the plan area including the location, status, critical habitat, and limiting factors of
ESA-listed fish populations; the location of high intrinsic potential stream channels; and past and current
amounts of large wood in stream channels, fine sediment in streams, stream temperatures, and peak flows.
157. Comment: The EIS statement “. . .streams are ranked by their intrinsic potential to provide habitat for
chinook, coho salmon, and steelhead” should be revised to explain that the intrinsic potential is for juvenile
rearing habitat for chinook, coho, and steelhead.
Response: The FEIS has been revised to provide additional clarity and explanation regarding this issue.
158. Comment: The EIS statement (pg 356) “thresholds beyond which [sediment] impairment occurs in
the field have not been established” is incorrect, as methods for assessment and thresholds for sediment have
been identified in published literature.
Appendices - 809
FEISfor the Revision of the Western Oregon RMPs
Response: The FEIS has been revised to show that thresholds at which fine sediment affects fish species is
highly variant between scientific studies and localized conditions. The Index of Biological Integrity (IBI)
approach recently published by the Environmental Protection Agency, Western Division (Wittier et al. 2007)
is one of many tools that can be used to assess the biological condition of streams, but its utility is limited
for analyzing the future effects on fish of different management strategies. The IBI is more appropriate for
monitoring to determine long-term trends. The western IBI used information from state fish books and
professional judgment to assign tolerance classes for fish-based metrics, The authors were unable to find
any IBI developers who had applied quantitative methods to assign tolerance classes to fish species. The IBI
values and tolerances are based on fish assemblages found at undisturbed sites. The values do not account
for natural fluctuations in fish assemblages or sediment loads.
For this EIS analysis, sediment yields to stream channels are expressed as tons/mile/year for each fifth-field
watershed. This analysis cannot be related to the IBI approach (because the threshold values rely on percent
embeddness). This output (tons/year) cannot be directly equated to a percent embeddedness and, therefore,
the thresholds and assumptions from Cederholm and co-authors (1981) provide a better method to evaluate
the differences among the alternatives than the IBI approach.
159. Comment: The EIS fails to adequately discuss the affected environment for ESA-listed and special
status fish species because the large body of information regarding the current conditions of populations
and habitats for these species is necessary to compare the direct, indirect and cumulative impacts of each
alternative.
Response: The DEIS and FEIS do describe the affected environment for ESA-listed and Special Status fish
species. The DEIS (pages 335-338 and Appendix H, pages 1,071 throughl,081) and the FEIS include a
description of fish species designated as threatened or endangered under ESA and Special Status Species
(DEIS, Table 256). The DEIS and FEIS also include status summaries for each evolutionary significant unit
(ESU) and distinct population segment (DPS) from the National Marine Fisheries Service “Updated Status
of Federally Listed ESUs of West Coast Salmon and Steelhead” and from Federal Register notices for fish
species listed by the U.S. Fish and Wildlife Service. The DEIS and FEIS also describe the current status,
population trends, status, and location of critical habitat, as well as limiting factors for each ESU/DPS and
the past and current condition of aquatic habitat.
To understand the cumulative effects of a proposed action, it is necessary to understand first what would
happen in the absence of a proposed action, which is described in the analysis of the No Action Alternative.
Thus, the analysis in the EIS includes the effects of past actions, other present actions, and reasonably
foreseeable actions to project over time what would happen if no action is taken to revise the resource
management plans. Comparing the action alternatives then against the context provided by the projected
trends of the No Action Alternative reveals the incremental effect of those action alternatives. Identification
of current conditions is only a step in the analysis of cumulative effects, and it is described in Chapter 3 of
the EIS. It would be erroneous and misleading to compare the effects described for the action alternatives to
the current conditions and ascribe the differences as the “cumulative” effect, since that comparison would
mask the effects of the other present actions and reasonably foreseeable actions.
160. Comment: The EIS should clarify how the watersheds discussed in Table 107 were selected, the
current condition of each watersheds’ streams, and the proportion of LSMA and other allocations is each
watershed.
Response: The representative watersheds used in the DEIS to display the results of the wood delivery model
were selected to show examples of various BLM ownership patterns and provinces. The data from these
Appendices - 810
Appendix T - Responses to Public Comments and Comment Letters
representative watersheds used in the DEIS was not extrapolated to any other watersheds. The FEIS does not
include the use of representative watersheds because the wood delivery model is now used across the entire
planning area for the FEIS.
161. Comment: The EIS should include criteria for when to thin riparian forests, and additional non-
timber management actions to maintain and restore riparian areas — such as correcting damage to riparian
vegetation and streambanks due to livestock grazing, invasive plants, recreational activities, and roads.
Response: The PRMP in the FEIS includes criteria for thinning riparian forests (including when to thin)
and non-timber management actions to maintain and restore aquatic and riparian habitat. Thinning in
riparian management areas would occur under the PRMP where necessary to speed the development of
large trees in order to provide an eventual source of large woody debris to stream channels. Under the
PRMP, thinning would not occur within 60 feet of a perennial or fish-bearing stream channel, or within 35
feet of a non-fish-bearing intermittent stream.
162. Comment: The EIS should disclose limitations as well as peer review, validation, and sensitivity
analysis of the three wood recruitment models developed for this analysis, as these steps are part of the
scientific model process and should be disclosed.
Response: Only one wood delivery model was used for the DEIS and FEIS analysis. The riparian tree-fall
portion of the wood recruitment model has been discussed at length in the literature with evaluations of
model sensitivity to parameters such as channel width, riparian management area width, channel-adjacent
slope gradient, and riparian stand characteristics (Robison and Beschta 1990, Van Sickle and Gregory 1990,
Beechie et al. 2000, Bragg 2000, Benda and Sias 2003, Meleason et al. 2003, Sobota et al. 2006). For the DEIS
and FEIS analysis, the application of this framework was extended to include a spatially explicit framework
with additional inputs for landsliding and debris flow. This greatly expanded the number of factors that
affect model results to include basin topography and channel network structure. The model is sensitive to
the spatial distribution of forest stand types to management strategies that alter that spatial distribution.
Applying the model to different management alternatives provides an indication of sensitivity to changes
in the spatial distribution of stand types. The wood delivery model was also revised for the FEIS to include
sensitivity analysis for the effects of forest stand growth on debris flow recurrence and potential wood
contribution.
In terms of model validation, the distribution of tree fall directions is based on empirical model components
from (Sobota et al 2006) and calibrated to Oregon data. The debris flow model relies on empirical modeling
described in Miller and Burnett (2007a), which was calibrated in the Oregon Coast Range, Cascades
and Klamath Provinces. The debris flow model also relies on an empirical model of debris-flow runout
described in Miller and Burnett (2007a) and calibrated to data from the Oregon Department of Forestry
1996 Storm Study (Robison et al. 1999). Estimates of channel extent, channel width, and floodplain extent
were based on digital elevation data using empirical models described in Clark, Burnett and Miller (2008).
Although validation of model predictions (potential wood contribution) has not been completed as part of
this analysis, this is not necessarily a shortcoming in use of the model for the analysis. The wood delivery
model is used to estimate the potential wood contribution based on forest stand conditions and is not used
to predict actual instream conditions for a given time period. Even in the absence of field validation, the
modeled predictions provide sophisticated tools to evaluate the topographic attributes that affect the debris-
flow extent across the plan area and how the magnitude and contribution of wood delivered from these
sources vary between alternatives; such comparisons were largely unavailable prior to development of this
analytical tool.
Although modifying key assumptions to evaluate difference in model outcomes may be appropriate in
scientific research, it is not directed by the Council on Environmental Quality regulation for implementing
Appendices - 811
FEISfor the Revision of the Western Oregon RMPs
the National Environmental Policy Act, nor would it help in providing a clear basis for choice among
options by the decision maker and the public (40 CFR 1502.14). Agencies are directed to conduct their
analyses based on actions and effects that are “reasonably foreseeable” (40 CFR 1502.22(b), 40 CFR 1508.7),
rather than varying assumptions about uncertain actions and effects. Additionally, the FEIS has been revised
to include additional information regarding any modeling uncertainties, errors, biases, assumptions and
validation.
163. Comment: The EIS should clarify if the wood recruitment models were developed for this analysis
as stated on Page FI- 1084, or if the method published in Miller and Burnett 2007 was used as stated in the
beginning of the section.
Response: Components of previously published models and scientific studies (Miller and Burnett 2007)
were used in the development of the wood delivery model developed for the DEIS and FEIS analysis by Dan
Miller (Earth Systems Institute). The 10-meter Digital Elevation Model (DEM) debris flow initiation and
runout model portion of the model is described in Miller and Burnett (2007), but was expanded from the
initial Coast Range work and calibrated to accommodate the extent of the Western Oregon Plan Revision
planning area for this analysis. The FEIS has been clarified to reflect this information.
164. Comment: The EIS should be revised to include sensitivity analysis of the numeric values chosen
for any of the various key model parameters, because this data is critical to understanding the merits and
consequences of model predictions, even more so when several models are used together in ways that can
compound their strengths and weaknesses. As case in point: the range of value for habitat vs. coho smolt
production is highly variable geographically and year to year; therefore, a geometric mean might result in
erroneous assumptions.
Response: The fish productivity index has been removed from the FEIS analysis. The riparian tree-fall
portion of the wood recruitment model has been discussed at length in the literature with evaluations of
model sensitivity to parameters such as channel width, riparian management area width, channel-adjacent
slope gradient, and riparian stand characteristics (Robison and Beschta 1990, Van Sickle and Gregory
1990, Beechie et al. 2000, Bragg 2000, Benda and Sias 2003, Meleason et al. 2003, Sobota et al. 2006). For
the EIS analysis, the application of this framework was extended to include a spatially explicit framework
with additional inputs for landsliding and debris flow. This greatly expanded the number of factors that
affect model results to include basin topography and channel network structure. The model is sensitive to
the spatial distribution of forest stand types to management strategies that alter that spatial distribution.
Applying the model to different management alternatives provides an indication of sensitivity to changes
in the spatial distribution of stand types. The wood delivery model was also revised for the FEIS to include
sensitivity analysis for the effects of forest stand growth on debris flow recurrence and potential wood
contribution. The FEIS has been revised to include a more thorough description of the sensitivity analysis,
model parameters, and modeling assumptions.
165. Comment: Further explanation and evidence should be added to support the statement “differences
among the alternatives, in terms of fish productivity, would be less than 3%” and to support the information
about fish habitat.
Response: The fish productivity index has been removed from the FEIS analysis.
166. Comment: The EIS should discuss impacts on the survival and recovery of Oregon Coastal Coho
Salmon Evolutionary Significant Unit and Southern Oregon Northern California Coho Salmon ESU. The
WOPR action Alternatives are most similar to Alternatives 7 and 8 in the Final Supplemental Environmental
Appendices - 812
Appendix T - Responses to Public Comments and Comment Letters
Impact Statement on Management of Habitat for Late-Successional and Old-Growth Forest related Species
within the Range of the Northern Spotted Owl (USDA and USDI 1994b) and Alternatives A, B, C in the
Medford District Proposed Resource Management Plan and Final Environmental Impact Statement (USDI,
BLM 1994e; see p.xix for comparisons of Riparian Management Area Protections and narrative comparisons
on p. 4-19). These FEIS’s made scientifically credible comparisons between alternatives that contained all
aspects of the Aquatic Conservation Strategy (WOPR No Action with ACS) and alternatives which primarily
rely on minimized riparian protective buffers (WOPR action alternatives).
Response: The EIS analyzes the effects of the alternatives on aquatic habitat for all fish species in the
planning area, including Oregon Coast Coho salmon and Southern Oregon Northern California Coho.
The FEIS analysis uses scientific information and analytical tools that were not available in 1994 for the
Northwest Forest Plan analysis. It would be inappropriate to incorporate an analysis completed 14 years
ago for alternatives that do not match the alternatives analyzed in this EIS and that fail to address new
information and scientific analyses.
167. Comment: The EIS environmental consequences for Fish should be revised to provide an integrated
discussion that determines compliance with the ESA because legal compliance with the ESA for listed
fish species is currently based on compliance with the Aquatic Conservation Strategy (ACS), which is not
discussed in the EIS and BLM projects are legally required to meet all ACS objectives.
Response: Management actions implemented under the FEIS would not be legally required to meet
ACS objectives. Demonstrating compliance with the Aquatic Conservation Strategy objectives to ensure
compliance with the Endangered Species Act (ESA) for listed fish species is not a statutory or regulatory
requirement. Rather, compliance with the ACS objectives is a requirement only under Northwest Forest
Plan, which is neither a statute nor regulation.
The Endangered Species Act requires the BLM to consult on actions authorized, funded, or carried out to
ensure they do not jeopardize any listed species or destroy or adversely modify designated critical habitat.
The BLM will meet this requirement by consulting under section 7(a)(2) of the Endangered Species Act with
the regulatory agencies (USFWS and NMFS).
168. Comment: The modeling inappropriately uses large wood as a surrogate for fish production, which is
not adequate for providing certainty of protection for ESA listed species.
Response: The FEIS analysis regarding the effects of the alternatives on fish habitat and fish populations has
been revised, and the fish productivity index was dropped from the FEIS analysis.
169. Comment: The analysis of environmental consequences to fish is flawed because the analysis
decouples sediment and stream temperature impacts from logging which eliminates numeric negative
“multipliers” from logging.
Response: The FEIS analysis focused on the ecosystem process that affects fish habitat and fish populations
including: large wood delivery, fine sediment delivery, stream temperature, and peak flows. The analysis did
not separate sediment and stream temperature impacts from timber harvest. Rather, each component of
the analysis relied on the forest stand projections that accounted for timber harvest over time under each
alternative, and the effects on these aquatic ecosystem components are shown.
Appendices - 813
FEISfor the Revision of the Western Oregon RMPs
170. Comment: The analysis of environmental consequences to fish is flawed because it is inconsistent with
the analytical assumptions and conclusions of the series of BLM 1994 programmatic impact statements
which showed differences among alternatives with respect to the impact analysis for salmonids due to
substantial differences in amounts of riparian protection from logging.
Response: The analysis completed for the NWFP used a delphi, outcome-based scale methodology to
determine the range of possible aquatic habitat trends and future habitat conditions on federal land and the
likelihood of attaining a set of habitat outcomes for each fish population. The FEMAT (1993) acknowledged
that the Northwest Forest Plan viability assessment did not directly correspond to the actual population
viability of the species since limited science existed to establish direct relationships between land-
management actions and population viability (FEMAT 1993).
Since 1994, analytical tools have become available that greatly increase the ability to project forest conditions
and determine the outcomes for aquatic habitat under management scenarios. The FEIS analysis does not
correlate the condition of the aquatic habitat over time to the viability of fish populations, because analytical
tools to assess population viability are limited at the scale of the Western Oregon Plan Revision planning
area. Unlike the analysis completed for the current (1995) RMPs/EISs, the FEIS analysis utilizes new
scientifically credible analytical tools and other updated scientific methods that can be used to make direct
correlations between the effects of the PRMP Alternative and the other action alternatives on aquatic habitat
that was not possible at the time of the current (1995) RMPs. Although many of these correlations are based
on extrapolations of data to the planning area, the FEIS analysis provides a greater ability, beyond what was
available in previous analysis, to evaluate future conditions and process rates, and is far more comprehensive
than other existing wood delivery models (Reeves 2005).
171. Comment: The EIS should clearly state whether risk of salmonid extirpation increases or not due to (1)
poor riparian protection standards and (2) no restraint on road building, which exist when the management
of BLM lands and private lands are intermingled.
Response: The FEIS includes a cumulative effects analysis for fish habitat and fish productivity, which
includes an assessment of the effects of various riparian management actions and road construction
activities for each alternative relative to land ownership patterns. The premise in the comment that under
the alternatives the riparian protection standards would be poor and that there would be no restraints on
road building is false. The EIS analysis does not show the deleterious effects implied in the commenter’s
presumption. In analyzing effects of road building, the EIS analysis must be based on what is reasonably
foreseeable. On the intermingled BLM and private lands, the road systems providing access to these lands
are already in place and have been for many decades. The EIS analysis must assume that private landowners
will abide by laws and regulations, rather than the commenter’s presumption that they will be unrestrained.
The EIS analysis is based on the likely levels of road construction, which in turn is based on historical
experience over the past few decades, rather than unsupported speculation.
The FEIS concludes that the contribution to fish habitat, including salmonids and fish productivity, would
increase from BLM-administered lands under the PRMP Alternative in the FEIS. Therefore, the risk of
extirpation would decrease under the PRMP.
172. Comment: The EIS should quantify or evaluate the impact of fine sediment from OHV use to
salmonids.
Response: The DEIS and FEIS included a qualitative analysis to evaluate the impact of fine sediment
from off-highway vehicle use on fish habitat. The environmental conclusions regarding the effects of fine
sediment on fish habitat in the DEIS and FEIS concluded that, compared to the current condition, fine
sediment delivery to stream channels would be reduced under the PRMP Alternative and the other action
Appendices - 814
Appendix T - Responses to Public Comments and Comment Letters
alternatives, since a more restrictive OHV-use designation has been adopted under the PRMP and the other
action alternatives, and because the Best Management Practices in the FEIS include measures to minimize
or eliminate effects to water quality from OHV activities. Under the PRMP Alternative and the other
action alternatives, OHV area designations would move from “open use” designation (under No Action) to
“limited” or “closed,” where off-highway vehicle activities would be limited to existing roads and trails.
A quantitative analysis on the fine sediment effects from off-highway vehicle use is not possible at the scale
of the Western Oregon Plan Revision planning area, since designated trail and road locations, proximity to
stream channels, OHV use levels, and season of OHV use is unknown. Additionally, off-highway vehicle use
would be the same under the PRMP Alternative and all other action alternatives, and would only differ in
the No Action Alternative. The qualitative analysis used to evaluate the impacts was sufficient to compare
the effects of off-highway vehicle use on fish habitat between alternatives, particularly since OHV use did
not vary between the PRMP and action alternatives.
173. Comment: The EIS should be revised to include streambed scour and fill as an important mortality
factor for egg-to-fry survival of fall spawning salmonids, as scouring flows may scour out and kill incubating
salmonid eggs, in particular the coho salmon population in Evans Creek.
Response: Determining the amount of streambed scour and fill is a reach level analysis. Analyzing reach
level effects at the scale of the planning area would not be appropriate because: 1) Whether an increase in
peak flows translates to an increase in stream bed scour depends on the channel type and existing substrate
of the stream reach. Including channel type and stream bed information for all streams within the planning
area is not possible, nor is the data available. 2) Analyzing reach-specific impacts at the planning area would
require speculation about other actions taking place at the time of the project-level actions and weather
conditions during the period of hydrologic recovery.
Additionally, the filling and scouring of stream channels does not correlate well with increases in peak flows.
Stream filling does not happen at higher stream flows, but rather in low velocity areas at stream margins or
during the recession of stream flows. Although, the FEIS identifies four sixth-field watersheds (<1%) that
are susceptible to peak flows, it does not imply that adverse impacts to stream channels would occur for the
following reason: (1) The majority of stream channels on BLM-administered lands in the planning area are
small headwater channels where streambed material is collected and transported downstream, rather than
along lower gradient alluvial channels where streambed material is stored and scour and fill typically occur
(Grant et al. 2008). Site-specific information regarding stream types and the resistance of each channel reach
to flows would need to be considered during subsequent NEPA analysis where peak flows and scour and fill
are issues requiring analysis.
174. Comment: The EIS should revise the peak flow impacts to fish and analyze much smaller watersheds
where coho salmon are known to spawn (e.g., upper West Evans Creek), and analyze areas where watershed
analyses have identified peak flows from rain-on-snow as a threat.
Response: The FEIS analyzes peak flow impacts at the smaller sixth-field subwatersheds (a U.S. Geological
Survey hydrologic unit) scale, because they are small enough areas to capture the patterns of BLM forest
lands and because tributary streams are more sensitive to vegetation and runoff-related changes. The FEIS
identifies the susceptible sixth-field sub-watersheds to peak flow increases in both rain-dominated and rain-
on-snow hydroregions. The sixth-field sub-watersheds identified in the FEIS as “susceptible” to peak flow
increases in the rain-on-snow hydroregion do not match those identified in previous watershed analysis.
Watershed analysis generally relied either on the Equivalent Clear-cut Acre (ECA) method to determine
where increases in peak flow would occur, or considered all rain-on-snow watersheds to be susceptible to
Appendices - 815
FEISfor the Revision of the Western Oregon RMPs
increases in peak flows. Although this ECA method may be useful in the rain-dominated hydroregion, since
response is roughly proportional to area harvested, merely tallying acres of harvest in a watershed does not
address the underlying mechanisms of how snow accumulates and melts in the rain-on-snow hydroregion.
The vertical and horizontal dimensions of forest openings and their size, as well as their distribution and
juxtaposition at the stand level, are sensitive to snow accumulation and melt processes (Harr and Coffin
1992). fn this hydroregion, melt is enhanced by energy released from condensation of moisture onto
snowpacks during warm and windy weather. This relationship is scaled by size; there are greater wind speeds
in larger openings that promote the process (Harr and McCorison 1979).
Since watershed analyses were completed, new scientific methods have become available to better evaluate
the watersheds that are susceptible to increases in peak flows in the rain-on-snow hydroregions. The peak
flow analysis in the FEIS is a more reliable and current method compared to ECA, because it utilizes an
empirical analytical technique to identify susceptible subwatersheds to peak flow increase within the
rain-on-snow hydroregion. This technique is patterned after the Washington State Department of Natural
Resources hydrologic change watershed analysis methodology (Washington State DNR 1997a). The
peak flow analysis is based on up-to-date published regression equations to generate a winter snowpack
(Greenburg and Welch 1988) that relates to snow accumulation by elevation using the snow telemetry
(SNOWTEL) data from the National Resources Conservation Service; basin characteristic regression
analysis with gauged watersheds that have long-term records (Harris et al. 1979); flood frequency equations;
GIS spatial analysis; satellite imagery for non-BLM-administered lands; and snowmelt equations from the
U.S. Army Corps of Engineers (USACE 1956, 1998).
175. Comment: The EIS should evaluate the impacts to fish from episodic land-sliding and elevated
sediment transport in the action alternatives because several large storm events are certain to occur on
lands denuded by logging and road-building. Models for mass erosion and threshold for fish impacts are
“available information” as defined by NEPA in previous BLM impact statements that analyze logging and
road building impacts to fish.
Response: The susceptibility oflandsliding from forest management in the Timber Management Area has
been modeled in the FEIS, using a state-of-the-art geomorphological methodology (Miller and Benda 2005).
The procedure determines susceptibility of shallow colluvial landsliding and delivery to a stream channel
and the subsequent results to fish habitat. (Refer also to comment 101).
176. Comment: The treatment of debris flows is biased in the DEIS because the models used in analyzing
potential debris flows favored those area that would provide beneficial large wood to streams (DEIS, pages
732 and 1,089) and ignored those areas where shallow landsliding harmful to fish would occur in logged
areas. The intermittent stream channels with the highest probability of debris flows to fish bearing stream
channels (DEIS, page 732) are not protected with 100 ft no cut buffers unless they were “stream channels
that are below unstable headwalls (as identified by the timber production capability classification (TPPC)
codes indicating significant instability (i.e. FGNW, FPNW, and FGR2).” See DEIS:80 footnote 4. This will
create inevitable sediment impacts to fish since there will be streams at high risk for contributing huge
amounts of fish killing sediment as evidenced by photos from Seattle Times and numerous case studies
(Frisell 1992, FEMAT V-19) that will not be protected with 100 ft no cut buffers. In addition, the BLMs use
of timber production capability classification (TPCC) to identify areas that would periodically deliver large
wood to streams is flawed.
Response: The debris flow component of the wood delivery model is not based in any way on TPCC,
but rather with a highly detailed 10-meter Digital Elevation Model topographical analysis that identified
landslide initiation sites across the entire planning area. This analysis determines the susceptibility of every
10-meter Digital Elevation Model pixel to deliver small and large wood to fish-bearing and non-fish-bearing
stream channels. Additionally, the PRMP Alternative of the FEIS includes a one-half site potential tree
Appendices - 816
Appendix T - Responses to Public Comments and Comment Letters
height distance and one site potential tree height distance Riparian Management Area along all streams,
which increased the Riparian Management Area width from the preferred alternative in the DEIS.
177. Comment: The EIS should adequately describe or quantify impacts to fish and fish habitat from
earthflows because earthflows are a second type of mass movement quite different from debris flows. Once
activated, the earthflow can deliver sediment directly to stream channels for years if not decades, and
chronic sediment from earthflows is particularly damaging to fish and fish habitat. “Occasional failures”
identified in the DEIS could be catastrophic for specific populations of coho salmon.
Response: The location and susceptibility of all shallow landslides, including debris flows, was modeled for
the DEIS and FEIS analysis. The location of deep seated landslides, including earthflows, was not included
in the DEIS or FEIS analysis. There are no existing models or scientific literature that provides the ability
to predict deep seated landslide locations, behaviors, or how management would affect the susceptibility.
Preliminary research is being done for the Tyee-Sandstone geographic region, but is too preliminary to
be extrapolated outside of the Tyee-Sandstone region, nor does it provide the ability to determine the
response of timber harvest on the susceptibility of failure. Additionally, the FEIS has been revised to include
additional analysis on the effect of land stability at a watershed-scale. That analysis is based on forest stand
projections using a GIS-based mass wasting hazard model (Miller and Burnet 2007) to estimate debris flow
susceptibility and the relative amount that would occur within the Timber Management Area outside of the
TPCC withdrawn areas and the relative effects to aquatic habitat.
178. Comment: The EIS should be revised to analyze impacts on the expected viability of coho salmon in
West Evans Creek and other locations where it is federally listed, because the data from various BLM and
state watershed analyses conclude that the viability of coho in West Evans watershed is at risk of extirpation
because of logging related sediment, which would increase under the WOPR action alternatives.
Response: Background rates of sediment in stream channels vary between watersheds. Within the planning
area, some watersheds function with higher background rates of sediment than others. The Evans Creek
Watershed was used as an example to show that in some cases viable fish populations continue to exist
within stream channels with higher levels of fine sediment. This discussion has been revised in the FEIS for
additional clarity.
179. Comment: The EIS should include an analysis of the adverse impacts that suction dredge mining
disturbance has on fall-spawning salmonids, such as the coho salmon. Egg-to-fry survival decreases
regardless of the size of suction dredge.
Response: Table 290 of the DEIS is a scenario. The actual future locations of where the suction dredging
would occur are unknown. Because programmatic, ongoing activities (i.e., suction dredging, road rights-of-
way, etc.) would occur at the same rate under all alternatives, and because it is impossible to predict at the
plan-level scale where these activities would occur in the future, the site-specific effects of these actions on
aquatic habitat and fish populations will be analyzed in setting the context for determining the cumulative
effects of subsequent project-scale NEPA analysis.
180. Comment: The EIS should analyze Oregon’s requirement, where salmon spawning and rearing is a
designated beneficial use, and in which the surface water temperature exceeds 64 degrees Fahrenheit, to
allow no measurable surface temperature increase from anthropogenic activities.
Response: The DEIS and FEIS contain a detailed analysis of stream shade and temperature and the effects
to fish populations using the Oregon Department of Environmental Quality’s water temperature criteria and
Appendices - 817
FEISfor the Revision of the Western Oregon RMPs
standards for fish species within the plan area. The analysis of environmental consequences in the FEIS for
the PRMP Alternative and the other action alternatives conclude that management actions occurring on
BLM-administered lands would not contribute to an increase in stream temperature.
181. Comment: The EIS should include analysis about how large wood should be balanced with some
disturbance near the stream to increase light and primary production to create “hot spots” in order to
benefit to fish populations.
Response: The FEIS has been revised to include an analysis of the effect of increased light near stream
channels and subsequent effects on primary production and fish species.
182. Comment: The EIS should specify which fish passage standards for new and replacement culverts the
BLM will use.
Response: The objective of providing fish passage is clearly stated in the FEIS. Specifics of fish passage
and stream crossing design would occur at the project implementation stage of the resource management
plan. Determining project-level protective measures and specifications at the scale of the planning area
would be inappropriate because it would eliminate flexibility needed to adapt to site-specific conditions.
Therefore, detailed specifications and protective measures based on applicable fish passage standards would
be incorporated at the project scale.
183. Comment: The analysis of sediment impacts to anadromous fish and their habitat is flawed because
it describes a linear comparison that equates the increase in stream sediment (1%) to a decrease in fish
survival (3.4%). The assumption that this relationship is linear and can be applied universally across the
planning area is oversimplified and flawed. In addition, the DEIS states (page 741) that fine sediment
delivery analysis will focus on changes in sediment that would “overwhelm the ability of fish to cope with or
avoid the stress” of sediment. There is no such analysis described in the DEIS.
Response: A linear, inverse relationship between fine sediment and the effects on fish species has been
documented frequently since the 1960s (Bjornn 1968, Phillips et al. 1975, Cederholm et al. 1981) and more
recently (Suttle et al. 2004). For this analysis, sediment yields to stream channels are expressed as tons/mile/
year for each fifth-field watershed. Since this output (tons/year) cannot be directly equated to a percent
embeddness, the thresholds and assumptions from Cederholm and co-authors (1981) provide the utility of
a relative increase method to evaluate the differences between the action alternatives, including the PRMP
Alternative. The DEIS and FEIS sediment analysis utilize this particular threshold to determine where
increases in fine sediment would overwhelm the ability of fish to cope with stress or to avoid stress. The FEIS
has also been revised to include an analysis of the non-lethal physiological effects that may occur to fish
species below this threshold.
184. Comment: The DEIS (page 741) contends that “thresholds have not been established for the levels of
sediment that would cause impairment to fish”. There is a wealth of literature on the effects of fine sediment
and aquatic organisms including salmon (Suttle et al. 2004). It is possible to establish targets that avoid most
sediment impacts to salmonid fish, their forage organisms, and their habitat.
Response: The FEIS has been revised to reflect this information and to include an analysis of the non-lethal
physiological effects that may occur to fish species below these thresholds.
Appendices - 818
Appendix T - Responses to Public Comments and Comment Letters
185. Comment: The DEIS conclusion that there will be no effect to fish populations from increased
sediment loads is flawed because it is based on an assumption that no additional landslides would occur
under increased intensity of land management due to the use of the TPCC. This DEIS conclusion is also
flawed because it relies on optional BMPs and the ability of fish to avoid turbidity. Relying on optional
practices and potential avoidance behavior of fish is not a reasonable basis to base the conclusion that
anadromous fish and their habitat will not be affected by sediment.
Response: The environmental consequences under the DEIS and FEIS are not only based on the landslide
analysis, but other variables as well. However, the FEIS has been revised to include additional analysis on the
effect of land stability at a watershed scale based on forest stand projections using a GIS-based mass wasting
hazard model (Miller and Burnett 2007) to estimate the susceptibility to shallow landsliding under the
action alternatives, including the PRMP Alternative. The landslide model was used to determine the relative
amount of unstable lands that would occur within the Timber Management Area outside of the Timber
Productivity Capability Classification (TPCC) withdrawn areas and the relative effects to aquatic habitat.
The use of Best Management Practices is not optional; rather, the RMP will direct managers to use
appropriate BMPs in designing projects that would be used to maintain water quality standards.
The DEIS and FEIS discuss the direct effects of fine sediment (substrate) and increased concentrations of
suspended sediment (turbidity) and the direct effects on fish behavior.
The DEIS and FEIS point out that it is well known that fish have the ability to avoid high concentrations
of suspended sediment (Hicks et al. 1991); however, the conclusions were not entirely based on this
assumption. The analysis of environmental consequences in the DEIS and for the PRMP Alternative in
the FEIS concluded that the timing and magnitude of increased suspended sediment has the greatest
effect on fish species; and that activities under all alternatives would increase suspended sediment during
low flow periods when fish are most vulnerable. The analysis of environmental consequences in the
FEIS also concluded that these effects would be short term and localized because of the application of
Best Management Practices and the local nature of the activities. This discussion in the FEIS has been
strengthened with a more thorough description of the direct effects to fish species from suspended
sediment.
186. Comment: The preferred alternative is likely to increase water temperature in fish bearing streams.
This will result in increased adult mortality of salmonids, reduced growth of alevins and juveniles, reduced
competitive success with non-salmonid fish, out-migration from unsuitable areas, increased disease
virulence, delay, prevention or reversal of smoltification and potentially harmful interactions with other
habitat stressors.
Response: The analysis of environmental consequences of the DEIS concluded that stream shade would
be insufficient to maintain stream temperatures only within the Management Area Adjacent to the
Coquille Forest land use allocation. However, the Coquille Tribal Management Area, which is included
in Alternatives 2 and 3, has not been included in the PRMP Alternative in the FEIS. The analysis of
environmental consequences in the FEIS concludes, as did the analysis in the DEIS, that management on
BLM-administered lands would not contribute to an increase of stream temperatures under the PRMP
Alternative and the action alternatives, except in the Management Area Adjacent to the Coquille Forest land
use allocation under Alternatives 2 and 3.
187. Comment: The DEIS also asserts (page 763) that shallow landslides will not increase over the next 10
years under any alternative because of the TPCC, and because of site-specific review of proposed activities.
However, the DEIS has not provided information about the effectiveness of the TPCC withdrawals, or about
Appendices - 819
FEISfor the Revision of the Western Oregon RMPs
the procedures, decision criteria, and effectiveness of the site-specific reviews. Because of the increased
amount of timber harvesting under Alternative 2, NMFS assumes the risks of sedimentation from landslides
will also increase.
The EIS should disclose potential effects related to the effectiveness of the TPCC withdrawals, the risks of
egg to fry survival of anadromous fish from probable increases in sedimentation, degradation of interstitial
habitat that support rearing juveniles, and decreases in production of invertebrate forage organisms in
affected stream reaches.
Response: The FEIS has been revised to include additional analysis on the effect of land stability at a
watershed scale, based on forest stand projections using a GIS-based mass wasting hazard model (Miller and
Burnett 2007) to estimate the susceptibility to shallow landsliding under the PRMP Alternative and all other
alternatives. Additionally, the DEIS and FEIS include a thorough analysis of fine sediment delivery to stream
channels and the effects to fish species including: egg to fry survival (Cederholm et al. 1981), degradation of
interstitial habitat, and decreases of forage (Suttle et al. 2004). Additionally, a riparian management strategy
with wider riparian management areas and with more restrictive management direction than that for
Alternative 2, which was identified as the preferred alternative in the DEIS, has been adopted in the PRMP
Alternative in the FEIS.
The FEIS has been revised to include additional analysis on the effect ofland stability and forest stand
projects under the PRMP Alternative and other action alternatives using the Miller model developed for the
plan area (based on Miller and Benda 2005). The analysis determines the susceptibility of 10-meter Digital
Elevation Models to shallow colluvial landsliding.
188. Comment: The EIS should be revised to consider the effects of the alternatives on other factors
limiting fish populations, such as water temperature, substrate sediment, and passage.
Response: The DEIS and FEIS analysis focused the analysis on those ecosystem processes that directly
influence aquatic habitat and limiting factors for listed fish species in the planning area. The DEIS and FEIS
used updated information from the National Marine Fisheries Service and Southwest Fisheries Science
Centers biological review teams regarding limiting factors for listed salmon and steelhead ESUs/DPSs in
the planning area (Good et al. 2005). Flabitat degradation was determined to be a limiting factor for the
majority of the ESUs/DPSs. Maintaining or increasing the amount of woody debris in stream channels is one
of many factors analyzed relative to the effects on fish productivity, because it has been documented as an
important factor in creating and maintaining habitat complexity that addresses this limiting factor.
For example, the Independent Multidisciplinary Science Team (IMST) and NMFS, as part of the Oregon
Coastal Coho Assessment (2005), found that although a diverse set of conditions affect the viability
of the ESU (water quality, ocean conditions, hatchery impacts, etc.), increasing freshwater habitat
complexity provides the greatest opportunity to improve fish productivity of the ESU. Nickelson (1998)
also documented in the Habitat-Based Assessment of Coho Salmon Production Potential and Spawner
Escapement Needs for Oregon Coastal Stream’s assessment that a large part of the recovery process of coho
salmon involves improvements in the habitat conditions in fresh water. As did the DEIS, the FEIS also
includes a thorough analysis on the other limiting factors for fish populations, including the effects of fine
sediment delivery, water temperature, peak flows, nutrient input, and aquatic restoration activities (e.g., fish
passage) on fish habitat and populations for the PRMP Alternative and the other action alternatives.
189. Comment: The EIS should disclose the effects of eliminating the Aquatic Conservation System (ACS)
on BLM Lands, which was designed to provide for the survival of at-risk resident and anadromous fish
Appendices - 820
Appendix T - Responses to Public Comments and Comment Letters
populations in the face of a severely degraded environmental baseline. The BLM should conduct a viability
analysis similar to that done in the NWFP for seven stocks of salmonids to determine the percent likelihood
that populations would be well distributed, be restricted to refugia or extirpated under each alternative.
Response: The Aquatic Conservation Strategy (ACS) was a region-wide strategy designed to protect those
processes and land forms that contribute habitat elements to streams and promote good habitat conditions
for fish and other aquatic organisms (FEMAT 1993), which is a component only of the No Action
Alternative. The FEMAT (1993) recognized that other aquatic conservation strategies are also effective to
maintain and restore aquatic habitat. The Riparian Management Area objectives in the action alternatives
are designed to provide for the survival and recovery of listed fish populations in the planning area. The
FEIS fully discloses the effects to fish populations for the No Action Alternative, which utilized the Aquatic
Conservation Strategy, and for the PRMP Alternative and other alternatives. The analysis of environmental
consequences for the PRMP Alternative in the FEIS concludes that the PRMP would provide for the survival
and recovery of fish populations over time.
The viability assessment done for the Northwest Forest Plan used a delphi, outcome-based scale
methodology to determine the range of possible aquatic habitat trends and future habitat conditions on
federal land and the likelihood of attaining a set of habitat outcomes for each fish population. The FEMAT
(1993) acknowledged that the Northwest Forest Plan viability assessment did not directly correspond to
the actual population viability of the species since limited science existed to establish direct relationships
between land management actions and population viability (FEMAT 1993). However, since 1993, existing
science and analytical tools has greatly increased the ability to project forest conditions and to determine
the outcomes for aquatic habitat under management scenarios. However, analytical tools are limited at the
scale of the Western Oregon Plan Revision to correlate the condition of the aquatic habitat over time to the
viability of fish populations. Unlike the analysis completed for the Northwest Forest Plan, the FEIS analyses
utilized sophisticated GIS, forest growth modeling, 10-meter Digital Elevation Model (DEM) analysis, and
other scientific methods to make direct correlations between the effects of the PRMP Alternative and the
other action alternatives on aquatic habitat. The BLM’s obligation under NEPA, to describe the effects of
BLM actions on aquatic habitat and fish species, has been fulfilled in the FEIS analysis.
190. Comment: The EIS should analyze the effects of the alternatives on the Lost River and shortnosed
suckers, bull trout, McKenzie River bull trout populations, and Oregon chub which are species listed as
Endangered under the ESA as well as special status fish species.
Response: The FEIS analyzes the effects of the alternatives for all fish species in the plan area. The FEIS
includes a thorough analysis and discussion of the affected environment, current habitat condition, species
status, existing and historical distribution, and effects of the alternatives for all threatened and endangered
fish species in the plan area including the Lost River and short-nose suckers and bull trout. The FEIS
acknowledges that the requirements for habitat and the responses to habitat changes vary by fish species
and the life history stage of the species. However, the habitat requirements for fish species within the
planning area are similar enough to permit an analysis of the effects for all aquatic and fish species together.
Therefore, a species-specific analysis and discussion was unnecessary. The Columbia River chum salmon
and the Oregon chub do not occur on BLM-administered lands in the planning area; and management
activities occurring on BLM-administered lands would not affect these species. The FEIS has been revised
for clarity to reflect this information.
191. Comment: The EIS conclusions regarding forest activity effects on downstream water temperature
are flawed because the EIS discounts the importance of both site-specific and cumulative effects from
forest practices, which is contrary to the scientific literature and extensive temperature assessment efforts
completed as part of DEQ’s total maximum daily loads.
Appendices - 821
FEISfor the Revision of the Western Oregon RMPs
Response: The FEIS does not discount the effects of forest practices on water temperature. The FEIS
documents the science used to design Riparian Management Areas in the alternatives ( Chapter 3, Water
section). Further, the analysis of environmental consequences in the FEIS concludes that the levels of
shade retention are expected to meet water quality standards and non-point source Total Maximum Daily
Load (TMDL) waste-load allocations under all alternatives. Additionally, the Oregon Department of
Environmental Quality’s core cold water designations have been included in the FEIS.
192. Comment: The EIS should be revised to clarify what method was used for the Fish Productivity
Model, and the EIS should disclose any peer review of validation of the Lawson model.
Response: Because of concerns by scientists, the fish productivity index has been removed from the FEIS
analysis. Additionally, the FEIS has been revised to include a more detailed description of the analytical
methods and assumptions used for the analysis.
193. Comment: The EIS should be revised to identify the Oregon Coast Coho Salmon Evolutionary
Significant Unit as threatened.
Response: Because the Oregon Coast Coho Salmon ESU was listed under the Endangered Species Act
subsequent to preparation of the DEIS, the FEIS has been revised to include the Oregon Coast Coho Salmon
as a listed fish within the planning area.
194. Comment: The BLM should run the large wood delivery model with different assumptions and
input variables to include smaller minimum tree diameters, higher site-potential tree heights, and different
distances from debris-flow prone streams over which trees can be incorporated into debris flows.
Response: Based on interaction with Pacific Northwest Research Station Scientists, the Western Oregon
Plan Revision Science Team, and National Marine Fisheries Service, the input variables for the wood
delivery model were revised for the FEIS analysis to include: 1) the contribution of smaller wood, based
on correlations from Beechie et al. (2000), to fish-bearing and non-fish-bearing stream channels; 2) highly
detailed stand-level tree height information for each 10-meter Digital Elevation Model (DEM) pixel to
determine site-potential tree height.
For the debris flow modeling, the model assumes that all standing trees and downed wood within a debris
flow track will be incorporated into the debris flow delivery. The modeling assumption is that downed wood
accumulates within a tree height of the stream channel, and that the debris flow tracks are six meters wide,
which is the average width reported for debris flows in the Oregon Department of Forestry’s 1996 storm
study (Robison et al. 1999). Because the model examines every possible debris flow track traced on the
DEM, starting from every DEM cell with landslide susceptibility greater than zero, the model effectively
includes all potential wood sources to debris flows that can be resolved with the Digital Elevation Model.
Water
195. Comment: The EIS should disclose the specific strategies and action that the BLM will use to replace
each aspect or component of the Aquatic Conservation Strategy and components that are not specifically
part of the Aquatic Conservation Strategy, but that were intended to further the goals of the Aquatic
Conservation Strategy
Response: The Aquatic Conservation Strategy is part of the land use allocations and management direction
of Northwest Forest Plan that this RMP revision proposes to replace. The action alternatives were not
designed to accomplish each aspect or component of the Aquatic Conservation Strategy, because the
Appendices - 822
Appendix T - Responses to Public Comments and Comment Letters
purpose of this RMP revision differs from the purpose of the Northwest Forest Plan. The Draft EIS analyzed
the effect of each alternative on various resources, including fish, water, and aquatic and riparian special
status species. This provides a basis for comparing the effects of the No Action Alternative (which includes
the Aquatic Conservation Strategy) with the action alternatives.
196. Comment: The EIS should be revised to fully discuss the ecological role of BLM lands within areas
of mixed ownership including an examination of all potential sediment sources, including roads currently
excluded from analysis, harvest activity, debris flow, and blowdown.
Response: The Draff EIS analyzed the ecological role of BLM-administered lands within areas of mixed
ownerships. For many resources, the Draft EIS analyzed conditions both on BLM-administered lands and
across all ownerships with unprecedented detail and quantification. Specifically, the analyses of sediment
included the effects of activities across all ownerships. It is not possible to model activities on other
ownerships with the same degree of precision and accuracy as the analysis models activities on BLM-
administered lands. However, the analysis of the cumulative effects of the BLM action together with actions
on other ownerships is sufficient to compare the effects of the alternatives.
197. Comment: Table 21 1 of the DEIS should be revised to include clearcutting on non-federal lands. The
action alternatives are very likely to push watersheds over thresholds of concern for peak flows.
Response: The analysis considers the effects of management actions on all lands, including non-federal
lands. The data are separated for the rain and rain-on-snow hydroregions (refer to the FEIS, Chapter
3- Water section, and Appendix 1-Water , Analytical Questions 1 and 2). Table 21 1 in the Draft EIS shows the
projected BLM stand establishment acres for each time period by alternative. There is no similar reference
for the variability of harvest from private lands, as such information is proprietary or market driven. For
all non-federal lands, the BLM relied on satellite imagery to develop acres of open conditions (similar to
stand establishment), and then compiled this information by hydroregion and particular methodology to
determine the likely effect on peak flow for the alternative projections.
198. Comment: The DEIS should be revised to explain the derivation of the ground cover correction
factor that applies to cut and fill slopes. Without knowing where the vegetation cover data came from, it is
impossible to evaluate the accuracy of the final vegetation correction factor layer.
Response: The ground cover correction factor data were supplied by district hydrologists who are familiar
with each watershed; they used a combination of district knowledge, aerial photography, and satellite
imagery. A public set of aerial photography is available for copying at each district office. The Interagency
Vegetation Mapping Project using satellite imagery was a collaborative effort between the United Sates
Forest Service (USFS) and the (BLM). Imagery can be obtained at: http://www.blm.gov/or/gis/data-details.
php?theme=dt000003&grp=IVMP&data=ds000103. The ground cover correction factors that were used are
included in the FEIS, in Appendix I- Water.
199. Comment: Alternatives 2 and 3 in the DEIS should be revised because they lack a sound scientific
basis for the aquatic/riparian strategy. Alternatives 2 and 3 would have substantial, long-term impacts
to water quality and exacerbation of current exceedances of water quality standards in streams listed as
impaired under Section 303(d) of the Clean Water Act (impaired waters) are anticipated. Other issues
include significant impacts to drinking water and aquatic species that could be corrected by project
modification or choosing another feasible alternative. Direct, indirect and cumulative impacts would affect
waters on both BLM and non-BLM lands.
Appendices - 823
FEISfor the Revision of the Western Oregon RMPs
Response: The BLM sees no substantive basis for these conclusions. It is well known that the primary
water quality parameters of concern from forest management in Northwest streams are variations of
stream temperature and deliverable sediment (Meehan 1991). Forest width and density of the Riparian
Management Areas (RMAs) under the alternatives are structured to maintain fully shaded perennial
streams, as well as provide an effective sediment filtration area along all stream channels. Under Alternatives
2 and 3, water quality would be fully protected because a sufficient forested Riparian Management Area
of varying width from 25 to 100 feet would be retained along each side of all stream courses to meet water
quality goals. In Alternative 2, the Riparian Management Area varies from 25 feet for intermittent streams,
to 100 feet for perennial and debris flow streams. Contrast the design of the BLM Riparian Management
Areas for these alternatives with private lands RMAs, where small streams are not required to include
retained merchantable trees at all in the RMAs (versus 25 feet from the stream edge for BLM), and perennial
streams are only required to maintain 20 feet of continuous retention from the stream edge (versus a
minimum of 60 feet for BLM). The strategy for BLM invokes considerable greater riparian management
areas and functionality, even though the Department of Environmental Quality found that RMAs on private
forestlands in Oregon to be sufficient for water quality protection (ODF and DEQ 2002).
In addition to the BLM Riparian Management Area strategy, Best Management Practices would be applied
to maintain water quality. For source water watersheds, this may involve having seasonal restrictions,
limiting road development and stream crossings, controlling access, or taking other measures. Water
quality in 303(d) listed waters would be maintained by Riparian Management Area design and Best
Management Practices. Water Quality Restoration Plans coordinated between BLM and the Department of
Environmental Quality would be followed, where Total Maximum Daily Loads (TMDLs) and waste-load
allocations have been determined. Therefore, the BLM sees no significant impacts to drinking water or
aquatic species, or furthering of 303(d) impairment under these alternatives.
200. Comment: The EIS predictions for steam temperatures should be revised based on the Heat Source
model run by the environmental Protection Agency (EPA), which resulted in an increase substantially
higher than the results reported in the Draft EIS (DEIS). The EPA conducted several temperature model
runs for Canton Creek. Canton Creek is a temperature- impaired waterbody located in the Umpqua Basin
for which a total maximum daily load (TMDL) was recently completed. We employed the Heat Source
model used in development of the Umpqua TMDL to evaluate the temperature change resulting from the
application of Alternatives 2 and 3. This modeling demonstrates that the application of Alternatives 2 and 3
would increase the 7-day average daily maximum (ADM) stream temperatures on Canton Creek over 0.7°
F. This is substantially greater than the 0.2° F per mile temperature increase predicted by the DEIS (p. 750).
Further, the EPA modeling results indicate that management on BLM lands under Alternatives 2 and 3
would increase instream temperatures on downstream “private” lands along Canton Creek.
Response: A point of clarification is that the Oregon Department of Environmental Quality (ODEQ) rather
than the Environmental Protection Agency constructed a temperature report for the Western Oregon Plan
Revision with Heat Source modeling runs using data from Canton Creek in the North Umpqua Subbasin
(ODEQ 2007). Canton Creek is atypical because of “naturally occurring grassy meadows, wetlands, or open
canopy forest” (ODEQ 2007). The simulations found the largest cumulative temperature increase (0.9° F)
that would increase the 7-day average daily maximum, to occur in these areas, which is different than a
typical, fully stocked, forested riparian management area.
Furthermore, BLM asserts there are various discrepancies within the simulations:
1) Reducing the model distance step from 328 feet (used in TMDL analysis) to 164 feet to increase
model sensitivity may not be appropriate. If the distance step was not increased, the ODEQ 2007
shows error statistics of 1.0° F versus 1.6° F for the plan simulations. This error is greater than the
predicted cumulative temperature increase. The simulations indicate multiple small spike elevations
of stream temperatures above the TMDL load allocations and then sharp returns to the pre-existing
Appendices - 824
Appendix T - Responses to Public Comments and Comment Letters
stream temperatures over very short distances (ODEQ 2007, Figures 10, 12 and 13). This suggests
that the predicted stream temperature change is false (would not actually occur) because of the
sharp temperature reversals not normally found in natural stream systems. Rather, it is more
probable that as sensitivity is increased, error noise is also increased.
2) The 303(d) listed stream segments are normally listed from mouth to headwaters. Streams warm
slowly in a downstream direction over long distances due to a variety of factors (e.g., stream
turbulence and ambient air temperature). Conversely, small streams higher in the watershed that
are typical of many BLM streams can recover when flowing from an opening into a downstream
forest. The Oregon Department of Forestry and the Oregon Department of Environmental Quality
(ODEQ) sufficiency analysis review of the Oregon Forest Practices Act (as reported by Dent and
Walsh 1997) showed that by using Analysis of Variance statistical tests, the streams higher in
watersheds showed a decrease in temperature 500 feet downstream of treatment, whereas streams
lower in a watershed did not. Figures 10, 12, and 13 in ODEQ (2007) show this temperature reversal
when proceeding from the simulation areas into system potential forest.
Reasonable measurement error of stream temperature with monitoring instruments (considered to be 0.9°
F) has not been taken into account. The BFM suggests that a 0.9° F measurement error threshold level be
shown on the ODEQ 2007 figures for comparison.
The spatial and temporal scale of the management activities would be far different than ODEQ 2007
modeled simulations. The BFM would not apply continuous treatments of thinning to 50% canopy closure
in the secondary shade zones of Riparian Management Areas (RMAs), nor continuous RMA boundary
regeneration harvests. Although BFM has shown that the RMA strategy in Alternatives 2 and 3 that provide
80% effective shade as a surrogate for stream temperature increases at an antidegredation level, the BLM
spatially distributed pattern of harvest in watersheds within and adjacent to RMAs over time would provide
an additional factor of safety.
201. Comment: The EIS should be revised to use the BLM inventory of riparian stream channels in its
analysis, and should present data by appropriate watershed scales into functional condition classes.
Response: It is not practicable to use BLM inventory of specific riparian stream channels in the analysis
of areas as broad as that of the Western Oregon Plan Revision, which is approximately 2.6 million acres. At
the field level, the BLM may assess the condition of riparian areas by using the process for assessing Proper
Functioning Condition (USDI BLM 1993) or similar methodology. These intensive inventories, involve field
crews and specific funding, and have only been completed primarily on portions of the Medford District.
The assessment data is on field forms and has not been assimilated in such a way as to make comparisons for
broad areas possible. The usefulness of the assessments as a surrogate for the planning area is not practicable
because of the breadth of data and replications required by the community type differences of riparian
management areas on other districts. Factors that make meaningful comparisons problematic include:
differing physiographic provinces, topography, riparian vegetative communities, valley bottom types, stream
types, stream channel condition, and watershed condition.
202. Comment: The EIS should disclose how BLM plans to ensure the use of Best Management Practices
(BMPs) to prevent significant water quality impacts, and should provide analytical data to support the
effectiveness of the BMPs.
Response: The introduction to the Best Management Practices in the FEIS, Appendix I-Wate r, has been
revised to show how BMPs would be typically selected and used. The BMPs are not designed to be an
engineering handbook showing design specifications, nor provide analytical or monitoring details to prove
Appendices - 825
FEISfor the Revision of the Western Oregon RMPs
effectiveness. Notwithstanding, the BMPs do provide stringent measures to maintain water quality. The
BMPs have been developed by specialists over many years of field trials, adaptive learning from monitoring,
and knowledge gained from specific research studies.
203. Comment: The EIS should disclose whether or not the models used analyzed the effect of timber
harvest and road building on debris flows and landslides.
Response: Approximately 90,000 acres (3.5% of BLM-administered lands) are currently withdrawn due to
land stability concerns under the BLM timber productivity capability classification (TPCC) inventory. Based
on commenter inquiries, an additional assessment has been made to analyze the effect of land stability at
a watershed scale from forest management projections of timber harvest and road building. Miller (2003),
Miller and Benda (2005), and Miller and Burnett (2007) have developed a GIS-based mass wasting hazard
model for western Oregon to estimate the susceptibility to shallow colluvial landsliding. This model was
used to determine the relative density of unstable lands that ‘as modeled” may occur in the harvest land
base. The results of this analysis are presented in the FEIS, in Chapter 4 (Water section). Because the TPCC
inventory included ground reviews in addition to aerial photography interpretation, it is considered to be
more accurate and reliable in mapping areas of instability, and is believed to have captured the most likely
sites. However, Best Management Practices for soil and water protection (included in the FEIS, Appendix
1-Water ) require that project planning for a proposed harvest area include completion of geotechnical
investigations. Where susceptibility to landsliding is indicated, criteria would be developed for adjustments
to the manner or location of harvest and road building. If additional lands are found that would have high
mass wasting potential, they would be added to the TPCC withdrawn areas.
204. Comment: The EIS should be revised to explain how the anti-degradation provisions of the State of
Oregon’s water quality standards would be met by each alternative.
Response: Oregon’s rules on anti-degradation (OAR 340-41-0004) designate waters as either Outstanding
Resource Waters (ORW), High Quality Waters, or Water Quality Limited Waters. There are no ORW on
BLM-administered land in the planning area. High quality waters are maintained by meeting applicable
numeric or narrative water quality criteria to meet standards by alternative design or by the application of
best management practices. Water quality limited waters usually identified on 303(d) lists, become part of a
basin scale Total Maximum Daily Load (TMDL).
Waste-load allocations for TMDLs are apportioned among basin landowners, depending on land
condition, level of collaboration, and ability to contribute. A component of Oregon’s TMDL process is
Water Quality Restoration Plans (WQRPs). These management plans are coordinated between the agency
and DEQ and specify passive or active restoration actions. To date, most of these plans involve stream
temperature reduction and specify passive restoration actions over time necessary to achieve results. The
applicable WQRP targets for the parameter of concern, such as stream temperature, are reviewed during
project planning to identify actions necessary to meet milestones. This method is used to implement anti-
degradation provisions on BLM-administered lands where there are 303(d) listed waters with a TMDL and
WQRP.
205. Comment: The EIS should be revised to discuss whether or not BLM will seek NPDES permit(s), per
recent legislation on the issue.
Response: Under the Federal Clean Water Act, the National Pollutant Discharge Elimination System
(NPDES) permitting program, administered by the Environmental Protection Agency and the Department
of Environmental Quality, regulates the discharge of pollutants to surface waters. Pollutant discharges may
be from point sources (discrete discharges) such as those from wastewater treatment plants, or industrial
Appendices - 826
Appendix T - Responses to Public Comments and Comment Letters
processing plants. Pursuant to the Clean Water Act amendments (1987), the Environmental Protection
Agency developed a Storm Water Program that applies to three sources of nonpoint discharge: industrial
sources, construction sites, and municipal separate storm sewer systems. Logging operations, road building,
and the array of silvicultural activities fall under the construction sites category and are viewed as nonpoint
in nature. In 2002, the 9th Circuit Court of Appeals issued an opinion that requires an NPDES permit for
aerial pesticide applications over forest lands ( League of Wilderness Defenders v. Forsgren, No. 01-35729, 9th
Cir 2002) where pollutants enter surface through other than stormwater runoff. The BLM is evaluating this
issue, but has no plans to apply for NPDES permits for activities at the present time. In any case, since this
revision is not making any decision on whether to aerial spray or not any specific area, there is no basis on
which to request an NPDES permit.
206. Comment: The EIS should define intermittent stream, as the definition impacts how many streams
may be clearcut over with no buffer.
Response: The glossary has been updated with a working definition: A drainage feature with a dry period,
normally for three months or more, where the action of flowing water forms a channel with well defined bed
and banks, supporting bed-forms showing annual scour or deposition, within a continuous channel network.
207. Comment: The EIS should include a modified sediment analysis that avoids the assumption that the
timing of sediment delivery is more important than the volume, considers effects of both the existing road
network and proposed roads, and that includes consideration of long-term sediment routing and effects.
Response: Timing and volume of sediment delivery are intertwined. The volume of sediment delivery is
highly dependent on streamflow level, where the few high flows of each annual series of stream flows carry
the majority of the sediment load (Luce and Black 1999). The analysis considered the effect of sediment
delivery from existing and proposed roads within a sediment delivery buffer by using the Department
of Natural Resources methodology (see the FEIS, Chapter 3- Water section; also see Appendix I -Water,
Analytical Question # 3). The modeled sediment yields are separated for new roads (less than 2 years
old) and existing roads (more than 2 years old), and when summed give a picture oflong-term potential
sediment delivery. The model parameters and processing were not sensitive enough to infer seasonal timing
of potential sediment delivery. The BLM has observed that under normal precipitation and runoff, many
roadside ditches carry little to no water or sediment. The BLM expects this seasonal pattern of a few large
storms to produce higher runoff and to yield the majority of the sediment load. Additionally, the variability
of watershed intrinsic factors in unmanaged areas, including widely scattered and infrequent landsliding
and streambank erosion, occurs with the few high annual stream flows and reduces the contributory effect
of road delivered sediment as a percentage of total sediment.
208. Comment: The EIS should explain whether the stream sizes, tree types, and heights used in the Brazier
and Brown (1972) study used by the EIS to explain how angular canopy density varies with different buffer
strip widths are applicable to the entire plan are, how that was determined, and what other information is
available. If the SHADOW model is used to support assumptions about angular canopy density, stream
shade, and water temperature, then the EIS should: better describe the data set used to develop the model;
disclose what streams were used to develop the statistical relationships; document model validation in the
different ecoregions covered by the WOPR; and report confidence limits, assumptions, and uncertainties.
Response: Table 3 in the Northwest Forest Plan Temperature Total Maximum Daily Load (TMDL)
Implementation Strategies (2005) was used to support assumptions about angular canopy density. The
derivation of Table 3 to determine the width of the primary shade zone was developed with a number of
Shadow model runs by the developer, Chris Park. Data from southwest Oregon, as well as the original data
from the Brazier and Brown study (1972), was used in the model runs to optimize the primary shade zone
Appendices - 827
FEISfor the Revision of the Western Oregon RMPs
n uli ti for different hillslopes and forest vegetation heights (Chris Park 2007). The BLM chose the largest
distance in Table 3 (60 feet) to use as a primary retention area.
209. Comment: The DEIS does not provide sufficient information to support the assumption that areas
farther than 100 feet from streams do not contribute to shade. The DEIS analytical assumptions regarding
the effectiveness of stream buffers to regulate temperature are inconsistent with existing science (Kiffney et
al. 2003).
Response: The BLM does not dispute that areas further than 100 feet from streams may provide shade to
streams. However, studies with the Shadow and Heat Source models show that this shade is secondary, is of
very marginal importance, and has little bearing on overall effective shade duration or quality throughout
the day. The BLM is satisfied, based on Shadow modeling, that normal stocking of riparian forest young-
mature trees at 100 feet width provide 80% or greater effective shade. The DEQ modeling with Heat Source
for the Western Oregon Plan Revision showed that shade and temperature goals could be met at 150-foot
riparian area widths, even though BLM believes that some of the modeling assumptions may not represent
average and fully stocked forested conditions.
210. Comment: The analysis in the DEIS is inadequate because it does not assess the likelihood of
blowdown of riparian trees under the various strategies, and analyze how this factor could affect stream
shade and water temperatures
Response: The riparian area analysis has been expanded to include blowdown of riparian trees, and to show
how some alternatives include riparian area widths that act as a factor of safety (see FEIS, Chapters 3 and 4,
Water sections).
211. Comment: The DEIS analysis is inadequate because it does not provide sufficient information about
the status and trends of water temperature on BLM lands, the status of stream shade on BLM lands, and how
land management has contributed to these conditions. These current condition and trends are necessary to
understand the effects of the alternatives.
Response: The status of stream shade has been added to the FEIS (see Chapter 3, Water section). Options
modeling for riparian trees within 100 feet of fish-bearing streams (includes all perennial and intermittent
fish bearing) indicates that 4% are currently in the stand establishment structural stage, 41% are young, 28%
are mature, and 27% are structurally complex. Based on comparing this forest structure with shade levels
of potential natural shade, there is a very high confidence that 80% effective shade goals are being met on
more than 55% of the Riparian Management Areas, and a high confidence that goals are met on more than
96% of the Riparian Management Areas. The BLM believes the status and trends of water temperature on
BLM-administered lands parallel improvements in riparian area forest structure, resulting in increased
shade. Although there is insufficient data to confirm this premise, stream monitoring is required for most
Total Maximum Daily Loads with Water Quality Restoration Plans to indicate the trajectory of water
temperature with forest tree growth. The BLM will use the results of these monitoring efforts to confirm that
the objectives for Riparian Management Areas are meeting water quality standards .
212. Comment: The EIS must consider the following factors in analysis of the effectiveness of riparian
management areas: stream orientation, sinuosity, aspect, bank and channel stability, channel migration, and
the potential for sediment loading.
Response: The factors of stream orientation, sinuosity, and aspect were included within Shadow modeling
to determine a sufficient Riparian Management Area that would provide adequate shade to maintain stream
temperatures. Bank and channel stability and channel migration is an “in field” higher level inventory,
Appendices - 828
Appendix T - Responses to Public Comments and Comment Letters
and these attributes are usually included within riparian assessments such as Proper Functioning Surveys
(USDI BLM 1993). Further, the stream channel stability attribute is not needed to make a reasoned choice
among the alternatives for the plan revision. The Riparian Management Area widths as described for the
alternatives in the FEIS, Chapter 2, are retained for a migrating stream channel, because the zone includes
the channel migration zone.
213. Comment: The EIS should be revised to explain or resolve apparent inconsistency in choosing to
include private land as a variable in predicting large wood inputs to streams while also choosing to exclude
private roadways as variables in predicting sediment impacts.
Response: Existing mapped private roads were included within the analysis (see the FEIS, Appendix
I- Water, Analytical Question #3, and Step # 4). The BLM GIS general transportation (roads) data layer
was used. This coverage includes all BLM primary, secondary, and tertiary roads and a high proportion
of private roadways. On BLM under the alternatives, roads needed for the types and amounts of forest
management indicated are projected into the future for the 10-, 20-, 50- and 100-year time periods. No such
comparison can be made for private land roads, because future management and transportation system
options are unknown.
214. Comment: The EIS should be revised to properly estimate the number of watersheds susceptible to
peak flow increases and related water quality impacts. The modeling approach taken in the DEIS likely
underestimates the contribution of sediment from the road network, land management activities, and debris
flow events (see analysis enclosed with comments).
Response: The BLM used a modeling approach to screen for watersheds that may be susceptible to peak
flow increases from the effects of vegetation management. First, the planning area was separated at a sixth-
field watershed scale (10,000 to 40,000 acres) by rain-dominated and rain-on-snow hydroregions. The
analysis was completed using GIS resource layers and computer programmed scripts that use logical and
mathematical relationships based on hydrological science (see the FEIS, Appendix I-Water, Analytical
Questions #1 and #2). The hydrological sciences used the relationships of rain and/or snow accumulation
and melt with rain (Grant et al. 2008, USAGE 1998) and effect on water available for runoff from different
vegetation conditions (Harris et al. 1979, WA DNR 1997a). The FEIS, Chapter 3 (Water section) has been
further expanded to include Grant et al. (2008) science report findings from the review of northwest
experimental watershed studies. The BLM uses equivalent area relationships with basal area for the rain-
dominated hydroregion, and an empirical modeling approach for the rain-on-snow hydroregion. The BLM
believes the approaches are valid and reflect the hydrological processes involved.
The modeling approach used in the DEIS to model potential deliverable sediment from roads was based on
an existing model (WA DNR 1997b). The BLM automated the model to include spatial GIS data layers such
as soils, roads and ownership (see the FEIS, Appendix I-Water, Analytical Question #3). This road model
does not consider land management activities or channelized debris flow events, but only road sources
of fine sediment from the cutslope, road tread, and fill slope (see the FEIS, Appendix I-Water, Analytical
Question #3; and Chapter 3-Water section).
The roads methodology that was used lacks a subroutine to calculate small road-related slumps or slides
that may sometimes occur. The random and non-intelligent nature of these occurrences leads to modeling
difficulties, and as such is an under-estimation of potential sediment delivery at a gross scale. The degree of
underestimation is uncertain, because road construction practices have dramatically improved in the last
20 years with corresponding fewer road failures (see the FEIS, Chapter 3-Water section). Extensive slide
inventories, which do not exist, would be required in each physiographic region to determine an adjustment
factor. However, the purpose of the plan-level roads sediment model was not to determine an absolute mass
balance of deliverable sediment, but rather to determine a consistent relative baseline, and then show how
Appendices - 829
FEISfor the Revision of the Western Oregon RMPs
each alternative compared to the baseline and the percent of departure. As such, the existing modeling is a
powerful tool to assess differences between alternatives, and is much improved over past land management
impact assessments where relative ratings or Likert scales were used.
215. Comment: The EIS should be revised to include data and reference to work completed by Swift
on roads where slash was used to increase roughness and reduce travel distance, because while Swift is
referenced in this discussion, these results were omitted. Another reference to incorporate on travel distance
research is Woods et al. 2006.
Response: This section in Chapter 3 (Water section) discussing road-related sediment travel distances has
been revised for the FEIS to include expanded discussion from Swift 1986 and others.
216. Comment: The buffer width model assumptions should be revised in the EIS, because EPA believes
they are flawed and that the model significantly underestimates shade levels and the potential temperature
responses of Alternatives 2 and 3. There are a number of limitations to the use of the Brazier and Brown
study which are not acknowledged in the DEIS. It is also important to acknowledge that the Brazier and
Brown shade study did not account for the likelihood of riparian corridor blow-down, disease, or other
factors that reduce angular canopy density.
Response: The Riparian Management Area width design portrayed under Alternatives 2 and 3 for perennial
streams is based on published science findings. The commenter is unsatisfied with the statistical design
of the landmark Brazier and Brown (1972) study, but offers no proof that the study does not support the
angular canopy density and riparian shade width conclusions. The Steinblums (1984) study science findings
on angular canopy density and riparian width from blowdown have been included in the FEIS, Chapters 3
and 4, Water section.
217. Comment: The EIS should be revised to correct the conclusion that 80% effective stream shade “...
corresponds to less than a 0.2°F change in stream temperature per mile of stream...” (DEIS, page 750),
because this approach relies on a non reach-specific temperature model sensitivity analysis conducted in
1999 as part of the Upper Sucker Creek Temperature TMDL analysis. In this analysis, the model sensitivity
analysis was not used to evaluate stream temperature response. The DEIS, however, uses these modeling
results to predict temperature response to timber harvest across the plan area. Because this model is not
reach-specific and does not consider site specific conditions or seasonal temperature variation, EPA believes
this approach does not predict or evaluate stream temperature response to the proposed alternatives in a
meaningful way.
Response: The commenter is referring to Figure 3-106, Stream Shade and Change in Water Temperature,
in the FEIS. This figure illustrates that as effective shade increases beyond 40%, there is a corresponding
reduction in stream temperature to a point (e.g., approximately 80%) beyond which further reduction in
stream temperature as a function of shade is not measurable (Boyd 1986). Boyd (1986) demonstrates that
the various temperature heat exchange pathways between a stream and its environment (in addition to
direct solar such as diffuse solar, long wave radiation, conduction or convection) introduce noise and negate
incremental additions of effective shade above the 80% level. In other words, shading by forest vegetation
has little effect above the 80% effective shade level because of other temperature fluxes operating in the
environment.
The BLM agrees that 0.2°F change in stream temperature per mile of stream, at an 80% effective shade level,
may not always capture site-specific conditions, but this does not diminish the broader scale value. These
relationships of effective shade and temperature increase were developed during low streamflow conditions
during a short temporal, maximum stream warming period (August) where seasonal variation is portrayed
Appendices - 830
Appendix T - Responses to Public Comments and Comment Letters
as the worst case. The BLM only has control over riparian area forest vegetation management and uses
shade as a surrogate measure for stream water temperature increase. Therefore, the use of the Upper Sucker
Creek TMDL sensitivity analysis over a summertime period almost certainly exaggerates changes in stream
temperatures, which would further diminish the possibility that shade contributions beyond the 80% level
would have any meaningful effect, contrary to the assertion of the commenter.
218. Comment: The sediment modeling in the EIS should be revised to account for forestry related
activities such as yarding, skidding, site preparation, and canopy removal which have been demonstrated to
contribute to surface, gully and large-mass soil movements, because they are currently not being considered.
Response: Potential sediment delivery impacts from cable yarding and ground-based skidding were
dropped from detailed plan-wide consideration because effects on water quality are minor and site specific
when Best Management Practices are applied at the time of project activity (Refer to the FEIS, Appendix
I-Water, Best Management Practices). Specific BMPS (e.g., suspension over certain stream channels, or
ground-based equipment limitation zones) are identified to minimize or prevent sediment delivery to
streams and waterbodies to a negligible level. Discussions in the FEIS ( Chapter 3, Water section; as well
as Appendix I-Water, Analytical Questions #2 and #3) provide details about forest canopy removal. The
principal effects are relevant to streamflow runoff response being scaled by hydroregion, watershed size,
and level of forest basal area removal. Aside from burning, overland flow is seldom observed in the analysis
area because infiltration capacities in undisturbed forest soils most often exceed 3 inches per hour, which is
greater than the most intense precipitation periods of characteristic storms (Meehan 1991).
Site preparation broadcast burning can have temporary effects on increasing onsite soil loss and potential
sediment delivery to watercourses, because of the consumption of ground cover and possible temporary
hydrophobic effects from hot burns. To maintain soil fertility, alleviate potential sediment delivery concerns,
and lower risk of wildfire, there are prescriptions for the majority of site preparation broadcast burning to
be completed in the late winter and spring. Soils and fuels moisture contents are higher during these time
periods and burn intensities are expected to be low. Furthermore, BLM broadcast burning prescriptions
often leave areas unburned (swamper burn), as long as replanting can achieve satisfactory results. The shrub
and noncommercial 25-foot Riparian Management Area along intermittent streams under Alternative
2 would have the highest probability for sediment delivery from burning. The anticipated amount of
regeneration harvest broadcast burning was estimated for each alternative and time period (see the FEIS,
Chapter 4, Water section). In summary, to differentiate between the alternatives, the BLM has analyzed the
important sediment pathways at a plan scale, which are the effects from harvest placement and roads on
land sliding and sediment delivery. Best Management Practices for individual forestry activities are specified
when site-level NEPA is completed. When implemented correctly, the hypothetical effects of concern to the
commenter are prevented.
219. Comment: The EIS should be revised to clarify which datasets were used to determine removal
of basal area and to provide the rationale for dataset and “surrogate measure” selection (i.e., 10% crown
closure) for the following reasons: On BLM lands, stand establishment structural stage was used as a
surrogate for the removal of basal area. For adjacent non-BLM lands areas of less than 10%, crown closure
was used as a surrogate for the removal of basal area (DEIS, page 384). Data underlying the peak flow
analysis on BLM lands was derived from the OPTIONS model, and data for “other lands” was derived from
the 1996 Interagency Vegetation Mapping Project (IVMP).
These methods raise a number of issues:
1) Rationale for establishing surrogate measures for the removal of basal area is not provided.
2) Methods employed to evaluate surrogate measures use two different time frames (BLM lands used
modeled outputs and non-BLM lands used a 1996 dataset).
3) Use of 10% crown closure as a surrogate for the removal of basal area may underestimate the
Appendices - 831
FEISfor the Revision of the Western Oregon RMPs
actual area which should be included as part of the “surrogate measure”. The 1996 Interagency
Vegetation Mapping Project (IVMP) produced several high quality datasets. The EPA identified four
IVMP datasets that could be used to estimate the canopy cover conditions on non-BLM lands: 1)
“Vegetation Canopy Cover” 2) “Conifer Canopy Cover” 3) Harvest History (1972 through 2002).
4) Size Class (Quadratic Mean Diameter). EPA analyzed each of these IVMP datasets as potential
“surrogate measures” for “basal area removal”. Our analysis found that the number of 6th field
HUCs shown to exceed 40% cut varied depending on the dataset considered (between 0 and 19%).
This discrepancy calls into question the DEIS conclusion that only 1 out of 635 subwatersheds
in the rain hydroregion (DEIS, page 385) and only 3 out of 471 subwatersheds in rain-on snow
hydroregion (DEIS, page 387) within the Plan Area are currently susceptible to peak flow increases.
We recommend that the Final EIS (FEIS) address this discrepancy, clarify which datasets were used,
and provide the rationale for dataset and “surrogate measure” selection (i.e., 10% crown closure).
Response: The 1996 Interagency Vegetation Mapping Project (IVMP) ARC classified satellite imagery
dataset “Vegetation Canopy Cover” that was used by BLM in several peak flow analysis. The IVMP
“Vegetative Canopy Cover” dataset is 1996 data. The IVMP “Harvest History” change detection dataset can
assess open conditions from 1996-2004. This change detection dataset was unintentionally omitted in the
DEIS. However, re-analysis for the rain and rain-on-snow using this additional dataset has been completed
for all alternatives in the FEIS.
When evaluating the alternatives, the findings for private or other lands open areas are held constant,
because there is no available information on which we may determine how age class distribution on
private lands would change over time. Much of this data is proprietary and market driven. Therefore, it
was assumed that existing proportions of forest age classes comprising the stand history in each sixth-
field watershed is near an equilibrium condition. Almost all private timber lands have now been managed
for a period longer than their average rotation cutting ages and, therefore, it is reasonable to assume that
the current age class distribution will roughly reflect the rate of change at the stage of equilibrium. Each
alternative effect is measured by determining the amount of the stand establishment structural stage on
BLM-administered lands in each sixth-field watershed for the 10-, 20-, 50- and 100-year time periods
and the amount of open area on other lands from these IVMP datasets. Specific details for the peak flow
planning criteria using these data layers is shown in the Table below and in Appendix I-Water (Analytical
Questions #1 and #2). Peak flow susceptibility in the rain-dominated hydroregion is based on removal
of forest tree basal area and equivalent clear-cut area; however, the rain-on-snow analyses uses physical
processes of snow accumulation and melt and requires a range of forested and open cover classes.
Table T-i. Vegetation Data Layers used in the Peak Flow Analysis
Data Layer
Rain Hydroregion
Rain-on-Snow Hydroregion
Domain
IVMP
Vegetation Canopy Cover
<30% crown closure
<10% crown closure
BLM & private for current
condition
IVMP
> 70% crown closure & <75%
BLM & private for current
Vegetation Canopy Cover
of the crown in hardwoods or
shrubs
condition
IVMP
10% - 70% crown closure
BLM & private for current
Vegetation Canopy Cover
& <75% of the crown in
hardwoods or shrubs
condition
IVMP
<10% crown closure,
<10% crown closure, 1996-
BLM & private for current
Harvest History
1996-2004
2004
condition
IVMP
Vegetation Canopy Cover; Nonforest
Included
BLM & private for current
condition
Options Structural Stage
Stand establishment
Stand establishment without
legacy
Alternatives
Appendices - 832
Appendix T - Responses to Public Comments and Comment Letters
For the rain-dominated hydroregion, the DEIS was in error on page 384, which reported that “10% crown
closure was used as a surrogate for the removal of basal area” for non-BLM lands. The correct figure of <30%
crown closure was reported in the DEIS analytical methods in Appendix I (page 1,096). The error on page
384 of the DEIS has been corrected in the FEIS. As seen in Chapter 3- Water section, Ziemer (1981, 1995)
found a nonstatistical (4%) increase in peak flow for 80-year old conifer stands that were harvested where
50% of the basal area was retained. It is reasonable to expect that any increases in peak flow would decrease
as the intensity of treatment decreases. For example, a greater increase in peak flow would be expected from
regeneration harvest (many acres) versus small patch cuts (less than one acre to several acres) and thinning,
the latter of which would have the least decrease. Although this general relationship is reasonable, past
experimental studies of peak flows in the Northwest have not fully examined the differences in peak flows
relative to many contemporary forest practices (Grant et al. 2008). The surrogate used in this analysis for
other lands in the rain-dominated hydroregion was set at less than 30% canopy closure. For a given timber
stand species, age spacing, etc, there are variations of crown area on the IVMP datasets when cross-walked
with basal area removed (Grant et al. 2008) for susceptibility of peak flow increase.
The BLM looked at tree diameter/crown diameter where ratios vary from 0.7 for mature trees, to 2 for trees
in young plantations. A normal forest density management treatment may remove one-third of the volume
and one-half of the stem count, resulting in 80 to 100 remaining trees per acre. For harvestable coniferous
forest stands, vertical projections were made to determine the area of remaining crowns after this normal
treatment. Stand summaries indicate that 40-50% canopy closure as a surrogate measure would maintain
50% of the basal area. However, as discussed in the FEIS planning criteria, canopy closure as a surrogate
for basal area removal was set at <30% canopy closure. This is because there are large areas of low density
unmanaged forest not attributable to timber harvest activities. These unmanaged low density forests are not
equivalent clearcut forest and could not be reasonably separated in the analysis, because the GIS algorithms
that processed the IVMP satellite imagery cannot distinguish between forest harvest and natural low density
forest. The affected subwatersheds are more numerous in southern Oregon in areas of higher fire frequency
and low precipitation. The degree in nonharvested area is uncertain.
A number of iterations by area inspection showed that the false identification increases as the canopy closure
is increased, even though the BLM did not absolutely quantify the differences over broad areas. From these
trial optimizations, the BLM chose to use the <30% canopy closure as a surrogate for basal area removed.
Others (Rothacher 1973, Harr 1976) have shown that decreases in evapotranspiration are expected to scale
somewhat lineally with the amount of vegetation removed by forest harvest. Although Grant et al. (2008)
defines a process to measure effects in the rain hydroregion using basal area removal with envelope curves,
they do not address the underlying hydrological processes for contemporary forest practices, especially
partial removals.
The Stratum- Weighted Accuracy for Vegetation Cover on all Lands by Interagency Vegetation Standards
Categories is 79% for the Oregon Coast Range and 67% for the Klamath region (Congalton and Green
1999). No IVMP accuracy data is available for the Western Cascades or Willamette Valley.
220. Comment: The EIS sediment analysis should be revised using a computer-based model that predicts
slope stability of potential landslide initiation sites based on slope, topography, rainfall, and other variables,
such as SHALSTAB. Papers developing the SHALSTAB model and showing its application include Dietrich
et al. 1992, 1993, 1995; Montgomery and Dietrich 1994; and Montgomery et al. 2000. This model works
various topographic data sources such as digitized 7.5 minute USGS quadrangle maps with enhanced
topographical contours at 10-rn intervals. The model assigns to each 1 0-m topographic cell a relative hazard
rating (low, medium, or high). Other slope stability models using similar input variables are also available. If
it is not possible to run such models for the entire plan area before the FEIS, then the FEIS should describe a
plan to update its slope stability investigations to include computer modeling.
Appendices - 833
FEISfor the Revision of the Western Oregon RMPs
Response: Computer landslide modeling was undertaken in the FEIS. The Shalstab model was considered,
but was rejected in favor of the Miller and Burnett (2007) model. This landslide model includes two
components: a measure of landslide susceptibility and an estimate of landslide runout potential. Both
components are necessary to estimate sediment and wood delivery to stream channels from landsliding.
SHALSTAB also provides a measure of landslide susceptibility, but no estimate of runout potential.
SHALSTAB is a process-based model that can be applied without calibration. It utilizes certain simplifying
assumptions (e.g., surface-parallel flow of shallow groundwater) with which topography and soil properties
can be related to the spatial distribution of soil pore pressures under steady-state rainfall conditions. These
assumptions have been challenged by Iverson (2000), who presents an alternative framework for estimating
spatially and temporally variable pore pressures. The model for landslide susceptibility that BLM has used is
empirical, so it must be calibrated and relies solely on spatial correlations among mapped landslide locations
and topographic and land cover (forest type, roads) attributes. The basis for the landslide susceptibility
portion of the model is described in Miller and Burnett (2007), and the basis for the runout portion of the
model is described in Miller and Burnett (2008).
221. Comment: The EIS should be revised to apply other models for validated peak flow response in rain-
on-snow hydroregion or compare the WOPR’s analytical model with other validated, peer-reviewed models,
because the model used (Washington Department of Natural Resources 1997) represents an untested
hypothesis with a series of untested parameters. (WOPR_PAPER_01962-18).
Response: The Washington Department of Natural Resources Hydrologic Change module has been used
in a number of watershed assessments and follows the fundamental science of the generation of peak
stream flows from water stored in shallow snowpacks. The BLM is aware of only one other model to assess
peak flow response in the rain-on-snow hydroregion: the Distributed Hydrology-Soil-Vegetation Model
(DSHVM). It is a GIS water balance model developed at the University of Washington that simulates runoff
and the impact of forest roads on watershed hydrology (Wigmosta et al. 1994). The model involves a high
level of parameterization, is costly to implement, and is not suitable for large planning areas.
222. Comment: The EIS TMDL ISE methodology should be revised, because it is simply a white-paper on
temperature modeling, and is a flawed basis for riparian management. The white-paper is technically weak
and incomplete despite its much iteration. It selects the Brazier and Brown (1973) shade curve rather than
the Steinblums et al. (1987) shade curve (the competing shade curve that has traditionally been reported
jointly with Brazier and Brown) because it permits narrower buffers. This approach increases risk to aquatic
resources greatly. Some assumptions in the white-paper do not comport even with Brazier and Brown.
Others are not internally consistent. The Brazier and Brown model itself is so poorly documented and
ridden by technical flaws that its use is highly suspect. In addition, shade and temperature modeling by the
BLM is not consistent with ODEQ TMDL standards and goals.
Response: The analysis in the LEIS has been expanded to include the Steinblums et al. (1987) shade curve.
This study includes the influence of blowdown. In order to accommodate similar sun blocking ability as in
the Brazier and Brown (1973) study, Riparian Management Areas become wider because there are fewer
trees resulting in lower forest density and fewer tree crowns to provide shade. See the FEIS, Chapter 3 (Water
section) for explanation of solar physics and influence of topography and forest trees. The BLM views the
Steinblums et al. (1987) shade curve as a factor of safety because the 40 study sites had a range of blowdown
from 11-54%, which is substantially higher than blowdown observed within riparian management areas in
a managed forest. Where higher levels of blowdown are present in the riparian zone, the Steinblums et al.
(1987) shade curve shows that 80% effective shade is reached within a riparian management area at 120 feet
from the stream, compared to 100 feet with incidental or no blowdown.
The Department of Environmental Quality (DEQ) has used their Heat Source shade and stream temperature
prediction model to evaluate the alternatives and find that stream temperatures do not change when riparian
Appendices - 834
Appendix T - Responses to Public Comments and Comment Letters
management areas along perennial streams are a minimum of 150 feet in width. The BLM believes that
DEQs assessment methods may have some technical shortcomings. Nevertheless, DEQs results indicate that
the Riparian Management Areas for the No Action Alternative, Alternative 1, and the PRMP Alternative
would fully meet shade goals and stream temperature water quality standards.
223. Comment: The EIS Peak Flow analysis should be revised to properly incorporate Gordon Grant’s
research results. The threshold for increases is percent in open category, not basal area (DEIS, page 1,096).
Grant (2007) suggested the threshold was at 30%. Rain-on-snow modeling in WOPR does not agree with
results using different techniques in NEPA documents and watershed analyses. Sensitivity testing is needed
on watersheds that were known to be damaged from recent 96/97 rain-on-snow events (e.g. Fish Creek
near Salem District, Sucker Creek in Medford District). The analysis did not look at 5 year events which are
certain to occur (see effects to SW Washington/ Veneta, Oregon from December 07 rain only storm).
Response: In the FEIS, the peak flow analysis in the rain hydroregion has been revised, using Grants
findings where maximum response at detection level is 29% of the watershed area cut with roads and a mean
of 45%. Analytical Question #1 in the FEIS, Appendix 1-Water has been revised with 29% open area used as
the threshold.
The rain-on-snow modeling undertaken in the Western Oregon Plan Revision is a more rigorous approach
than techniques previously or even currently used in watershed analysis or other NEPA documents. The
model uses information on climatology, topography, hydrology, and physical processes to calculate water
available for runoff. This degree of rigor is greater than the most commonly used method that involves
interpolating a risk diagram. The user enters a risk class figure with area information, which is the percent
of land within a rain-on-snow elevation, and the percent of the rain-on-snow area with less than 30%
crown closure, to determine a risk of peak flow enhancement (Watershed Professionals Network 1999
IV- 1 1). This methodology ignores some rather obvious major factors that would determine a watershed’s
susceptibility to peak flow issues, such as the climate and topology in the watershed. Although ongoing
verifications are underway, the output from the analytical rain-on-snow procedure used in preparation of
the Western Oregon Plan Revision certainly results in more accurate and supportable conclusions in terms
of susceptibility as this risk procedure.
All event sizes are certain to occur from ordinary to extreme, but the recurrence interval increases for the
larger runoff events. The methodology used for peak flow analysis in the rain dominated hydroregion is not
recurrence interval specific and, therefore, covers all return periods. The methodology used for peak flow
analysis in the rain-on-snow hydroregion looked at 2-year events rather than 5-year events, because these
stream flows are in the range of effective streamflow that do the most morphological work on the channel
(modification of bed and banks) in the long run (Leopold 1994).
Different land areas within the same watershed or different watersheds have different susceptibilities to
landsliding and stream channel changes based on inherent watershed characteristics. Precipitation and
runoff may vary widely from extreme storms in watersheds with differential effects. The BLM does not
consider landsliding, deposition of sediments, or large wood from extreme storms to be “damage” unless
watershed equilibrium has so markedly shifted that it can be traced to anthropogenic activities. Despite
differing watershed characteristics and uncertain climatology, the BLM has withdrawn from timber
management the majority of susceptible mass wasting lands under the Timber Productivity Capability
Classification.
224. Comment: The EIS should be revised to provide adequate cumulative effects analysis of the 16
subwatersheds deferred from timber harvest in 1994. The current analysis does not demonstrate that
conditions have improved enough to warrant renewed timer harvest as proposed in the WOPR action
alternatives.
Appendices - 835
FEISfor the Revision of the Western Oregon RMPs
Response: This comment refers to the Medford District 1995 RMP management direction: “Defer the
following areas (approximately 49,636 acres) identified as having high watershed cumulative effects from
management activities, including timber harvest and other surface-disturbing activities for ten years,
starting from January 1993.... The following areas will be reevaluated during the next planning cycle or by
January 2003.”
This 49,636-acre area within 16 subwatersheds on the Medford District was analyzed in the Western Oregon
Plan Revision DEIS for cumulative watershed effects. Important cumulative watershed effects across all
lands were evaluated, including a peak flow analysis and a roads potential sediment delivery to streams
analysis (refer to the DEIS, Chapter 4, Water section). Variations in modeling assumptions were evaluated in
the DEIS: 1) deferrals were continued for one decade under the No Action Alternative, and 2) deferrals were
continued under Alternative 1, with no ASQ simulated (refer to the DEIS, Appendix Q-Vegetation Modeling,
page 1,568). The results of these analyses in the DEIS did not reveal environmental impacts that warrant
reinstating the 1993 deferral of harvest.
225. Comment: The EIS should be revised to consider cumulative impacts of stream shade variation
in mixed ownership areas, because streams flowing through mixed ownerships will be affected by lower
shading levels on private lands.
Response: The BLM recognizes a disparity of stream shade rules between federal and state agencies.
Although appearing intuitive, the observation that “streams flowing through mixed ownerships will be
affected by lower shading levels on private lands” does not necessarily translate to stream temperature
increase. As is the case on many private forests, the majority of streams on BLM-administered lands are
headwater streams, where approximately 67% of the stream network is intermittent and do not require
shade to ameliorate temperature increase. Many other channels have low summer stream flows. For small
streams (<2 cfs average annual streamflow), streams flowing through unbuffered regeneration harvest units
receive significant cooling downstream as the streams re-enter the forest (Robison et al. 1995). Dent and
Walsh (1997) showed, based on Analysis of Variance statistical tests, that streams higher in watersheds
showed a decrease in temperature 500 feet downstream of treatment, whereas streams lower in a watershed
did not. Their conclusions infer that streams warm naturally in a downstream direction. This is partly due to
wider, low gradient streams in the valleys with more surface area exposed to solar heating and lower rates of
water flow.
Larger streams in lower watershed areas more frequently encounter private lands. State Forest Practices
protection measures along riparian management areas include 20 feet of continuous no-cut area along each
side of medium and large streams with a variable basal retention area up to 350 square feet outward to 100
feet (100 x 1,000) (OAR 629-640-0200). Dent and Walsh (1997) reported for a sample of medium to large
private forestland streams that stream temperatures were at or below the 64°F numeric criteria 90% of the
time. Furthermore, they could not differentiate the proportion of the temperature increase that was due to
a partial decrease in shade from the proportion attributable to expected downstream increases in stream
temperatures.
In consideration of the foregoing, it is concluded that the cumulative impacts of stream shade variation in
mixed ownership lands are not being aggravated by BLM. The BLM conservative shade rules manifested in
the design of Riparian Management Areas under all of the alternatives already promote an anti-degradation
standard with a high level of effective shade. Higher levels of effective shade beyond 80% are not expected to
change stream temperature profiles from ambient conditions (see FEIS, Chapter 3-Water section).
226. Comment: The EIS should be revised to disclose the impacts to aquatic resources from logging on
private land as well as on public land. Although the BLM asserts that sediment delivery to streams from
Appendices - 836
Appendix T - Responses to Public Comments and Comment Letters
1,000 miles of new roads and hundreds of thousands of acres of new clearcuts is negligible, the cumulative
impact of sediment delivery from these types of actions are expected to be significant.
Response: Based on literature findings (in Chapter 3-Water section), and as indicated in the planning
criteria (DEIS, Appendix I, pages 1-1106 to 1-1113), water runoff from roads that could deliver sediment
to streams was modeled across all BLM and private lands by fifth-field watershed. A 200-foot sediment
delivery buffer was used as a reasonable approximation for the source area of potential road erosion. Each
alternative’s total miles of new roads were considerably reduced when this methodology was applied.
It is important to consider that much of the road system is already developed within watersheds, along
transportation routes that cross streams, and the road additions to forest treatment areas include many short
road segments on ridges or topography well separated from streams. Findings from the analysis for all lands
show that miles of new permanent road, within a potential sediment delivery distance to streams under the
alternatives as an addition to the existing roads (reported as a watershed average), ranged from less than
0.005 to 0.14% increase, which is a negligible amount. Furthermore, the analysis showed the potential fine
sediment delivery addition to streams from all lands (reported as a watershed average) to be less than 0.27
tons per year addition, which is also a negligible amount (refer to the DEIS, Chapter 4, Water section, Table
212).
227 . Comment: The EIS should be revised to take a more conservative approach to classifying and
managing landslide prone areas. The assumption that “the rate of susceptibility to shallow landsliding from
timber harvests... would not increase... because fragile soils that are susceptible to landsliding... would be
withdrawn” (DEIS, page 763) marginalizes the issue, and conflicts with observed landslides on BLM lands
not withdrawn from timber harvest. Given the observed landslides on BLM harvest units and research
demonstrating that clearcut logging on unstable landforms increases landslide frequency, this approach
should be revised.
Response: The BLM has not attempted to marginalize the issue of preventing landslides in managed
areas. The BLM soil scientists have identified 89,937 acres (3.5% of BLM-administered lands) that need
protection due to land stability concerns. These areas are currently withdrawn from programmed timber
harvest. During project-level planning in the Timber Management Area, field reconnaissance by specialists
would also identify any further stability concerns that are more discernible with the closer site-specific look
taken during project planning. Based on these assessments, the type or area of proposed harvest would be
adjusted. Additionally, for the FEIS, a GIS computer modeling landsliding assessment (Miller and Burnett
2007) was made, based on forest management projects, to analyze land stability at a watershed scale and to
disclose any related impacts within the harvest land base and other BLM-administered lands, by alternative.
228. Comment: The EIS should be revised to consider the potential effects of increased magnitude,
duration, frequency, or timing of peak flows, and how increased peak flows may affect the biological
communities and primary constituent elements of critical habitat of listed salmonid fish within susceptible
subwatersheds.
Response: The magnitude and frequency of peak flows from management activity and potential effects
has been analyzed and discussed thoroughly in the FEIS, Chapters 3 and 4, Water sections. The potential
effects to biological communities and associated primary constituent elements for fish have been discussed
thoroughly in the FEIS ( Chapters 3 and 4, Fish sections). Duration or timing of peak stream flows is
primarily dependent on climatic conditions. Demonstration of an impact on biological communities and
primary constituent elements of critical habitat of listed salmonid fish within susceptible subwatersheds is
guided by site-specific evaluation procedures.
The DEIS and FEIS ( Chapter 4, Water sections) have shown that less than t% of the subwatersheds are
susceptible to peak flow increase from the degree of forest management activities described under all
Appendices - 837
FfJ-S/or the Revision of the Western Oregon RMPs
alternatives. No studies have shown a direct correlation between peak flow changes due to forest harvest
and measured changes to the physical structure of streams (Grant et al. 2008). This is partly due to the
problems separating causal mechanisms. Nevertheless, within the few susceptible subwatersheds, a useful
framework described by Grant et al. (2008), that will be used during site-specific NEPA, would be to classify
the stream types as cascade, step-pool, gravel-bed, or sand-bed (Montgomery and Buffington 1997). A
rigorous channel cross-section assessment would be required. In general, percent increases in peak flows
from forest management would be indexed against the capacity of the channel to move sediment; however,
sediment movement does not imply destruction of the channel armor layer. Risk factors could also be used
to consider the degree of road connectivity to streams by roadside ditches, drainage efficiency, forest patch
size, and characteristics of riparian buffers. Based on these findings, a determination would be made for the
likelihood of potential to affect and the degree of channel change.
229. Comment: The EIS should address the impacts of road-related changes in peak flows for both
hydroregions and also consider the frequency and duration of peak flows and their effects to stream
processes and the biological communities.
Response: Runoff response from roads was considered in the analysis. Within the rain hydroregion
subwatersheds, the area of forest harvest and roads was summed in aggregate, divided by the subwatershed
area, and compared against the maximum reported change envelope curve of Northwest experimental
studies (Grant et al. 2008). Results from this aggregation are discussed in Chapter 4 (Water section). Within
the rain-on-snow hydroregion, roads were modeled as open areas along with non-forest, agricultural lands,
and waterbodies, and they were subject to the same snow accumulation and melt processes within rain-on-
snow elevations. These results are discussed in Chapter 4 (Water section).
230. Comment: The EIS should be revised to analyze and disclose the effects of soil compaction caused
by roads, landings and logging; the impacts of roads on peak flows; and the amount of area occupied by
existing landings.
Response: Soil compaction was not analyzed in detail because the area of compaction from new
roads, landings, and logging for forest management operations seldom reaches a level that statistically
increases runoff. At the catchment scale, Harr (1975) indicates that peak flows on Deer Creek in the Alsea
experimental watersheds were increased significantly when roads, landings, and skid trails occupied more
than 12% of the watershed. For somewhat larger watershed areas (1.7 square miles), Keppeler and Ziemer
(1990) found that the roads, landings, and skid trails that occupied 15% of the South Fork on Caspar Creek
in northern California had no significant effects on peak flow. An average of 64% of the timber volume was
also removed in a three-year period in the same watershed. Based on these findings at the site level, Best
Management Practices specify “plan use on existing and new skid trails, to be less than 12 percent of the
harvest area” (refer to FEIS, Appendix I-Water). Grant et al. (2008) concludes that peak flow response can
never be greater than at the site level, and that larger watershed scales diminish peak flow levels for a variety
of reasons (refer to the FEIS, Chapter 3, Water section).
From the effect of the alternatives, the net effect of road building versus road decommissioning results in less
than 1% increase over the current road and landing acreage in Alternatives 2 and 3, and a net decrease in
acres in the No Action and Alternative 1 (refer to Chapter 4, Soils section). At the fifth-field watershed level,
the BLM assessed several individual watersheds and derived estimates of total compacted area, summing the
area of existing and new roads, landings, and logging disturbance under alternative projections. Findings
from these assessments show that compacted area does not exceed 6% of the watershed area, which is below
a peak flow response level. Therefore, significant effects on the elevation of peak flows from management
activities of road building and harvest are not anticipated from any of the alternatives.
Appendices - 838
Appendix T - Responses to Public Comments and Comment Letters
231. Comment: The EIS should provide references for the assertion that sediment generation by overland
flows (the mechanism for sediment from cutting and yarding timber) is not an issue because of high water
infiltration in forest soils.
Response: Infiltration capacity in forest soils is the rate at which rain or melted snow enters a wetted
soil surface. This rate is governed by soils composition and the depth, size, and shape of pore spaces.
Coarse-grained soils derived from colluvium, alluvium, or tills are highly permeable, whereas fine-grained
soils derived from marine materials or weathered siltstone, sandstone, or volcanic rocks usually have
lower permeability. Two studies in the western Cascades (Coyote Creek, located on the South Umpqua
Experimental Forest; and the H. J. Andrews Experimental Forest) show that fall infiltration capacities
average 4.8 inches per hour (Johnson and Beschta 1981). A review of soil survey data, from the Natural
Resources Conservation Service, in the analysis area reveals that infiltration rates can vary from 2 inches to
6 inches per hour, depending on location. The Pacific Northwest precipitation amounts rarely exceed these
infiltration capacities of forest soils on an hourly basis.
232. Comment: The EIS should be revised to assess the impacts of eliminating riparian reserve buffers on
unstable slopes.
Response: The BLM Timber Productivity Capability Classification identifies susceptible landforms to mass
wasting, and these lands have been withdrawn from management activity (see Chapter 3, Water section).
233. Comment: The EIS should be revised to address the physical and biological impacts of reduced
riparian reserves considering all relevant information available, particularly relevant considering that BLM
produced many of these documents.
Response: The DEIS and FEIS include a thorough analysis on the different riparian management widths for
each alternative and the effects to water and fisheries resources using state-of-the art modeling, analytical
methods, and current scientific literature. The FEMAT scientists originally proposed interim riparian
management areas, pending the outcome of watershed analysis. Riparian forest effects on streams as a
function of buffer width (FEMAT 2004 V-27) show that most attributes (including root strength, litter fall,
shading, and coarse wood cumulative effectiveness) to be leveling off at 0.5 tree height (approximately 100
feet from the stream edge).
Riparian “buffer effects science” in the last 10 years reveals that primary functionality, including riparian
buffer effects on microclimate, can be retained within this distance (Chan et al. 2004, Rykken et al. 2007).
These conclusions demonstrate the adequacy of the Riparian Management Area design for the No Action
Alternative, Alternative 1, and the PRMP Alternative for all streams. By retaining sufficient widths for large
wood delivery, perennial and intermittent debris flow streams in Alternative 2 and perennial streams in
Alternative 3 are also fully functional for the primary attributes. In Alternatives 2 and 3, intermittent stream
channels are fully functional where harvest does not occur, and are functional to an undetermined but lesser
degree for some attributes in riparian areas adjacent to areas of regeneration harvest.
234. Comment: The DEIS analysis of impacts to stream temperature are flawed because it is based on a
limited and selective view of riparian science that is heavily skewed toward consideration of only the shade
function.
Response: The BLM recognizes land uses that can contribute to stream heating include vegetation removal
(resulting in loss of shade), stream channel modifications (resulting in wider and shallower streams),
floodplain dissection and downcutting (resulting in loss of cooler stored water that can exchange with
stream water), and hydrologic alterations (such as groundwater withdrawals). To determine primary effects
Appendices - 839
FEISfor the Revision of the Western Oregon RMPs
in most situations, the BLM relies on the shading ability of forest vegetation as a surrogate for temperature
change. When considering all energy fluxes of temperature gain or loss, direct solar radiation has been
shown to be the greatest contributor to stream heating from the loss of shade (Brown 1969, Boyd 1996,
Chamberlin et al, 1991).
In forest watersheds during the summer months, the combination of direct solar radiation reaching the
stream surface, the relative number of stream tributaries, and a decrease of stream discharge has the greatest
effect on stream temperature change in a downstream direction (Beschta et al. 1987). The BLM has little to
no control over seasonal stream discharge, but has shown in Chapter 4 (Water section) that the Riparian
Management Area strategies under the alternatives and resulting effective shade is expected to fully meet
water quality standards along most stream reaches. Stream channel modifications, floodplain downcutting,
and withdrawals are unique, reach specific analysis, and are best suited for evaluation during development
of a project activity.
235. Comment: The EIS analysis of impacts of harvest in riparian areas on stream temperature, and
impacts to fish and other aquatic biota is flawed because it did not consider data from FWS, EPA and NMFS
evaluations (Oregon Department of Forestry and Department of Environmental Quality 2002; National
Marine Fisheries Service 2001).
Response: The FEIS analysis utilizes the best scientific information available from a variety of sources.
Additionally, the PRMP Alternative and FEIS fisheries and water management actions and analysis were
revised in part based on evaluations and input from the Environmental Protection Agency, Fish and Wildlife
Service, National Marine Fisheries Service, and other cooperators. For example, the BLM examined the
stream temperature modeling by the Department of Environmental Quality for the various alternatives.
Also, due to comments received from the Environmental Protection Agency and the National Marine
Fisheries Service, the PRMP Alternative in the FEIS has an additional area beyond 100 feet as a factor of
safety for the primary and secondary shade zone for episodic occurrences of blowdown.
236. Comment: The EIS should more fully acknowledge the risks to the water, fish and wildlife in the Coos
Bay District from coal bed methane development; analyze these impacts and the develop protective lease
stipulations, including a prohibition on discharge of produced water and an option to require treatment of
produced water prior to reinjection. The EIS should also list the requirements for management of produced
water.
Response: For the Western Oregon Plan Revision, Reasonably Foreseeable Developments (RFDs) oil and
gas potential impact assessments were prepared for each district (including Coos Bay) (see the Energy
and Minerals Appendix). The assessments provide an overview of potential hydrocarbon energy resources
within the planning area. Overarching leasing stipulations are also listed in the Energy and Minerals
Appendix. The analysis of effects in Chapter 4 shows how the Reasonably Foreseeable Developments interact
with the land use allocations to determine the appropriate lease stipulations. Further assessments of the
Coos Bay District coal bed methane development beyond that in the RFDs will be completed in subsequent
project-level NEPA. The BLM is not making any decision on whether to proceed to develop coal bed
methane under this FEIS. Management of produced water would be addressed through the Department of
Environmental Quality’s authority, as delegated by the Environmental Protection Agency through the Clean
Water Act. The BLM, and state and federal agencies, would be involved in determining measures to mitigate
potential impacts to fish and wildlife. Where needed, area-specific leasing stipulations would be augmented
at the application for Permit to Drill (APD) level through Conditions of Approvals (COA).
237. Comment: The EIS should be revised to address the fact that vegetation removals (and in particular,
logging) exacerbates seasonal extremes of water runoff from watersheds.
Appendices - 840
Appendix T - Responses to Public Comments and Comment Letters
Response: The BLM has described the effect of vegetation removal from timber harvest on water runoff in
watersheds in Chapter 3 (Water section). The discussion focuses on stream flows that fill the active channel
up to a 6-year recurrence interval event. These are the stream flows most susceptible to having stream forms
changed or biological communities negatively impacted from the effects of forest management. It is well
known that low flows are increased by forest management (Ziemer 1998, Jones and Grant 1996). However,
these stream flows are well contained within the boundaries of the active channel and normally do not have
enough stream power to mobilize and carry sediment. Increasing seasonally low stream flows has beneficial
effects as well, such as augmentation of water volume to buffer against summertime stream heating. As
discussed in Chapter 3 (Water section), large floods (>6- year recurrence interval event) are not evaluated
either because the runoff effects from forest management are overridden by the storm flow volume of runoff,
or because the smaller effects of forest management are subsumed by the far larger effects of the storm itself.
238. Comment: The EIS should provide justification for the five representative watersheds that were
selected in the analysis. It certainly does not describe Tost Creek on the Middle Fork Willamette, which is an
intense rain-on-snow watershed. This needs to be addressed and analyzed in the WOPR.
Response: Representative watersheds were not used in the peak flow analysis. Rather, all subwatersheds
(10,000 to 40,000 acres) within the rain-on-snow hydroregion were analyzed for the susceptibility of
enhancement of peak flows (refer to Chapters 3 Sc 4, Water sections).
239. Comment: The EIS should take into account the mobility of aquatic corridors over time.
Response: In drainage evolution, the most probable state always exists to satisfy physical requirements.
New drainage is built or extended only if erosion exceeds resistance to erosion. Further, geomorphology
obeys laws of geometrical proportions for the resulting stream network (Teopold et al. 1964). The rates of
channel development within incipient headwater channels are episodic, but slow; changes are certainly not
important in a management plan timeline. Meandering rivers or streams can migrate laterally over time,
depending on the equilibrium between bed and bank materials, stream slope, width and depth, discharge,
and sediment supply (Rosgen 1996). Little lateral movement occurs under most ordinary streamflow
conditions, but changes can occur during large flood events, with scour on the convex side of the river or
stream and accretion on the concave side. For these unique situations, the FEIS includes delineation criteria
for measuring Riparian Management Areas from the ordinary high water line of the channel migration
zone.
240. Comment: The EIS should address the fact that Alternatives 2 and 3 would result in substantial, long-
term impacts to water quality and exacerbate continued exceedance of water quality standards in streams
listed as impaired under Section 303(d) of the Clean Water Act (CWA).
Response: The BLM believes that Alternatives 2 and 3 would maintain water quality just as well as the other
alternatives. The BLM has shown in Chapter 3 (Water section) how the primary and secondary shade zones
would maintain effective shade at levels of 80% or higher, which is near potential system shade in most
watersheds.
The BLM has cooperated with DEQ regarding Water Quality Management Plans in TMDL watersheds,
and many are either approved or in development. These plans specify active or passive restoration and
monitoring to coincide with the assigned temperature allocation.
Appendices - 841
FEISfor the Revision of the Western Oregon RMPs
241. Comment: The EIS should address the fact that Alternatives 2 and 3 are not consistent with the TMDL
Strategy (Northwest Forest Plan Temperature TMDL Implementation Strategies 2005) and do not meet the
terms of the DEQ conditional approval.
Response: The majority of BLM streams are not 303(d) listed for stream temperature, and the management
goal along these streams is to meet the applicable DEQ numeric criterion of 64 degrees Fahrenheit in most
basins (OAR 340-041). Only a very small portion of BLM streams (<4%) are TMDL listed for temperature.
The Riparian Management Areas, including width and retained forest tree density, under all alternatives
were designed using the primary elements within the Northwest Forest Plan Temperature TMDL
Implementation Strategies 2005 (TMDL strategy), which included a primary and secondary shade zone
along summertime waters. Furthermore, the minimum requirements for these Riparian Management Areas
under the alternatives were developed using primary science findings contained within the TMDL Strategies
(Brazier and Brown 1972) and Shadow Temperature Model iterations.
The BLM adopted the width of the primary shade zone from Table 3 of the TMDL Strategies (referenced
above), using the most conservative assumptions (greatest width), as well as the 50% canopy cover
recommendation for the secondary shade zone. Therefore, Alternatives 2 and 3 are believed to be entirely
consistent with the TMDL Strategy. The BLM has an ongoing agreement with DEQ as a Designated
Management Agency for implementation of the Clean Water Act and amendments on BLM-administered
lands. This agreement is currently being updated and will be revised to reflect the PRMP Alternative of the
FEIS.
The DEQ performed a temperature analysis on Canton Creek, which in BLM’s view has some shortcomings.
The BLM encourages DEQ to retest Alternatives 2 and 3 along several other forested stream environments
using the design for Riparian Management Areas for Alternatives 2 and 3. The Riparian Management Areas
would be shown to be effective.
242. Comment: The EIS should discuss the limitations of the Brazier and Brown study, including (1) that
the study was done on a small non-random sample of 13 reaches along nine small mountain streams in
Oregon; (2) the relationships identified in the study may be subject to artificially high R2 values; and (3) the
study did not account for the likelihood of riparian corridor blow-down, disease or other factors that reduce
angular canopy density. The EIS should also explain the complex nature of the analysis of buffer width.
Response: (1) The 1973 Brazier and Brown study “Controlling Thermal Pollution in Small Streams” does
not include information about randomness of the selected sample reaches. The sample reaches were split
between two physiographic provinces: the Oregon Coast Range and the Cascades. Although the BLM
believes that having two samples are important because overstory and understory forest vegetation type
and density varies between regions, the results were remarkably similar. (2) In an effort to remove non-
comparable influences, the study did exclude several reaches from the sun blocking (change in heat) and
buffer width relationships. As noted by the authors, the overriding topographic influences, stream channel
shape, and influence of groundwater within the study reach were separated to derive better comparisons.
Whether or not this separation led to artificially high R2 values in the regression equations is a matter of
opinion; however, the Brazier and Brown study findings were reinforced by combining data sets with the
Steinblums et al. (1984) study. (3) Discussion was added to the FEIS regarding riparian corridor blowdown,
disease, other forest risk factors, and the effect on shade. The complex nature of riparian forest community
types, topography, and stream factors in providing effective shade has been described in Chapter 3 (Water
section).
243. Comment: The EIS should address the conclusions that a 0.2°F increase over 1 mile, and that this is
“within the range of natural variability” (DEIS, page 750) would conflict with the TMDL load allocations
established for some basins.
Appendices - 842
Appendix T - Responses to Public Comments and Comment Letters
Response: In a planning area context, less than 4% of BLM total stream miles are listed on the 303(d) list
for temperature, and a lesser subset is covered by completed Total Maximum Daily Loads (TMDLs) load
allocations. The most restrictive load allocations given to BLM as a target are 0.1°C (0.1 8°F) temperature
increase, which is nearly equivalent to 0.2°F. For example, the Umpqua Basin TMDL (approved by EPA
04/12/2007) has 0.1°C temperature increase allocated to nonpoint source activities. Further, surrogate
measures as effective shade targets for riparian vegetation translate the numeric TMDL allocation. Although
these shade targets sometimes exceed 80% in the TMDL, the objective is to stay within the temperature
allocation. The BLM has shown how maintaining 80% effective shade would limit water temperature
increase to this range (refer to Chapter 3, Water section).
Additional points to consider regarding the 0.1 °C TMDL allocation level of precision are:
1) Stream temperatures increase naturally in a downstream direction, regardless of riparian vegetation
removal, and this warming effect is difficult to separate from harvesting effects on stream
temperature (Dent and Walsh 1997).
2) At this expected level of attainment, stream monitoring studies are inconclusive because the
variance of temperature measurement instruments is greater than the variance of the expected
results. For example, measurement errors in water monitoring studies can be up to 0.5 °C (0.9°F)
different, even when initially calibrated against a National Institute of Standards and Technology
(NIST) thermometer. Reasons for the differential may include drift throughout the temperature
range due to irregularities in hardware manufacture or programming algorithms, placement in the
stream, or other factors.
3) Heat losses to stream temperature occur normally (e.g., stream bed conduction or groundwater
inflows confound interpretation).
4) Proximity factors leading to stream temperature fluctuation over space and time cannot be
separated out.
244. Comment: The EIS should analyze the contribution of sediment from a larger portion of the road
network and its impacts to water quality. A 1997 study of channel network extension by forest roads in the
western Cascades of Oregon found 57% of roads are hydrologically connected to streams (Wemple et al.
1996).
Response: Results for sediment delivery from roads planning criteria (refer to FEIS, Appendix 1-Water )
estimate that 36% of all roads on BLM-administered lands are within the likely sediment delivery distance.
All streams mapped on the BLM GIS streams layer (updated prior to the Western Oregon Plan Revision)
received a 200-foot sediment delivery buffer, and then the GIS roads layer was merged with the common
areas of the streams and the sediment delivery data layer. This 200-foot coverage was based on the results
of research within different geologies, and for different parts of the road corridor (cutslope, travelway,
ditchline, fillslope) where mean sediment travel distances range from 12 feet to 126 feet (refer to Chapter 3,
Water section).
The commenter notes that Wemple et al. (1996), in a study in the Cascades, found that 57% of all roads
surveyed drained to stream channels. However, this study also reveals that 34% of the roads surveyed
actually drain to stream channels, but the remaining 23% were ditch relief culverts draining to a gully that
traveled a minimum of 35 feet below the road. The study notes that most of these gullies are discontinuous
and do not link with a stream. Inasmuch as the emphasis of this paper focuses on the hydrologic
implications of extension of stream channels by roads and not sediment delivery, it is inappropriate to use
these results in the FEIS because there is not a sediment travel pathway from a discontinuous gully to a
flowing stream.
Another monitoring study in western Oregon, where road systems were randomly sampled in watersheds
within five physiographic provinces, found that for 285 miles of forest road, 25% drained directly to streams
and another 6% were rated as possible (Skaugset and Allen 1998). The BLM estimation of road length with
Appendices - 843
FEISfor the Revision of the Western Oregon RMPs
stream connectivity, although calculated differently, appears to be very similar to research and monitoring
findings. Therefore, the BLM maintains that the portion of the road network analyzed is appropriate.
245. Comment: The EIS conclusions regarding water quality in relation to source water are flawed because
they are inconsistent with DEQ/ODF Sufficiency Analysis February 28, 2001. The RMA boundaries and
no cut zones along perennial streams under Alternatives 2 and 3 are similar to prescriptions in place on
private lands that EPA, NMFS and USFWS have found are not sufficient to protect water quality and restore
salmonid fisheries. We recommend the proposed action in the FEIS maintain the network of key watersheds
as mapped under the No Action Alternative and continue to manage those areas consistent with direction
obtained from watershed analyses and source water protection plans.
Response: The comparison of BLM Alternatives 2 and 3 to the DEQ/ODF Sufficiency Analysis and
evaluation of Oregon Department of Forestry forest practices is not appropriate because the management
prescriptions are far different. The commenter suggests that the boundaries of the Riparian Management
Areas along perennial and intermittent streams under Alternatives 2 and 3 are similar to the Oregon
Department of Forestry forest practices. However, there are large differences. The DEQs source water
guidance defines sensitive zones along streams within an eight-hour travel time to the withdrawal point of a
public water supply, rather than whole watersheds (even if mapped for location purposes). Oftentimes, the
entire sensitive zone or source water protection area is downstream of BLM-administered lands, or within
perennial stream areas on BLM-administered lands, where the widths of Riparian Management Areas under
the alternatives vary from 100 feet to approximately 440 feet.
Source water watershed locations have little correlation with key watersheds developed under the Northwest
Forest Plan. Source water watersheds should be managed consistent with source water protection plans
when they are developed. The FEIS concludes that streams contributing to source water sensitive zones from
BLM-administered lands are adequately protected by BLM actions based on:
• a pattern of lands that are distant relative to many public water supply intakes
• Riparian Management Area designs that retain the functionality of stream systems and are
expected to maintain water quality
• Best Management Practices that would be applied during projects where the objective of
maintaining water quality is not expected to be attained
246. Comment: The EIS should be revised to ensure that the cumulative impacts of existing conditions and
proposed actions on peak flows are analyzed and disclosed from soil compaction caused by grazing.
Response: Livestock grazing is currently allocated on approximately 560,000 acres in the Medford District
and Klamath Falls Resource Area. However, under the PRMP Alternative in the FEIS, grazing authorizations
would decrease to approximately 419,000 acres, which is a net reduction of 25% of the current grazing lands.
The decrease represents allotments that are vacant and not currently grazed. Livestock distribute unevenly
on the range resource, often being controlled by topography and the availability of water. For example, cattle
and horses both generally prefer grazing on slopes less than 20%, unlike deer (Ganskopp and Vavra 1987).
During the growing season, there is a propensity for increased grazing in riparian areas because of the low
slopes, increased forage, and close availability of water.
Riparian areas in rangeland systems often comprise less than 5% of the watershed area. Within an allotment,
compacted areas could occur from livestock hoof action. There is an array of variables including the type of
livestock, season of use, and grazing system. Also, livestock may congregate on susceptible soils that lack
adequate ground cover during wet conditions. The effects of livestock that may compact the ground surface
are correlated with vegetation and soil properties. Different vegetation types show variation in responses
Appendices - 844
Appendix T - Responses to Public Comments and Comment Letters
to hoof action, which could affect the impacts of livestock on riparian areas (Kauffman et al.
proportion of sand, silt, and clay in soils determines their water-holding capacity and surface firmness
during wet conditions.
Although there is an intuitive causal mechanism, the BLM is unaware of any specific range studies
demonstrating livestock compaction and an effect on peak flows. This lack of specific studies may be due
to livestock habits and livestock management in a watershed, where total compacted area is too limited to
measure an effect.
Grazing evaluations done to determine specific effects are best performed at the project level. The BLM will
manage livestock grazing in accordance with the Standards for Rangeland Health and Guidelines for Livestock
Grazing Management for Public Lands Administered by the Bureau of Land Management in the States of
Oregon and Washington. General guidelines include providing adequate vegetation and plant residue cover
to promote infiltration, promoting surface soil conditions that support infiltration, and avoiding sub-surface
soil compaction that retards movement of water in the soils. The FEIS closures of 25% of the analysis area
rangelands, along with management and planned improvements of livestock fences and off-stream water
development would have a beneficial effect on further reducing livestock compaction (see Chapter 4,
Grazing section).
1983). The
247. Comment: The EIS should be revised because the action alternatives would violate the Clean Water
Act, as water quality management plans for 303(d) listed streams on BLM land would no longer be valid
because the criteria and standards from the ACS would no longer apply to BLM lands with the WOPR
action alternatives.
Response: The Aquatic Conservation Strategy (ACS) as defined under the Northwest Forest Plan does not
confer any water quality standard. The BLM finds that ACS objectives are goal statements or concepts that
cannot be reasonably measured under forest plan spatial and temporal scales. Where possible, important
elements of the ACS objectives have been retained within the design of the alternatives and within Riparian
Management Areas in the action alternatives. The environmental conclusions for the PRMP Alternative and
other alternatives (including the No Action Alternative with ACS) in the FEIS, are that the alternatives meet
water quality standards and nonpoint source TMDL waste-load allocations and, therefore, would not violate
the Clean Water Act.
Currently, it is BLM’s understanding that approved TMDLs by the Department of Environmental Quality
and the Environmental Protection Agency, and appurtenant Water Quality Restoration Plans (WQRP), do
not have provisions for updating when agency land management plans change. However, the BLM’s portion
of the nonpoint source TMDL waste-load allocations do not change, nor does the BLM commitment to
maintain water quality. As a designated management agency, the BLM is working with the Department
of Environmental quality to update WQRPs to reflect how BLM will meet the nonpoint source TMDL
allocation.
248. Comment: The EIS conclusion (DEIS, page 723) that alternatives other than 2 and 3 would not result
in increases in stream temperature that would affect fish habitat or populations is flawed because it conflicts
with watershed analysis of Sucker Creek drainage in Josephine County that stream temperatures would
increase due to Port-Orford-cedar mortality. Stream temperature analysis in the DEIS (page 756) is flawed
because it does not take into account mortality of Port Orford cedar.
Response: Chapter 4 (Fish and Water sections) have been clarified in the FEIS to show that the BLM
conclusions regarding effective shade levels and effect on stream temperature do not include riparian areas
along waterbodies with infected or infested Port-Orford-cedar (POC) torest stands. Tire mortality of Port-
Orford-cedar within riparian areas has been previously analyzed under the FSEIS for Management oj Port-
Appendices - 845
FEISfor the Revision of the Western Oregon RMPs
Orford-Cedar in Southern Oregon (2004). The Port-Orford-cedar infestations are limited to no more than
40 feet downslope from roads, except where streams or wet areas are present to facilitate further movement
(Goheen et al. 1986). Further, Port-Orford-cedar infestations occur lineally, close to the stream channel. In
a downstream direction, high risk vectors for Port-Orford-Cedar spread include water flowing in stream
channels and connected off channel areas and floodplains. Predicted stream temperature increases from
Port-Orford-cedar mortality were modeled within the Port-Orford-cedar FSEIS (Appendix 9). Results show
that for small and large watersheds, temperature increases of no more than 0.5 to 1.2 °C per mile would
occur where the first 15 feet of the stream-side stand is killed.
249. Comment: The DEIS analysis of OFiV activity is flawed because it fails to adequately address point
and non-point source discharge resulting from OHV use and the effects of OHV use on water quality,
particularly drinking water.
Response: The FEIS recreation management actions for off-highway vehicle area designations (refer to
Chapter 2, Alternatives section) indicate no acres in the “open” use designation, an increase from 2,156,712
acres to 2,373,908 acres in the limited designation, and an increase in the “closed” designation from
84,589 acres to 98,795 acres when comparing all alternatives against the No Action Alternative. For the
action alternatives, Chapter 4 (Water section) has been corrected to show that these off-highway vehicle
designations would have a positive impact on water quality compared to the No Action Alternative. This
is because there is no open acreage where OFiV traffic is allowed to have indiscriminate pathways across
the land nor unrestricted access and crossing of streams. Within the largest designation of “limited,” off-
highway vehicles are restricted to existing roads and trails, and this acreage has been increased. The Best
Management Practices for soil and water protection ( Appendix I-Water) include more than 15 measures for
off-highway vehicles. These conservation practices are expected to maintain water quality and are applied at
the site level, where needed, regardless of whether the area is within a source water watershed or within the
Timber Management Area.
250. Comment: The EIS should be revised to include an operational definition of Channel Migration Zone.
Response: Channel migration zone has been added to the glossary. It is the extent of lateral movement of a
river across a floodplain toward the convex side of an original curve.
251. Comment: The EIS should explain how the BMPs outlined in the EIS are different from existing BMPs
in order to allow a comparison of effectiveness in preventing resource damage.
Response: The BLM chose a Best Management Practice (BMP) framework in the FEIS that displays, side
by side, a BMP by forest activity category, causative mechanism, and applicable water quality standards (see
Appendix I-Water). This logic path shows potential pathways for nonpoint source pollution to affect water
quality, the reference water quality standard, and the Best Management Practices that are expected to control
such impairment. In contrast, past plans show objectives for categories of forest practices and corresponding
Best Management Practices expected to minimize water quality degradation. However, in the past plans,
primary causative mechanisms are not identified nor are the expected attainment level to maintain water
quality.
The Best Management Practices in the FEIS, including those from past plans, were selected by resource
professionals and determined to be effective through field trials or monitoring. A soil and water
interdisciplinary team (IDT) compiled the Best Management Practices for the FEIS by reviewing BMPs
in each district’s current (1995) resource management plans. Those Best Management Practices that, in
practice, are highly effective were included in the FEIS. The BMPs that showed marginal benefit through
Appendices - 846
Appendix T - Responses to Public Comments and Comment Letters
implementation or effectiveness monitoring, or professional experience, were not included
FEIS. Furthermore, some Best Management Practices have been modified or deleted altogether due to
improvements in forest technology, equipment, and methods or erosion control materials.
Each interdisciplinary team member worked individually on a specific category of forest practices and
corresponding Best Management Practices; therefore, the merged lists cannot be easily disentangled to show
additions or deletions from past plans. Fiowever, Best Management Practices were only included in the FEIS
when there was consensus among the interdisciplinary team members following review. In some cases,
these Best Management Practices were further modified where internal cooperators or public comments
indicated revising them for clarity, or to address situations where Best Management Practices may have been
overlooked.
Fire and Fuels
252. Comment: The EIS should disclose the degree of confidence in their estimates of how many trees
might die post-fire, and the risk and consequences of false positive findings of tree mortality.
Response: Analysis of the effects of such disturbances prior to their occurrence and the possible associated
salvage would require making so many speculative assumptions regarding specific circumstances that the
conclusions of the analysis could not be used to make reasonably informed decisions regarding management
action. Such detailed analysis is only possible after fire occurrence when specific circumstances can be
analyzed. Determination of post-fire mortality is done after analysis of site-specific information such as fire
severity, scorch height, species, and diameter of trees that were burned.
253. Comment: Table 213 of the DEIS should be revised to include another important principle of fire
resiliency which is that an ample canopy cover helps provide cool, moist and less windy conditions and
helps suppress the growth of ladder fuels.
Response: The EIS acknowledges the role of canopy cover in fire resiliency. Table 213 in the DEIS relates
structural stages to various principles of fire resiliency. The amount of canopy cover cannot be derived
from BLM data bases or structural stage information. The EIS acknowledges that a complete and detailed
assessment of fire hazard and fire resiliency is dependent on site-specific stand conditions including canopy
density, which cannot be modeled at the scale of analysis necessary for the Western Oregon Plan Revision.
254. Comment: The EIS should be revised to include wildfire modeling within the alternatives analysis.
Response: A detailed modeling of wildfire is dependent on many variables (e.g., location and weather
conditions); therefore, such analysis would be so speculative as to have little utility. In addition, detailed
modeling of wildfire behavior requires site-specific information that is unavailable at the scale of analysis
of the Western Oregon Plan Revision. The analysis in the EIS is based on fire behavior models. Specific fire
behavior models have been assigned to the various structure classes to provide examples of the surface fire
behavior that can be expected from each structure class. This process facilitates the analysis of long-term
effects on surface behavior between various alternatives as structure classes change over time.
The level of detail in the data is not sufficient to allow modeling with change over time by a more
sophisticated model such as Flammap. The Flammap model, which would be necessary to model crown fire
behavior, requires site-specific information. This type of fire behavior modeling is more appropriate at the
landscape or project level. The analysis in the DEIS revealed the need to develop a silviculture prescription
in the high fire frequency areas of Medford and Klamath Falls to address fire hazard and fire resiliency. The
Appendices - 847
FEISfor the Revision of the Western Oregon RMPs
application, in the PRMP Alternative in the FEIS, of an uneven-age management prescription and area to
which the prescription would be applied is a result of the information gained through analysis completed in
the DEIS.
255. Comment: The EIS should analyze the impacts that increased fire risk would have on habitats
and resources of concern. The EIS should take into consideration the following when determining the
distribution of fuel treatments: the topographic diversity of the WOPR planning area and its unique weather
patterns during fire season.
Response: The EIS analyzed fire severity, hazard and resiliency and also ranked the alternatives in terms
of these factors. The analysis in the EIS included consideration of diversity within the planning area and
unique weather patterns. Accordingly, the analysis was separated into different geographic areas to more
effectively address topographic and weather conditions. In Chapter 3 of the EIS, the burning index (degree
of fire behavior) is discussed as a function of weather patterns. The EIS analysis addresses the importance
of height to live crown and canopy base height. In addition, the significance of tree diameter and basal area
were considered. Management direction was incorporated into the PRMP Alternative in the FEIS to address
the dry forests of Medford and Klamath Falls in acknowledgement of fire risk to habitat and resources of
concern.
256. Comment: The EIS should be revised to consider the effects altered fire regimes and increases in
disturbance by fire will have on forest species. The EIS currently discloses the changes to fire regimes under
the action alternatives but does not analyze impacts to biodiversity, listed species, big game, or other species.
Response: The Draff EIS analyzed the effects on listed species, big game, and other species that would result
from the same changes in vegetation conditions that would result in changes in fire severity and fire hazard
ratings. This analysis was included in the wildlife, botany, and fish sections. However, the Draft EIS did not
specifically analyze the effects of future wildfires on species. The Draff EIS identified that there is inadequate
information to predict the location, timing, severity, and extent of future wildfire. Additional discussion has
been added to the Final EIS to provide more description of the general effects of wildfire.
Recreation, Wilderness, Wilderness Characteristics, Off
Highway Vehicles
257. Comment: The EIS should be revised to explain the apparent contradiction concerning OFIV
designated areas. The planning document states that all alternatives would reduce the amount of OHV areas,
but the EIS itself states that all alternatives would increase opportunities for OHV use.
Response: The action alternatives reduce the amount of acres of areas where motorized vehicles are
permitted to travel cross country off existing trails (open areas). Due to the terrain and dense vegetation
that characterizes much of the planning area, most OHV use occurs on existing trail surfaces. The change
in designation from “open” to “limited” would not by itself result in a reduction of off-highway vehicle
opportunity, since during the interim period before route designation, all existing routes would continue
to be available for use. The determination of which of these existing trails would remain open for OHV
recreation will be determined at a later date through the Comprehensive Travel Management Plans that will
be completed after the plan revision is finalized.
Compared to the No Action Alternative, the action alternatives in the FEIS (including the PRMP
Alternative) increase the number of areas in the planning area where off-highway vehicle recreation would
be emphasized and receive focused management. The No Action Alternative has 3 OHV emphasis areas,
Appendices - 848
Appendix T - Responses to Public Comments and Comment Letters
and there are between 4 and 17 under the action alternatives. The perceived contradiction may be explained
by the fact that OHV Emphasis Areas and Special Recreation Management Areas that focus on off-highway
vehicle recreation improve OHV opportunity by enhancing the quality of the recreation experience through
trail maintenance and other management activities, while at the same time reducing the areas open to
unregulated OHV use.
258. Comment: The EIS should be revised to examine additional areas for wilderness characteristics.
On the Medford District, the Wellington Mountain/Long Gulch, Dakubetede, Wild Rogue (including the
Whiskey Creek area) and the Enchanted Forest roadless areas are all over 5,000 acres in size and should be
protected as Wilderness Study Areas (WSA) like the Soda Mountain WSA. Failure to consider these areas
as WSAs using updated inventories violates FLPMA. The BLM must assess the wilderness qualities in the
WOPR and include the information in the EIS, regardless of whether the BLM believes that the areas are
exempt from wilderness review due to the presence of O&C lands. See Portland Audubon Society v. Lujan,
998 F.2d 705, 709 (9th Cir. 1993) (NEPA was “passed after the O&C Act” and it applies “to all governmental
actions having significant environmental impact, even though the actions may be authorized by other
legislation”); Portland Audubon Society v. Lujan, 795 F.Supp. 1489, 1507 (D. Or. 1992) (“There is not an
irreconcilable conflict in the attempt of the BLM to comply with both NEPA and the O&C Act”).
Response: The Department of the Interior, Bureau of Land Management completed the wilderness review
of public land in Oregon as required by the Federal Land Policy and Management Act (FLPMA) on
October 7, 1991. The Oregon and California Railroad Company lands (O&C lands) were exempted from
the wilderness review by the provision in Section 701 (b) of FLPMA that directs that the management of
timber resources shall prevail on lands administered under the O&C Act when a conflict or inconsistency
arises between the two Acts. The designation of wilderness study areas (WSAs) through the wilderness
inventory and study process, and the subsequent management under the non-impairment standard required
by FLPMA, was determined to be inconsistent with the management of these areas for timber resources.
The BLM’s authority to designate additional lands as Wilderness Study Areas expired on October 21, 1993 as
affirmed in the agreement that BLM settled in Utah v. Norton.
The BLM may accord management protection for special values, including wilderness characteristics,
through the land use planning process by the designation of Areas of Critical Environmental Concern
and Special Recreation Management Areas, to the extent such designations are consistent with laws,
regulations, and the resource management plan. The areas cited in the comment were evaluated by the
Medford District to determine if they contained wilderness characteristics. Dakubetebe and Whiskey Creek
were found to contain wilderness characteristics that included naturalness and were selected for ACEC
designation in the PRMP Alternative in the FEIS. Wellington Mountain/Long Gulch was found to have
outstanding opportunities for primitive and unconfined recreation, but did not warrant designation as a
Special Recreation Management Area. The Enchanted Forest unit was not found to possess any wilderness
characteristics.
259. Comment: The EIS should be revised to address all eligible and suitable Wild and Scenic Rivers,
including considering potential additions and how the rivers would be protected.
Response: The eligibility determinations and suitability studies for all potential Wild and Scenic Rivers
in the planning area were completed as part of each BLMs 1995 district resource management plans. New
eligibility determinations and suitability studies would only occur if the BLM were to acquire additional
acreage along potentially eligible rivers that warrant further study.
260. Comment: The EIS should be revised to include the Wild Rogue Additions for wilderness
recommendation because the BLM itself noted the value of the large roadless areas for aesthetics, solitude,
Appendices - 849
FEISfor the Revision of the Western Oregon RMPs
undeveloped recreational opportunities, wildlife, fisheries, water quality, and the intrinsic value of having
wild, undeveloped places (see Version 2.0 of this analysis, issued in December 1999 and available online:
http://www.blm.gov/or/districts/medford/plans/files/wild_rogue_north_wa_acc.pdf).
Response: The BLM completed the wilderness review of public land in Oregon as required by the Federal
Land Policy and Management Act (FLPMA) on October 7, 1991. Much of the Oregon and California
Railroad Company lands (O&C Lands) within the Wild Rogue Additions proposal were exempted from the
wilderness review by the provision in Section 701 (b) of FLPMA that directs that the management of timber
resources shall prevail on lands administered under the O&C Act when a conflict or inconsistency arises
between the two Acts. The designation of wilderness study areas (WSAs), and the subsequent management
of O&C lands under the non-impairment standard required by FLPMA, was determined to be inconsistent
with management of these areas for timber resources. Currently, it is not possible for the BLM to designate
additional lands as Wilderness Study Areas nor to recommend lands for designation as wilderness since the
BLM’s authority to designate WSAs expired on October 21, 1993, as affirmed in the agreement that BLM
settled in Utah v. Norton.
The BLM may accord management protection for special values, including wilderness characteristics,
through the land use planning process by the designation of Areas of Critical Environmental Concern
and Special Recreation Management Areas, to the extent such designations are consistent with laws,
regulations, and the resource management plan. The areas cited in the comment were evaluated by the
Medford District to determine if they contained wilderness characteristics. Dakubetebe and Whiskey Creek
were found to contain wilderness characteristics that included naturalness and were selected for ACEC
designation in the PRMP Alternative in the FEIS. Wellington Mountain/Long Gulch was found to have
outstanding opportunities for primitive and unconfined recreation, but did not warrant designation as a
Special Recreation Management Area. The Enchanted Forest unit was not found to possess any wilderness
characteristics.
261. Comment: The EIS should consider and disclose the effects of the action alternatives on State Scenic
Rivers, including the area of O&C lands within state scenic river corridors and the effects of the proposed
action on these rivers, and whether or not BLM would need a permit to comply with requirements related to
these rivers.
Response: The EIS analyzed the effects of the action alternatives on all river segment corridors that are
designated, suitable, or eligible for inclusion in the National Wild and Scenic Rivers System on the lands
administered by the Bureau of Land Management within the planning area. The analysis examined the
effects of the alternatives on 78 river corridors that were a 0.25-mile wide on each side of each river segment.
These river corridors overlap with the eight State Scenic Waterways that have been designated within the
planning area.
262. Comment: The EIS should be revised to address the enforcement and management challenges, such
as the need to increase police funds and staff, which are likely to arise due to the planned increase in OHV
emphasis areas with the implementation of any of the action alternatives.
Response: Operations and maintenance issues are implementation level concerns that are addressed
by recreation area plans rather than at the resource management plan level. The EIS includes an overall
estimate of the BLM staffing and budgets that would occur under the alternatives.
Appendices - 850
Appendix T - Responses to Public Comments and Comment Letters
263. Comment: The DEIS analysis of the Anderson Butte OHV Emphasis Area is flawed because it does
not consider effects on the complex mosaic of ecosystems on the south slopes of Anderson Butte and
because it ignores the fact that 1 1,094 acres of designated Deer Habitat Management Area, also known as
critical deer winter range are within the 11,742-acre Anderson Butte OHV Emphasis area.
Response: The Anderson Butte area has been designated for only limited motorized vehicle use on
designated routes and trails in order to limit environmental impacts from OHV use. The routes and trails
that will be open to motorized vehicle use will be determined through development of a Comprehensive
Travel Management Plan and associated environmental analysis, as appropriate, which will be completed
after the Western Oregon Plan Revision Record of Decision.
The designation of these routes and trails will be consistent with the criteria outlined under BLM s
regulatory requirements in 43 CFR 8342.1. These designation criteria require that trails be located so as to:
(a) Minimize damage to soil, watershed, vegetation, air or other resources of the public lands.
(b) Minimize harassment of wildlife or significant disruption of wildlife habitats. Special attention will
be given to protect endangered or threatened species and their habitats.
(c) Minimize conflicts between off-road vehicle use and other existing or proposed recreational uses
of the same or neighboring public lands, and to ensure the compatibility of such uses with existing
conditions in populated areas, taking into account noise and other factors.
264. Comment: The EIS should be revised to explain why it predicts a 27 percent increase in non-
motorized recreation and a 5 percent increase in motorized recreation, but does not focus on how the action
alternatives would foster providing quality areas for non-motorized recreation.
Response: Most of the potential recreation trails and potential recreation sites in the 1995 resource
management plans would be carried forward under the action alternatives, and 26 new potential recreation
sites and 29 new potential recreation trails would be identified. Most of these sites and trails would provide
benefits to support non-motorized recreation in recognition of the growing demand for these opportunities
throughout the planning area.
265. Comment: Appendix K of the EIS should be revised to clarify the criteria used to define wilderness
characteristics. Appendix K currently specifies that the wilderness characteristics must be in a roadless area
of 5,000 acres, or a smaller roadless area of sufficient size to make its preservation practical, or adjacent to
a U.S. Forest Service roadless area such that the combined acreage is a minimum of 5,000 acres (K-1257).
Appendix K goes on to assert that the “size of the roadless area is a critical factor in the determination of the
presence or absence of individual wilderness characteristics, since such characteristics are dependent on the
sufficient size of the roadless areas (K-1258).” This latter statement is entirely circular and inconsistent with
BLM’s current guidance.
Response: The BLMs current policy outlined in Instruction Memorandum No. 2003-275, Consideration of
Wilderness Characteristics in Land Use Plans, makes no mention of minimum size criteria as a precursor
to determining if an area possesses the wilderness characteristics of naturalness; outstanding opportunities
for primitive and unconfined recreation; and outstanding opportunities for solitude. For the purposes of
establishing objective scale, roadless areas of at least 5,000 acres are generally considered large enough
to support the wilderness characteristics of naturalness, outstanding opportunities for primitive and
unconfined recreation, and solitude. However, there are four exceptions in which smaller areas can be
considered to meet the minimum size criteria:
(1) Roadless areas that represent an unusual situation when they are less than 5,000 acres, but because
of their topography, vegetative screening, or other features are considered large enough to provide
for preservation and use in an unimpaired condition.
Appendices - 851
FEISfor the Revision of the Western Oregon RMPs
( 2 ) Roadless islands of any size.
(3) Roadless areas that are contiguous with a Wilderness Area managed by BLM or another agency.
(4) Roadless areas that overlap the boundary of another agency when the BLM portion is less than
5,000 acres, and the other agency has authority to manage components of the National Wilderness
Preservation System (Forest Service, National Park Service, U.S. Fish and Wildlife Service).
The Wilderness Appendix has been revised to clarify this distinction in the evaluation criteria.
Soil
266. Comment: The EIS should include an analysis that quantifies the magnitude of road-related sediment
sources. The EIS should identify sites for road upgrades and/or restoration treatment in order to mitigate
these effects. These predictable and definable sediment sources are found all along the 14,000 miles of
existing forest roads in the Plan area and the EIS fails to address these ongoing threats.
Response: The analysis identifies the potential delivery of fine sediment by existing and proposed roads,
and the magnitude of the effects are described in terms of tons/square mile/year. These estimates are based
on the road surface type for each fifth-field watershed and summed for the planning area.
The identification of specific road upgrades and restoration treatment of 14,000 miles of roads within the
planning unit is not practicable in the large scale analysis of the Western Oregon Plan Revision effort.
Specific road upgrades or restoration treatments will be addressed through the site-specific analysis and
planning associated with implementing the approved RMP
267. Comment: The EIS should be revised to identify the cumulative impacts of all sources of sediment and
not adopt the reasoning that one sediment source will mask other sources.
Response: The risks of sedimentation are described in the EIS. The EIS does not assert that one source of
sediment will “mask” the effects of another. However, based on a review of the literature, the EIS states that
it appears road runoff and landslides in the planning area are the primary sources of sediment in terms of
the volume of material moved. The EIS has estimated the potential delivery of fine sediment by road runoff
in terms of tons/square mile/year for the planning area in the Water section of Chapter 4. This estimate is
based on a reasonable assumption of the soils and geology the roads will be built on. The analysis in the
EIS estimated the impacts of sedimentation from all sources that would occur in the event no revision of
the plans are made. Hie analysis then compared that to the sedimentation that would occur for each of the
action alternatives under detailed consideration. The difference in sedimentation impacts between the No
Action Alternative and each of the action alternatives is the incremental effect (i.e., the cumulative effect of
each of those alternatives).
Grazing
268. Comment: Grazing reduces the density and vigor of grasses that usually outcompete tree seedlings,
leading to dense stands of fire-prone small trees. Cows also decrease the abundance of fine fuels that are
necessary to carry periodic, low intensity fires. This reduces the frequency of fires, but increases their
severity (Belsky and Blumenthal 1997, Wuethner 2003). The EIS should be revised to further analyze these
livestock grazing effects on forest health, as well as outline possible mitigation measures to avoid these
negative effects.
Response: All alternatives provide for the control of tree density through thinning to prevent the
development of over-dense forest stands and to reduce fire hazard.
Appendices - 852
Appendix T - Responses to Public Comments and Comment Letters
The commenter cites references that suggest grazing reduces the density and vigor of grasses leading to
dense stands of fire-prone small trees. The conclusions in those studies are not applicable, because they
are based on circumstances that do not currently exist on BLM-administered lands in the planning area
and practices that would not occur under any of the alternatives. In addition, recent studies (Hosten
2007) in southwest Oregon suggest that native perennial grasses have increased in response to improved
management of livestock and, therefore, livestock grazing is not playing a major role in altering forests
(grazing on BLM-administered lands only occurs in southwest Oregon).
Areas of Critical Environmental Concern
269. Comment: The EIS should be revised to provide justification and analysis for removal of the existing
Baker Cypress Area of Critical Environmental Concern (ACEC). The Baker Cypress meets the importance
and relevance criteria for an ACEC, yet its being removed under all action alternatives.
Response: The BLM would manage ACECs where their management would not conflict with sustained
yield forest management in areas allocated to timber production on O&C lands. The Baker Cypress ACEC
continues to meet the relevance and importance criteria; however, it occurs within the Timber Management
Area land use allocation under all action alternatives, and the special management attention required to
maintain the relevant and important values conflicts with the purpose and need described in Chapter 1 of
the EIS for managing the O&C timberlands.
270. Comment: The EIS should be revised to provide justification and analysis for removal of the existing
Sterling Mine Ditch ACEC. This area includes an important trail, historic mining trail and special status
plants, yet no justification is provided from removing the ACEC.
Response: The Sterling Mine Ditch was incorrectly included on Table 285 in the DEIS appendices. The
Sterling Mine Ditch is protected under the National Historic Preservation Act as eligible for listing and,
therefore, does not require special management attention through designation as an ACEC.
271. Comment: The EIS should be revised to clarify how the Crabtree Valley ACEC will be managed
under Alternative 2. The Alternative 2 map shows the entire ACEC/Research Natural Area (RNA) as
administratively withdrawn, but Appendix M in the DEIS says the ACEC without O&C lands will be
managed as an ACEC. This means everything outside of section 16 (which is public domain), would be part
of the timber base and not specially managed to maintain or enhance R&I values. In addition, the DEIS
(page 807) states that all RNAs would be retained.
Response: The Crabtree Complex Research Natural Area (RNA)/Outstanding Natural Area (ONA)
encompasses two existing RNAs (Shafer Creek and Carolyns Crown) and the existing Crabtree Lake ONA.
Appendix M includes these three areas under the Crabtree Complex RNA/ONA. The two RNAs would
continue to be retained under all alternatives in their entirety. The Crabtree Lake ONA includes Timber
Management Areas that are on O&C lands under Alternatives 2 and 3; only the areas outside of the Timber
Management Area within the O&C lands area would be designated under these alternatives.
272. Comment: The EIS should be revised to include the Jimbo Mountain and Marten Creek ACEC under
Alternative 2 because the area has been found to meet ACEC eligibility criteria, and it requires special
management attention to protect its important and relevant values. Ibis status is needed to protect the area’s
late-seral and old-growth habitat from inappropriate logging practices (allowed in the AMA designation
under the NWFP] that would degrade or destroy these special values.
Appendices - 853
FEISfor the Revision of the Western Oregon RMPs
Response: Jimbo Mountain and Marten Creek are included within the boundaries of the proposed Lower
Elevation Headwaters of the McKenzie River ACEC. Jimbo Mountain and Marten Creek were not analyzed
as a separate ACEC. The Lower Elevation Headwaters of the McKenzie River occur within the Timber
Management Area on O&C lands under all action alternatives, and the special management attention
required to maintain the relevant and important values conflicts with O&C timber management.
273. Comment: The EIS should be revised to provide justification why proposed ACECs did not meet the
relevance and importance criteria and subsequently were not included in the EIS.
Response: The proposed ACECs in each BLM district were reviewed by district staff against the eligibility
criteria. The reason that proposed ACECs were not given ACEC status under the action alternatives is
because they did not met criteria for importance and relevance; did not need special management attention;
or conflicted with sustained yield timber management on O&C lands. The documentation of the reviews by
district staff is part of the administrative record.
274. Comment: The EIS should be revised to include an analysis of the impacts associated with removing
ACEC designations in the Eugene District (specifically Coburg Hills and Dorena Lake Relic Forest Islands,
Cougar Mountain Yew Grove, and Cottage Grove Old-Growth Environmental Education Area) under
Alternative 2, because removing designations is contrary to the 1995 ROD. The ROD states, “Preserve,
protect or restore native species composition and ecological processes of biological communities in ACEC.
ACEC, especially RNA, will be available for short or long term scientific study, research and education and
will serve as a baseline against which human impacts on natural systems can be measured.”
Response: The 1995 record of decision is being revised in this decision, and subsequent revisions of plans
are not required to comply with the plan they are revising. Such a rule would prevent any plan from ever
being changed once adopted.
The BLM would manage ACECs on O&C lands where management of the ACEC would not conflict with
sustained yield forest management in areas dedicated to timber production. All RNAs, regardless ofland
status, are retained in all action alternatives since their scientific value is relevant to sustained yield forest
management. Several Areas of Critical Environmental Concern that are on O&C lands (including Coburg
Hills and Dorena Lake Relic Forest Islands, and Cougar Mountain Yew Grove) and that are not also
Research Natural Areas occur within the Timber Management Area under one or more action alternatives.
Special management attention required to maintain the relevant and important values of these areas
conflicts with the purpose and need described in Chapter 1 of the EIS for managing the O&C timberlands.
The Cottage Grove Old Growth Environmental Education Area (EEA) was incorrectly included on the
ACEC table in Appendix M of the DEIS. This area will continue to be managed as an EEA and is included in
the Recreation section in the Final EIS.
275. Comment: The proposed Waldo-Takilma ACEC boundary should be revised to include sections 26 &
36 (T40S, R05E) on the slopes of Hope Mountain; in Section 3 (T4IS, R05E) on the saddle between Scotch
and Cedar Gulches; and in Section 10 (T41 S: R05E) on the east side of Takilma Road across from Long
Gulch, because they do not appear to be included. These areas are as worthy as the recommended ones and
their inclusion will strengthen the ACEC in retaining its outstandingly remarkable ecological and historical
attributes.
Appendices - 854
Appendix T - Responses to Public Comments and Comment Letters
Response: The DEIS maps did not show the entire proposed Waldo-Takilma ACEC boundary. This has
been corrected in the Final EIS. It is likely that the commenter mistakenly listed the wrong range for these
areas since Range 5 East is in California. The disjunct parcels included in the proposed Waldo-Takilma
ACEC are located in Township 40 South, Range 8 East, Sections 26 and 35 (Section 36 is privately owned)
and Township 41 South, Range 8 East, Sections 3 and 10.
276. Comment: The EIS should designate the “Low Elevation Headwaters of the McKenzie River” ACEC
for recreational, scenic, and wildlife values.
Response: The proposed Lower Elevation Headwaters of the McKenzie River ACEC occurs within the
Timber Management Area on O&C lands under all action alternatives. The special management attention
required to maintain the relevant and important values conflicts with the purpose and need described in
Chapter 1 of the EIS for managing the 08cC timberlands.
Cultural
277. Comment: The EIS should be revised to state that any land transfers/disposals within the original
boundaries of the Siletz (Coast) Reservation should be initially offered to the Confederated Tribes of the
Siletz Indians, because it is the tribe’s position that the intent of the 1855 Executive Order was to create as
permanent the Siletz (Coast) Reservation.
In addition, the EIS should be revised to recognize the Confederated Tribes of the Siletz Indians in the
following ways:
1. Since several of the parcels identified for disposal are within one of the four areas in which the
Siletz Tribe has an interest in acquiring land, it is suggested that the language be revised to read,
“Suitability of the land for management by another Federal agency or Federally Recognized Indian
Tribe” instead of “Suitability of the land for management by another Federal agency.”
2. Add a criterion to this section that reads “Disposal assists a Federally Recognized Tribe in restoring
its land base pursuant to the Indian Reorganization Ac4 25 Use 465.”
3. Add a fifth criterion for disposal: “Disposal would be beneficial to the Federally Recognized Indian
Tribe with the strongest ancestral and legal successorship ties to the parcels in question.”
Response: The BLM will follow the land disposal process as set forth in 43 USC 1713 (Federal Land Policy
and Management Act of 1976), Title 2, Sec. 203 - 214. The Secretary does have authority, under 25 USC
§450j(f), to donate real property found to be in excess of the needs of the Federal government.
Appendices - 855
FEISfor the Revision of the Western Oregon RMPs
Appendices - 856
Appendix T - Responses to Public Comments and Comment Letters
Comment Letters From Congressional
Representatives, Indian Tribes, and Government
Agencies
On the following pages are the comment letters that the BLM received from congressional representatives;
federal, state and local governments; and Indian Tribes.
Appendices - 857
Appendices - 858
Appendix T - Responses to Public Comments and Comment Letters
CjA~
RON WYDEN
OREGON
V
$
/
230 D1RKSEN SENATE OFFICE BUILDING
WASHINGTON, DC 20510
(202) 224-5244
(202) 224-1280 (TDD)
United States Senate
WASHINGTON, DC 20510-3703
COMMITTEES:
COMMITTEE ON THE BUDGET
COMMITTEE ON ENERGY AND NATURAL RESOURCES
SUBCOMMITTEE ON PUBUC LANDS AND FORESTS
SPECIAL COMMITTEE ON AGING
SELECT COMMITTEE ON INTELUGENCE
COMMITTEE ON FINANCE
September 25, 2007
o
o
.,—4
\
Ed Shepard
State Director
Bureau of Land Management
333 S.W. 1st Avenue
Portland, Oregon 97204
RECEIVED
OCT 03
OCT 0 1 2007
S tate Director’s Gfff :e
C5
s
o
CT Cjj
-< ro
Dear Mr. Shepard:
I have heard from County Commissioners and other constituents from several Oregon
O&C counties regarding their concerns about the limited opportunity for meaningful
public review and comment for the Western Oregon Plan Revisions (WOPR). Due to
their concerns, and the breadth, complexity and importance of this proposal, I am writing
to support their requests for a 1 20 day extension of the review period.
The WOPR is a voluminous document with huge implications for Oregon and the Pacific
Northwest. Over 1 ,600 pages are included in the Draft Environmental Impact Statement,
including 310 tables, 348 figures and 35 maps. Not only is this a massive document that
is complex for the public to read, assess and analyze, the conclusions in the WOPR DEIS
rely on additional maps, models and related GIS files. The substantial amount of material
and data makes it challenging for both elected officials and the public-at-large to provide
a thoughtful review within the 90-day comment period. In addition, it has come to my
attention that several public outreach sessions were moved with limited notice, resulting
in interested parties being denied the opportunity to participate. This underscores the
need for additional time for further review and participation in the public process.
I know that a great deal of work has gone into the preparation of the WOPR and that the
Bureau of Land Management has invested significantly in preparation of the materials
and the accompanying public outreach. As merits such a significant and important effort,
I would urge that requests to extend the public comment period be granted.
Sincerely,
Ron Wyden
United States Senate
700 NE MULTNOMAH ST
SUITE 450
PORTLAND, OR 97232
(503) 326-7525
151 WEST 7TH AVE
SUITE 435
EUGENE, OR 97401
(541) 431-0229
SAC ANNEX BUILDING
105 HR ST
SUITE 201
LA GRANDE, OR 97850
(541) 962-7691
U.S. COURTHOUSE
310 WEST 6TH ST
ROOM 118
MEDFORD, OR 97501
(541)858-5122
HTTP://WYDEN. SENATE.GOV
PRINTED ON RECYCLED PAPER
THE JAMISON BUILDING
131 NW HAWTHORNE AVE
SUITE 107
BEND, OR 97701
(541) 330-9142
707 13THST, SE
SUITE 285
SALEM. OR 97301
(503)589-4555
Appendices - 859
FEISfor the Revision of the Western Oregon RMPs
/S73
COQUILLE INDIAN TRIBE
P.O. Box 783 • 3050 Tremont • North Bend, OR 97459
Telephone 541-756-0904 • FAX 541-756-0847
Received
JAN 1 1 2008
January 9, 2008
Ed Shepard, State Director GR/WA.
Bureau of Land Management
P.O. Box 2965
Portland, Oregon 97208
Re: Western Oregon Plan Revision FiS comments
Mr. Shepard,
The Coquiile Indian Tribe (die ‘Tribe”) appreciates the opportunity to participate in the
Western Oregon Plan Revision (WOPR) process. This is truly the most intensive
environmental analysis that has been undertaken by a federal agency in the Pacific
Northwest; we applaud the BLM’s efforts. We have reviewed the WOPR draft EIS and
provide the following comments:
BACKGROUND:
The Tribe manages 5,410 acres of forest land, the “Coquiile Forest”, within die WOPR
planning area. Congress transferred the Coquiile Forest to the Tribe to be held in trust by
the Assistant Secretary of die Interior (P.L. 101-42) (The “Coquiile Forest Act”). In the
Coquiile Forest Act, Congress requires the Secretary of the Interior to manage these
forest lands subject to the standards and guidelines of plans of nearby or adjacent federal
lands. The most “nearby” and adjacent Federal forest lands are Coos Bay District BLM
O&C lands subject to this WOPR process. Therefore, federal law places the BLM in a
position to establish the minimum standards and guidelines for management of the
Coquiile Forest Because the management of die Coquiile Forest has great bearing on the
Tribe’s Self-Sufficiency, the WOPR process, by definition involves a great degree of
control over the use and management of this trust asset and the welfare of Coquiile Tribal
members.
It is well-established that the Department of Interim' must act in die best interest of tribes
when developing or administering management plans that effect trust assets. This U.S.
Supreme Court has indisputably established this trust obligation, specifically in the
WOnt DEIS COMMITS- FTNAL_1W2©08
L61 1 10.1625
1
Coquiile Mian Tribe
Appendices - 860
Appendix T - Responses to Public Comments and Comment Letters
context of the management of Indian forest lands. United States v. Mitchell. 463 U.S.
206, 224 (1983) (commonly referred to as “Mitchell II”). This forestland trust obligation
extends to the WOPR process and its resulting management plan. Establishment of a
Tribal Cooperative Management Area (TCMA) as proposed by the Tribe is the means by
which BLM may satisfy this obligation in this context.
CHAPTER 1— PURPOSE AND NERD
PP. 3-7 — The purpose and need for the plan revisions should be revised to include a brief
discussion about the Department of the Interior’s trust obligation to Tribal forestlands as
well as a background on the unique management requirements for the Coquille Forest
Lands. The discussion described here is necessary to establish the “need” for analyzing
the TCMA management direction an federal lands in this DEIS. The discussion on the
top of page 20 could be re-worded slightly to include this necessary legal background.
CHAPTER 2— ALTERNATIVES
Although none of the alternatives completely meet all of the needs of the Tribe, the
Alternative 2, most closely fits the Tribal forest management goals, while providing the
economic benefits to the Counties, and protections for the environment.
In light of the Supreme Court’s decision in Natl. Ass’n of Homebuilders v. Defenders of
Wildlife. 127 S. Q. 2518, 168 L.Ed.2d 467 (June 25, 2007), we believe that BLM must
first establish and define the non-diseretionary duties mandated by foe O&C Act Only
after completion of that process should the document determme what discretion is
permissible under Federal environmental laws. This evaluation is imperative because
the O&C Act itself constitutes the very motivation for this WOPR planning process.
Die document must expressly state what foe requirements of foe O&C Act are, whether
the selected alternative^) comply with that Act, and why or why not the alternative
deviates from foe O&C Act requirements. We assert that, if the O&C Act is foe
dominant use act, the alternative must yield to it. If you determine that foe O&C Act is
not the dominate use act, foe document should include your analysis to reach this
conclusion, including citations to relevant legal sources.
PP. 84 — The TCMA area should be better defined. The number of acres is not arbitrary,
the proposed 15,000 acres represent those BLM lands that are both within 1/2 mile of
tribal lands and within shared watersheds.
WOPR DOS COMMHOS- FINALJ W2006 2 Coquile Mian Tribe
L61 110.1625
Appendices - 861
ItlS for the Revision^ of the Western. Oregon. RTVfPs
CHAPTER 3— AFFECTED ENVranNMirisnr
“5,7: ™sJmap « hard «o read; Ms should be a colored map that shows
the TCMA area (BLM lands), the Tribal lands, and shared watershed boundaries.
CHAPTER 4 — ENVIRONMENTAL CONSEOIIENCF.S
Spotted Owls and Marbled Murrelets
The use of suitable habitat to assess affects on Northern Spotted Owls (NSO) and
Marbled Murrelets (MAMU) is confusing to the reader. There are no clear definitions of
suitable habitat fra- these species in the document. The definition on page 868 is vague
and needs refinement. We suggest defining suitable habitat based on individual species
Although page 637 states: [effects to populations were not analyzed because population size
« affected by numerous factors other them habitat ", the way that the analysis is written makes die
reader assume that changes m habitat are synonymous with changes in population. This
statement needs clarification.
The differences between suitable habitat and critical habitat should be made clearer. In
addition, further clarification as to why suitable habitat was used to analyze effects to
NSO and MAMU as opposed to population is needed. Is there population data that can
be assessed? This document never addresses current occupancy by NSO and MAMU on
BLM lands.
Does the establishment of LSMA’s for maintaining MAMU and NSO habitat, conflict
with the O&C Act?
If LSMAs are created in areas where occupancy has not been determined, then the
establishment of these areas would be arbitrary and capricious. These areas would not
meet the O&C act, nor would these areas fall under the BLM’s mandate under Section 7
of the ESA..
“insure that any action authorized, funded, or carried out " by the agency “is not
likely to jeopardize the continued existence of any endangered species ...or
result m the destruction or adverse modification of habitat of such species. “16
U.S.C. § 1536(a)(2).
Without appropriate surveys to verify occupancy, there is not enough scientific evidence
to support the development of LSMAs. According to the 9* Circuit Court of Appeals
case Oregon Natural Resources v. Allen, No. 05-8350 (July 28, 2006), habitat cannot be
used as a surrogate for Jeopardy; there must be a numerical measurement for take.
WOPR DEIS COMMENTS- FINAL 1/9/2008
L6m®.1625
CoqoiBc Indian Tribe
Appendices - 862
Appendix T - Responses to Public Comments and Comment Letters
ADDITION AI. fi
IMI.TI
ENTS
In order to me^liieO&C act in LSMA areas theRlM^
intensive management strategy in these areas.' want t0 consider a more
^ ■*--^— ** rede.,
the effects of implementatioii of the Ptaf s Starfart Sm* ^ ■COnd“t moni,°ring of
monitoring identified in the Record of Guidelines. One dement of
Their Culture” (ROD Implementation E 9) Effort *** ? ” 1S American Mans and
take place at 10-year intervals. The results of the frih^655 m+0nJtonng mder Plan is to
10-year period were completed in 20Q3and mibliS!? "*2?*^ component for the first
First Ten Years (I994-2<Mm FfwT Published as: “Northwest Forest Plan - The
£-02-2006). This important tribal monitoring 00^^™^'“'’”
the momtonng strategy „f a* WOPR and snbL.uTnJ.^m mcoaporatcd tnto
^yprJi^^^^rprsr^LM * - w~»
Sincerely,
Edwm-d L. Metcalf, Tribal Council Chairman
Coqmlle Indian Tribe
CC: Dick Prather
Weston Oregon Plan Revisions
P.O. Box 2965, Portland, OR 97208
VraPR Dg COMMENTS- FIN AL_ 1/9/2008
CoqntBe Jndiaa Tribe
Appendices - 863
FEISfor the Revision of the Western Oregon RMPs
received
Confederated Tribes of Sile^lfilllllfis
P.O. Box 549 Siletz, Oregon 97380
(541) 444-2532 • 1-800-922-1399 • FAX: (541) 444-2307
f(k$0
December 14, 2007
Team Leader
Western Oregon Plan Revisions Office
P.O. Box 2965
Portland, OR 97208
Dear Team Leader:
On behalf of the Confederated Tribes of Siletz Indians, I offer the following
comments regarding the Bureau of Land Management’s Western Oregon Plan Revisions.
I am writing this letter in support of the Lands Actions as described in Appendix O, and I
am suggesting modifications in those actions that would support the Siletz Tribe’s efforts
at increasing its land base.
The Confederated Tribes of Siletz Indians is a federally recognized tribe,
headquartered in Siletz, Oregon. Our tribe has over 4,000 enrolled members. Most live
in the area covered by the Western Oregon Plan Revisions.
One goal of the Siletz Tribe is to consolidate and diversify its land base to support
sustainable economic growth. The Tribal economy is reliant on a sovereign land base, its
resource stewardship, and its economic commodities to provide a cornerstone for
sustainable economic growth and stability. The Tribal economy, in turn, supports tribal
services including health care, housing, and educational and employment opportunities.
As a self-governance tribe, the Siletz Tribe is steadily building its capacity to operate
such programs sufficient to serve the growing memberships’ needs. The Western Oregon
Plan Revisions offer your agency a unique opportunity to help the Siletz Tribe achieve
economic growth and meet the needs of tribal members by targeting land disposal actions
to benefit federally recognized Indian tribes.
There are four geographic scales for which we are interested in the proposed
Lands Actions. The first is our ancestral lands. In pre-contact times, the ancestors of the
Confederated Tribes of Siletz Indians belonged to over 25 diverse tribes from western
Oregon and Northern California. Because of the diversity of the bands that comprise our
ancestors, our ancestral land in Oregon stretches from the Oregon coast to the crest of the
Cascade Mountains, from the Columbia River to the California state line. Any land
disposal action within this area, including exchanges or sales, would be of inherent
interest to our tribe. Land exchanges or disposals to non-Tribal entities could have
Appendices - 864
Appendix T - Responses to Public Comments and Comment Letters
adverse affects on areas important to our culture. Additionally, we would be interested in
any land acquisition opportunities that may arise throughout the Western Oregon Plan
Revision affected area, so we may manage and protect resources important to our culture.
The second scale of interest to the Siletz Tribe is land within the original
boundaries of the Coast (Siletz) Reservation. Our Siletz Reservation was established by
an Executive Order, signed by President Franklin Pierce on November 9th, 1 855, and
originally contained over 1.1 million acres. The establishment of a permanent reservation
was called for by several treaties signed with our western Oregon Tribes as early as 1 853,
which had been ratified and proclaimed law by the President prior to the 1855 Executive
Order. In particular, the Rogue River Treaty of September 10, 1853, established a
"temporary reservation" in the Rogue Valley (Table Rock) "until a suitable selection shall
be made by the direction of the President of the United States for their permanent
residence, and buildings erected thereon, and provision made for their removal"
(emphasis added). The original Coast Reservation boundary included all the lands from
Cape Lookout to the divide between the Siuslaw and Smith Rivers, including all that
drained into Siltcoos Lake and Siltcoos River and eastward to the western boundary of
the 8th Range of Townships West of the Willamette Meridian. The map that
accompanied the Executive Order confirms this description. Under the language of the
Rogue River Treaty, the President only had power to create a permanent reservation in
discontinuing the temporary Table Rock Reservation and others like it in Western
Oregon. He did not have the discretion to make the Coast Reservation “temporary” under
the language of the treaty. In spite of this, our reservation was systematically dismantled
by having large chunks opened to settlement without our consent. Our position is that the
intent of the 1855 Executive Order was to create as permanent the Siletz (Coast)
Reservation. Therefore, any land transfers/disposals within the original boundaries of the
Siletz (Coast) Reservation should be initially offered to the Confederated Tribes of Siletz
Indians.
The third scale of interest to the Siletz Tribe is our 1 1 -county “service area.” The
Siletz Tribe was terminated by the Western Oregon Indians Termination Act of 1954, 25
U.S.C. § 691 et seq. In 1977, Congress restored the Siletz Tribe to federally recognized
status (25 U.S.C. § 71 1, et seq.), but a land base for the Tribe was not restored at the
same time. The Siletz Reservation Act of 1980 created a 3,600-acre permanent
reservation, but it consisted only of small scattered parcels around Siletz. Since
restoration, we have been able to add to our land base through the Bureau of Indian
Affairs’ “fee to trust” process, but our land base is still inadequate to meet the needs of
our members. Because many federal programs for which Indians and Indian tribes are
eligible require residence on or near an Indian reservation, Congress created a Siletz
"Service Area" that was deemed equivalent to an Indian reservation for purposes of
qualification for federal services and programs. The Siletz Service Area includes the
counties of Lincoln, Benton, Linn, Lane, Multnomah, Polk, Washington, Yamhill,
Marion, Clackamas, and Tillamook. Land acquisition opportunities in these 1 1 counties
where we could provide housing, economic opportunities, or services to tribal members
would directly benefit the Siletz Tribe. In fact, some years ago, BLM and CTSI were
working together with the Oregon Congressional delegation to transfer the public domain
land in Lincoln County to the Siletz Tribe. Unfortunately, there was not enough support
Appendices - 865
FEISfor the Revision of the Western Oregon RMPs
among Oregon’s Congressional delegation to make it happen. Regardless, we remain
interested in acquiring the public domain land in Lincoln County. We would like an
opportunity to revisit this issue in the near future.
The fourth and smallest scale of interest to the Siletz Tribe is our Tribal Land
Consolidation Area. The Indian Reorganization Act of 1934 (IRA), 25 U.S.C. § 465,
allows the Secretary of Interior, at his or her discretion, to take land into trust for the
benefit of an Indian tribe or of individual Indians. The Bureau of Indian Affairs adopted
regulations to implement the provisions of the IRA (see 25 CFR 151.3(a)(1)). These
regulations allow for acquisition of land into trust when the land lies within the exterior
boundaries of an established reservation, or when the land is within a tribal consolidation
area. In 1980, the Bureau of Indian Affairs Northwest Regional Director adopted a
consolidation area for the Siletz Tribe. Acquisition of land within the Consolidation Area
is important to the Siletz Tribe because these lands are centered around the community of
Siletz, which is the historic, cultural, and social center of the tribe. The consolidation
area consists of the following area:
Township 9 South, Range 1 1 West;
Township 9 South, Range 10 West;
Township 9 South, Range 9 West;
Township 10 South, Range 1 1 West;
Township 10 South, Range 10 West;
Township 10 South, Range 9 West; and
Portion of Township 10 South, Range 8 West,
Willamette Meridian, Lincoln County, Oregon.
I have three suggested modifications in Appendix O that would recognize our
tribe’s historic and cultural ties to the land. First, on page 0-1361, one of the “General
Land Tenure Adjustment Evaluation Factors” reads, “Suitability of the land for
management by another Federal agency.” You allocate many parcels of land for Land
Tenure Zone 3 (disposal). Several of those parcels are within one of the four
aforementioned areas in which the Siletz Tribe has an interest in acquiring land. I
suggest an amendment to that factor, so that it reads “Suitability of the land for
management by another Federal agency or Federally Recognized Indian Tribe.”
Second, I proposed that another criterion in this section should be “ Disposal assists a
Federally Recognized Tribe in restoring its land base pursuant to the Indian
Reorganization Act, 25 USC § 465. ”
Third, on page 0-1362, you list four criteria for disposal. I suggest adding a fifth
criterion: “ Disposal would be beneficial to the Federally Recognized Indian Tribe with
the strongest ancestral and legal successorship ties to the parcels in question .”
With this amended language, if the Siletz Tribe and the Bureau ever entered into a
planning process for transferring ownership to the Bureau of Indian Affairs or the Siletz
Tribe directly, the actions would clearly be in conformance with your land use plan,
which will be important when you consider specific proposals.
Appendices - 866
Appendices - 867
FEIS for the Revision of the Western Oregon RMPs
Rp fa OR/WA
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I !
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JAN 1 1 ?0O8
;:.i: Orix 0
Mr. Edward W. Shepard
Bureau of Land Management State Director
Oregon State Office
P.O. Box 2965
Portland, Oregon 97208
UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
NATIONAL MARINE FISHERIES SERVICE
Northwest Region
7600 Sand Point Way N.E., Bldg. 1
Seattle, WA 98115
January 1 1 , 2008
R E C E I V E D
JAN 1 4 2008
Re: Review of Draft Environmental Impact Statement for the Revision of the Resource
Management Plans of the Western Oregon Bureau of Land Management Districts
Dear MryShepard:
TheyNational Oceanic and Atmospheric Administration (NOAA) is pleased to provide comments
on the draft environmental impact statement (DEIS) for the Revision of the Resource
Management Plans of the Western Oregon Bureau of Land Management (BLM) Districts of
Salem, Eugene, Coos Bay, Roseburg, and Medford Districts, and the Klamath Falls Resource
Area of the Lakeview District, dated August, 2007. According to the DEIS, the BLM proposes
to revise the resource management plans for each of the districts, and provide guidance for future
management of approximately 2.6 million acres of public and tribal land in the coastal mountains
and on the west slope of the Cascade Mountains in Oregon.
In August, 2007, a team from the Northwest Region of NOAA’s National Marine Fisheries
Service (NMFS) met with a team of your staff to discuss potential issues with the DEIS analyses,
provide a list of preliminary comments, and request additional information on various aspects of
the analyses. The comments provided at the August meeting should be considered and
incorporated into the final environmental impact statement (FEIS), as appropriate.
In addition to those previously provided comments, NMFS has enclosed additional comments
that have arisen following a thorough review of the DEIS. The comments are based on a review
by my Habitat Conservation Division staff, as well as by staff of NMFS’ Northwest Fisheries
Science Center (NWFSC). The NMFS is providing these comments due to our responsibilities
to manage, conserve, and protect marine and coastal living resources as provided under the
Endangered Species Act (ESA), the Magnuson-Stevens Fishery Conservation and Management
Act (MSA), and the Fish and Wildlife Coordination Act. In all cases, the comments are relevant,
either directly or indirectly, to NMFS’ responsibilities under the aforementioned statutes, and are
consistent with the agency’s regulatory obligation to its trust resources.
Printed on Recycled Paper
Appendices - 868
Appendix T - Responses to Public Comments and Comment Letters
These comments do not satisfy the obligation of the BLM to consult under the ESA or MSA on
the selected alternative. The following species of Pacific salmon and steelhead that are listed or
proposed for listing under the ESA occur within the planning area for the proposed action:
Lower Columbia River and Upper Willamette River Chinook salmon; Southern Oregon/Northem
California Coast, Oregon Coast, and Lower Columbia River coho salmon; Columbia River chum
salmon; and Upper Willamette River and Lower Columbia River steelhead. All of the above
species are listed as threatened, except for Oregon Coast coho salmon, which are proposed for
listing as threatened. NMFS has also designated critical habitat for all of the above listed species
except Lower Columbia River coho salmon. Essential fish habitat also has been designated
under the MSA for Chinook salmon and coho salmon within the planning area.
The following is a summary of the major issues with the DEIS and with the preferred alternative
that NMFS found in its review of the DEIS:
1 . The DEIS does not contain a coherent and cohesive conservation strategy for anadromous
fish and their habitat in any of the action alternatives. A clearly defined, scientifically-
robust strategy is essential to conserving these resources.
2. The riparian management scenario proposed in the preferred alternative would not
adequately maintain and restore the riparian and aquatic habitat conditions and processes
that are critical to the conservation of anadromous fish.
3. The action alternatives do not include well-defined management objectives for fish
habitat or firm standards and guidelines, both of which are needed to ensure adequate
conservation of anadromous fish.
4. The action alternatives rely on reach-scale analysis and management, and thus do not
accommodate the watershed-scale analysis and conservation that are the underpinnings of
conservation biology for anadromous fish.
5. Several of the critically important analyses (i.e., fish productivity, large wood, shade,
peak flow) rely heavily on models that in some cases have not been fully documented,
and in other cases have not been adequately validated for the entire plan area. This
introduces considerable uncertainty into the analyses.
6. There are a number of assumptions or methods associated with the modeling exercises
listed in number 5 above that do not comport with the findings of published scientific
literature. These assumptions and methods cascade through the analyses, leading to some
conclusions that likely are erroneous.
A substantial amount of work must be completed to ensure that the FEIS adequately describes
the existing environment and adequately analyzes and discloses impacts to the environment that
would arise from the proposed action. We expect that many of these issues, which are discussed
in greater detail in the enclosure associated with this letter, will be important for the eventual
consultations under the ESA and the MSA on the selected alternative.
NMFS staff has begun to formulate a framework that would help to address some of the issues
that are listed above and described more fully in the enclosure. Although we are severely limited
in staff resources, we would welcome the opportunity to work closely with your staff to
incorporate this framework into the proposed action before release of the FEIS. The key
-2-
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FEISfor the Revision of the Western Oregon RMPs
elements of this comprehensive conservation strategy for anadromous fish, which are described
in detail at the beginning of the enclosure, are listed below:
1 . Identification and differential management of a network of aquatic-emphasis watersheds
for fish recovery, public water supply, and water quality.
2. Use of watershed-scale assessment and planning to guide land management actions.
3. Protection of current high-quality fish habitat, in addition to restoration of habitat with
high intrinsic geomorphic potential as is planned.
4. Adjusted riparian management areas (RMAs) with more conservative management in
aquatic-emphasis watersheds.
5. Increased specificity of objectives for conservation of anadromous fish habitat.
6. Standards and guidelines that are mandatory, but are selected based on type of
management action and site conditions.
7. Clearer pathways for plan implementation, monitoring, and adaptive management.
NMFS appreciates the opportunity to comment on this DEIS and looks forward to continuing to
provide BLM with assistance on development of the FEIS. Please direct questions regarding this
letter to Dr. Kim Kratz of my staff in the Habitat Conservation Division of NMFS Northwest
Region at 503.231.2155.
Sincerely,
;/D. Robert Lohn
Regional Administrator
Enclosure Comments on Draft Environmental Impact Statement for the Western Oregon
Plan Revisions
cc: Linda Goodman, USFS
Elin Miller, EPA
Kemper McMaster, USFWS
3 -
Appendices - 870
Appendix T - Responses to Public Comments and Comment Letters
_ , _ Comments of National Marine Fisheries Service, Northwest Region
Draft Environmental Impact Statement (DEIS) for the Western Oregon Plan Revisions
(WOPR)
January 11, 2008
The below comments begin with an overview of how well the preferred alternative (Alternative
„he August’ 2007’ draft environmental impact statement (DEIS) for the Western Oregon
Plan Revisions (WOPR) of the Bureau of Land Management (BLM) meets the conservation
needs of anadromous fish at the landscape scale. This analysis is followed by a list of key
elements needed for a successful conservation strategy for anadromous fish. The list is followed
by comments organized according to the chapters of the DEIS, and by references.
GENERAL COMMENTS ON CONSERVATION OF ANADROMOUS FT sh
The following species of Pacific salmon and steelhead that NMFS has listed or proposed for
listing under the ESA occur within the planning area for the proposed action: Lower Columbia
River and Upper Willamette River Chinook salmon; Southern Oregon/Northem California
Coast, Oregon Coast, and Lower Columbia River coho salmon; Columbia River chum salmon-
and Upper Willamette River and Lower Columbia River steelhead. All of the above species are
listed as threatened, except for Oregon Coast coho salmon, which are proposed for listing as
threatened. NMFS has also designated critical habitat for all of the above listed species except
Lower Columbia River coho salmon. Essential fish habitat also has been designated under the
MSA for Chinook salmon and coho salmon within the planning area.
The preferred alternative (Alternative 2) does not include a coherent and cohesive conservation
strategy for anadromous fish, including those that are listed or proposed for listing as threatened
in the WOPR area. BLM’s Land Use Planning Handbook (H- 1601-1) includes the following
statement under Special Status Species, Land Use Plan Decisions (Appendix C, p. 4) that
indicates the need to develop a conservation strategy for threatened and endangered species:
Given the legal mandate to conserve threatened or endangered species and BLM’s policy
to conserve all special status species, land use planning strategies, desired outcomes, and
decisions should result in a reasonable conservation strategy for these species. Land use
plan decisions should be clear and sufficiently detailed to enhance habitat or prevent
avoidable loss of habitat pending the development and implementation of
implementation-level plans. This may include identifying stipulations or criteria that
would be applied to implementation actions. Land use plan decisions should be consistent
with BLM’s mandate to recover listed species and should be consistent with objectives
and recommended actions in approved recovery plans, conservation agreements and
strategies, MOUs, and applicable biological opinions for threatened and endangered
species.
The Purpose and Need statement on p. XLIV states that “In accord with the Endangered Species
Act, the plans will use the BLM’s authorities for managing the lands it administers in the
Comments on DEIS for the WOPR
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FEISfor the Revision of the Western Oregon RMPs
planning area to conserve habitat needed from these lands for the survival and recovery of
species listed as threatened or endangered under the Endangered Species Act.” The section does
not explain how the WOPR will “conserve” this habitat.
Other sections of the DEIS include some information that pertains to conservation strategy -
such as ecological objectives - but the information is not tied together as a cohesive strategy to
accomplish this end. Below is a list of objectives for Alternative 2 related to fish conservation,
which we compiled from the Fish section on p. 34, the Water Quality section on p. 57, and the
Riparian Management Area section on p. 81:
• Restore stream complexity.
• Restore access to stream channels for all life stages of fish species.
• Prevent livestock from causing trampling disturbances to spawning beds where federally-
listed salmonid fish species occur.
• Maintain and restore water quality.
• Maintain and restore the proper functioning condition of riparian and wetland areas to
provide shade, sediment filtering, and surface and streambank stabilization.
• Maintain or promote the development of mature or structurally complex forests.
• Provide for the riparian and aquatic conditions that supply stream channels with shade,
sediment filtering, leaf litter and large wood, and root masses that stabilize streambanks.
• Maintain and restore water quality.
There are some additional objectives for particular BLM districts or areas subject to special
management, such as the Klamath and Coquille Resource Areas. These are special cases NMFS
is not analyzing in this part of its review due to the need to focus on core issues because of
insufficient time and staff resources.
Other sections of the DEIS include information about a restoration strategy based on areas with
high IP for rearing. Taken together, these components do not comprise a suitable conservation
strategy for the following reasons:
• There is no centralized description of a conservation strategy for anadromous fish that
would include all of the relevant ecological objectives, management actions to protect
and restore fish habitat at the watershed scale, and provisions for: (1) Implementation,
effectiveness, and validation monitoring; and (2) adaptive management.
• There is no analysis of the status of fish populations in plan area lands, such as
abundance, distribution, diversity or productivity; location of particularly important
spawning or rearing areas; or connectivity between populations and population segments.
• With the arguable exception of the objective for mature and structurally complex forests
in riparian areas, the objectives listed above do not include descriptions of what
constitutes desired conditions or levels of functional processes (i.e., desired future
conditions or DFCs). The objective for mature and structurally complex forests in
riparian areas, if pursued aggressively, is likely to sharply reduce recruitment of wood
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Appendix T - Responses to Public Comments and Comment Letters
pieces from non-mature trees that are able to form pools and trap sediment in the small
streams that are most numerous on plan area lands. Please see an extensive discussion of
this issue under Chapter 4 - Environmental Consequences/Fish/Large Wood-Fish
Productivity.
• There is no consideration of how management and restoration actions would affect
factors limiting anadromous fish populations in their freshwater life-history stages.
• “Proper functioning condition” for riparian areas is not defined.
• There is an objective for stream complexity, but the variable is not defined, and there is
no DFC. There are no objectives for other aspects of stream and watershed conditions
and processes that may limit populations of anadromous fish.
• The livestock objective is clear, but too narrow, as it implies the only negative effect of
livestock grazing is trampling of redds. This objective should also consider streambank
stability, the composition, vigor and structure of riparian vegetation, sediment generation,
and other factors affected by livestock grazing.
• There are no objectives or DFCs for hydrologic function, sediment generation and
routing, stream substrate, stream channel conditions, or nutrients.
• Most land management activities are not constrained by whether or not they would
contribute to, delay, or prevent attainment of the objectives listed above.
• There are no provisions for analyzing and understanding watershed-scale conditions and
processes that create and maintain fish habitat, or for using this information in planning
actions. This is likely to result in uncoordinated actions, planned at the scale of the
stream reach, that are unlikely to maintain and restore fish habitat at larger scales.
• There is no strategy for identifying and protecting the functionality of areas of existing
high-quality fish habitat at either the reach or the river-basin scale. Due to the patchwork
configuration of BLM ownership, and the different management histories of BLM vs.
non-Federal lands, many streams on BLM lands likely are functioning as habitat refugia
supporting remnant populations of salmon and steelhead due to higher stream channel
complexity, lower fine sediment loads, and higher amounts of stream shade.
• Land management actions at the site scale are not constrained by mandatory standards
and guidelines that would ensure that actions meet aquatic habitat objectives, but by best
management practices (BMPs), the selection of which is optional for individual actions.
The DEIS states on p. 1135 that the BMPs are intended to “reduce nonpoint source
pollution to the maximum extent practicable” and “to meet water quality objectives when
implementing management actions.” Meeting water quality objectives (which in this
case are Oregon water quality standards) would, in some cases, support the conservation
of anadromous fish, but may not be sufficient to achieve levels of habitat protection and
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FEISfor the Revision of the Western Oregon RMPs
restoration needed to recover threatened species. Besides improving water quality,
conserving anadromous fish will require standards and guidelines supporting the
maintenance and restoration of landscape, watershed, hydrologic, riparian, and instream
habitat conditions and processes. Without adequate aquatic management objectives and
firm standards and guidelines to establish sideboards, there is no assurance that individual
actions completed under the WOPR will maintain and restores anadromous fish
populations.
• The proposed stream restoration strategy focuses on stream reaches with high IP for
rearing, but does not address larger scales (i.e., river basin or landscape), other than
including a description of a general action to give priority to high-priority fish
populations that have been defined in recovery plans (p. 34). There is no strategy for
areas where recovery plans have not been completed.
NMFS expects that many of the above issues will surface in the eventual ESA and MSA
consultations on the selected alternative, and recommends that the FEIS address all of the issues
in the above bullet list. Regarding the scale issue, the river basin is the scale most relevant to the
metapopulation structure of Pacific salmon (National Research Council 1996). Healthy
populations of salmonid fishes use habitats throughout watersheds (Naiman et al. 1992), and
riverine conditions reflect biological, geological and hydrological processes operating at the
watershed level (Nehlsen et al. 1997, Bisson et al. 1997). Most land management effects on
streams and rivers are carried downstream readily, and some can travel upstream as well ( e.g .,
channel head cutting). Also, watershed divides provide clear boundaries for analyzing the
combined effects of multiple activities (National Research Council 1996).
A watershed perspective is needed to identify and assess biological habitat refugia and highly
productive habitat patches, and to assess connectivity between these areas and between fish
population segments (Sedell et al. 1990, Naiman et al. 1992, Li et al. 1995, Bisson et al. 1997).
For these reasons, habitat conservation and restoration strategies axe most likely to be effective if
carried out at the scale of the watershed (or composites of multiple watersheds in a specie’s
range; Reeves et al. 1995, Frissell and Bayles 1996), not the stream reach (Reeves and Sedell
1992, Botkin et al. 1995, National Research Council 1996, Nehlsen et al. 1997).
As described in previous meetings, NMFS would like to work with BLM to develop the
following components of a comprehensive conservation strategy for anadromous fish.
According to EPA Region 10, such a strategy would also help meet the requirements of the
Clean Water Act:
1 . Network of aquatic-emphasis watersheds for fish recovery, public water supply, and
water quality.
NMFS would like to work with the BLM to develop a network of aquatic-emphasis
watersheds, that would be managed in a more biologically conservative manner, to
provide an adequate level of confidence that habitat essential for recovery will be
maintained and improve over time at the watershed scale. This could be done using
available information, such as data on: (1) Status of fish populations in plan area lands,
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Appendix T - Responses to Public Comments and Comment Letters
including available information about abundance, distribution, diversity or productivity;
and (2) location of particularly important spawning or rearing areas; and connectivity
between populations and population segments. The work done by NMFS’ technical
recovery teams (TRTs) and critical habitat review teams would be highly valuable in this
effort.
2. Watershed-scale assessment and planning to guide recovery and other land management
actions.
The selected alternative in the FEIS should commit to continued use of existing Federal
watershed analyses, source water protection plans, and local watershed analyses for
planning and implementing land management actions, particularly in aquatic emphasis
watersheds. The selected alternative should require use of watershed-scale information
when planning actions at the reach scale, and updating existing watershed analyses with
new information, as it becomes available.
3. Ecological objectives to support aquatic habitat.
The selected alternative in the FEIS should include a set of objectives specific to aquatic
habitats that pertain to watersheds, riparian areas, and instream habitat, and are adequate
to maintain and restore anadromous fish populations. The objectives should include
descriptions of what constitutes desired conditions or levels of functional processes ( et
al., DFCs) for hydrologic function, sediment generation and routing, stream substrate,
stream channel conditions, or nutrients.
4. Standards and guidelines to aid project development and implementation.
The selected alternative in the FEIS should include mandatory standards and guidelines
to set sidebars for individual actions. Management activities should be constrained under
the standards and guidelines depending on whether they would contribute to or delay
attainment of the aquatic habitat objectives listed above.
5. Provisions to protect and restore high-quality fish habitats.
Successful conservation of anadromous fish will require the protection of currently
functioning high quality or highly productive fish habitat, at the watershed scale, in
addition to restoring habitat with high intrinsic geomorphic potential (IP). Information
used to prioritize restoration actions in aquatic-emphasis watersheds should include
Federal and local watershed analyses, source water protection plans, and targets in total
maximum daily loads (TMDLs) prepared under the Clean Water Act.
6. Adjusted riparian management areas (RMAs).
NMFS would like to work with BLM to develop a RMA strategy that provides adequate
protection and recovery potential for anadromous fish habitats and water quality.
Aquatic-emphasis watersheds should have more protective RMAs than other watersheds.
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FEISfor the Revision of the Western Oregon RMPs
Rather than simple default values, RMA widths should be based on factors relevant to
factors forming and maintaining aquatic habitat functions, et al. , floodplains, channel
migration zones, unstable slopes, site-potential tree heights, shade, bank stability, etc.
RMA widths, and the constraints that apply within RMAs, should balance the need to
maintain or protect existing aquatic habitat conditions and processes with the need for
active restoration in some situations. RMAs should include zones of different
management intensity including a zone of total protection to protect bank stability ; a zone
for protection of shade and litterfall; a zone accommodating both protection of existing
values and active management, where needed, to improve aquatic habitat conditions; and
a zone for transitioning into upland management strategies.
7. Expanded provisions for plan implementation, monitoring, and adaptive management.
The selected alternative needs to describe a clear framework for linking individual
resource management plans (RMPs) to regional-scale conservation efforts, including
recovery plans for listed fish species. The selected alternative should also explain how
the plans will be implemented in each BLM district, and how the districts will contribute
to meeting aquatic habitat objectives at the watershed scale. The BLM should fill in
needed details about how implementation, effectiveness, and validation monitoring will
be carried out as the plans are implemented, and how it will use adaptive management to
respond to new information about plan effectiveness. The BLM should commit to
participating in the regional framework for federal land management aquatic
effectiveness monitoring. NMFS would like to work with BLM to better define how the
individual RMPs would link to other adjacent land management plans ( e.g ., those of the
U.S. Forest Service and affected Indian tribes), and how they tier to project planning and
implementation.
CHAPTER 1 - PURPOSE AND NEED
This section provides a rationale for the proposed plan revisions; identifies cooperators, affected
laws and guidance; and defines the planning area, issues identified, and the planning process.
The section discusses coordinating plan revisions with draft recovery plans for anadromous fish
species listed under the Endangered Species Act (ESA) on p. 5, but the alternatives do not appear
to incorporate key elements of draft recovery plans or related recovery planning products {et al. ,
documents from TRTs). The FEIS should explain how BLM will integrate recovery planning for
ESA-listed anadromous fish into the plan revision.
The DEIS (p. 23) acknowledges the requirement to consult under section 7 of the ESA on
amendments to the individual resource management plans under the proposed action, but does
not propose a framework for completing these consultations. Due to past litigation on adoption
of Federal forest management plans, it is essential that BLM work closely with NMFS on such a
consultation framework.
The DEIS says on p. 24 that draft recovery plans will be incorporated into BLM plan revisions if
they are completed before WOPR implementation. NMFS expects that recovery plans for the
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Appendix T - Responses to Public Comments and Comment Letters
Upper Willamette River and Lower Columbia River species of ESA-listed anadromous fish will
be proposed in 2008. The FEIS should explain how recovery plans that are completed after
WOPR implementation begins would be incorporated into land management actions.
CHAPTER 2 - ALTERNATIVES
Management Common to All Alternatives
Fish
This section (p. 34) consists of a list of three objectives and four management actions that apply
to all alternatives. The stated objectives are:
• Restore stream complexity.
• Restore access to stream channels for all life stages of fish species.
• Prevent livestock from causing trampling disturbances to spawning beds where federally
listed salmonid fish species occur.
The following management actions are listed:
• Priority for restoration activities would be given to projects in streams with a high
intrinsic potential for fish and to high-priority fish populations that have been defined in
recovery plans.
• Stream complexity would be restored through the placement of large wood and boulders.
• New and replacement stream-crossing structures on fish-bearing streams would be
designed to provide access within stream channels for fish.
• For streams with salmonid species listed under the Endangered Species Act, livestock
would not be released into riparian areas until 30 days following the emergence of
salmonids from spawning beds.
Considering the complexity of interactions between forest lands and the habitat of anadromous
fish, the numerous problems with fish habitat in the plan area, and the range of actions needed to
maintain and restore fish habitat, the lists of objectives and management actions seem to be
overly simple and incomplete. The lists are not supplemented by additional objectives and
management actions for fish or stream habitat in any of the action alternatives, although the
alternatives do have short lists of objectives and management actions for riparian areas.
The list of objectives for fish and fish habitat does not include many of the habitat factors
limiting populations of anadromous fish that are listed or proposed for listing in the plan area that
could be affected by how BLM lands are managed, such as water quality, flow, and substrate
conditions. The list of management actions seems to assume that restoration by itself can restore
habitat, and misses the importance of not degrading existing habitat quality, and the role of other
factors affecting complexity of stream habitat ( et al., flow regime, sediment regime, disturbance
regime). Adding these features to the FEIS is critical to demonstrating a conservation strategy
for anadromous fish. A commitment to address the limiting factors in recovery plans as they are
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developed, through habitat protection and restoration, would be a reasonable step for BLM to
take pending completion of recovery plains.
Regarding the list of management actions for all alternatives, the FEIS should specify which fish
passage standards for new and replacement culverts the BLM will use (NMFS and Oregon
Department of Fish and Wildlife each have their own standards; we recommend that BLM
commit to meeting NMFS’ standards in streams with anadromous fish). Regarding the last
management action in the above list, it is unclear how the BLM will know when complete fry
emergence has occurred in order to define the 30-day period before release of livestock into
areas near streams. NMFS recommends that BLM include a commitment in the FEIS to
implement recovery plan actions that are appropriate for Federal lands.
Riparian Areas
The action alternatives (alternatives 1, 2 and 3) include the following two objectives for riparian
areas:
• Maintain or promote the development of mature or structurally complex forests.
• Provide for the riparian and aquatic conditions that supply stream channels with shade,
sediment filtering, leaf litter and large wood, and root masses that stabilize streambanks.
NMFS commented on the aquatic habitat objectives above under “General Comments on
Conservation of Anadromous Fish.”
The alternatives share the following management actions for riparian areas:
• Thinning and other silvicultural treatments would be applied along smaller-order streams
(generally, first-, second-, and third-order streams) to promote the development of mature
forests.
• Thinning and other silvicultural treatments would be applied along larger-order streams
(generally, fourth-order and larger streams) to promote the development of structurally
complex forests.
• Snags and coarse woody debris would be retained in thinning operations, except for
safety or operational reasons ( et al. , maintaining access to roads and facilities).
• Salvage would not occur in stands that are disturbed by a fire, windstorm, disease, or
insect infestations, except to reduce hazards in wildland urban interface areas.
• Timber from thinning and salvage operations would be available for sale, with different
amount of emphasis on active management in riparian areas.
The above actions emphasize thinning in riparian areas for all stream sizes, but this will only
benefit the habitat of anadromous fish under certain conditions ( et al., where there is sufficient
instream wood already present to provide habitat functions during the lag between thinning a
forest and recruitment of logs from the thinned forest to the stream, and where existing trees are
too small to form pools when they fall into streams). Available research {et al., Beechie and
Sibley 1997, Bilby and Ward 1989) indicates that trees as small as 5-6 inches in diameter can
form pools in small streams. Thinning along along small streams with wood deficits can
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Appendix T - Responses to Public Comments and Comment Letters
significantly reduce recruitment of wood to streams (Beechie et al. 2000), and the risks of this
happening appear to be significantly increased by the above management actions. NMFS
provides additional information about this issue in its review cf the DEIS’s large wood analyses
in later sections of this document.
NMFS recommends that BLM develop criteria for when to thin riparian forests, and additional
non-timber management actions to maintain and restore riparian areas - such as correcting
damage to riparian vegetation and streambanks due to livestock grazing, invasive plants,
recreational activities, and roads.
The Alternatives
Alternative 2
The DEIS provides information about proposed RMAs for Alternative 2 in Table 3 1 (p. 79-80).
Some needed definitions are lacking. What scientific information was used to define the
“streambank zone,” “water influence zone,” and “intermittent, non-fish bearing streams,” and how
would these zones be delineated in the field?
The only difference we could discern among the action alternatives with respect to objectives
and management actions is that Alternative 3 includes a management action not found in the
other action alternatives:
• Prescribed bums would be used in areas of high fuel loadings to reduce the potential for
uncharacteristic wildfires.
The FEIS should include a discussion of whether or not this action would be useful in the
preferred alternative.
CHAPTER 3 - AFFECTED ENVIRONMENT
General Comment
It is confusing to have subchapters on sediment, temperature and stream flow in both the Fish
and Water sections of this chapter, especially since the subchapters are only rarely cross-
referenced. It is unclear why most of the details are in the Water sections, and the Fish sections
are relatively brief. NMFS recommends that the BLM use cross-referencing to minimize
duplication between the sections.
Fish
Large Wood
This section, which begins on p. 340, provides a more extensive historical background, literature
review, and baseline assessment than any of the other sections within the “Fish” chapter. It
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would helpful if the other sections with the Fish chapter provided a similar amount of
background information.
The DEIS analysis of large wood examines only five out of 176 fifth-field watersheds within the
plan area that contain BLM ownership. Three of the five “representative” watersheds were
selected from the Klamath Province, which probably is not representative of BLM lands in other
provinces. It is not clear how effective these five watersheds are in characterizing wood delivery
or potential impacts of management activities to the 1 0 listed fish species described in this
section. Wood delivery to streams by debris flows is influenced by forest condition, topography
and other factors that would vary dramatically between the provinces. The FEIS needs to
include a larger sample size of watersheds, well distributed across the plan area and stratified by
physiographic province, BLM ownership, and other meaningful geomorphic and watershed
variables, that would more accurately model wood recruitment to streams.
The conclusion that only wood >20 inches diameter at breast height is ‘functional’ is contrary to
published relationships between wood size and pool formation ( et al. , Beechie and Sibley 1 997,
Bilby and Ward 1989), leading to the erroneous conclusion that significant timber harvest in
riparian zones under alternatives 2 and 3 has little effect on habitat for anadromous fish. Other
issues with the methodology used for the wood recruitment model that NMFS’ staff has
previously discussed with BLM’s staff include assumptions of site-potential tree heights that
seem too low for parts of the WOPR area, and the distances from debris-flow prone streams over
which trees can be incorporated into debris flows. NMFS understands that BLM is working on
new model runs with different assumptions and input variables, and we encourage BLM to
include model runs with smaller minimum tree diameters, and to report the results of these
investigations in the FEIS.
Large wood contribution is used as a surrogate for productivity of salmonid fish populations in
this analysis. The DEIS states that “improved habitat complexity correlates to improved fish
survival and production” (p. 343). This assumption ignores the concept of limiting factors for
species’ productivity (Wilson and Bossert 1971). Observations where augmenting wood
densities did not lead to increases in smolt production (p. 343) substantiate that habitat
complexity is not the only limiting factor for anadromous fish. The fish analysis should consider
effects of the alternatives on other factors limiting fish populations, such as water temperature,
substrate sediment, and passage. Information about limiting factors often is available in
proposed recovery plans, TRT products, and Federal or local watershed analyses.
Sediment
This section (p. 355-357) begins with a paragraph about provision of organic matter to streams
from vegetation that appears to be out of place. It continues with a brief (<2 pages) summary of
various effects of fine sediment and turbidity on salmonid fish and their habitat. NMFS provides
some comments on this summary below.
The DEIS states (p. 356) that “The timing of the sediment inputs relative to the biological
vulnerability of each fish species is more important than the absolute quantity of sediment.” This
statement is true only where habitat effects of sediment are transient and very short term (days to
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weeks), which is only the case for turbidity effects. In the case of turbidity, it may be reasonable
to assume that timing is critical, because sediment delivered and evacuated during non-critical
periods is unlikely to kill large numbers of fish. However, the statement seems to assume that
sediment deposition in streambeds is short term, and is not coincident in time with incubation of
salmonid eggs in spawning gravels. In fact, sediment usually is not so transient in the gravel,
and salmonid eggs are incubating during most periods of erosion and fine sediment delivery.
Introduction of fine sediments ( et al. , sand and smaller particles < 2mm in diameter) alters
channel morphology and habitat by several mechanisms. The smallest particles travel
downstream as wash load, while larger particles may travel as bed load (Richards 1 982).
Suspended particles and fine bed load can accumulate in spaces between gravel particles
(Beschta and Jackson 1979, Lisle 1989), restricting the subsurface movement of water through
the gravel and reducing survival of eggs and fry. Fine sediments can also fill pools and
interstitial rearing spaces, and can increase turbidity during high flows. This assumption also
does not consider indirect effects of increased fine sediment, such as reduced production of
invertebrate food organisms (Suttle et al. 2004).
The DEIS does not explicitly consider these non-transient sediment effects and bases its analysis
only on the proposed increases in road length, rather than total road length. Moreover, the
method underestimates surface erosion by at least a factor of two (see discussion under Water,
Sediment below). Thus, it remains unclear what the overall effect of forest roads will be under
any of the alternatives.
Effects of changes in coarse sediment supply are not considered in the alternatives because all
alternatives assume no increase in landslide rates, and therefore no increase in mixed-grain-size
sediment supply. This assumption may not be well-supported (see comments about how BLM
uses the “timber productivity capability classification” (TPCC) to screen for landslide-prone
areas, and withdraws them from general forest management, that pertain to Chapter 3, Water,
Sediment on p. 378 of the DEIS). If the possibility of increased landslides due to increased
intensity of land management were considered, it would be clear that sediment quantity is of
greater importance than timing of erosion for coarse sediments. This is because there is a time
lag of years to decades between a change in sediment supply and a change in morphology of a
downstream reach (et al., Kelsey 1982b, Madej and Ozaki 1996, Beechie 2001, Beechie et al.
2005b), and the amount of sediment determines channel and habitat response. The time lag is
due to the time required for sediment to travel from its source to the reach of concern (Kelsey
1982a). Once sediment enters a stream reach, its persistence is partly a function of the sediment
transport capacity of the reach (Benda and Dunne 1 997b), and both the timing and persistence of
changes in the morphology of downstream reaches are related to the rate at which sediment
moves through a channel network (Madej and Ozaki 1996). Therefore, timing of erosion is
rarely equal to timing of impact on salmonid fish, and erosion timing cannot be considered a
reasonable criterion for concluding that erosion has little effect on these fish.
The effects of coarse sediments on fish habitat quality vary, depending on the amount of
sediment delivered. In general, increased supply of sediments to lower-gradient reaches
increases the amount of fine sediment on streambed surfaces (Dietrich et al. 1989), reduces pool
depth (Lisle 1982, Madej and Ozaki 1996), and causes channel aggradation (Madej 1982, Lisle
1 982) and channel widening (Kelsey 1 982b, Madej 1 982). Initial increases are accommodated
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by deposition of finer sediments into pools ( et al. , Lisle and Madej 1992, Lisle and Hilton 1992,
1999). Larger increases cause aggradation of the channel bed and channel widening {et al ., Lisle
1982; Madej 1982, 1992; Harvey 1987; Pitlick and Thome 1987; Harvey 1991), and channels
may become laterally unstable (Bergstrom 1982, Church 1983). As sediment moves through a
reach, the proportion of sediment stored in bars increases rapidly, and then decreases over a few
years to a few decades (Lisle 1982, Madej 1987, Madej 1992). Depths of pools may begin to
recover while sediment remains within the reach (Madej and Ozaki 1 996), but typically do not
fully recover until the sediment pulse passes through the reach (Lisle 1982, Collins et al. 1994).
All of these effects persist for years to decades.
The final three paragraphs of this section (p. 356-7) downplay the effects of sediment on fish and
their habitat, including a statement that “.. ..no model can predict the exact mechanism of
sediment delivery and instream routing. Therefore, it is not possible to quantify or accurately
predict the affects that sediment delivery has on fish species.” Yet the DEIS uses a sediment
model in the “Water” section of the DEIS to predict routing mechanisms and quantify the
amount of sediment transported to streams within the plan area.
NMFS recommends that the FEIS include a modified sediment analysis that avoids the
assumption that the timing of sediment delivery is more important than the volume, that
considers effects of both the existing road network and proposed roads, and that includes
consideration of long-term sediment routing and effects.
The effects of water temperature on fish, which are limiting factors for some of the anadromous
fish populations in the plan area, are addressed with a striking lack of detail in the Fish section in
less than half a page (p. 357). The section includes a table with most of Oregon’s numeric water
temperature criteria (it is not the complete standard, since the standard includes the beneficial use
designations and the antidegradation policy, which the DEIS does not mention). Missing from
the table is Oregon’s “core cold water” criterion of 60.8 degrees F, which DEQ designated in the
North Coast Basin (an upper portion of the Necanicum River, Ecola Creek and Plympton Creek)
and Mid-Coast Basin (Siuslaw River) (Oregon Department of Environmental Quality 2003).
This section outlines very general effects of high temperatures on salmonid fish, and gives the
total amount of stream miles on BLM lands that are listed by ODEQ water-quality impaired for
temperature. NMFS assumes this is for the plan area, although that is not clear; BLM should
clarify this in the FEIS. NMFS suggests that this section of the FEIS include a more extensive
discussion of the extensive literature on effects of water temperature on listed salmonid fish
found in the plan area, including inferences about effects of water temperatures in the plan area
on salmonid fish. Suitable reviews that may be helpful include McCullough (1999), Dunham et
al. (2001), Matema (2001), McCullough et al. (2001), and Sauter et al. (2001).
The pattern of stream flow, including the timing and volume of peak and base flows, is another
critical environmental attribute for salmonid fish (Spence et al. 1996). The Fish section of this
Temperature
Stream Flow
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chapter includes only one paragraph about stream flow. The single paragraph poorly describes
the affected environment, as it does not describe any conditions within the plan area, does not
describe factors that contribute to stream flow problems, and does not outline the BLM’s role
with respect to stream flows. NMFS recommends this section refer the reader to the more
complete analysis in the Water Quantity section of the Water chapter, and that either this or the
Water Quantity section describe conditions within the plan area, describe factors that contribute
to stream flow problems, and outline the BLM’s role with respect to stream flows.
Water
Stream Temperature
The bulk of this section (four of six pages beginning on p. 366) is devoted to building a case for
the sizes of the RMAs and proposed management strategies within those RMAs under
Alternative 2, as opposed to actually describing the affected environment (et al., status and
trends in water temperature in the plan area, and the reasons for those conditions), which is what
is needed. This case as it relies heavily on dated literature and unpublished sources, and does not
include a broad or representative treatment of the extensive literature on physical controls of
stream temperature and how land management affects temperature. Neither does the section
demonstrate that the studies and models used are valid and suitable for the diversity of
ecoregions and conditions in the WOPR plan area (et al.. Lower Columbia River tributaries,
Coast Range, Willamette River Basin, Umpqua River Basin, Klamath Mountains, and East and
West Cascade Range). Because the BLM has not provided this information, NMFS has limited
confidence in the proposed strategy as a tool to avoid increasing water temperature following
timber management within riparian areas. NMFS elaborates on the reasons for this statement
below.
The analysis in the DEIS relies on canopy closure as a surrogate for stream shade. On p. 367, the
DEIS cites Brazier and Brown (1972) to explain how angular canopy density (a measure of
vegetation canopy closure) varies with different buffer strip widths up to 100 feet (Fig. 98, p.
367). It is unclear whether the stream sizes, tree types and heights used in this study are
applicable to the entire plan area. If they are, how was that determined, and if not, what other
information is available?
Also on p. 367, the DEIS cites Park (1991) to demonstrate a relationship between angular canopy
density and stream shade (as shown in Fig. 99 on p. 367). This citation is not in the References
section of the DEIS; NMFS assumes this should be Park (1993), which the References section in
the DEIS has as the SHADOW model. If the BLM is going to use the SHADOW model to
support their assertions regarding angular canopy density, stream shade, and water temperature,
then it needs to better describe the data set used to develop the model (et al. , what streams were
used to develop the statistical relationships?); document model validation in the different
ecoregions covered by the WOPR; and report confidence limits, assumptions and uncertainties in
the FEIS. That will allow for a full evaluation by NMFS, decision-makers and the public.
The strategy for Alternative 2 is to maintain 80% effective or potential shade, whichever is less,
in the “primary shade zone.” The DEIS does not adequately demonstrate that this 80% shade is a
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valid target for the “mature, structurally complex” forests that are the objective for riparian areas,
nor does it adequately demonstrate that this amount of shade will maintain and restore water
temperatures. On p. 368, the DEIS asserts that shade levels over 80% do not produce
measurable decreases in stream temperature. This information is based on Boyd (1996), which is
an unpublished master’s thesis that was based on limited sampling. NMFS is concerned that the
DEIS is relying so heavily on one source for this information. The DEIS has provided no
information on the data set used to develop the model, model validation for the different
ecoregions covered by the WOPR, confidence limits, assumptions and uncertainties. Also, was
Boyd (1996) considering only the ‘primary shade zone’ in the calculations used for this figure?
Other available information suggests that the relationship explained in the DEIS may not be
universally true. A recent master’s thesis found differences in water temperature between 80%
and 100% shade following harvest in riparian areas of Oregon Coast Range streams where
retained shade ranged from 51% to 99%, with a mean of 79%, which is essentially the same as
BLM’s target of 80% (p. 3 1 and Fig. 3.9 in Fleuret (2006). Based on this information, the
uncertainties around BLM’s analysis, the requirement for site-potential shade in all total
maximum daily loads completed by the Oregon Department of Environmental Quality under the
Clean Water Act, a target of site-potential shade, at least in aquatic emphasis areas, would be a
better strategy for the selected alternative.
The assertion in the DEIS that areas greater than 1 00 feet from streams cannot contribute shade
to stream is not adequately demonstrated. On p. 368, the DEIS asserts that Fig. 100
demonstrates that “there is marginal improvement in shade for riparian areas wider than 1 00 feet,
because the variables of total solar radiation reaching a stream is (sic) diminished by the
blocking ability of a tree’s canopy.” This is a confusing statement. Fig. 100 does not include
widths of riparian areas, and the last clause of the sentence does not have enough information to
make sense. NMFS is not confident that riparian areas wider than 1 00 feet cannot contribute
shade. Among other variables, this would depend on stem density and canopy density at various
distances from the stream, tree heights, and topography. Water temperatures of three streams in
British Columbia, Canada increased by 1 .6° C relative to control streams when streamside areas
were logged with buffers of 30 m (98 feet) (Kiffney et al. 2003). This suggests that buffers
essentially the same as the 100 feet cited by the DEIS did not fully protect shade. The analysis in
the FEIS needs to consider this additional information.
A discussion of riparian widths for primary and secondary shade zones begins on p. 369 the
DEIS. This section relies on information presented in Table 1 13, which is based on tree heights
of only 1 00 feet or less - considerably shorter than site-potential trees in much of the plan area.
How would the sizes of the primary and secondary shade zones change for trees that were as tall
as the site potential trees in the plan area (as shown in Fig. 102 on p. 370)? Also, we have not
seen data explaining the effects of varying tree retention in the ‘secondary shade zone’ on
effective shade. The BLM should provide this information {et al ., the rationale for why retaining
50% canopy in the secondary shade zone is adequate) in the FEIS. The FEIS also should assess
the likelihood of blowdown of riparian trees under the various strategies, and analyze how this
factor could affect stream shade and water temperatures. Overall, the DEIS has not provided
sufficient justification for how its riparian management areas under Alternative 2 would protect
stream shade and prevent heating of streams. The BLM should work with NMFS to amend its
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RMA delineations and actions to provide a higher level of confidence that its management
strategies will maintain and restore shade and stream temperatures.
In order to adequately describe the existing condition, NMFS recommends that this section of the
FEIS provide more information about the status and trends of water temperature on BLM lands.
Information that could be provided, if it is available to BLM, includes which streams are
monitored, status of compliance with the Oregon temperature standard and trends over time, and
summaries of results of TMDLs done in the plan area, particularly modeling of natural thermal
potential and how this compares to current temperatures. This section in the FEIS should also
discuss the status of stream shade on BLM lands, to the extent that information is available to
BLM, and discuss how land management has contributed to current shade and water temperature
levels. All information about how the proposed management strategies would affect stream
shade and temperature should be moved to Chapter 4, Environmental Consequences, in the FEIS.
Sediment
The sediment section contains limited information about the status and trends of sediment in
streams within the plan area. Table 115 includes information about potential fine sediment yield
from existing roads, but the DEIS does not explain how this information was generated, nor does
it explain whether any empirical data is available for lands in the plan area. Table 1 16 shows
ratings of the Oregon Department of Environmental Quality (ODEQ) for sediment in four
physiographic provinces occurring in the plan area for 1994 to 2001. On p. 382, the DEIS states
that it is unclear how these results apply to BLM lands because of mixed land uses in the
watersheds. Do ODEQ sampling stations occur on BLM lands? Additional information on
substrate sediment is available from habitat surveys done by Oregon Department of Fish and
Wildlife.
On p. 376, the DEIS begins a summary of the results of modeling of how the alternatives would
affect delivery of fine sediment into streams. This information would fit better in Chapter 4,
Environmental Consequences.
Some of the assumptions that went into the sediment modeling do not appear to be well-
supported, including the following:
• An assumption of moderate traffic under all alternatives, when the log traffic logically
would vary with the different rates of tree cutting among alternatives.
• An assumption that fine sediment yield would not vary with the varying amounts of
timber cutting and slash burning under the different alternatives.
• An assumption that sediment is not delivered to streams from portions of the road that are
more than 200 feet from channels. This is problematic if the average cross-drain spacing
is 500 feet, which is another assumption of the model (p. 1-1 1106). This will
underestimate the length of road connected to streams by a factor of two or more. 1 The
' This assumption is not part of the method that the DEIS follows. The Washington Department of Natural
Resources’ (DNR) watershed analysis methodology states, “If the road drains directly to a stream channel via a ditch
or gully: assume 100% delivery from the parts of the road that drain directly to the stream.”
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DEIS assumes that sediment is not delivered to streams from portions of the road that are
more than 200 feet from channels. It may also be appropriate to determine a correction
factor that accounts for the percentage of cross-drain culverts that are not functioning at
any given point in time, and apply this factor to the analysis.
• The section includes an implicit assumption that BLM’s methods for identifying
landslide-prone lands and their mitigation measures for these lands are 100% effective,
which seems unlikely (see discussion below regarding p. 378).
There may be important ecological implications for the habitat of anadromous fish if the various
sediment modeling assumptions are not met. What information does BLM have to support these
assumptions? In order to support the results of its modeling exercise, the BLM should explain
the basis for these assumptions in the FEIS. NMFS also recommends that BLM complete a
sensitivity analysis by running the model with varying log truck traffic and sediment yield based
on varying levels of timber harvests, and report the results in the FEIS.
There are other parts of the methodology used for the sediment modeling exercise that may be
problematic, but it is difficult to tell due to insufficient information. These potential issues
include:
• The method includes an assumption (p. 1-1107) that roads not crossing a stream do not
deliver sediment, yet also includes an assumption about delivery of sediment from
drainage ditches. These ditches can deliver sediment to streams regardless of where the
road segment crosses a stream. Also, the validity of the assumption about stream
crossings depends heavily on the map resolution for streams used in the analysis. Even
the smallest stream channels route fine sediments, and many of these tend not to show up
on geographic information system hydrography layers ( et al., 1 :24,000 blue lines of the
U.S. Geological Survey miss a significant portion of the stream network). This means
that the analysis likely underestimates the number of road segments hydrologically
connected to streams.2
• Table 212, p. 760, indicates that Alternative 2, which has the greatest amount of timber
cutting, has the lowest projected mileage of new roads. The FEIS should explain how
this is possible.
• The DEIS does not explain the derivation of the “ground cover correction factor” (p. I-
1 107, also called “ground cover density factor” in Table 262 on p.-l 107), which applies
to cut and fill slopes. Without knowing where the vegetation cover data came from, it is
not possible to evaluate the accuracy of the final vegetation correction factor layer. The
FEIS should explain the derivation of this factor.
On p. 378, the DEIS describes how BLM uses the “timber productivity capability classification”
(TPCC) to screen for landslide-prone areas, and withdraws them from general forest
management. This classification is done by silviculture and soil specialists based on the
interpretation of aerial photography and ground review. Over 89,937 acres of BLM-
2 In the DNR watershed analysis methodology, channel locations are determined in the field, with a channel defined
as “any drainage depression with a defined bed and banks, extending continuously below the drainage site. The
flow regime can be ephemeral, intermittent, or perennial.”
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administered lands (3.5% of BLM administered lands) are withdrawn due to forest capability or
land stability concerns. NMFS would expect the amount of lands susceptible to shallow, rapid
landslides alone to be larger than 3.5% of BLM lands in the plan area, considering the amount of
steep lands and the stream density in much of the plan area. Since all of the NEPA alternatives
rely on this system, and since it is relevant to both the analyses of the risk of sedimentation and
of the recruitment of large wood to streams from landslides, the FEIS should provide any
evidence BLM has about the effectiveness of the TPCC in identifying landslide-prone lands.
The FEIS should also include information about the procedures, decision criteria, and
effectiveness of site-specific reviews that can also be used to withdraw areas from harvest due to
slope stability concerns.
Ideally, BLM would redo its sediment analysis using a computer-based model that predicts slope
stability of potential landslide initiation sites based on slope, topography, rainfall, and other
variables, such as SHALSTAB. Papers developing the SHALSTAB model and showing its
application include Dietrich et al. 1992, 1993, 1995; Montgomery and Dietrich 1994; and
Montgomery et al. 2000. This model works various topographic data sources such as digitized
7.5 minute USGS quadrangle maps with enhanced topographical contours at 10-m intervals. The
model assigns to each 10-m topographic cell a relative hazard rating (low, medium, or high).3
Other slope stability models using similar input variables are also available. If it is not possible
to run such models for the entire plan area before the FEIS, then the FEIS should describe a plan
to update its slope stability investigations to include computer modeling.
On p. 379-381, the DEIS discusses studies of landslides by the U.S. Forest Service and the
Oregon Department of Forestry that occurred during winter storms in 1996, but includes no
information about landslides on BLM lands. The FEIS should provide any available information
about landslides on lands in the plan area in 1996 or other years.
Water Quantity
The DEIS cites studies done in the 1970s (DEIS, p. 388) by Rothacher (1973) and Harr (1976) to
support analysis of management effects on peak flows with 5-year return intervals. Jones (2000)
and Bowling and Lettenmaier (1998), which address road effects on peak flows, would also be
appropriate references to discuss.
The DEIS concludes (p. 385) that one out of 635 subwatersheds in the rain hydroregion, and only
three out of 471 subwatersheds in rain-on-snow hydroregion (p. 387), within the plan area are
currently susceptible to peak flow increases. This is an underestimate, because it assumes that
baseline peak flow conditions within the plan area are currently functioning naturally. These
conclusions also seem difficult to accurately predict in any meaningful way without considering
site-specific information regarding the spatial distribution of patch cuts with respect to current
conditions. Peak flow analysis in the DEIS (p. 361) considers the largest spatial scale (sixth-
field subwatersheds, 10-40 square miles, that is generally acceptable to recognize any change in
3 Some inner gorges (See Kelsey 1988 for a definition) may not be included in the model results and would need to
be identified by field surveys for actual layouts of timber sales, since these features do not typically show up on
topographic maps.
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magnitude of peak flows, obscuring dispersed localized impacts that may be occurring at a finer
scale. The temporal scale of peak flow analysis is relatively short (et al., 5-year return).
The effects of roads are not modeled or considered, even though they often contribute to
increased peak flow responses (Johnson 2000, Grant et al. in review). The FEIS should include
a cumulative effects analysis that examines not only the cumulative decrease in peak flow
response at large watershed scales (Grant et al. in review), but also the cumulative effects of
many small watersheds {et al.,< 10 square kilometers) dispersed within target landscapes
experiencing increases in peak flows. The gross geomorphic effects of these dispersed increases
in magnitude might be small due to resilience of channels (Grant et al. in review); however, a
variety of effects {et al., fine sediment transport, reduced stream bank stability, reduced large
wood retention) may result in significant effects to anadromous fish habitat at the stream reach
scale.
Peak flow analysis for the rain-dominated hydroregion (p. 384-385) was performed for the DEIS
through comparisons to empirical results from paired watershed studies, using OPTIONS
modeling and 1996 data from the Interagency Vegetation Mapping Project to estimate amount of
disturbance (equivalent clearcut area or ECA). The DEIS compares anticipated ECAs to ECAs
that caused peak flow response in small watershed studies (roughly 25 to 2,500 acres) to develop
predicted responses in sixth-field watersheds. The DEIS used a 40% ECA threshold to classify
sixth-field subwatersheds susceptible to peak flow increases. A regression analysis of twelve
previously published Pacific Coast studies by Stednick (1996) suggested a harvest of 25% or
more of a watershed can measurably increase annual water yield (although none of the studies
examined areas where less than 25% of the watershed had been cut). The BLM should complete
sensitivity analysis using a lower ECA threshold, and disclose results in the FEIS. Pending
results of this analysis, NMFS recommends a more conservative ECA value (perhaps 20-25%) to
be used as the threshold for classifying subwatersheds susceptible to peak flow increases.
Peak flow analysis for the rain-on-snow hydroregion used a process model derived from
estimated winter snowpack (from empirical data) and forest cover data. Snow melt was
simulated for “average environmental conditions” of a rain storm with a 2-year return interval.
Water equivalents from this analysis were converted to rainfall and used to estimate stream flow.
This stream flow value was compared to flows for storms with a 5-year return interval. Sixth-
field watersheds that exceeded 5 -year flows were considered susceptible to peak flow change.
NMFS has concerns with the validity and practical application of this analysis, including the
extent of the mapped intermittent snow zone, the applicability of gauged watershed data used for
comparison, the response metric, and the use of an untested process model when other models
and empirical results are available. NMFS recommends that BLM strengthen this analysis by
validating this model with a comparison to either empirical evidence from the plan area or with
another validated model that is applicable to the plan area.
The DEIS analysis of peak flow response in rain-on-snow hydroregion used a unique process
model (Washington Department of Natural Resources 1997), although other more detailed
process models (Lewis et al. 2001) and spatially distributed dataset models (Bowling and
Lettenmaier 1998, Tague and Band 2001) have been developed, validated and published. It is
difficult to assess the value of this modeling approach since it represents an untested hypothesis
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with a series of untested parameters. NMFS recommends that BLM strengthen this analysis by
either applying those validated models in the DEIS or, at a minimum, comparing the WOPR’s
analytical model with these validated, peer-reviewed models.
The FEIS should provide any available empirical data from within the plan area that supports the
validity of the Washington Department of Natural Resources’ model for use in this area. As with
the rain-dominated region, the effects of existing and new roads should be included in the
analysis. Using generalized average environmental conditions ( et al., 15 mph wind speed during
2-year storms) does not seem to emulate actual conditions that would develop in such a storm;
NMFS recommends using sensitivity analysis to explore responses under higher wind speeds.
CHAPTER 4 - ENVIRONMENTAL CONSEQUENCES
Fish
Large Wood
NMFS questions whether the large reduction in buffer widths along different stream types
relative to the No-Action Alternative, particularly for Alternatives 2 and 3, would provide fully
functioning riparian and stream ecosystems. The recommended 1 00-ft buffer for perennial and
fish-bearing streams in Alternative 2 (the preferred alternative) is considerably less than the
published studies the DEIS cites to justify this width on p. 730. In addition, this buffer does not
account for wetlands or sensitive habitats that may require a wider buffer to ensure a fully
functioning stream network. Along many streams in the Cascade and Coast Ranges, the 25-foot
no-cut buffer consists of a scattered string of alders that may deliver little functional wood.
Fish Productivity
The DEIS fish productivity model makes several erroneous assumptions regarding the ‘value’ of
channel or habitat types for salmon, and these assumptions lead to an erroneous conclusion that
smaller streams have less value for salmonid fish than larger rivers. The DEIS fish productivity
model incorrectly applied equations relating pool spacing to wood loading, contributing to an
erroneous conclusion that the there is little difference in fish productivity across the alternatives.
The DEIS assumes that available habitat is proportional to available channel area {et al., large
channels can support more fish than small channels). This assumption is not warranted, because
available habitat depends more on channel complexity than channel area. Large, simple {et al. ,
low wood density) channels may support lower densities of fish than small, complex channels.
{et al. , Beechie et al. 2005 found very low densities in large mainstem pools, riffles and glides
that had low wood densities).
The DEIS assumes that steelhead avoid unconstrained reaches. This assumption is simplistic as
juvenile steelhead are typically observed rearing in unconstrained reaches with coho {et al.,
Beechie et al. 2005a found steelhead rearing throughout the Skagit River mainstem, which is
unconstrained). They may be at lower densities in low gradient sections, but this may be more a
result of competition with coho than habitat selection.
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The DEIS seems to assume that the quality and productivity of fish habitat are controlled solely
by physical characteristics. This assumption is unwarranted, because a large amount of evidence
supports the hypothesis that fish growth and survival are also dependent on aquatic productivity
{et al., prey availability). For example, unconstrained, low gradient channels that have a higher
density of prey available will likely have a higher potential to support juvenile coho salmon than
a similar stream with low prey density ( et al., Kiffney and Roni 2007). Furthermore, high
gradient, confined reaches may be actually provide a high level of support for rearing coho and
Chinook salmon if prey availability is high.
The DEIS assumes that channels with low geomorphic intrinsic potential (IP) for rearing habitat
require less protection than channels with high intrinsic potential. This assumption is also
unwarranted in that channels with low IP for juvenile salmonid fish may be important sources of
water, sediment, organic matter or nutrients to channels with high intrinsic potential (Rice et al.
2001, Kiffney et al. 2006). In other words, the intrinsic potential of a river network is likely a
result of habitat attributes as defined in the IP model, but also a result of important connections
between habitat types and basal productivity. Therefore, conserving, restoring and protecting
linkages among habitat and channel types may be a key action needed to increase populations of
these fish species.
The DEIS definition of large wood is not the same as the definition of large wood used in the
literature cited by the DEIS (Beechie and Sibley 1997) to estimate frequency of pool formation.
For example, Beechie and Sibley determined that the minimum pool forming diameter of wood
varies as a function of stream size and can be expressed by the equation:
Minimum pool forming wood diameter = 0.028*(Bankfull Width) + 0.0057,
and that pieces < 1 5 cm (6 in) diameter could form pools. However, the DEIS only considers
wood > 50.8 cm (20 in) diameter at breast height (DBH) to be large wood. By excluding all
pieces of wood < 20 inches DBH from their analyses, the DEIS grossly underestimates the
importance of wood to the formation of pool habitat, and by extension the importance of riparian
forests with trees < 20 inches DBH to instream habitat.
Another critical problem with the FPI (pp. H- 109 1-1 092) is that it uses an incorrect equation
(derived from Beechie and Sibley 1997) to estimate that:
The number of pools per channel width = 2.7 - 4.6(slope x LWD/m) + 1.6(slope).
Using this equation, one would erroneously conclude for example that a stream with no wood
and a slope of 0.01 will have about 3 pools per channel width, which is extremely high. The
equation should read:
number of channel widths per pool = 2.7 - 4.6(slope x LWD/m) + 1 .6(slope),
which means that the distance between pools is three channel widths.
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Appendix T - Responses to Public Comments and Comment Letters
Using this inaccurate information, the DEIS erroneously concludes that the pool frequency
ranges from a maximum frequency of 2 pools per channel width (with high wood loading) to a
minimum frequency of 2.7 + 1 .6* Slope {et al. about 3 pools per channel width for a stream
gradient of 0.01). These results clearly contradict Beechie and Sibley (1997, Table 2 and Figure
3), which shows that fewer wood equals fewer pools, and that when there is no wood, estimate
the distance between pools can be as great as 8 channel widths. The cause of this error is that the
analysis confuses “pools per channel width” with the distance between pools, measured in
channel widths. It is not clear how far this error permeates the DEIS.
Because the DEIS inappropriately applies the data from Beechie and Sibley (1997) to estimate
pool frequency, and because these data are applied to estimate the FPI, the FPI appears to be
inaccurate, and the conclusion that there is little difference (< 3%) in fish productivity among the
four alternatives most likely is erroneous.
The DEIS states (p. 734) “relative proportion of the maximum potential watershed coho salmon
productivity ... would increase from the current level of 38% to 2106 levels of 49%...”, yet
presents no basis or source of these values, nor does it discuss the uncertainty associated with
each. Assessing the scientific basis for these claims is virtually impossible without a clear
identification of the analytical assumptions underlying each result, and evaluating the meaning of
any change is truly impossible without a statement of the confidence intervals surrounding these
numbers.
The DEIS assumes that standing stock of wood accumulates without consideration of the
reduction of wood from decay, floods, and other processes. This contributes to the conclusion
that “large wood contributions would increase over time under all four alternatives. . .” (p. 729).
Proper modeling of wood balance would include balance of inputs vs. outputs, such as
decomposition, recognition of (bedrock) bed characteristics making reaches more porous to
wood (May and Gresswell 1 996, Montgomery 1 996), and shifts between hardwoods (fast
decomposition) and conifers (slower decomposition), to quantify changes in standing crop of
wood in comparison to natural abundances of wood in streams.
There are also problems in defining as important only those trees > 150 feet high and > 20
inches diameter at breast height, so that harvest of any trees smaller than these dimensions has no
effect on model outputs {et al., there will be no change in the FPI). This makes it appear that
Alternatives 2 and 3 have little effect on recruitment of large wood, and therefore the FPI,
relative to the No- Action Alternative or Alternative 1 . Thus, for example, the DEIS (p. 113)
concludes that the large wood contribution from all four alternatives “Increases to near
maximum in long term”, and that the large wood contribution from Alternatives 2 and 3 is
“slightly less” (than the No-Action Alternative). Both of these statements are incorrect.
Alternatives 2 and 3 will substantially decrease the large wood contribution to fish bearing
streams relative to the No-Action Alternative, and the decreases will be long-term. This is
because thinning will remove wood large enough to form pools from the riparian zone (if the
term large wood is defined by its ability to form pools rather than the arbitrary value of >20
inches diameter) (Beechie el al. 2000). Alternative 1 will substantially decrease the large wood
contribution to fish-bearing streams from non-fish bearing streams relative to the No-Action
Alternative.
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Also, there is a problem in assigning equal value to wood delivered to fish-bearing streams from
debris flows as is wood delivered to streams from direct riparian recruitment or channel
migration. Since large wood delivered to fish bearing streams from debris flows occurs
infrequently and tends to deposit large piles of wood in and around streams, most of which
contributes little to important functions such as pool formation, it may not be appropriate to
consider a piece of debris-flow derived wood as functionally equivalent to wood entering
streams from other sources. Because the DEIS treats all sources of large wood equally, and
estimates long term annual averages, it exaggerates the average amount of functional large wood
that will be in streams. For example, a stream could have very little functional wood most years,
but a debris flow that deposited a large pile of wood to the stream in a single year would then
boost the annual average and potentially make it appear that there was, on average, substantial
amounts of functional wood in the stream, when in fact that was not the case.
NMFS recognizes that a considerable amount of work went into the fish productivity model, but
for the reasons described above, additional work is needed using: (1) more valid assumptions
about functional wood sizes, value of wood from different sources, and wood longevity; (2) the
correct equation for the number of pools per channel width; (3) a more realistic view of the
totality of factors that may limit fish productivity; and (4) better disclosure of assumptions and
methods used to estimate fish response to stream channel changes.
Nutrient Input
This short section (three paragraphs on p. 741) asserts that all four alternatives will maintain a
level of allocthonous nutrient input that is similar to current levels, which may not be justified.
The DEIS says on p. 741 that “...along non-fish bearing intermittent streams, some localized
shifts in vegetation would occur because the riparian management areas would not include all of
the areas that provide organic matter inputs to streams.” In fact, these streams receive very little
protection under Alternative 2 or 3, and organic matter inputs would be reduced. The FEIS
should provide a more realistic analysis of the effects of the alternatives on nutrient inputs to
non-fish bearing intermittent streams, and discuss how these changes relate to productivity of
fish-bearing streams.
Fine Sediment Delivery
The DEIS states on p. 741 that the fine sediment delivery analysis will focus on changes in
sediment that would “overwhelm the ability of fish to cope with or avoid the stress” of sediment.
This section describes a linear comparison to equate the increase in stream sediment (1%) to a
decrease in fish survival (3.4%). Assuming that this relationship is linear and can be applied
universally across the plan area tends to over-simplify the variety of conditions found within the
plan area. There is no analysis described in this section.
The DEIS (p.741) contends that “...thresholds have not been established for the levels of
sediment delivery that would cause impairment to fish.” There is a wealth of literature on the
effects of fine sediment and aquatic organisms including salmon (et al. , Suttle et al. 2004), and
although true thresholds are difficult to identify, it is certainly possible to establish management
targets that avoid most sediment impacts on salmonid fish, their forage organisms, and their
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m
habitat. Such an approach would require an analysis similar in depth to that completed for the
in-stream wood issue in the DEIS.
The section concludes that there will be no effect to fish populations from increased sediment
loads. This conclusion is based in part on an assumption of no additional landslides under
increased intensity of land management due to use of the TPCC. Please see our comments about
TPCC under Chapter 3, Fish, Sediment, above. The other basis for the conclusion appears to be
reliance on the optional BMPs and the ability of fish to avoid turbidity. Relying on optional
practices and potential avoidance behavior of fish does not provide a reasonable level of
confidence that anadromous fish and their habitat will not be affected by this sediment.
The BLM should provide additional analysis and documentation for this section in the FEIS to
address the issues described above.
Peak Flows
This short section (three paragraphs, p. 743) does not consider the potential effects of increased
magnitude, duration, frequency, or timing of peak flows. This section should discuss how
increased peak flows may affect the biological communities and primary constituent elements of
critical habitat of listed salmonid fish within susceptible subwatersheds, as this is likely to be an
issue during site-specific ESA consultations on timber harvest projects completed after WOPR is
in effect.
Temperature
This one paragraph section on p. 743 primarily downplays the potential effects of increasing
temperature in 31 miles of perennial streams within the Coquille Basin that are currently listed as
water quality limited by the ODEQ for temperature. The reference to mitigation provides an
optional suggestion to maintain additional canopy within the secondary shade zone, but the DEIS
does not provide any meaningful assurance that the mitigation will be applied during project
implementation. The FEIS should provide this assurance by modifying the strategy.
Considering that OC coho are proposed for listing as threatened under the ESA, the FEIS should
provide a higher level of assurance that it will provide the necessary habitat conditions to
maintain and recover their populations. It would be appropriate for the FEIS to make a
commitment to complete mitigation, at the very least, that would restore temperatures on its
lands within the Coquille Basin.
Based on the information presented above for Chapter 3, Water, Temperature, the preferred
alternative (Alternative 2) is likely to increase water temperatures in some fish-bearing streams
in the plan area. By increasing water temperatures in some areas. Alternative 2 is likely to
increase risks to anadromous fish of: (1) increased adult mortality and reduced gamete survival
during pre-spawn holding; (2) reduced growth of alevins or juveniles; (3) reduced competitive
success relative to non-salmonid fish; (4) out-migration from unsuitable areas and truncation of
spatial distribution; (5) increased disease virulence, and reduced disease resistance; (6) delay,
prevention, or reversal of smoltification; and (7) potentially harmful interactions with other
Comments on DEIS for the WOPR - 23 —
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habitat stressors (Zaugg and McClain 1972, Adams et al. 1975, Zaugg and Wagner 1973, Zaugg
1981, Reeves et. al. 1987, Berman 1990, Marine 1992, 2004, McCullough 1999, Dunham et al.
2001, Matema 2001, McCullough et al. 2001, Sauter et al. 2001, Marine and Cech 2004). This
is one of the reasons NMFS is recommending that BLM work with us and EPA to amend the
RMA delineations and management strategies in the selected alternative.
Water
Peak Water Flow
Streams are most susceptible to change in peak flows at scales smaller than sixth field
watersheds (Grant et al. in review). Thus, individual logged reaches within a sixth field
watershed could have peak flow increases that are masked by uncut reaches sharing the same
sixth field watershed. The cumulative effects of multiple small watersheds having increased
peak flows may include limited stream geomorphic change, since most small watersheds are
dominated by large particle size (Grant et al. in review), but could increase fine sediment
transport, with downstream deposition. The DEIS uses the sixth field as the scale for its analysis
and therefore does not acknowledge the potential compounding effects of increased peak flows
from multiple smaller sub water sheds.
Empirical and modeling studies summarized in Grant et al. (in review) suggest that at a
minimum road-related processes increase peak flows; modeling studies for Washington suggest
an approximate doubling of harvest-only effects (Grant et al. in review, p. 15). Road effects are
not included in the DEIS analyses for either hydroregion. The FEIS should include the effects of
road-related changes in peak flows for both hydroregions.
The DEIS analyzes only the magnitude of peak flows. It would also be appropriate to also
consider the frequency and duration of peak flows and their effects to stream processes and the
biological community. Lewis et al. (2001) found that the return interval for the largest peak
flows was halved following clearcutting. Thus the largest peak flows did not increase in size, but
doubled in frequency, “roughly doubling the geomorphic work on the channel.”
Timing of peak flow changes should also be considered in the analysis. Lewis et al. (2001)
found that peak flows increased after clearcut logging, but the increase was only significant at
the beginning of the rainy season, when the soil is driest. These potential changes may have
considerable effects on salmonid fish due to adults spawning at this time. Many of the changes
in peak flow measured following harvest are within the yearly range of flows in studied
watersheds (Grant et al. in review), complicating the ability to detect changes. However, the full
range of flow responses should be considered to determine whether substantive changes in flow
regime would occur following logging.
There are a number of reasons that the results of both paired small watershed studies and process
models, such as those used in the DEIS, should be interpreted cautiously. The sample size
described in the meta-analysis by Grant et al. (in review) relevant to the plan area is small {et al. ,
n-3 for 40-80% ECA rain-dominated systems), with a large amount of variability. Grant et al (in
review) state that peak flow responses can be highly variable due to management factors
Comments on DEIS for the WOPR - 24 —
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Appendix T - Responses to Public Comments and Comment Letters
including roads, types and arrangements of harvest ( et al., clearcut vs. thinning, clumped vs.
dispersed), as well as landscape pattern (Grant et al. in review, p. 53). Hydrologic process
models (Lewis et al. 2001) and spatially distributed dataset models (Bowling and Lettenmaier
1998, Tague and Band 2001) have been developed and used in the Pacific Northwest and can
incorporate some of these parameters. Rain-on-snow modeling used in the DEIS analysis
apparently did not incorporate these parameters.
The FEIS should provide a validation or accuracy assessment for the peak flow models used in
the analysis. The variability across the plan area and the fact that both analyses are untested
within the plan area create low confidence that the results are reliable and accurate. Coupling
these factors with the use of the largest spatial scale suitable to detect changes in peak flows
further reduces confidence in the analysis.
Water Quality - Shade
Based on the information presented above for Chapter 3, Water, Temperature, NMFS disagrees
with the assertion on p. 754 that under Alternatives 2 and 3, the riparian management areas along
permanently flowing non-fish-bearing and fish-bearing streams would fully retain the shade that
is necessary to block sunlight from reaching the streams and increasing their temperature.
Water Quality — Sediment
The DEIS asserts on p. 758 that sediment generation by overland flows (the mechanism for
sediment from cutting and yarding timber) is not an issue because of high water infiltration in
forest soils. The DEIS should provide references for this assertion in the FEIS. Log yarding and
subsequent site preparation ( et al. , prescribed burning, scarification prior to planting) can
increase soil exposure, runoff, and surface erosion (Chamberlin et al. 1991). The magnitude of
effects depends on the type of equipment used; the location ( et al. proximity to stream channels),
extent, and type of disturbance; slope; soil types; the time required for revegetation; and whether
runoff can be concentrated by roads or other features. Under Alternative 2, ground disturbing
activities will occur as close as 25 feet to perennial (including fish-bearing) streams, or up to the
bank of intermittent streams not subject to debris flows. Because buffer widths needed for
sediment filtration vary from 100 to 300 feet or more depending on slope, parent rock type, and
other factors (Spence et al. 1996 p. 219, FEMAT 1993 p. V-38), NMFS predicts that Alternative
2 will increase fine sediment yield to streams in the plan area. Stream-side buffers are not
effective in removing sediment carried in channelized flows (including intermittent streams) that
originate outside of the buffer and continue through it (Belt et al. 1992).
The DEIS also asserts (p. 763) that shallow landslides will not increase over the next 10 years
under any alternative because of the TPCC, and because of site-specific review of proposed
activities. However, the DEIS has not provided information about the effectiveness of the TPCC
withdrawals, or about the procedures, decision criteria, and effectiveness of the site-specific
reviews. Because of the increased amount of timber harvesting under Alternative 2, NMFS
assumes the risks of sedimentation from landslides will also increase.
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Probable increases in sedimentation under Alternative 2 would increase risks that egg to fry
survival of anadromous fish will be reduced, that pool volume and interstitial habitat that support
rearing juveniles will be degraded, and that production of invertebrate forage organisms will
decrease in affected stream reaches (Chapman and McLeod 1987, Gregory et al. 1987, Bjomn
and Reiser 1991, Hicks et al. 1991).
NMFS recommends that the FEIS disclose the potential effects described above. Adjustments to
the preferred alternative likely are needed to ensure that fine sediment yields are not increased in
watersheds that are important to anadromous fish. As stated earlier, NMFS is willing to work
with BLM to develop these adjustments.
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Appendix T - Responses to Public Comments and Comment Letters
n
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approach. Transactions of the American Fisheries Society 136:1088-1 103.
Lewis, J., S.R. Mori, E.T. Keppeler, R.R. Ziemer. 2001. Impacts of logging on storm peak
flows, flow volumes and suspended sediment loads in Casper Creek, Califormia. P. 85-
125 in Land Use and Watersheds: Human Influence on Hydrology and Geomorphology
in Urban and Forest Areas. Water Science and Application Volume 2, American
Geophysical Union, Washington, D.C.
Li, H.W. and 12 others. 1995. Safe havens: Refuges and evolutionarily significant units. Amer.
Fish. Soc. Special Symposium 17:371-380.
Lisle, T.E. 1982. Effects of aggradation and degradation on riffle-pool morphology in natural
gravel channels, northwestern California. Water Resources Research 1 8: 1643-165 1 .
Lisle, T.E. 1989. Sediment transport and resulting deposition in spawning gravels, north coastal
California. Water Resources Research 25:1303-1319.
Lisle, T.E., and S. Hilton. 1992. The volume of fine sediment in pools: an index of sediment
supply in gravel-bed streams. Water Resources Bulletin 28:371-383.
Comments on DEIS for the IVOPR - 30 —
01-11-2008
Appendices - 900
Appendix T - Responses to Public Comments and Comment Letters
Lisle, T.E., and S. Hilton. 1999. Fine bed material in pools of natural gravel bed channels.
Water Resources Research 35:1291-1304.
Lisle, T.E., and M.A. Madej. 1992. Spatial variation in armouring in a channel with high
sediment supply. P. 277-293 in P. Billi, R. D. Hey, C. R. Thome, and P. Tacconi, eds.
Dynamics of gravel-bed rivers. John Wiley and Sons, Ltd., New York.
Madej, M.A. 1982. Sediment transport and channel changes in an aggrading stream in the Puget
Lowland, Washington. P. 97-108 in F. J. Swanson, E. J. Janda, T. Dunne, and D. N.
Swanson, eds. Sediment budgets and routing in forested drainage basins. U.S. Forest
Service General Technical Report PNW-141, Portland, Oregon.
Madej, M.A. 1987. Residence times of channel-stored sediment in Redwood Creek,
northwestern California. P. 429-438 in R. L. Beschta, T. Blinn, G. E. Grant, G. G. Ice,
and F. J. Swanson, eds. Erosion and sedimentation in the Pacific Rim. IAHS Publication
165, Wallingford, UK.
Madej, M.A. 1992. Changes in channel-stored sediment, Redwood Creek, northwestern
California, 1947 to 1980. U.S. Geological Survey Open-file Report 92-34, Denver,
Colorado.
Madej, M.A. and V. Ozaki. 1996. Channel response to sediment wave propagation and
movement, Redwood Creek, California, USA. Earth Surface Processes and Landforms
21:911-927.
Marine, K.R. 1992. A background investigation and review of the effects of elevated water
temperature on reproductive performance of adult Chinook salmon. Department of
Wildlife and Fisheries Biology, University of California, Davis.
Marine, K.R. and JJ. Cech, Jr. 2004. Effects of High water temperature on growth,
smoltification, and predator avoidance in juvenile Sacramento River chinook salmon.
North American Journal of Fisheries Management 24:198-210.
Matema, E. 2001. Temperature interaction. Issue paper 4. Prepared as part of EP A Region 1 0
Temperature Water Quality Criteria Guidance Development Project. EPA-910-D-004.
U.S. Environmental Protection Agency, Region 10, Seattle, Washington. 33 p.
May, C.L. and R.E. Gresswell. 1996. Large wood recruitment and redistribution in headwater
streams of the Oregon Coast Range, USA. Can. J. of Forest Res. 33:1352-1362.
McCullough, D.A. 1999. A review and synthesis of effects of alterations to the water
temperature regime on freshwater life stages of salmonids, with special reference to
chinook salmon. Prepared for the U.S. Environmental Protection Agency, Region 10,
Seattle, Washington. February 22. 279 p.
Comments on DEIS for the IVOPR -31 —
01-11-2008
Appendices - 901
FElSfor^ the Revision 0/ the Western. Oregon. RMPs.
McCullough, D.A., S. Spalding, D. Sturdevant, and M. Hicks. 2001. Summary of technical
literature examining the physiological effects of temperature on salmonids. Issue paper
5. Prepared as part of EPA Region 10 Temperature Water Quality Criteria Guidance
Development
Montgomery, D. R. and W.E. Dietrich. 1994. A physically based model for topographic control
on shallow landsliding, Water Resources Research 30:1 153 1171.
Montgomery, D. and J. Buffington. 1996. Channel reach morphology in mountain drainage
basins. Geological Society of America Bulletin 109: 596-611. From: Stillwater
Sciences/NCASI.
Montgomery, D.R., K.M. Schmidt, H.M. Greenberg, and W.E. Dietrich. 2000. Forest clearing
and regional landsliding. Geology 28(4):3 11-314.
Naiman, R.J., T.J. Beechie, L.E. Benda, D.R. Berg, P.A. Bison, L.H. MacDonald, M.D.
O Connor, P.L. Olson, and E.A. Steel. 1992. Fundamental elements of ecologically healthy
watersheds in the Pacific Northwest coastal ecoregion. P. 127-188 in: R.S. Naiman, ed.
Watershed Management: Balancing Sustainability and Environmental Change. Springer
Verlag, N.Y.
National Research Council. 1996. Upstream - Salmon and Society in the Pacific Northwest.
National Academy Press, Washington, D.C.
Nehlsen, W. 1997. Prioritizing watersheds in Oregon for salmon restoration. Restoration
Ecology 5(4S):25-43.
ODEQ. 2003. A description of the information and methods used to delineate the proposed
beneficial fish use designations for Oregon’s water quality standards. Division 41
revisions. Attachment H to EQC Staff Report. November. Available online at:
http://www.deq.state.or.us/wq/standards/docs/temperature/eqcstafffptatth.pdf
Pitlick, J.C., and C.R. Thome. 1987. Sediment supply, movement, and storage in an unstable
gravel-bed river. P. 121-150 in C. R. Thome, J. C. Bathurst, and R. D. Hey, eds.
Sediment transport in gravel-bed rivers. John Wiley and Sons, London
Project. EPA-910-D-005. U.S. Environmental Protection Agency, Region 10, Seattle,
Washington. 1 1 4 p.
Reeves, G.H., F.H. Everest, and J.D. Hall. 1987. Interaction between the redside shiner
(Richardsonius balteatus) and the steelhead trout ( Salmo gairdneri) in western Oregon:
The influence of water temperature. Can. J. Fish. Aquat. Sci. 44:1603-1613.
Comments on DEIS for the WOPR - 32 —
01-11-2008
Appendices - 902
Appendix T - Responses to Public Comments and Comment Letters
Reeves, G.H. and J.R. Sedell. 1992. An ecosystem approach to the conservation and
management of freshwater habitat for anadromous salmonids in the Pacific Northwest.
Proceedings of the 57th North American Wildlife and Natural Resources
Conference:408-415.
Rice, S.P., Greenwood, M.T., and Joyce, C.B. 2001. Tributaries, sediment sources, and the
longitudinal organization of macroinvertebrate fauna along river systems. Can J Fish
Aquat. Sci. 58:824-840.
Richards, K. 1982. Rivers: Form and process in alluvial channels. Methuen, London.
Rothacher, J. 1973. Does harvest in west slope Douglas-fir increase peak flow in small streams?
Pacific Northwest Forest and Range Experiment Station, US Department of Agriculture
US Forest Service. Portland, OR.
Sedell, J.R., G.H. Reeves, F R. Hauer, and C.P. Hawkins. 1990. Role of refugia in recovery
from disturbances: Modem fragmented and disconnected river systems. Environmental
Management 14(5):71 1-724.
Spence, B.C., G.A. Lomnicky, R.M. Hughes and R.P. Novitzki. 1996. An ecosystem approach
to salmonid conservation. TR-4501 -96-6057. ManTech Environmental Research
Services Corp., Corvallis, OR. Available online at
http://www.nwr.noaa.gov/Publications/Reference-Documents/ManTech-Renort.cfm
Stednick, J.D. 1996. Monitoring the effects of timber harvest on annual water yield Journal of
Hydrology 176:79-95.
Suttle, K.B., M.E. Power, J.M. Levine, and C. McNeely. 2004. How fine sediment in riverbeds
974a*rS ^rowt*1 survival of juvenile salmonids. Ecological Applications 14: 969-
Tague, C., L. Band. 2001. Simulating the impact of road construction and forest harvesting on
hydrologic response. Earth Surface Processes and Landforms 26(2): 135-151.
Washington Department of Natural Resources. 1997. Surface Erosion Module v. 4.0. Available
online at http://www.dnr.wa.gov/forestpractices/watershedanalysis/manual/hvdrologv.pdf
Waters, T. F. 1995. Sediment in Streams: Sources, Biological Effects, and Control. American
Fisheries Society Monograph 7. Bethesda, Maryland.
Zaugg, W.S. 1981. Advanced photoperiod and water temperature effects on gill Na+ -K+
adenosine triphosphatase activity and migration of juvenile steelhead (Salmo gairdneri)
Can. J. Fish. Aquat. Sci. 38(7):758-764.
Zaugg, W.S. and L.R. McLain. 1972. Steelhead migration: potential temperature effects as
indicated by gill adenosine triphosphatase activities. Science 176:415-416.
Comments on DEIS for the WOPR
01-11-2008
Appendices - 903
FEISfor the Revision of the Western Oregon RMPs
Zaugg, W.S., and H.H. Wagner. 1973. Gill ATPase activity related to parr-smolt transformation
and migration in steelhead trout ( Salmo gairdneri ): Influence of photoperiod and
temperature. Comp. Biochem. Physiol. 45B:955-965.
Comments on DEIS for the WOPR
01-11-2008
Appendices - 904
Appendix T - Responses to Public Comments and Comment Letters
RECEIVED
United States Department of the Interior
NATIONAL PARK SERVICE
Oregon Caves National Monument
19000 Caves Highway
Cave Junction, Oregon 97523
IN REPLY REFER TO:
A76(ORCA)
Tim Reuwsaat , District Manager
Bureau of Land Management
Medford District
3040 Biddle Road
Medford, OR 97504-41 19
Dear Tim,
Thank you for providing the opportunity to comment on the BLM’s Western Oregon Plan Revision. In
general, this planning document is one of the most comprehensive and well-written ones we have seen.
However, as required under NEPA, Oregon Caves National Monument should have been directly
consulted as an “affected federal agency” before the final draft. Absent that consultation, we have some
specific comments and questions prior to the end of the public comment period.
The No Action Alternative would have the least adverse impacts to species on the Monument in terms of
air quality (smoke & C02), fire hazard and resiliency, soil disturbance (grazing & harvest), streams
(large-wood, sedimentation & temperatures, non-native invasions, forest fragmentation, forest recovery
from salvage logging, road and ORV trail density, edge effects, and global warming. Alternative 3
would be most detrimental to the Monument, for most of the same reasons, including the fact that it
would result in the least acreage of ACECs (p. 809).
Under the section dealing with mineral extraction, there is no mention of the marble quarry adjacent to
Monument. We assume that the quarry will continue to be withdrawn from mineral extraction under all
alternatives.
Off Road Vehicles
Your planning document states that all alternatives would reduce the amount of area open to off-highway
vehicle use. However, the document also states that under all alternatives, the off-highway vehicle
opportunities would increase (page 777). Does this apparent contradiction mean that in the action
alternatives, ORV areas would be better marked, publicized, or otherwise developed? The document
suggests this but does not directly address the apparent contradiction.
Effects on Species
Extirpations of species on BLM administered lands from some of the listed impacts may lengthen
stochastic extirpations on and in the Monument as a result of reduced migration. Given past
anthropogenic extinctions in southern Oregon, some species have such narrow or narrowed ranges (one or
two counties) that extinctions are likely to occur as well over a hundred year span.
Take Pride'
in/^MERICA^^
Appendices - 905
FEISfor the Revision of the Western Oregon RMPs
There are some actual or likely lepidopteran endemics to the Klamath-Siskiyous. Most
have ranges more restricted geographically, have higher taxonomic status or smaller
populations than those species assessed on p. 714, such as:
Whulge (Taylor’s) checkerspot butterfly (southern range limit in Williamette Valley);
Callophrys polios (hoary elfin) (boreal Pacific NW from NWT to Rockies, disjuncts in
sOR coast, AK, sRockies);
Oregon silverspot butterfly (near coastal southern limit). Fender’s blue butterfly (endemic
to Williamette Valley);
Insular blue butterfly (Plebejus saepiolus insulanus) possibly in Lane Co. near or at
southern limit in range);
Chloealtis aspasma at the southern limit in Jackson Co. of its Benton Co. to sOR range;
Littorina subrotundata (= Algamorda s.; A. newcombiana) at the southern end of its OR
to WA range.
The high biodiversity and endemism of species in caves in Oregon Caves National
Monument suggests that certain BLM-managed caves in the Siskiyous may have similar
biologic values that would qualify them to be nominated as significant under the Federal
Cave Resources Protection Act, an authority not referenced in your document.
Therefore, some non-listed species need to be assessed under environmental
consequences, consistent with page 719 in which “special status species would be
managed to avoid contributing to the need to list as threatened or endangered under the
Endangered Species Act.”
As with about ten beetle taxa, some of the taxa listed below are presently known only
from Siskiyou County in California. These species might soon have a major portion of
their range identified on Oregon BLM lands once comprehensive databases for Oregon
are completed. Further, many of these species are likely to move northward due to
climate change. Some of these species have already been documented over the past few
years as appearing at Oregon Caves National Monument for the first time. Comparison
with just one genus from the more comprehensive (Oregon and California) snail
databases suggests that more pebblesnails should be evaluated than what are listed on
page 715 and that beetles and lepidopterans with narrow ranges are almost as common in
Josephine or Jackson counties as in Siskiyou Co. Larger lists could have been generated
for beetles, snails, macrofungi, and dipterans and smaller lists could be compiled for
many other taxa, such as the stonefly Hydatophylax schuhi (endemic to Klamaths in
Jackson Co., & westernmost Great Basin in Klamath Co., Oregon) and the caddisfly
Rhyacophila colonus endemic to Josephine & Del Norte Cos.).
Species listings should be reviewed by your exceptional staff of botanists before final
publication of the plan to correct some typographical or misspelling errors as indicated in
the following examples:
Volume 1 p. 20
Gentener’s fritillary is misspelled and should be Gentner’s fritillary
Fritillary gentneri is misspelled and should be Fritillaria gentneri
Castelleja is misspelled and should be Castilleja levisecta
2
Appendices - 906
Appendix T - Responses to Public Comments and Comment Letters
Astaragalus applegatei is misspelled and should be Astragalus applegatei
Some statements in the plan should be revised to enhance clarity. We believe that the
following statement could cause confusion:
State listed species where the BLM has not entered into a conservation agreement and
species listed by the BLM as sensitive or assessment species will be managed on public
domain land and on O & C lands where protection does not conflict with sustained yield
forest management in areas dedicated to timber production. This is so that special status
designation would no longer be warranted and so that actions will not contribute to the
need to list the species under the Endangered Species Act. Where conflicts with sustained
yield management occur, protections on O & C lands will only be applied to prevent
extinction of a species even if it is not yet listed under the Endangered Species Act”
The statement as written gives the impression that sustained yield forest management will
help remove special status designation and such actions will not contribute to the need to
list the species. Yet there is no evidence given that this would be the case. Also,
preventing extinction needs to be better defined. Does this mean, for example, the likely
elimination of a species from greater than 50% of its range?
To better understand ways to avoid plant extinctions, it would be useful to analyze
species that likely were once within or close to the management areas covered by this
document but which are now apparently extinct, such as Neothremma siskiyou,
Fluminicola undescribed sp. (Frest & Hohannes, 1 999) (endemic in Shasta River
valley, Siskiyou Co.), Plagiobothrys lamprocarpus and Calochortus indecorus. The
latter should be included even if it was considered a hybrid and not a true species.
Appendix G- 1 068 - Why is Vespericola sierranus listed as a species of concern? It is
abundant in northern California. Does this document assume that species at the limit of
their geographic range are of concern because they are more likely to be extirpated there
than elsewhere? Several similar examples could be cited.
Effects of Climate Change
“The analysis assumes no change in climate conditions, because the specific nature of
regional climate change over the next decades remains speculative”. We believe that any
analysis that assumes no change in climate conditions is itself speculative. Global climate
change has been identified as one of the greatest potential impacts to our National Parks
and their natural and cultural resources. An increase in the average annual regional
temperature is not just likely; it has already occurred. Increased temperatures could also
result in significant changes to hydrologic processes, including reduced snow pack,
earlier snowmelt, and shifting of the rain-on-snow zones. Some of these changes have
already occurred.
3
Appendices - 907
FEISfor the Revision of the Western Oregon RMPs
There is no mention of the likely effects of increased atmospheric carbon dioxide on
changing the carbon versus nitrogen ratio in plant biomass and the resulting effect on
decomposition rates as cited in a recent USFS contracted paper.
Forest Management and Effects from Timber Harvest Activities
p. 564 - The assumption here is that fertilization would speed up growth but there are no
cited references supporting that assertion. Several published studies indicate that the
effect may be negated by adverse affects on ectomycorrhizae and aquatic animals.
The document does not adequately discuss potentially antagonistic effects between
mycorrhizae and fertilization and how that interaction may be important in assuring the
survival of planted trees and enhancing the growth of desirable trees in harvested or
disturbed areas
The assumption that “improved genetics” would increase tree growth also has no cited
references. Several published articles suggest that “improved genetics” for faster growth
may also make trees more vulnerable to insect and fungal infestations.
P. 494 - It is unlikely under most definitions of what defines “old forest” that the “patch
size of mature and structurally complex forests” would increase across all ownerships
under Alternative 3 if 63% is harvested in a century. This is likely to be especially true
when on the same page where it is asserted that “On the BLM-administered lands, the
size and connectivity of the patches of the mature and structurally complex forests would
decrease in all provinces under Alternative 3.”
p. 510 - We recommend that you cite Daniel Sarr, NPS Klamath Network Inventory and
Monitoring Coordinator, and others on the increase in salmonberry dominated areas in
highly productive riparian areas in our region.
p. 557 - It would appear that the volume from thinning is highest under the No Action
Alternative. If true then this alternative would be most likely to accelerate the attainment
of a more natural mix of old growth and structurally complex forests.
Page 723 - We disagree with the assertion that none of the alternatives would result in
increases in stream temperature that would affect fish habitat or populations, except
under Alternatives 2 and 3. Federal key watershed analysis of the Sucker Creek drainage
in Josephine County concluded that stream temperatures would increase due to Port
Orford mortality in riparian areas as a result of Port Orford-Cedar rot. Further into the
document, (p. 756) stream temperatures are analyzed to some extent, although Port
Orford mortality was not taken into account.
Page 745 - We disagree with excluding dissolved oxygen “because their effects are site
specific and have limited applicability to forest management” This needs to be reworded
to say that there are only a few sites with such problems - if indeed this is the case (see
comments on Port Orford mortality).
Appendices - 908
Appendix T - Responses to Public Comments and Comment Letters
p. 749 - “This inconsequential stream lengthening would have no effect on the timing of
runoff. . We believe this statement would be more accurate written as “This
inconsequential stream lengthening would have no measurable effect on the timing of
runoff’
p. 775 - We disagree that sightseeing does not require recreation developments.
Increased activity of this nature generally leads to requested or constructed improvements
on roads and trails including but not limited to roadway enhancement, pullouts and
overlooks.
p. 865 - The definition of sustained yield includes “without impairment of the
productivity of the land”. In conjunction with other BLM goals and objectives,
something should be said of biodiversity, as often the two are incompatible. We believe,
biodiversity should be a goal, as well as the fish productivity stated on page 738, even if
both goals cannot be maximized.
p. 866 - The term “recover potential mortality” is unclear and may not be understood by
other agencies, cooperators or the public.
If you have any specific questions or desire clarification of these comments, please
contact me or Natural Resource Specialist John E. Roth at 541-592-2100. The National
Park Service looks forward to working with you on implementation of the final, selected
alternative in a manner that will protect Monument resources and benefit our shared
stakeholders and owner public.
5
Appendices - 909
FEISfor the Revision of the Western Oregon RMPs
United States Department of the Interior
mo
FISH AND WILDLIFE SERVICE
911 N.E. 11* Avenue
Portland, Oregon 97232-4181
In Reply Refer to:
<eply Refer to:
FWS/R1/AES
JAN 1 0 2008
Memorandum
RECEIVED
JAN 1 5 2008
To:
Project Manager, Western Oregon Plan Revisions
Bureau of Land Management
From:
Assistant Regional Director, Ecological Services, Region 1
Portland, Oregon
I
Subject: Comments on the Western Oregon Plan Revisions
The Fish and Wildlife Service (Service) has reviewed the August 2007 Draft Environmental
Impact Statement (DEIS) for the Western Oregon Plan Revisions (WOPR). Our review has
focused on important trust resources including species listed under the Endangered Species Act
(ESA). In our role as a cooperating agency on the WOPR, we have been involved for the last 3
years in discussing and advising Bureau of Land Management (BLM) on the development of the
DEIS. We have continued to work with the BLM following release of the DEIS and have made
progress in offering recommendations for a final action. We have focused our attention on
identifying important conservation needs of listed species and possible management actions to
address those needs.
We recognize that BLM must balance a number of goals and objectives as they move forward
with revised land management plans. Our comments reflect our mandate to comment on
concerns with fish and wildlife resources as addressed in the DEIS, especially those associated
with the Late-successional Reserve (LSR) network established via the Northwest Forest Plan.
The LSR network provided a conservation strategy for many old grow dependent species,
including marbled murrelets and northern spotted owls (spotted owls), federally listed species
under the ESA. The Service’s Draft Recovery Plan for the northern spotted owl relies on a
smaller footprint of management areas than is currently provided for with LSR, although
management of the areas would be similar. The Service received a number of comments from
scientists and the public on the draft recovery plan. Based on the concerns raised, we have
requested a science panel to review the scientific basis of the plan in addition to the science
relevant to the ecology of the owl. We recognize that the BLM relied on the same science
relevant to the owl, including the draft recovery plan, and will keep BLM informed as to the
results of the science panel.
Take PrideTEt-^ -»
IM A
inAmerica^^<
Appendices - 910
Appendix T - Responses to Public Comments and Comment Letters
General Comments:
1 . We believe Alternative 1 provides a protected network of large blocks of late-
successional forest habitat that contains the greatest level of conservation among the
action alternatives.
2. The landscape management outcomes produced from Alternative 3 do not appear
favorable for achieving a viable conservation strategy for spotted owls, marbled murrelets
and fisher (a candidate species). The alternative does not provide large blocks of habitat,
removes and degrades current habitat through partial harvests, increases fragmentation,
thereby reducing overall habitat quality over the planning horizon, and only provides
temporary protection to known sites of listed species. Additionally, Alternative 3 does
not specifically provide any special management direction in designated critical habitat
for listed species.
2. We believe the retention of structural legacies including green trees, snags, and down
wood is a fundamental component of providing for wildlife and ecological diversity and
should be incorporated as a strategy in the preferred/final alternative. Without a robust
strategy to provide for structural legacies there is concern that these older forest
characteristics will be lost in future stands produced from regeneration harvest. The
incorporation of structural legacies in young stands provides those elements needed to
more quickly accelerate the development of habitat for species associated with late-
successional forest. We recommend that green tree and snag retention be representative
of the average stand diameter or larger.
3. In August 2007, the Service, BLM, and Forest Service signed a Conservation Agreement
for the Siskiyou Mountains salamander ( Plethodon stormi ). The agreement and
associated Conservation Strategy are intended to promote the conservation of the species.
We suggest acknowledging the implementation of this Agreement in the final EIS and
RMP.
4. For the purposes of jeopardy analyses under section 7 of the ESA, the Service must
address the effect of an action, in this case the BLM’s selected alternative of the WOPR,
on a species numbers, distribution, and reproduction. While we have commented on a
broader scale, information needed to address these parameters is included in species
specific comments.
Below are more specific comments on particular species or species groups.
Northern Spotted Owl
Population Issues
BLM has contributed to supporting the Northern Spotted Owl Effectiveness Monitoring Plan as
part of the regional monitoring strategy developed under the NWFP. The purpose of this
monitoring effort is to assess trends in spotted owl populations and habitat. Monitoring efforts
have provided integral information on northern spotted owls since inception of the NWFP. We
recommend that the DEIS state whether BLM will continue to participate in this monitoring
Appendices -911
FEISfor the Revision of the Western Oregon RMPs
3
effort in Western Oregon and whether any changes to that monitoring effort will be proposed
under the selected alternative.
We recommend the DEIS contain an evaluation of the effect of the alternatives on known spotted
owl sites. BLM has some of the best and most extensive spotted owl databases; apparently there
is no use of this information in the DEIS beyond describing the 2001 to 2004 occupancy,
including no analysis specific to the alternatives. In addition, the description of occupancy
would be more useful if addressed by District and/or physiographic province.
With respect to the key points on page 282, the DEIS states that populations have been stable
since 1985 on Roseburg, Coos Bay, and Medford Districts, and the Klamath Falls Resource
Area. What is the basis for this conclusion on Coos Bay, Medford, and Klamath Falls? We are
unaware of demographic studies addressing these Districts, and therefore assume that BLM
extrapolated from data on other study areas, which carries uncertainties of comparability. The
statement does not indicate the source of the information, nor does it seem to acknowledge the
uncertainty potentially involved. We recommend that BLM cite the information used for this
statement, including the basis for this extrapolation and indicate which demographic study areas
are being used in this portion of the document.
Other Non-habitat Factors
The analysis of the effect of the alternatives on spotted owls is generally limited to habitat
conditions and does not address non-habitat effects to populations that may operate on BLM
lands. There appears to be an implicit assumption that habitat (at appropriate distribution and
levels) will be occupied by spotted owls. However, this does not acknowledge the effect of non-
habitat factors, in particular barred owls. The Service acknowledges that there are information
gaps regarding the effects of barred owls on spotted owls and habitat usage, and that research is
underway to address these information needs. The DEIS should acknowledge these
uncertainties over barred owl effects on spotted owl populations and describe the manner in
which BLM intends to respond to future changes in spotted owl numbers. A final Recovery Plan
should assist BLM in developing an adaptive management response to an unacceptable decline
in spotted owl numbers.
Habitat Issues
Page 634 states that both quantity and quality of habitat is analyzed. However, the rest of the
section does not address quality, but simply shows the quantity for each alternative and the
change over time. We recommend including a discussion of the quality of the various forest
classes. This is particularly important given that the increase in younger forest habitat acres is
used to offset the loss of “152,400 acres of existing old forest under Alternative 1 [sic]...”
(should read Alt. 2 on page 507 assuming Table 151 is correct). Figure 201 also displays a
reduction of old-growth forests on BLM lands and an increase of younger forest habitat over the
100 year analysis time frame (page 589). The impact of replacing existing old forest with
younger habitat needs to be fully analyzed since not all spotted owl habitat provides equal
benefits to spotted owls. Younger replacement habitat may not provide the full range of benefits
to spotted owl survival and reproduction.
Appendices - 912
Appendix T - Responses to Public Comments and Comment Letters
4
Dispersal habitat analysis
The current analysis addresses the total amount of dispersal habitat in general and by 6th field
watershed, but is not as clear on how the distribution of the 6th field watersheds with lower
amounts of habitat effects the potential dispersal. Furthermore, the maps in the DEIS (pages
664-665 ) demonstrate the current status and no harvest scenario, but lack a similar visual for the
other alternatives, including the preferred alternative. Without a similar spatial representation of
dispersal habitat for the preferred alternative, we have insufficient information to provide
specific comments. Some type of landscape-level discussion of the pattern is important to the
understanding of dispersal.
Stand Level Management Issues
Neither Alternative 1 nor Alternative 2 provides any leave trees in regeneration harvest units.
This would likely, over time, reduce the quality of harvested units to provide for spotted owl
dispersal across the landscape between the Late-successional Management Areas (LSMAs) by
depleting the majority of the prey-base and structural cover in harvested units. The Service
recommends adding green tree retention and snag creation/retention guidelines at levels that will
increase the likelihood of spotted owl prey species persisting in harvested areas until habitat
develops again.
Down wood is a critical component of spotted owl habitat, in particular for spotted owl prey.
There are no down wood requirements for Alternative 1 and 2 in timber management areas other
than leaving noncommercial wood. We recommend adding requirements that would establish a
base level of retained wood, requiring larger wood be left to meet the target if noncommercial
wood is insufficient.
Reserve Design - Size and Location
It is our understanding that Alternative 2 was developed based on the guidelines for Options 2 in
the Draft Recovery Plan for the Northern Spotted Owl (USFWS 2007) As previously stated,
peer review of the draft plan identified issues regarding the scientific foundation of the plan,
particularly Option 2. The Service is undertaking an independent, scientific review to address
these criticisms. The Service will continue to work with BLM as we identify ways to resolve the
issues raised by the peer review.
Page 652 of the DEIS states that in Alternative 2 LSMAs “were allocated explicitly to create
spacing of no more than 12 miles between blocks large enough to support 20 pairs (defined in
Table 187), and to create spacing of no more than 7 miles between blocks large enough to
support 10-19 pairs” with the support of Forest Service lands. We concur with the inclusion of
Forest Service LSRs in your analysis of future habitat blocks, but question the size of some
blocks. Some of the Alternative 2 LSMAs, as described in Table 190, appear to rely on the
inclusion of adjacent non-federal acres to achieve the large block size needed to maintain 20
pairs. This is problematic because of the low likelihood that these lands will provide significant
contributions of suitable habitat in the long-term. We agree with the assessment on page 639
that most non-federal lands are unlikely to provide suitable habitat and these lands should not be
relied upon for significant contributions for long-term planning. We suggest this assessment be
considered in the block size and spacing analysis of Alternative 2.
Appendices - 913
FEIS for the Revision of the Western Oregon RMPs
5
Reserve Management
The Service believes thinned stands in the LSMA allocation should follow a variable density
thinning prescription in an effort to create stands with a greater diversity of canopy heights, tree
size, species diversity and openings, among other characteristics. We recommend adding this
specifically to the thinning management action for this allocation in Alternatives 1 and 2.
Currently, there is not enough specificity for us to understand how thinning in LSMAs will allow
or accelerate owl habitat development.
As described above, down wood is very important to northern spotted owl prey. The legacy
snags and downed wood created by stand replacing events are important components of high-
quality spotted owl habitat, and the landscape distribution of pockets with high quantities of
snags and down wood are likely the most difficult to mimic through silvicultural actions.
Retaining some percentage of these components in LSMAs would help meet BLM objectives for
this allocation. If salvage is allowed in LSMAs, we recommend that the DEIS include standards
specific to the minimum amount of leave trees (burned and not) to meet the ecological
development needs, with the remainder available for harvest.
Marbled Murrelet
The marbled murrelet recovery plan (USFWS 1997) relies on the LSR network of the Northwest
Forest Plan (USDA and USDI 1994) to achieve recovery and describes any suitable habitat in
LSRs within Zone 1 as essential nesting habitat for the species (USFWS 1997, page 131). These
areas are also currently designated and proposed critical habitat for murrelets (USFWS 1996 and
2006 Alternative 1 is consistent with the murrelet recovery plan in providing a network of well
distributed, large blocks of protected habitat. Alternative 1 projects a gradual increase in
murrelet habitat in Zone 1 (0-35 miles inland) during the first 50 years and additional increases
out to 1 00 years. In addition, Alternative 1 would maintain and improve habitat quality and
possibly reduce nest predation
We believe the strategy for Alternative 2 overlooks key recommendations of the marbled
murrelet recovery plan and its guidance for achieving the recovery needs of the species.
Alternative 2 projects a continual decrease in the amount of murrelet habitat for the first 50
years, and excludes important areas from habitat protection in LSMAs. Although the Alternative
projects habitat will increase from 50-100 years, this has uncertain value to the species if the
preceding 50 years of habitat declines produces population impacts that result in fewer murrelets
occupying BLM administered lands. Alternative 2 holds the potential to decrease habitat quality
and increase nest predation. Nest predation is a major threat to the species and increased
predation resulting in reduced reproductive success of murrelets could forestall recovery. The
Service believes the LSMA network of Alternative 2 and projected loss of habitat during the first
50 years does not provide an effective strategy to address the conservation and recovery needs of
the marbled murrelet.
In our role as a Cooperator, the Service has worked with the BLM to review the murrelet
recovery plan actions along with BLM’s most recent survey and habitat information to develop a
potential strategy that recognizes BLM’s timber management needs as well as the recovery needs
of the murrelet. The outcome of the team was a mapped LSMA network that focused on
Appendices - 914
Appendix T - Responses to Public Comments and Comment Letters
6
conservation in Zone 1 . We recommend this work be further refined and considered as a basis
for a final strategy in the WOPR.
Currently, BLM management under the RMPs implements murrelet surveys prior to timber
harvest in suitable habitat. When surveys identify murrelet occupied sites, those areas are
protected from harvest. This is an important management action in determining where occupied
murrelet sites occur on the landscape and is emphasized in the recovery plan under recovery
action 4. 1 .6. The plan states, “all aspects of marbled murrelet recovery in the terrestrial
environment depend on identification of nesting habitat”. Surveys are the only practical means
of identifying marbled murrelet nesting areas (i.e. occupied sites). Alternative 1 proposes to
maintain surveys prior to habitat-disturbing activities and the DEIS projects that surveys would
lead to the discovery of 601 new occupied marbled murrelet sites. Alternative 2 does not
propose to maintain surveys prior to habitat-disturbing activities, and using the same projection
from Alternative 1 , approximately 600 occupied murrelet sites would be available to timber
harvest impacts. Furthermore, the number of murrelet sites that could be impacted would likely
be higher under Alternative 2 because of its smaller LSMA network compared to Alternative 1 .
The DEIS does not contain an analysis of the population effects from the loss of occupied
murrelet sites due to discontinuing surveys and protection of additional sites under Alternative 2.
The Service believes that surveys prior to removal of suitable habitat that result in protection of
occupied nest sites are a critical component in providing for adequate conservation of nesting
habitat and breeding sites. We recommend the final EIS/RMPs include direction to continue
surveys prior to timber harvest and protect areas where occupied behaviors are observed.
Aquatic Species and Riparian Habitat
The designation of Riparian Management Areas relies heavily on the information contained in
the document “Northwest Forest Plan Temperature TMDL Implementation Strategies” dated
September 9th 2005. The Service was asked by the BLM and Forest Service to comment on the
TMDL Implementation Strategies and did so in a letter addressed to Kathym J. Silverman and
Michael J. Haske dated July 24, 2007 (attached). In the letter, the Service comments on several
items in the TMDL Implementation Strategy that could benefit from further description or
explanation. Given the significant role of the TMDL Implementation Strategies document/
SHADOW model in regard to the designation of riparian buffer widths/management areas,
clarity in the DEIS could be provided by addressing our previous set of comments.
The information provided in the DEIS chapter 3, affected environment, stream temperature
section, heavily cites the Northwest Forest Plan Temperature TMDL Implementation Strategies
document in regard to describing solar physics and relationships between shade zones and
temperature changes. The TMDL Implementation Strategies document is specific in regard to a
narrow/focused evaluation of solar radiation delivery to water bodies and the resultant
temperature change. The TMDL Implementation Strategy document acknowledges that the
strategy only pertains to temperature related issues and does not address other important riparian
functions such as hydrologic, geomorphic, and ecologic processes that affect riparian condition.
The DEIS relies on shade zones to set Riparian Management Area widths, but the DEIS does not
resolve issues associated with reduced riparian area widths as it pertains to hydrologic,
geomorphic, and ecologic processes that affect riparian condition and ultimately fish resources
(listed or not).
Appendices - 915
FEISfor the Revision of the Western Oregon RMPs
7
The TMDL Implementation Strategy document acknowledges that stream orientation, sinuosity,
aspect, bank and channel stability, channel migration, and the potential for sediment loading
must also be considered in determining the width of the primary shade zone. The DEIS needs to
explain how these factors are accounted for in delineating the width of the Riparian Management
Areas across the broad landscape of the WOPR area.
Aquatic species of high interest to the Service include bull trout, shortnose and Lost River
suckers, coastal cutthroat trout, and Pacific lamprey, in addition to anadromous salmonids.
These species would benefit from management that provides for recovery or conservation
measures that would preclude the need to list under the ESA. In addition to fish-bearing streams,
the riparian buffers for non fish-bearing streams are equally important for the needs of sensitive
species, including amphibians such as the tailed frog and torrent salamanders (BLM sensitive or
assessment species). These amphibians rely on cold, clear water and adjacent riparian areas with
late-successional forest characteristics. The buffers in Alternative 2 provide little forest retention
that maintains these characteristics, and in the case of small streams, no conifer forest buffer is
retained. On page 345 the DEIS states, “a small portion of the headwater stream network is
important in producing landslides and debris flows that can provide large wood to streams”,
however, this rational does not recognize that the majority of watershed area is adjacent to
intermittent and low order headwater streams, so cumulatively, these areas may be
disproportionately important in creating and maintaining aquatic habitats. We recommend the
DEIS include more clarity and specificity on how the reduced buffer widths in the action
alternatives adequately address the conservation and recovery needs of listed and sensitive
aquatic and riparian species.
Botany
Federally Listed Plants
The DEIS on page 594 describes all alternatives as having no loss of occupied habitat, individual
plants, or populations as a result of management activities because species recovery measures
would be applied. We understand that Appendix E provides an abbreviated summary of
recovery plan actions, but we are unclear how these actions relate to management commitments
in WOPR that lead to protecting plants as intended. For example, if plant surveys were a key
action to ensuring no loss of plants or populations prior to management, they should be identified
as a management action. It would be helpful to provide more specificity on which recovery
actions would be implemented. This is particularly important for listed plants that do not have
completed recovery plans.
On page 46, Table 19, we note an error in the inclusion of Kincaid’s lupine as a species with a
completed recovery plan. The Service anticipates a draft recovery plan available for review in
the summer of 2008.
BLM Sensitive and Assessment Species
There are 134 species identified as BLM special status species that occur in the planning area.
Under BLM’s Special Status Species Policy conservation measures would be applied for many
of these species. According to the DEIS, conservation measures would not be applied to special
status species in the conifer habitat group that occur on O&C lands unless 20 or fewer
Appendices - 916
Appendix T - Responses to Public Comments and Comment Letters
8
populations were known to exist. On page 46, it states that where species conflict with sustained
yield management, protections on O&C lands will only be applied to prevent extinction. The
Service is concerned that managing species populations to only prevent extinction could reduce
species numbers or populations to a point where conservation measures are applied too late to be
effective. This could present a high risk of local extirpation and contribute to the need to list
species under the ESA. Page 604, states, “Any population losses from management activities to
species with 20 or fewer populations would contribute to the trend toward local extirpation or
extinction of the species within the planning area (Ellstrand and Elam 1993, USFWS 2003, Kaye
pers, com. 2007, Friedman, pers com, 2007).’’ The total number of populations needed for
species persistence may depend on many factors including the health or robustness of the
individual populations, distribution, rate of decline, and the degree of threats affecting those
populations. For example, eight plant species in Oregon were listed under the ESA with greater
than 20 populations. We recommend the DEIS acknowledge that the health of individual
populations, the threats to those populations as well as the total number of populations need to be
examined when considering whether to provide conservation measures. There may be concern
for species persistence when greater than 20 populations exist.
We recommend the final EIS provide more clarity as to whether BLM management presents a
risk of extirpation or extinction of any sensitive and assessment species in the conifer habitat
group, and whether certain species may need additional conservation measures. In the interest of
complete information, we suggest a table of the Special Status Species in the conifer forest
habitat group that would be provided with conservation measures and those species that would
not be protected. The table should include number of populations, the population size in areas,
and respective number of individuals in the populations. The final EIS should also acknowledge
the Conservation Agreement for the Wayside Aster ( Euchephalis vialis ) recently completed in
2006 between the Service, BLM, and Forest Service.
Land Birds
Appendix A of the DEIS lists various major legal authorities relevant to the proposed plan
revisions, but does not include the Migratory Bird Treaty Act (MBTA)(191 8). The MBTA
makes it unlawful, “by any means or manner, to pursue, hunt, take, capture [or] kill" any
migratory bird except as permitted by regulation (16 U.S.C. 703-704). On July 18, 2000, the
United States Court of Appeals for the District of Columbia held in Humane Society v.
Glickman, 217 F. 3d 882 (D.C. Cir. 2000), that the MBTA applies to Federal agencies. As all
Federal agencies are subject to the jurisdiction of the D.C. Circuit, the Service implements the
MBTA consistent with this decision. Therefore, take of migratory birds by Federal agencies is
prohibited unless authorized pursuant to regulations promulgated under the MBTA. The DEIS
analyzes effects on land birds (i.e. migratory birds), but it is not clear how those effects comport
with the BLM’s obligations under the MBTA. We suggest adding the MBTA to the list of major
legal authorities that are relevant to the planning process.
In concert with the MBTA and other relevant legal authorities, we recommend adding Executive
Order 13186 (Responsibilities of Federal Agencies to Protect Migratory Birds), which states that
each Federal agency taking actions that have, or are likely to have, a measurable negative effect
on migratory bird populations is directed to develop and implement a Memorandum of
Understanding with the Fish and Wildlife Service that shall promote the conservation of
migratory bird populations, with special emphasis on management for Birds of Conservation
Appendices - 917
FEISfor the Revision of the Western Oregon RMPs
Concern. We suggest some analysis on whether such an MOU is necessary to address any
negative effects to migratory bird populations, especially in eastside conifer forests where the
analysis predicts significant negative trends in habitat.
In the DEIS, we support the use of the Partners in Flight (PEF) bird conservation plans, structural
features of the habitat classes, and focal species that indicate those desired conditions. In
particular, we emphasize support for retention of legacy components of green trees and snags (in
clumps) in regeneration harvest units. We note that none of the focal habitats in Altman’s
Lowlands and Valleys bird conservation plan is incorporated (see Table 103) despite the overlap
with BLM lands, and your reference to this bird conservation plan (Altman 2000b on p. 327).
This could be addressed by including plant groups called Riparian, Oak, & Chaparral, and
choose focal species that represent habitat conditions as with the other analytical groups adopted
in the DEIS from the other PIF plans.
On page 328, the habitat objectives are general, but no link is provided to the Focal Species in
Table 103. Focal species are responsive to the habitat conditions listed in Table 103, and their
abundances indicate success in achieving desired habitat conditions. Monitoring abundance of
focal species should be mentioned here, as the path to evaluating the effectiveness of
management. Since they are ‘analytical groups’ of land birds, the DEIS should explain how they
will be analyzed. It should be noted that several species in Table 100 should occur in more than
one group. For example, Purple Martin and Lewis’s Woodpecker under the ‘snag-dependent’
group, Yellow-breasted Chat under the ‘riparian’ associates, and White-headed Woodpecker and
Flammulated Owl should be under the ‘older forest’ associates.
The analysis of effects on land birds from the alternatives concludes that all alternatives meet
objectives for mature and structurally complex forests. While this may be the case at 100-year
projections, the analysis does not evaluate the effects to species in the near term (10-50 years)
where some alternatives exhibit a decline of structurally complex forests prior to later increases
(50-100 years out). The consequences for some birds of concern would be improved with
retention of structural legacies including green trees, snags, and down wood well distributed in
regeneration harvest units. Lacking a strategy for retention of structural legacies is likely to add
to the declining status of some Birds of Conservation Concern.
Summary
In closing, these comments are intended to assist the BLM in developing a final management
plan that addresses late-successional and old-growth forest resources and complies with the ESA.
We have significant concerns that the preferred alternative would undermine current efforts to
provide conservation and recovery of currently listed species, in particular the northern spotted
owl and marbled murrelet. However, we believe the DEIS has analyzed the building blocks for a
strategy that would fully meet the BLM’s obligations. We are currently working with your
agency to address these issues and value our role as a cooperator in the development of the final
Resource Management Plans. We appreciate the opportunity to review the DEIS and look
forward to continued collaboration. If you have questions regarding these comments, please
contact Lee Folliard or Miel Corbett at (503) 231-6179.
Appendices - 918
Appendix T - Responses to Public Comments and Comment Letters
10
References:
USDA (U.S. Department of Agriculture) and USDI (U.S. Department of Interior). 1994. Record
of decision for amendments to Forest Service and Bureau of Land Management planning
documents within the range of the northern spotted owl; standards and guidelines for
management of habitat for late-successional and old-growth forest related species within the
range of the northern spotted owl. USDA Forest Service and USDI Bureau of Land
Management. Portland, Oregon.
USFWS (U.S. Fish and Wildlife Service). 1996. Endangered and Threatened Wildlife and
Plants; Final Designation of Critical Habitat for the Marbled Murrelet; Final Rule. Fed. Reg
Vol. 61. 102:26256-26320. May 24, 1996.
USFWS (U.S. Fish and Wildlife Service). 1997. Final recovery plan for the marbled murrelet.
U.S. Fish and Wildlife Service. Portland, Oregon.
USFWS (U.S. Fish and Wildlife Service). 2006. Endangered and Threatened Wildlife and
Plants; Designation of Critical Habitat for the Marbled Murrelet; Proposed Rule. Fed. Reg. Vol.
71. 176:53838-53951. September 12, 2006.
USFWS (U.S. Fish and Wildlife Service). 2007. 2007 Draft Recovery Plan for the Northern
Spotted Owl, Strix occidentalis caurina : Merged Options 1 and 2. Portland, Oregon. 170 pp.
Appendices - 919
FEISfor the Revision of the Western Oregon RMPs
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 10
1200 Sixth Avenue
Seattle, WA 98101
January 9, 2008
Reply to
EPA Ref: 91-0079-BLM
Attn Of: ETPA-088
Edward W. Shepard, State Director
USDI Bureau of Land Management
Western Oregon Plan Revisions
P.O. Box 2965
Portland, OR 97208
Dear Mr. Shepard:
The U.S. Environmental Protection Agency (EPA) has reviewed the Draft Environmental Impact
Statement ( DEIS) for the Revision of the Resource Management Plans of the Western Oregon Bureau of
land Management (BLM) Districts of Salem, Eugene, Roseburg, Coos Bay, and Medford, and the
Klamath Falls Resource Area of the Lakeview District (CEQ No. 20070332). Our review has been
conducted in accordance with our responsibilities under the National Environmental Policy Act (NEPA)
and Section 309 of the Clean Air Act.
The Western Oregon Plan Revision (WOPR) will establish management guidelines for
approximately 2.6 million acres of BLM-managed land in Western Oregon. The DEIS considers a “no
action” alternative (current management under the Northwest Forest Plan) and three additional action
alternatives. The current annual timber harvest level is 268 million board feet and riparian management
area (RMA) widths range from 180 feet to 360 feet depending on stream type. Alternative 1 proposes an
annual timber harvest level of 456 million board feet and proposes RMA widths of 90 feet to 180 feet
depending on stream type. The preferred alternative. Alternative 2, proposes an annual timber harvest
level of 727 million board feet, proposes RMA widths of 25 feet to 100 feet depending on stream type,
and increases timber harvest levels within RMAs. Alternative 3 sets annual timber harvest at 471 million
board feet and employs a riparian strategy similar to Alternative 2.
EPA recognizes the management challenges created by the mixed private/federal ownership of
the WOPR landscape, the diverse resource needs, and multiple statutory requirements. The BLM EIS
interdisciplinary team is to be commended for their effort in this ambitious and difficult undertaking. We
also want to recognize BLM’s efforts to engage and inform the public in new and innovative ways and
trust this will help inform BLM’s selection and development of the proposed action in the final EIS.
EPA has served as a cooperating agency on this project for over two years. In that capacity, EPA
has consistently raised concerns about the sufficiency of the aquatic/riparian strategy in Alternatives 2 and
3 in meetings, during WOPR planning criteria and alternatives development, and in writing. EPA’s
concerns have not been addressed in the DEIS. These concerns are heightened by what EPA believes to
be the lack of a sound scientific basis for the aquatic/riparian strategy proposed in Alternatives 2 and 3.
EPA is concerned that Alternatives 2 and 3 would result in substantial, long-term impacts to
water quality and exacerbate current exceedances of water quality standards in streams listed as impaired
under Section 303(d) of the Clean Water Act (impaired waters). EPA is also concerned about significant
impacts to drinking water and aquatic species that could be corrected by project modification or choosing
Appendices - 920
Appendix T - Responses to Public Comments and Comment Letters
2
another feasible alternative. Direct, indirect and cumulative impacts would affect waters on both BLM
and non-BLM lands. Therefore we have assigned this draft EIS a rating of EO-2 (Environmental
Objections - Insufficient Information). A copy of the rating system used in conducting our review is
enclosed for your reference.
Watersheds covering approximately one million acres of the BLM planning area include streams
that do not meet water quality standards (WQS) designed to protect drinking water, aquatic life, and other
beneficial uses. Over 900 stream miles on BLM lands in the planning area are listed as impaired due to
management-related temperature, sediment, and other pollutant loadings. Over one million Oregonians
receive their drinking water from source water originating in watersheds on BLM lands in western
Oregon. Salmon and trout species listed under the Endangered Species Act (ESA) and numerous at-risk
fish stocks are dependent on cold water refugia on BLM lands within a fragmented western Oregon
landscape where degraded conditions exist on non-BLM lands. To ensure that management of BLM lands
protects and restores water quality, drinking water, and aquatic life, EPA recommends inclusion of a
demonstrated, conservative aquatic protection strategy in the proposed action alternative in the final EIS.
On streams listed as impaired for failing to meet WQS, the Oregon Department of Environmental
Quality and EPA are required to develop total maximum daily loads (TMDLs) that address water quality
impairments. The Aquatic Conservation Strategy (ACS) under the Northwest Forest Plan (NWFP) has
been a cornerstone of the federal land contribution to water quality improvement for BLM lands and for
developing and implementing TMDLs. Monitoring and assessment efforts have demonstrated the success
of the ACS in improving watershed health on federal lands. EPA considers these improvements to be an
important achievement and we are deeply concerned that alternatives 2 and 3 would reverse positive
trends achieved under the ACS. Extensive research and assessment efforts support continued application
of the ACS as necessary to protect riparian functions critical to maintenance and restoration of water
quality and beneficial uses.
For example, there are 710 stream miles in the WOPR planning area that do not meet the State
WQS for temperature. The RMAs currently in place under the ACS will provide the system potential
shade as well as the full complement of large wood inputs and sediment filtering necessary for improved
stream conditions and reduced stream temperatures. In addition to the broad body of science related to
water quality and riparian function (please see our enclosed detailed comments), modeling conducted by
EPA indicates that application of WOPR Alternatives 2 and 3 would increase stream temperatures
substantially more than predicted in the DEIS.
Additional water quality concerns identified in our review include impacts to sediment loading
and peak flow from increased harvest levels and decreased riparian protection. Our analysis, also detailed
in the enclosure, indicates that the modeling approach taken in the DEIS likely underestimates the
contribution of sediment from the road network, land management activities, and debris flow events. It
appears that the DEIS underestimates the number of watersheds susceptible to peak flow increases and
related water quality impacts, due to the nature of data and assumptions that were used in the peak flow
analysis.
Finally, we are concerned that the action alternatives in the DEIS do not afford additional
protection for BLM lands in the WOPR planning area that provide drinking water to over one million
Oregonians through 1 13 community water systems. Given the importance of BLM lands to drinking
water in Oregon, the potential direct water quality impacts under the action alternatives, and the
cumulative effects to water quality from harvest on BLM and adjacent private lands, EPA believes that a
more protective approach should be pursued in source water areas on BLM lands.
Appendices - 921
FEISfor the Revision of the Western Oregon RMPs
3
In order to address the issues we have identified in our review, we recommend that the final EIS
consider the adoption of a more conservative approach to RMAs as follows:
• In those watersheds currently meeting water quality standards, and which are not designated for
fish recovery or public water supply, EPA recommends adoption of RMAs as described in the no
action alternative or as described in Alternative 1.
• In watersheds with impaired waters, and watersheds designated for fish recovery or public water
supply, we recommend adoption of RMAs as described in the no action alternative.
• Where Key Watersheds have been identified, EPA recommends that they be maintained, and
managed consistent with direction obtained from watershed analysis and source water protection
plans.
• We also recommend that the final EIS consider the adoption of a requirement for continued
watershed analysis and a monitoring and adaptive management program.
Our detailed comments and recommendations are enclosed. EPA appreciates the opportunity to
engage with BLM as a cooperating agency and recognizes the challenges posed by adhering to the
rigorous schedule assigned to this EIS. EPA remains committed to working with BLM to address these
issues . If you have any questions regarding EPA’s comments, please contact me at 206-553-1272, or
Christine Reichgott, Manager, NEPA Review Unit at (206) 553-1601.
Sincerely,
I si
Michelle Pirzadeh, Director
Office of Ecosystems, Tribal and Public Affairs
cc: ODEQ, Neil Mulane
NOAA, Mike Tehan
USFWS, Kemper McMaster
EPA, Dave Powers
Enclosures: 1) EPA Region 10 Detailed Comments
2) EPA Rating System for Draft EISs
Appendices - 922
Appendix T - Responses to Public Comments and Comment Letters
Western Oregon Plan Revision
Draft Environmental Impact Statement
EPA Detailed Comments
1.0 WATER QUALITY
EPA is concerned that Alternatives 2 and 3 would result in substantial, long-term impacts
to water quality and exacerbate continued exceedances of water quality standards in
streams listed as impaired under Section 303(d) of the Clean Water Act (CWA). EPA’s
concerns are based on a broad body of science related to riparian buffer effectiveness and
water quality, information provided in the DEIS, and EPA water quality temperature
modeling of the DEIS riparian protection strategy. EPA’s analysis of the alternatives’
potential impacts related to temperature, sediment and peak flow is provided below. We
also provide input on the analytical assumptions underlying the DEIS modeling effort
that relate to shade and buffer width.
1. 1 SCOPE AND CONTEXT
BLM lands in Western Oregon provide drinking water to over one million Oregonians
through 1 13 community water systems (USDI/USDA, 1996). In addition, there are many
Oregonians not served by community water systems that rely on BLM lands for drinking
water. There are currently over 900 stream segments on the 303(d) list in the BLM
planning area which are impaired by excess temperature, sediment, and other pollutants.
These streams do not meet the water quality standards which are deemed to be protective
of beneficial uses such as fish and aquatic life and drinking water.
The aquatic conservation strategy (ACS) currently in place on BLM lands is recognized
by EPA and the Oregon Department of Environmental Quality (DEQ) as key to the
implementation of TMDLs and meeting water quality standards. The ACS is also a
critical element of DEQ’s conditional approval of BLM’s temperature total maximum
daily load (TMDL) implementation strategy.
When the Northwest Forest Plan (NWFP) was adopted, studies showed 70 percent of
streams on lands administered by the BLM to be out of compliance with CWA standards
(FEMAT Report, Chapter V). After 10 years of NWFP implementation, watershed
conditions for 57% of the watersheds across the NWFP area have improved and only 3%
of the watersheds, primarily in areas that have experienced large scale fires, are on a
declining trend (Gallo, et. al., 2005). In an analysis of several hundred research,
assessment, and monitoring efforts, investigators found that the level of management in
the NWFP is appropriate, stating that there is “no scientific evidence that either the
default prescriptions [riparian reserves] or the options for watershed analysis in the
Northwest Forest Plan... pro vide more protection than necessary to meet stated riparian
management goals.” (Everest et. ah, 2006). The overwhelming body of science and the
1
Appendices - 923
FEISfor the Revision of the Western Oregon RMPs
importance of aquatic resources to drinking water and aquatic species strongly support
continued application of aquatic protection measures currently in place on BLM lands.
1.2 TEMPERATURE ANALYSIS
EPA has examined the science and assumptions in the DEIS supporting the proposed
stream shade target and the proposed riparian management area (RMA) widths for
perennial streams. We have concerns about how the information was used to support
conclusions in the DEIS. In addition, we have concerns about relying on “natural
variability” as a management concept in the analyses. Based on our review and our own
modeling efforts, we are concerned that Alternatives 2 and 3 would result in impacts to
water temperature and exacerbate continued exceedances of temperature standards in
impaired waters.
1.2.1 Shade Target
The DEIS states that 80% effective stream shade .. corresponds to less than a 0.2°F
change in stream temperature per mile of stream, which is considered to be within the
range of natural variability.” (p. 750). This conclusion is based on an interpretation of
figure 3 1 1 in the DEIS (p. 1-1 1 16). Figure 3 1 1 was developed as part of the 2005
Northwest Forest Plan Temperature TMDL Implementation Strategy (TMDL Strategy).
EPA worked closely with DEQ, the Forest Service and BLM as the TMDL Strategy was
developed. We are concerned that individual components of the TMDL Strategy (such as
figure 311) have been excised and incorporated into the DEIS in ways that are
inconsistent with agreed upon criteria and caveats associated with TMDL Strategy
implementation.
The TMDL Strategy was developed to demonstrate the adequacy of existing direction
(i.e. the NWFP ACS) to protect and maintain stream shade, and to demonstrate how
riparian thinning could benefit long-term achievement of higher shade levels and other
riparian functions in site specific cases. It was not intended that an 80% stream shade
target would be adopted as a landscape target. Nor was it intended that the site-specific
management provisions within the TMDL strategy would be implemented independent of
the Northwest Forest Plan and its attendant standards and guidelines.
Under the TMDL Strategy, riparian thinning is limited to projects in dense stands that
would benefit from thinning. The Strategy also limits thinning within the RMAs and
calls for continued application of the NW Forest Plan ACS. The need to implement the
ACS was reiterated by DEQ in their 2005 approval of the temperature TMDL Strategy
for use on federal lands within the NWFP area. In addition, DEQ's approval letter calls
for continued monitoring, and additional analysis for shade, sediment, and cumulative
effects. EPA believes that WOPR alternatives 2 and 3 are not consistent with the TMDL
Strategy and do not meet the terms of the DEQ conditional approval.
2
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Appendix T - Responses to Public Comments and Comment Letters
1.2.2 Riparian Management Area Determination
Alternatives 2 and 3 apply a 1 00-foot Riparian Management Area to perennial streams.
The justification for this prescription relies on Figure 5 in Brazier and Brown (1972),
which is represented as Figure 98 in the DEIS (p. 367). This figure relates angular canopy
density (ACD) to buffer width. There are a number of limitations to the use of the Brazier
and Brown study which are not acknowledged in the DEIS. First, this study was done on
a small non-random sample of 1 3 reaches along nine small mountain streams in Oregon
bringing into question the extrapolation of the study to a broad scale. Secondly, the
relationships identified in the Brazier and Brown study may be subject to artificially high
R“ values.
For example, Figure 3 in Brazier and Brown illustrates the observed relation between
buffer strip width and heat blocked. While the calculation behind this figure includes a
regression with a high R2 (0.8749), that high R2 is achieved by excluding 4 data points
and forcing the regression calculation through 0. Recalculating that regression with all
'y
1 3 data points and without forcing the regression through 0 leads to an R" of less than
0.2. This key relationship on which the analysis of buffer width is largely based is much
more complex than portrayed in the DEIS.
It is also important to acknowledge that the Brazier and Brown shade study did not
account for the likelihood of riparian corridor blow-down, disease, or other factors that
reduce angular canopy density. Research has found that in the 1 to 3 years after harvest,
windthrow affects, on average, 33% of buffer trees with blowdown exceeding 90% at the
high end of the range (Grizzel and Wolff 1998). Other analysis from the west Cascades
of Oregon indicates that about 75% of riparian buffers less than 80 feet wide experience
greater than 20% blowdown (Pollock et. al. 1998). In 2007, the Washington Department
of Ecology compared the Brazier and Brown shade curve with a shade curve derived
from a study done by Steinblumes et al. (1984) that accounted for blowdown in the
riparian buffer. (WADOE, 2007). The results of that comparison are captured in
Figure 1:
Figure 1. Shade Curve Comparison
3
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FEISfor the Revision of the Western Oregon RMPs
As can be seen in Figure 1, the buffer widths needed to achieve a given shade level are
wider under the Steinblums curve than are those under the Brazier and Brown curve.
For example, to achieve an angular canopy density of 80%, the Steinblums curve
suggests that a buffer of at least 120 feet is needed. We also note that the Steinblums
curve shows ACD to be still increasing beyond 120 feet. Brosofske et al. (1997)
analyzed the relationship between solar radiation received by streams and buffer widths
for streams in western Washington. The Brosofske study measured solar radiation
directly (using a LI-COR silican pyranometer) as opposed to visually estimating solar
radiation (ACD measurement). This study found that 100% of natural shade levels are
provided by riparian areas approaching 250 feet wide. These findings are in contrast with
the DEIS which states, “There is little shade gained from trees that are more than 1 00 feet
away from a stream’s edge” (p. 366).
Based on the information presented above, EPA believes that there are flaws with the
analytical assumptions associated with the buffer width model, and that the model
therefore significantly underestimates shade levels and the potential temperature
responses of alternatives 2 and 3.
1.2.3 Managing to “Natural Variability”
As noted above, the DEIS concludes that maintaining 80% effective shade corresponds
roughly to a 0.2°F increase over 1 mile, and that this is “within the range of natural
variability” (DEIS, p. 750). EPA is concerned that a 0.2° F increase would be in conflict
with TMDL load allocations established for some basins. DEQ's TMDLs generally call
for system potential shade (which may be greater or less than 80% shade) and some
TMDLs in the planning area have load allocations less than 0.2° F for nonpoint sources
(Umpqua basin and Willamette TMDLs). The TMDLs within the planning area include
load allocations that represent a threshold protective of both aquatic life and water
quality. We recommend that the DEIS use TMDL allocations or other scientifically
supported targets at least as protective of stream temperature conditions as TMDLs.
Another sound approach would be for the DEIS to commit to and analyze no net increase
in stream temperature loading, and propose a system of modeling (and monitoring) at
smaller spatial scales.
1.2.4 Temperature Modeling
As noted above, the DEIS bases its conclusion that 80% effective stream shade
“...corresponds to less than a 0.2°F change in stream temperature per mile of stream...”
(p. 750) largely on figure 311. This approach relies on a non reach-specific temperature
model sensitivity analysis conducted in 1999 as part of the Upper Sucker Creek
Temperature TMDL analysis. In this analysis, the model sensitivity analysis was not
used to evaluate stream temperature response. The DEIS, however, uses these modeling
results to predict temperature response to timber harvest across the plan area. Because
this model is not reach-specific and does not consider site specific conditions or seasonal
4
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Appendix T - Responses to Public Comments and Comment Letters
temperature variation, EPA believes this approach does not predict or evaluate stream
temperature response to the proposed alternatives in a meaningful way.
Recent modeling efforts and field studies indicate that stream temperature response to
buffer width can be highly variable, and sensitive to site-specific conditions. The
Washington Department of Ecology (2007) modeled the effects of several riparian buffer
widths on stream temperature. Over 1,000 feet of harvest, they documented increases of
1.5, 1.2, and 1.1 °F for buffer widths of 30, 50, and 75 feet, respectively. In 2005, Moore
considered field studies looking at 30 meter buffers. That publication described
temperature responses ranging from 0.5° F (in British Columbia) to 3.6° F in Oregon
(Moore 2005, Table 1).
This observed variability and sensitivity to small changes in the riparian zone suggests
that application of heat budget models, such as Heat Source1 * * * 5, should be used to diagnose
temperature variations in response to riparian stand treatments and as a tool for confident
extrapolation to new management situations. To this end, EPA conducted several
temperature model runs for Canton Creek. Canton Creek is a temperature-impaired
waterbody located in the Umpqua Basin for which a TMDL was recently completed. We
employed the Heat Source model used in development of the Umpqua TMDL to evaluate
the temperature change resulting from the application of alternatives 2 and 3. This
modeling (included as attachment A) demonstrates that the application of Alternatives 2
and 3 would increase the 7-day average daily maximum (ADM) stream temperatures on
Canton Creek over 0.7° F. This is substantially greater than the 0.2° F per mile
temperature increase predicted by the DEIS (p. 750). Further, the EPA modeling results
indicate that management on BLM lands under Alternatives 2 and 3 would increase
instream temperatures on downstream “private” lands along Canton Creek.
In addition, because it can be expected that the narrower riparian buffers under
Alternatives 2 and 3 would result in significant blowdown (see blowdown discussion in
section 1.2.2), EPA adjusted the Canton Creek model to evaluate the effects of blowdown
on stream temperature consistent with appropriate blowdown research. Results showed
that the 7-day ADM temperature increases would exceed over 2 degrees F on Canton
Creek (see Attachment A).
These modeling results lead us to conclude that the riparian management scenario under
Alternatives 2 and 3 would significantly compromise BLM’s ability to meet water quality
standards for temperature and TMDL load allocations. The impacts would be direct,
cumulative and have long-term effects both on and off of BLM lands.
1 Heat Source is the temperature model used by Oregon Department of Environmental Quality to quantify
temperature response to prescribed TMDL allocations. The Heat Source model was review by the
Independent Multidisciplinary Science Team (IMST) and they concluded that it is a scientifically sound
model and incorporates the major physical factors that determine stream temperature -
http://www.fsl.orst.edu/imst/reports/summaries/2004-01es.pdf.
5
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FEISfor the Revision of the Western Oregon RMPs
1.3 SEDIMENTA TION ANAL YSIS
The DEIS states that the increase in the amount of fine sediment delivered to streams
from new permanent roads would be less than 1% under each of the alternatives (p. LXI).
This appears to be the primary source of management-related sediment considered to
impact water quality in the DEIS. EPA is concerned that this conclusion appears to
understate the contribution of sediment from the larger road network, land management
activities, and management-related debris flow events. EPA recommends that the FEIS
further consider the following issues as they relate to Alternatives 2 and 3.
1.3.1 Road Related Sediment
In the DEIS, the analysis of sediment delivery to streams is limited to the portion of BLM
roads “within 200’ of a stream channel where ditch flow carrying fine sediment could
enter streams” (p. 377). DEIS Table 1 15 projects that approximately 36% of the BLM
road miles would likely deliver sediment. This stream-connectivity value is lower than
values established by previous research. A 1 997 study of channel network extension by
forest roads in the western Cascades of Oregon found 57% of roads are hydrologically
connected to streams (Wemple et al. 1996). Reid and Dunne (1984) reported 75% road-
stream connectivity in the Clearwater basin of Washington. Waterbars, midslope road
segments, and cross-drain culverts not associated with stream crossings can also deliver
sediment to streams (Skaugset and Allen, 1998). EPA believes the contribution of
sediment from a larger portion of the road network is likely and should be considered in
analyzing potential sediment impacts.
1.3.2 Harvest Related Sediment
The sediment modeling approach in the DEIS does not account for forestry related
activities such as yarding, skidding, site preparation, and canopy removal which have
been demonstrated to contribute to surface, gully and large-mass soil movements
(Megahan 1972, Karwan et al. 2007). Alternatives 2 and 3 are of particular concern, as
they have narrower RMAs on both perennial and intermittent streams and allow extensive
timber harvest within and outside of RMAs.
Under Alternatives 2 and 3, harvest of trees within and adjacent to RMAs would decrease
both bank stability and canopy-related protection of soils with attendant increases of
sediment delivery to streams. Vegetation strongly influences the mode and timing of
erosion processes through modifications to soil strength, surface materials, and
hydrology. Roots are effective at avoiding progressive bank failure (Thome 1990) and
root networks in forests can lend cohesion to soils of low inherent strength (Schmidt et al.
2001). Shallow landslides in some areas are characteristically located at some distance
from the nearest trees (Roering et al. 2003). Forest canopy intercepts precipitation and
contributes periodic inputs of organic material to the forest floor reducing the
displacement of soils near streams. Sediment inputs from bank disruption tend to be
relatively fine-grained, and can increase turbidity during low-flow periods when natural
turbidity levels tend to be low. Low-flow inputs can stress aquatic organisms already
impacted by low flows or high stream temperatures (Reid 2005).
6
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Appendix T - Responses to Public Comments and Comment Letters
Alternatives 2 and 3 would allow harvesting of all but 10-15 trees per acre (leaving
approximately one tree every 1 15 feet) within the 25-foot RMAs along non-debris flow
intermittent streams. These streams constitute a major portion of the stream network,
particularly in western Oregon, and have a high probability of excessive erosion from
ground disturbing activities where a moderate to high erosion hazard is present. In some
watersheds (e.g., Scappoose Bay Watershed) the majority of the intermittent stream
network on forested lands has a moderate to high erosion hazard rating (David Evans and
Associates, 2000). In addition to extensive harvest next to intermittent streams, removal
of 50% of the canopy over a substantial portion of the RMAs within 100 feet of perennial
streams would be permitted under alternatives 2 and 3. Clearcutting with no green tree
retention would occur directly adjacent to the 25-foot and 100-foot buffers, respectively.
1.3.3 Stream Channel Sediment
The significant reduction of trees within harvested riparian buffers and clearcutting
adjacent to RMAs would result in near term and long term reductions of inputs of large
wood, particularly for intermittent stream channels. Wood, in both intermittent and
perennial streams, serves to route, store, and attenuate the downstream delivery of
sediments. Montgomery et.al. (2003) showed that the sediment retained on site behind
large downed wood can be fifteen times greater than sediment transported downstream.
Large wood also plays an important role in forming and providing habitat for aquatic
species.
The ecological impact of reduced large wood inputs has been documented in watersheds
with a high proportion of private lands in western Oregon. Oregon Department of Fish
and Wildlife surveys on 2,000 miles of streams on private industrial forest lands found
that 60% of the surveyed streams were rated as poor for large wood, and large conifer
stocking levels on 94% of these streams were rated as poor. The surveys also found
elevated sediment levels in smaller streams on private industrial forest lands (Thom et al.
1999). From 1995 - 2004 over $30 million was spent by the Oregon Plan partnership for
riparian and instream enhancement projects to address degraded riparian and stream
conditions on private lands. Forest Service and BLM lands are frequently the only source
of large wood within mixed ownership watersheds for projects on private lands. BLM’s
proposed RMAs and harvest requirements under Alternatives 2 and 3 have the potential
for significant direct and cumulative impacts related to large wood inputs and associated
sediment effects, and EPA believes these issues warrant consideration in the FEIS.
1.3.4 Debris Flow Events
“Landsliding, mass failures, and debris torrents” are discussed as potential results of
harvest (DEIS, p. 378). However, sediment and large wood delivery related to these
processes are marginalized in the DEIS analysis, which assumes “the rate of
susceptibility to shallow landsliding from timber harvests. . .would not increase. . .because
fragile soils that are susceptible to landsliding... would be withdrawn” (DEIS, p. 763).
This assumption conflicts with observed landslides on BLM lands not withdrawn from
7
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FEISfor the Revision of the Western Oregon RMPs
timber harvest. The Timber Production Capability Condition (TPCC) approach BLM
used to identify “fragile soils” in the DEIS was developed to identify the land base
suitable or unsuitable for harvest, not specifically to predict potential landslide sites. The
DEIS indicates that 71% of the 1996 landslides measured on BLM lands were from
clearcut harvest units that are still in the land base suitable for harvest (p. 379). Based on
the DEIS soils analysis, some areas judged to be of lower risk have failed in the past (p.
797). The DEIS indicates that 89,937 acres of the 2,600,000 acre WOPR area (less than
4% of the land base) are withdrawn from timber harvest via TPCC. Given the observed
landslides on BLM harvest units and research demonstrating that clearcut logging on
unstable landforms increases landslide frequency (Sidle 1985, Swanston 1991, Robison
1999), we believe that a more conservative approach to classifying and managing
landslide prone areas is warranted.
1.3.5 Sediment Modeling
In modeling sediment impacts, the DEIS caps the sediment delivery buffer at 200 feet,
and assumes that 25-100 feet of filtering duff and vegetation will prevent most diffuse
sources of sediment from reaching streams (p. 1-1 108). EPA believes that a more
conservative transport estimate should be used. Belt and O’Laughlin (1994) conclude
that an effective buffer width is 91m (300ft) unless the runoff forms a channel. They also
note that sediment-laden runoff in channels can travel through buffers up to 1370m
(4500ft). While narrower buffers can be effective at filtering sediment, buffer
effectiveness is largely dependent on site specific factors such as soil roughness and
structure, hillslope, existing vegetation, and the extent of disturbance. Much of the
Oregon Coast Range and many other areas in Western Oregon on BLM lands include
steep topography and erosive soils. In the absence of site specific analysis, EPA believes
the EIS should employ more conservative assumptions about sediment travel distance.
1.4 PEAK FLOW ANALYSIS
An examination of available literature and the assumptions guiding the modeling
approach undertaken in the DEIS indicates that the DEIS underestimates the number of
subwatersheds susceptible to peak flow increases; specifically, the DEIS states that only
one out of 635 subwatersheds in the rain hydroregion and only three out of 471
subwatersheds in rain-on-snow hydroregion within the Plan Area are currently
susceptible to peak flow increases.
1.4.1 Peak Flow Literature and Assumptions
The DEIS cites Grant et. ah, 2007 (in review) to conclude there would be no detection of
changes in peak flows until the area cut in a drainage basin exceeds 40%. Applying this
assumption, the DEIS finds that none of the alternatives would result in increases in peak
flows in fifth-field watersheds to a level that would affect fish habitat. Because the Grant
et al. article has not yet been published, EPA has not had an opportunity to review it. If
this study was designed to determine a threshold cut level, above which peak flow
alterations are virtually certain, EPA recommends that the EIS analysis acknowledge this
8
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Appendix T - Responses to Public Comments and Comment Letters
and reassess peak flow impacts using different threshold assumptions. Hypothesis tests
designed to minimize Type I errors (false assertion of adverse impacts) are standard and
acceptable procedures in scientific research, but they are often inappropriate for assessing
alternatives designed to minimize adverse water quality and natural resource impacts. A
primary objective in impact analysis is to prevent type II errors in interpretation of data
(false assertion of no adverse impact) (McGarvey 2007). Application of this type of
statistical equivalence test may require re-analysis or re-interpretation of the cited Grant
et al. information to specify a level of cut below which absence of hydrologic alteration is
reasonably assured.
In addition, the DEIS relies heavily on this one unpublished citation, while discounting
the findings from other published studies on the same topic. For example, Jones and
Grant (1996) reported that road construction combined with patch clear-cutting of 10 to
25% of the basin area produced significant, long-term increases in peak discharges.
Lewis et al. (2001) found that clearcutting can double the return interval frequency for
the largest peak flow. And a study conducted within the planning area (South Umpqua
Experimental Forest) found that watersheds treated with partial harvest may be subject to
significant peak flow increases (Jones 2000). EPA recommends that the FEIS reanalyze
the potential impacts of harvest on erosion rates and stream turbidity levels assuming
higher and more frequent peak flow events.
1.4.2 Peak Flow Modeling Approach
On BLM lands, stand establishment structural stage was used as a surrogate for the
removal of basal area. For adjacent non-BLM lands areas of less than 10%, crown closure
were used as a surrogate for the removal of basal area (DEIS p. 384). Data underlying
the peakflow analysis on BLM lands was derived from the OPTIONS model, and data for
“other lands” was derived from the 1996 Interagency Vegetation Mapping Project
(IVMP). These methods raise a number of issues: 1) the rationale for establishing
surrogate measures for the removal of basal area is not provided; 2) the methods
employed to evaluate surrogate measures use two different time frames (BLM lands used
modeled outputs and non-BLM lands used a 1996 dataset); and 3) the use of 10% crown
closure as a surrogate for the removal of basal area may underestimate the actual area
which should be included as part of the “surrogate measure”.
The 1996 Interagency Vegetation Mapping Project (IVMP) produced several high quality
datasets. EPA identified four IVMP datasets that could be used to estimate the canopy
cover conditions on non-BLM lands: 1) “Vegetation Canopy Cover” 2) “Conifer Canopy
Cover” 3) Harvest History (1972 through 2002) and 4) Size Class (Quadratic Mean
Diameter). EPA analyzed each of these IVMP datasets as potential “surrogate measures”
for “basal area removal”. Our analysis found that the number of 6th field HUCs shown to
exceed 40% cut varied depending on the dataset considered (between 0 and 19%). This
discrepancy calls into question the DEIS conclusion that only 1 out of 635 subwatersheds
in the rain hydroregion (DEIS, p. 385) and only 3 out of 471 subwatersheds in rain-on-
snow hydroregion (DEIS, p. 387) within the Plan Area are currently susceptible to peak
flow increases. We recommend that the FEIS address this discrepancy, clarify which
9
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FEISfor the Revision of the Western Oregon RMPs
datasets were used, and provide the rationale for dataset and “surrogate measure”
selection (i.e., 10% crown closure).
2.0 SOURCE WATER
EPA is concerned that management within the 5 or 4 hydrologic unit codes (HUCs)
upstream from water system intakes do not receive a more protective harvest approach
under the proposed action alternatives. In particular, we are concerned that
implementation of Alternatives 2 or 3 could result in impacts to drinking water supplies
due to increased sediment and harvest related chemical use.
2.1 Management in Source Water Watersheds
As noted above, over 1 million Oregonians in the planning area receive their drinking
water from source water watersheds located on BLM land. Under the NWFP a number
of these source water watersheds were designated as Tier 2 Key Watersheds in response
to concerns over water quality. Within Key Watersheds, management is guided by
watershed analysis, road building in inventoried roadless areas is restricted, and priority
is given to restoration. These measures have resulted in a higher level of improved
watershed conditions than in non-Key watersheds (Gallo et al. 2005). Under the
proposed action alternatives, key watershed designations would be removed, riparian
protection would be reduced, and a larger proportion of source water watersheds would
be managed as part of the timber base.
Given potential water quality impacts from management activities associated with
proposed increased harvest, EPA is concerned that source water watersheds would
receive insufficient management consideration. Of key concern is increased sediment
and harvest related chemical use. Sediment can affect drinking water supplies by causing
taste and odor problems, blocking water supply intakes, fouling treatment systems, and
filling reservoirs. In addition, higher turbidity levels are often associated with higher
levels of disease-causing organisms, such as viruses, parasites and some bacteria. Higher
turbidity and associated health problems can result in an acute health threat to the
drinking water system users. Many treatment facilities are not designed to deal with
turbidity spikes, nor to remove the full spectrum of chemicals from drinking water. The
use of fertilizers, herbicides, and other chemicals associated with silvicultural activities is
a major concern to many municipalities. Even the best state-of-the-art drinking water
treatment facilities cannot fully remove many of the commonly used pesticides and fire
retardants (Blomquist, J.D. et al, 2001).
Several Oregon municipalities are currently working to address high turbidity levels in
their source water resulting from forest practices on private lands upstream of public
water intakes. These turbidity levels can be largely attributed to roads and harvest levels,
especially in areas where protection is limited on steep slopes and along intennittent and
smaller perennial streams. The RMA boundaries and no cut zones along perennial
streams under Alternatives 2 and 3 are similar to prescriptions in place on private lands
which EPA, NMFS and USFWS have found are not sufficient to protect water quality
10
Appendices - 932
Appendix T - Responses to Public Comments and Comment Letters
and restore salmonid fisheries. (Multi-agency comment letter on 2000 draft report titled
DEQ/ODF Sufficiency Analysis, dated February 28, 2001). We also note that harvest
within RMAs around a large percentage of intermittent streams under alternatives 2 and 3
would allow harvest right up to the streams edge. This is particularly significant because
over half of the streams within a watershed may be intermittent.
EPA believes that providing the highest quality water possible to source intakes at the
least cost to downstream users should be the management objective on BLM lands within
watersheds providing public water supply (see section 6.0 - Socioeconomics). We
recommend the proposed action in the FEIS maintain the network of key watersheds as
mapped under the no action alternative, and continue to manage those areas consistent
with direction obtained from watershed analyses and source water protection plans.
Further, we recommend that a more protective harvest approach be adopted for riparian
areas within the 5th or 4th code HUCs upstream from water system intakes (see section 3.0
- Recommendations).
3.0 RECOMMENDATIONS TO ADDRESS SOURCE
WATER AND WATER QUALITY CONCERNS
In discussions with BLM to date, EPA has identified the need for additional protection
measures for aquatic resources within the planning area. We recommend that the
following elements be given consideration in the FEIS and be included in the proposed
action alternative ultimately selected by BLM in the Record of Decision. EPA's
recommendations are strongly supported by research, monitoring, and assessment efforts
relevant to protection of water quality, drinking water, and aquatic resources.
• In those watersheds currently meeting water quality standards, and which are
not designated for fish recovery or water supply, EPA recommends adoption
of RMAs as described in the no action alternative or as described in
Alternative 1.
• In watersheds with impaired waters, and watersheds designated for fish
recovery or public water supply, we recommend adoption of RMAs as
described in the no action alternative.
• Where Key Watersheds have been identified, EPA recommends that they be
maintained, and managed consistent with standards and guidelines under the
no action alternative or information obtained from watershed analysis and
source water protection plans.
• We also recommend that adoption of a requirement for continued watershed
analysis and a monitoring and adaptive management program be considered
in the final EIS.
11
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FEISfor the Revision of the Western Oregon RMPs
4.0 CUMULATIVE EFFECTS
The DEIS repeatedly notes that in western Oregon, BLM is rarely the predominant
landowner within a fifth-field watershed, and that the management of the intermingled
private lands differs from that of the BLM-administered lands. This creates implications
for the management of BLM lands (DEIS p. 184, 189, 196, 233). It remains unclear,
however, to what degree conditions on lands outside of BLM ownership were considered
in the analysis. This is of particular concern in the context of stream temperature, stream
complexity (sediment and large wood), fish and wildlife habitats, source water impacts,
and watershed restoration.
4.1 TEMPERATURE
In determining that none of the alternatives would contribute to an increase in
temperature, the DEIS shade analysis on page 1-1118 only considers shade zones on
BLM-managed lands. BLM’s analysis does not consider effects from the mixed
ownership present in most of the planning area. EPA recommends that reduced shade
levels from BLM alternatives be considered at the watershed scale. Given the importance
tB
of shade in regulating stream temperature, EPA conducted an analysis of shade at the 5
field watershed scale on four watersheds in the planning area (Scappoose, Upper Alsea,
Upper Siuslaw, and Rock Creek) using the RAPID shade model developed by BLM and
the Forest Service. Results of this modeling (included as attachment B) demonstrate that
in each of the watersheds considered, shading levels on private land are significantly
lower than shade levels on BLM land. Stream shade on private land ranged between 41%
and 54%, whereas shade levels on BLM land approached 80%. Streams flowing through
mixed ownerships will be affected by lower shading levels on private lands. We
therefore recommend that this variability be considered within the context of cumulative
impacts.
4.2 SEDIMENT AND LARGE WOOD
Thom and Jones (1999) found that private non-industrial lands in western Oregon are
characterized by higher fine sediment levels, lower wood volumes and number of key
(large) wood pieces, lower densities of deep pools, and lower levels of shading. They
also found that on the private lands surveyed, very few stream reaches had high quality
habitat largely due to sediment loading. Within this context, federal lands play a key role
in terms of providing areas of high quality refugia. Without high quality refugia,
moderate quality areas cannot support a large abundance of salmonids through periods of
frequent disturbance (Thom and Jones 1999). We recommend that the FEIS fully discuss
the ecological role of BLM lands within areas of mixed ownership. This would include
an examination of all potential sediment sources, including (as noted above) roads
currently excluded from analysis, harvest activity and debris flow. This analysis should
also consider the potential for blowdown. As noted previously, riparian buffers
experience an average of 33% blowdown in the 2 years following harvest. This has
implications for future large wood recruitment, bank stability, sediment delivery, and
temperature.
12
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Appendix T - Responses to Public Comments and Comment Letters
4.3 DRINKING WATER
Many of the source water watersheds in the planning area are also in mixed
(checkerboard) ownership. Within these watersheds, land in private ownership is often
managed more intensively than is federal land. In these instances, it is often the federal
lands which have the large intact blocks able to provide the ecosystem services
(temperature regulation, nutrient cycling, filtration, flow attenuation, and storage)
necessary to maintain high quality drinking water (see Attachment C - Example Source
Water Watershed). Cumulative impacts to drinking water systems should be considered
within this context, and EPA believes BLM should consider guidelines directing federal
land managers to work closely with drinking water system operators and local watershed
groups to ensure that management on federal land will not adversely impact water
systems and drinking water quality.
4.4 WA TERSHED RESTORA TION
EPA believes that the importance of BLM lands to water quality, drinking water, and fish
and wildlife habitat is significant from a cumulative impacts perspective where a
substantial portion of watersheds consist of private lands. There are approximately 90
local watershed groups in Oregon that have spent tens of millions of dollars to protect
and restore watersheds in Western Oregon. Many of the watershed groups have
completed watershed assessments outlining science based conservation and restoration
strategies that apply watershed wide, to both federal and private lands. EPA believes that
proposed reductions of riparian and upland habitat protection under Alternatives 2 and 3,
and to a lesser extent Alternative 1, run counter to many of those strategies. For example,
the Scappoose Bay Watershed Assessment (David Evans and Associates, 2000) identifies
intact habitat areas and potential salmonid refugia within the watershed. While BLM
lands make up only about 15% of the total watershed, a disproportionately high amount
of intact habitat and refugia areas are found on BLM lands, including intact riparian areas
and all of the remaining old growth in the watershed. The Scappoose Bay Watershed
Council has worked with BLM spending almost two million dollars to restore habitat and
remove barriers to ESA listed steelhead and coho to allow access to salmonid refugia on
BLM lands. BLM lands also provide the highest quality habitat in the Scappoose Bay
Watershed’s municipal water supply catchments. Alternatives 2 and 3 would allow
intensive timber harvest that could adversely impact drinking water and salmon recovery
efforts in 3 of the 4 highest priority drainages in Scappoose Bay Watershed.
5.0 ECOSYSTEM BASED MANAGEMENT
In developing the NWFP, scientists and managers from NOAA Fisheries, and the U.S.
Fish and Wildlife Service Services, land management agencies, and EPA incorporated
knowledge about species needs and aquatic systems functions into an ecosystem
management framework designed to conserve both terrestrial and aquatic ecosystems.
This integrated approach resulted in significant overlap between areas managed for late
successional species (late successional reserves or LSRs) and areas managed for other
13
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FEISfor the Revision of the Western Oregon RMPs
ecosystem functions, such as providing high quality water and refugia for at-risk fish
species (Key Watersheds and Riparian Reserves).
Monitoring and assessment efforts indicate that this integrated approach is delivering
environmental benefits in areas of key concern to EPA, such as water quality protection,
watershed restoration, and protection of public water supply. Assessment of 10 years of
NWFP implementation found that 97% of the watersheds where the NWFP has been
implemented are on a stable or improving trend, and that 74% of the “key” watersheds
targeted for restoration showed improvement (PNW-GTR-647, Gallo et al. 2005). Fate
Successional Reserves (FSRs) also had higher watershed condition scores than Matrix
lands designated for timber harvest. Considering these results, we are concerned that the
reductions in FSRs and riparian reserves, and elimination of key watersheds proposed in
Alternatives 2 and 3 should be considered within an ecosystem-based context.
5. 1 LA TE SUCCESSIONAL RESERVES
Beyond providing habitat for late successional and old-growth (FSOG) dependent
species, LSRs play an important role protecting and restoring water quality, providing
refugia for salmonids, and supplying large wood (NWFP 1994). Monitoring and
assessment results indicate that these are performing well with respect to improved
FSOG and watershed conditions. In spite of these positive terrestrial and aquatic habitat
gains, Alternative 2 reduces the amount of area managed for late successional
characteristics by 17%. We recommend that consideration be given to the role played by
these areas in tenns of providing key ecosystem services beyond FSOG habitat.
5.2 RIPARIAN RESERVES
Riparian protection zones are the primary mechanism for protecting water quality on
forest lands. However, in taking an ecosystem approach, the NWFP anticipated that the
various land use allocations under the NWFP, including riparian reserves, would serve
multiple ecological functions. This assumption has been reinforced by research.
Numerous studies have demonstrated the importance of riparian habitats as refugia
(Olson et al. 2007), in support of biological and process diversity (Richardson 2000), and
as a mediator/corridor for processes and species (Olson et al. 2007).
The DEIS departs from this ecosystem-based approach by looking at one parameter
(wood delivery) in establishing buffers around intennittent streams under Alternatives 2
and 3. EPA believes that this approach is inconsistent with current research indicating
that navigable waters are significantly influenced by headwater streams through
hydrological and ecological connectivity (Wipfli et al. 2007). Although the DEIS
provides an analysis of management related impacts to large wood delivery under
alternatives 2 and 3, it is not clear what other riparian functions or processes might be
lost. Considering that headwaters can comprise 60-80% of drainage networks (Benda et
al. 2006), and the recognized importance of these systems (Olson et al. 2007, Johnson
and O’Neil 2001), we recommend that the FEIS take a more holistic view of the role
played by headwater streams. Specifically, the FEIS should analyze the effects of the
14
Appendices - 936
Appendix T - Responses to Public Comments and Comment Letters
Alternatives on riparian fauna, microclimate, and processes such as flow, nutrient, and
sediment regimes.
5.3 KEY WA TERSHEDS
A cornerstone of the NWFP strategy was the designation of key watersheds. These
watersheds, widely distributed across the landscape, were determined to provide, or
expected to provide high quality fish habitat, and high quality water. These watersheds
were selected not only for their habitat and water production value, but also for their
restoration potential. And as noted above, investment in these areas has proven
successful, with 74% of the key watersheds targeted for restoration showing
improvement (Gallo et al. 2005). In spite of these successes, the DEIS moves away from
the key watershed approach. Instead, areas are prioritized for restoration based on
“intrinsic potential.” EPA understands that intrinsic potential is an important concept.
However, we are concerned that relying solely on intrinsic potential significantly limits
the potential for effective BLM restoration efforts, ignores critical salmonid life histories,
and does not recognize other key watershed values. As noted on page 339, the
percentage of high intrinsic stream miles on BLM land is less than 10% for each of the
listed fish stocks. We encourage the BLM to continue to recognize and manage key
watersheds according to NWFP standards and guidelines and established watershed
analyses. As noted in the FEMAT report (1993), past attempts to recover fish
populations were unsuccessful because the problem was not approached from a
watershed perspective.
6.0 SOCIOECONOMICS
In our review of the socioeconomic issues in the DEIS, we considered the methodology
used to estimate impacts, and sought to review the underlying assumptions and input
parameters. As a result of our review, we have concerns about the use of input/output
models without complete descriptions of assumptions and limitations, and the treatment
of non-market values (such as water quality).
6. 1 INPUT/OUTPUT MODELS
Input-Output (I/O) models can be useful tools for estimating economic impacts. As with
any model, however, there are limitations that should be acknowledged. Two
assumptions of an I/O model are that prices and technology are fixed for the time period
being modeled. As a result, I/O models are not able to address flexible supply-demand
relationships, and are not able to address consumer and producer surplus and resulting
substitutions. We recommend that these limitations be discussed in the FEIS.
In addition, the DEIS uses county level input/output models designed specifically for
analysis of this project but does not provide the reviewer with information regarding each
county’s model assumptions and inputs. This is important since these models are unique
to the DEIS. We recommend that the FEIS include specific information about
assumptions and input parameters for each model.
15
Appendices - 937
FEISfor the Revision of the Western Oregon RMPs
6.2 NONMARKET VALUES
Changes in nonmarket values are not well described or quantified in the analysis. These
values affect the economic well-being, health, and resiliency of local communities. As an
example, clean drinking water is a valuable commodity produced by BLM forests. There
are dozens of drinking water systems fed in part by BLM lands (p. 1-1120). BLM
management in these areas is of key economic importance because as forest cover
decreases in a Source Water Protection Area, treatment costs generally increase (Trust for
Public Land 2004). More intensive management in source water watersheds may
therefore result in increased costs to the water users. This could be due to increased
operations and maintenance costs (filtration, monitoring, chemical treatment, etc) or
increased capital costs (plant or system upgrades). We recommend that the FEIS
examine, and to the extent possible, quantify these costs so they are included in the
economic cost/benefit analysis.
7.0 INVASIVE SPECIES
On page 269 the DEIS states that the condition of invasive plant infestations on BLM
land in the planning area can be characterized by analyzing a few (11) representative
invasive species. The analysis does a good job of discussing the mechanisms of dispersal
and relationships to land management activity, light tolerance, and current distribution.
We are concerned, however, that these descriptions address the consequences of the
presence of these species in a very limited way. For three (Canada Thistle, False Brome,
and Leafy Spurge) there is no discussion of the consequences. For six the consequences
are limited to crowding out of native species. This absence of a real focus on economic
and ecosystem consequences limits the usefulness of this analysis.
In addition, the analysis of the risk of introduction is limited to a 10-year period (p. 611).
While this near-term focus is useful, it doesn’t correspond to the temporal horizon of the
plan analysis, and thus consequences over longer periods should be evaluated.
Finally, a limited set of mitigation measures is offered, but no evidence is offered of the
observed potential cost or experienced effectiveness of these measures in either a relative
or an absolute sense. In addition, these measures are all oriented towards reducing the
risk of introduction - a necessary, but not sufficient emphasis. We recommend that the
FEIS also discuss mitigation measures that could be used in the event of an introduction,
as well as the ecosystem consequences of those measures.
16
Appendices - 938
Appendix T - Responses to Public Comments and Comment Letters
References
Benda, L., M.A. Hassan, M. Church, and C.L. May. 2006. Geomorphology of steepland
headwaters: the transition from hillslopes to channels. JAWRA 41(4):835-851.
Brazier, J. and G. Brown. 1972. Controlling thermal pollution in small streams. US Gov
PO EPA-r2-72-083
Belt, G.H. and J. O’Laughlin. 1994. Buffer strip design for protecting water quality and
fish habitat. Western J. Appl. Forestry 9: 41-45.
Blomquist, J.D., Denis, J.M., Cowles, J.L., Hetrick, J.A., Jones, D.R., & Birchfield, N.B.
2001. Pesticides in Selected Water-Supply Reservoirs and Finished Drinking Water,
1999-2000: Summary of Results from a Pilot Monitoring Program. US Geological
Survey Open-File Report 01-456.
David Evans and Associates, Inc. 2000. Scappoose Bay Watershed Assessment.
Prepared for the Scappoose Bay Watershed Council. Scappoose, OR.
Everest, F.H.; Reeves, G.H. 2006. Riparian and aquatic habitats of the Pacific Northwest
and southeast Alaska: ecology, management history, and potential management
strategies. Gen. Tech. Rep. PNW-GTR-692. Portland, OR: U.S.D.A., Forest
Service, Pacific Northwest Research Station. 130 p.
Gallo, K.; Fanigan, S.H., Eldred, P., Gordon, S.N., Moyer, C. 2005. Northwest Forest
Plan-the first 10 years (1994-2003): preliminary assessment of the condition of
watersheds. Gen. Tech. Rep. PNW-GTR-647. Portland, OR: U.S.D.A., Forest
Service, Pacific Northwest Research Station. 133p.
Graham, R.T.; A.E. Harvey, T.B. Jain, and J.R. Tonn. 1999. The effects of thinning and
similar stand treatments on fire behavior in Western forests. USDA Forest Service,
Pacific Northwest
Grizzel, J.D. and N. Wolff 1998. Occurrence of windthrow in forest buffer strips and its
effect on small streams in Northwest Washington. Northwest Science 72: 214-223.
Johnson, D.A. and T. A. O'Neil. 2001. Wildlife-Habitat Relationships in Oregon and
Washington. Oregon State University Press, Corvallis OR.
Jones, J. A., and G.E. Grant. 1996. Peak flow responses to clear-cutting and roads in
small and large basins, western Cascades, Oregon. Water Resources Research.
32(4): 959-974.
Jones, J. A. 2000. Hydrologic processes and peak discharge response to forest removal,
regrowth, and roads in 1 0 small experimental basins, western Cascades, Oregon.
Water Resources Research. 36(9): 2621-2642
Fewis, J., S.R. Mori, E.T. Keppeler, and R.R. Ziemer, 2001, Impacts of logging on storm
peak flows, flow volumes, and suspended sediment loads in Caspar Creek,
California, in Fand Use and Watersheds: Human Influence on Hydrology and
Geomorphology in Urban and Forest Areas, M.S. Wigmosta and S.J. Burges (eds.).
Amersican Geophysical Union, Washington, D.C., pp. 85-126.
McGarvey, D.J. 2007. Merging precaution with sound science under the Endangered
Species Act. Bioscience. 57(l):65-70.
Mclver, J.D., and F. Starr. 2000. Environmental effects of postfire logging: literature
review and annotated bibliography. USDA Forest Service Pacific Northwest
Research Station, Portland, Oregon. General Technical Report PNW-GTR-486,
72 p.
17
Appendices - 939
FEISfor the Revision of the Western Oregon RMPs
Montgomery, D.R; and W.E. Dietrich. 1994. A physically-based model for the
topographic control on shallow landsliding. Water Resources Research 30: 1 153-
1171.
Karwan, Diana L., Gravelle, John A., Hubbart, Jason A. 2007. Effects of Timber Harvest
on Suspended Sediment Loads in Mica Creek, Idaho. Forest Science 53(2) 181-188.
Lewis, J., S.R. Mori, E.T. Keppeler, and R.R. Ziemer. 2001. Impacts of logging on storm
peak flows, flow volumes, and suspended sediment loads in Casper Creek,
California, in Land Use and Watersheds: Human Influence on Hydrology and
Geomorphology in Urban and Forest Areas, M.S. Wigmosta and S.J. Burges (eds.).
American Geophysical Union, Washington, D.C., pp. 85-126.
Megahan, W. F., Kidd, W. J. 1972. Effects of Logging and Logging Roads on Erosion
and Sediment Deposition from Steep Terrain. Journal of Forestry. 70(3): 136- 141.
Montgomery, D.R; and W.E. Dietrich. 1 994. A physically-based model for the
topographic control on shallow landsliding. Water Resources Research 30: 1 153-
1171.
Moore, R.D., D.L. Spittlehouse, and A. Story. 2005. Riparian Microclimate and Stream
Temperature Response to Forest Harvesting: A Review. Journal of the American
Water Resources Association. 41 (4):8 1 3-834.
Olson, D.H., P.D. Anderson, C.A. Frissell, H.H. Welsh, and D.F. Bradford. 2007.
Biodiversity management approaches for stream-riparian areas: perspectives for
Pacific Northwest headwater forests, microclimates, and amphibians. Forest
Ecology and management 246: 81-107.
Pollock, Michael M., and Paul M. Kennard. 1998. A low-risk strategy for
preserving riparian buffers needed to protect and restore salmonid habitat in
forested watersheds of Washington state. 10,000 Years Institute, Bainbridge Island
Washington.
Reid, L.M. In press. Channel erosion, mass wasting, and fuel treatments. Chapter 6 in:
Elliot, W.J. and Audin, L.J., (Eds.). DRAFT Cumulative Watershed Effects of Fuels
Management in the Western United States. [Online]. Available:
http://forest.moscowfsl.wsu.edu/engr/cwe/ [2006, March 22 — access date]. To be
issued as a USDA Forest Service Rocky Mountain Research Station General
Technical Report.
Reid, L.M., and M.J. Page. 2003. Magnitude and frequency of landsliding in a large New
Zealand catchment. Geomorphology 49(1-2): 71-88. Mountain forests, USA.
Journal of Hydrology 231: 220-229.
Richardson, J.S., R.J. Naiman,., F.J. Swanson, and D. Hibbs. 2005. Riparian
communities associated with Pacific Northwest headwater streams: assemblages,
processes, and uniqueness. JAWRA 43 (1): 935-947.
Roering, J.J.; K.M. Schmidt, J.D. Stock, W.E. Dietrich, and D.R. Montgomery. 2003.
Shallow landsliding, root reinforcement, and the spatial distribution of trees in the
Oregon Coast Range. Can. Geotech. J. 40: 237-253.
Saunders, I., and A. Young. 1983. Rates of surface progresses on slopes, slope retreat and
denudation. Earth Surface Processes and Landforms 8: 473-501.
Savigny, K.W., and P. Buchanan. 1990. Factors controlling debris avalanche initiation.
Canadian Geotechnical Journal 27(5): 659-675.
18
Appendices - 940
Appendix T - Responses to Public Comments and Comment Letters
Schmidt, K.M.; J.J. Roering, J.D. Stock, W.E. Dietrich, D.R. Montgomery, and T.
Schaub. 2001. The variability of root cohesion as an influence on shallow landslide
susceptibility in the Oregon Coast Range. Can. Geotech. J. 38: 995-1024.
Skaugset, A., and Marganne M. Allen. 1998. Forest Road Sediment and Drainage
Monitoring Project Report for Private and State Lands in Western Oregon.
Prepared for Oregon Department of Forestry. [Online], Available:
http://www.oregon.g0v/ODF/PRIVATE_FORESTS/fpmpProjects.shtml#Forest_
Roads [2007, November 20 - access date].
Steinblums, I.J., H.A. Froehlich, and J.K. Lyons. 1984. Designing stable buffer strips for
stream protection. Journal of Forestry 81(1 ):49-52.
Swanston, D.N.; G.W. Lienkaemper, R.C. Mersereau, and A.B. Levno. 1987. Effects of
timber harvesting on progressive hillslope deformation in southwest Oregon. Pp.
141-142 in R.L. Beschta, T. Blinn, G.E. Grant, G.G. Ice, and F.J. Swanson (eds.),
Erosion and sedimentation in the Pacific rim. International Association of
Hydrological Sciences Publication no. 165.
Swanston, D.N.; R.R. Ziemer, and R.J. Janda. 1995. Rate and mechanics of progressive
hillslope failure in the Redwood Creek basin, northwestern California. USDI
Geological Survey Professional Paper 1454 E, 16 pp.
Thom, B.A., and K.K. Jones. 1999. Stream Habitat Conditions on Industrial Forest Lands
in Coastal Streams of Western Oregon. Special Report to the Oregon Forest
Industries Council. Oregon Department of Fish and Wildlife, Corvallis, OR.
Thom, B.A., K.K. Jones, and R.L. Flitcroft. 1999. Steam Habitat Conditions in Western
Oregon. Monitoring Program Report 1999-1 to the Oregon Plan for Salmon and
Watersheds, Governor’s Natural Resources Office, Salem,Oregon.
Thome, C.R., and N.K. Tovey. 1981. Stability of composite river banks. Earth Surface
Processes 6(5): 469-484.
USDA Forest Service and USDI Bureau of Land Management. 1996. Public lands in
Oregon and Washington. Map and data compiled by the U.S. Forest Service and
Bureau of Land Management. U.S. Government Printing Office: 1996-793-998.
Washington Department of Ecology. 2007. Modeling the Effects of Riparian
Buffer Width on Effective Shade and Stream Temperature. Publication No. 07-03-
028.
Watson, A.; C. Phillips, and M. Marden. 1999. Root strength, growth, and rates of decay:
root reinforcement changes of two tree species and their contribution to slope
stability. Plant and Soil 217(1-2): 39-47.
Wemple, B.C., J.A. Jones, and G.E. Grant. 1996. Channel network extension by logging
roads in two basins, western Cascades, Oregon. Water Resources Bulletin. 32(6):
1195-1207.
Wipfli, Mark S., John S. Richardson, and Robert J. Naiman, 2007. Ecological Linkages
Between Headwaters and Downstream Ecosystems; Transport of Organic Matter,
Invertebrates, and Wood Down Headwater Channels. Journal of the American
Water Resources Association (JAWRA) 43(l):72-85.
19
Appendices - 941
FEISfor the Revision of the Western Oregon RMPs
ATTACHMENT A - TEMPERATURE ANALYSIS
The calibrated Heat Source 7.0 model, from the recently completed Umpqua Basin
TMDL, was used in this modeling effort. The Heat Source model has undergone
extensive peer review and has been field calibrated for numerous EPA approved TMDLs
in Oregon. Modeling for Canton Creek was calibrated using both field data and remote
sensed data. Higher resolution was provided by changing the model distance step from
100 meters to 50 meters. Model Simulations for Canton Creek reflect the time period
July 12-31, 2002 and cover 16.95 river kilometers, from the upstream reach of Pass
Creek to the mouth of Canton Creek. The EPA modeling delineates three land
management categories (Forest Service, Private, and BLM) and five Riparian
Management Area (RMA) zones (i.e., 0 to 25 feet, 25 to 60 feet, 60 to 100 feet, 100 to
150 feet, and > 150 feet). Results of the analysis are presented in figures A-l through A-
3.
Figure A-l - Partial application of the proposed alternatives in which it is assumed that
current conditions will be maintained out to 60 feet.
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20
Appendices - 942
Appendix T - Responses to Public Comments and Comment Letters
Figure A-2 - Comprehensive application of the proposed alternatives in which the zone
from 25-60 feet is assumed to provide 80% shade.
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Figure A-3. Temperature change resulting from the application of WOPR Alternatives
2/3, along with 30% windthrow blowdown, to riparian buffers along Canton Creek.
21
Appendices - 943
FEISfor the Revision of the Western Oregon RMPs
ATTACHMENT B - SHADE ANALYSIS
Analysis associated with shade target development for the draft WOPR EIS was obtained
from the “Northwest Forest Plan Temperature TMDL Implementation Strategy (TMDL
Strategy - USDA, USDI 2005). The “Shadow”” model was the primary tool used to
develop the TMDL Strategy. Recently, BLM and the Forest Service, with support from
EPA and DEQ, included the algorithms and assumptions associated with the “Shadow”
into a watershed scale shade model. That model is now known as the RAPID Shade
Model (available at ftp://ftp2.fs.fed.us/incoming/r6/sis/jhawkins/StreamAssessment/)
Using the RAPID Shade Model, EPA conducted an analysis of shade at the 5th field
watershed scale on four watersheds in the planning area (Scappoose, Upper Alsea, Upper
Siuslaw, and Rock Creek). Default model settings were used during these modeling runs.
Results of this modeling can be seen in Table B-l. Figures B-l and B-2 provide
examples of model output for the Scappoose watershed. Overall, shading levels on
private land are significantly lower than shade levels on BLM land. Stream shade on
private land ranged between 41% and 54%, whereas shade levels on BLM land
approached 80%.
Table B-l. Calculated Shade using the RAPID Shade Model for Four Oregon HUCs
Scappoose
Upper Alsea
Upper Siuslaw
Rock
Entire Basin
47
64
61
62
BLM
79
78
75
74
Forest Service
89
Private
41
50
51
54
Figure B-l. RAPID Shade Model output for the Scappose watershed (red signifies less
shade, and green signifies more shade)
22
Appendices - 944
Appendix T - Responses to Public Comments and Comment Letters
Figure B-2. Calculated Shade Distribution for the Scappoose Watershed
100%
a)
~o
.c
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-4— »
3
O
ro
O
All
BLM
Private
□ 80 to 100
37%
71%
31%
□ 60 to 79
13%
8%
13%
□ 40 to 59
8%
3%
9%
□ 20 to 39
5%
3%
5%
□ 0 to 19
37%
15%
41%
Land Management Catagories
23
Appendices - 945
FEISfor the Revision of the Western Oregon RMPs
ATTACHMENT C - EXAMPLE SOURCE WATER WATERSHED
Land Ownership
|." 1 BUREAU OF LAND MANAGEMENT
I | PRIVATE
Figure C-l . The area indicated by the red line in the middle of the image is the S. Fork
Scappoose Creek Source Water Area for the City of Scappoose (BLM lands are in pink)
24
Appendices - 946
Appendix T - Responses to Public Comments and Comment Letters
U.S. Environmental Protection Agency Rating System for
Draft Environmental Impact Statements
Definitions and Follow-Up Action*
Environmental Imnact of the Action
2o/o. Z-
LO - Lack of Objections
The U.S. Environmental Protection Agency (EPA) review has not identified any potential environmental impacts
requiring substantive changes to the proposal. The review may have disclosed opportunities for application of mitigation
measures that could be accomplished with no more than minor changes to the proposal.
EC - Environmental Concerns
EPA review has identified environmental impacts that should be avoided in order to fully protect the environment.
Corrective measures may require changes to the preferred alternative or application of mitigation measures that can reduce
these impacts.
EO - Environmental Objections
EPA review has identified significant environmental impacts that should be avoided in order to provide adequate
protection for the environment. Corrective measures may require substantial changes to the preferred alternative or
consideration of some other project alternative (including the no-action alternative or a new alternative). EPA intends to work
with the lead agency to reduce these impacts.
EU - Environmentally Unsatisfactory
EPA review has identified adverse environmental impacts that are of sufficient magnitude that they are unsatisfactory
from the standpoint of public health or welfare or environmental quality. EPA intends to work with the lead agency to reduce
these impacts. If the potential unsatisfactory impacts are not corrected at the final EIS stage, this proposal will be
recommended for referral to the Council on Environmental Quality (CEQ).
Adequacy of the Impact Statement
Category 1 - Adequate
EPA believes the draft EIS adequately sets forth the environmental impact(s) of the preferred alternative and those of the
alternatives reasonably available to the project or action. No further analysis of data collection is necessary, but the reviewer
may suggest the addition of clarifying language or information.
Category 2 - Insufficient Information
The draft EIS does not contain sufficient information for EPA to fully assess environmental impacts that should be
avoided in order to fully protect the environment, or the EPA reviewer has identified new reasonably available alternatives that
are within the spectrum of alternatives analyzed in the draft EIS, which could reduce the environmental impacts of the action.
The identified additional information, data, analyses or discussion should be included in the final EIS.
Category 3 - Inadequate
EPA does not believe that the draft EIS adequately assesses potentially significant environmental impacts of the action, or
the EPA reviewer has identified new, reasonably available alternatives that are outside of the spectrum of alternatives analyzed
in the draft EIS, which should be analyzed in order to reduce the potentially significant environmental impacts. EPA believes
that the identified additional information, data, analyses, or discussions are of such a magnitude that they should have full
public review at a draft stage. EPA does not believe that the draft EIS is adequate for the purposes of the National
Environmental Policy Act and or Section 309 review, and thus should be formally revised and made available for public
comment in a supplemental or revised draft EIS. On the basis of the potential significant impacts involved, this proposal could
be a candidate for referral to the CEQ.
* From EPA Manual 1640 Policy and Procedures for the Review of Federal Actions Impactine the Environment. February,
1987.
Appendices - 947
FEISfor the Revision of the Western Oregon RMPs
United States
Forest
Service
Pacific
Northwest
Region
333 SW First Avenue (97204)
PO Box 3623
Portland, OR 97208-3623
503-808-2468
USDA Department of
Jill
File Code: 1 500
Route To:
RECEIVED
DEC 5 - 2007
Date: December 3, 2007
Subject: Western Oregon Plan Revision
To: Ed Shepard, State Director, Bureau of Land Management
Thank you for the opportunity to review and comment on the Draft Environmental impact
Statement for Revision of the Resource Management Plans of the Western Oregon Bureau of
Land Management Districts (WOPR). Forest Service staff have read the document and
participated in numerous meetings of your cooperator group.
Our first comment is to extend compliments to your planning team and District participants for
the quality of the analyses and the process involved. Considering the scope and scale of this
effort, your Draft EIS is impressive. At various work sessions and meetings. Forest Service staff
have provided comments on technical aspects of the analyses directly to your planning team.
The Forest Service and Bureau of Land Management are interdependent in management of much
of the federal lands in Oregon. In planning for management of ecological processes that operate
across administrative boundaries, we acknowledge the complexity of developing plans for BLM
managed lands that are intermingled with or in close proximity to National Forest lands.
Forest plan revisions for National Forests in western Oregon are still five to ten years in the
future. For purposes of WOPR planning we suggest your analyses assume that neighboring
National Forest system lands will continue to be managed under current applicable law,
regulation, and land management plans.
As our agencies move forward with land management plan implementation projects, I hope both
agencies will continue to seek opportunities to collaborate on project scale planning and
operations.
LINDA GOODMAN
Regional Forester
Caring for the Land and Serving People
Printed on Recycled Paper
Appendices - 948
Appendix T - Responses to Public Comments and Comment Letters
/^/
Theodore R. Kulongoski
Governor
January 10, 2008
RECEIVED
JAN 1 1 2008
Mr. Edward R. Shepard, State Director
USDOI Bureau of Land Management
PO Box 2965
Portland, OR 97208
Re: Western Oregon Plan Revisions
Dear Director Shepard:
Land °T X Wi*h the °f
State cooperating agency status T Z! 1 a?” Under the *ha> gives the
that will frame our ongoing cooperating ag'ency in^/veiTnT^your 'pI^ntnTproces^T^ces.
(O&C Art places adiffe2n!8°? °gnizes ,hat the °reg°" “d California Lands Act of 1 937
exists on otlfer federal forestlands0 The O&C AcT manage™ent ^“'rements on BLM than
management of most of the BLM land in w Provl es e primary legal authority for the
“• "ff0r P™™* fOTest production, and the timber So^hS^solTcu,"
conform, ty with the principal of sustained yield for the purpose of nrnv din ’ m
of timber supply, protecting watersheds, regulating streZflow and contribuhnaTtiT' S°Ur°e
(TuTcTmTaf10031 COmmU"“ieS a"d industri^ ™> Providing recreational facilities ...”
STATE CAP, TOE. SALEM 9T30, -AOA7 <503, 378-3, I , FAX <503, 37S-ASS3 TTY <803, 378-4853
WWW.GOVERNOR.OREGON.GOV
Appendices - 949
FEISfor the Revision of the Western Oregon RMPs
Appendices - 950
Appendix T - Responses to Public Comments and Comment Letters
Attachment: 08Janl0_Govemor Letter
WOPR and Oregon NR Agencies Cooperating Status
1 2 Coequal Principles
January 10, 2008
Page 1 of 5
/rM^-
TWELVE COEQUAL PRINCIPLES
1. The final plan must be fully implemented through adequate leadership, and human
and financial resources.
The current Northwest Forest Plan (NWFP) has not been fully implemented. In particular,
adaptive management strategies and timber harvest objectives have not been met. The Bureau of
Land Management (BLM) needs to have adequate resources to carry out management strategies
that will be adopted in the Western Oregon Plan Revision (WOPR). Budget reductions and
reallocations have led to major reductions in federal agency resources since the early 1990s,
which has influenced agency capacity and created concern over whether institutional capacities
are adequate. The State of Oregon (State) believes it is imperative that the final plan be fully
institutionalized within BLM and supported by adequate resources both within BLM mid
cooperating federal agencies. The State strongly supports a plan that can and will be fully
implemented.
2 A robust and detailed monitoring strategy supported by appropriate research must
be implemented as a key part of BLM’s plan. The monitoring strategy must examine key
questions related to the implementation, effectiveness and validity of plan assumptions and
objectives, land use allocations, and management actions; and must also be designed to
support adaptive management.
Monitoring provides essential information about whether management actions are implemented
as directed in the resource management plan, and examines their effectiveness in achieving
desired outcomes. The BLM’s plan must commit to adequate monitoring and research to
generate and utilize new information as it becomes available, and employ an adaptive
management approach to ensure that the best available knowledge and information is acquired
and used efficiently and effectively. The monitoring approach outlined in the BLM plan must be
adequate to provide information needed to support adaptive management.
3 The BLM’s plan must produce predictable and sustainable timber harvest as well as
non-timber resources and values that contribute to the economic stability of the Oregon &
California Lands Act counties.
The Oregon & California Lands Act (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, and contributing to the economic
stability of the local communities and industries, and providing recreational facilities. 1 imber
sale revenues from these lands are shared by the federal government and counties with the 25
percent federal share dedicated to the administration and management of O&C lands. The other
75 percent was to go to the 18 O&C counties after certain repayment obligations were satisfied.
The past obligations were satisfied by 1952 and, in 1953, the counties received their full 75
percent share. Since 1953, the counties voluntarily returned one-third of their share (25 percent
of the total) to the federal government for reinvestment in infrastructure on the O&C lands. 1 he
counties’ “plowback funds” were used by BLM for construction of roads and bridges,
Appendices - 951
FEISfor the Revision of the Western Oregon RMPs
Attachment: OSJanlO Govemor Letter
WOPR and Oregon NR Agencies Cooperating Status
12 Coequal Principles
January 10, 2008
Page 2 of 5
reforestation, the construction of campgrounds
contributions. The plowback fund existed from 1953 to 1981.
m^s of m^dng^paymCTtts to
and grazing fees.
Ttas, BLM’s plan must support.^
In ^
managing state-owned lands.
end^gered^T&E^
MSSfc' SSf 2SS .0 Store listings8 critics! habitat determ, nations, and
recovery plans by the USFWS and NOAA Fisheries.
Different forestland ownerships play different roles ”
modify management strategies to improve outcomes over im . Th P approfches on
Appendices - 952
Appendix T - Responses to Public Comments and Comment Letters
Attachment: 08 Jan lO Govemor Letter
WOPR and Oregon NR Agencies Cooperating Status
1 2 Coequal Principles
January 10, 2008
Page 3 of 5
agency efforts to adaptively manage fuels. Adaptive management strategies must be design
and implemented to test the effectiveness of alternative management options.
5 Riparian management strategies and best management practices must maintam and
restore freshwater habitat for salmonids, contribute to the conservation of other fish and
wildlife habitats and comply with the federal Clean Water Act including sustain g
beoencial uslf insistent state water quality standards and by proteetutg source water
used for drinking water.
Aauatic and riparian areas must be managed to maintain or restore high quality aquatic habitat to
aid fS sZTnTe^vii efforts and to contribute to the conservation of otner species. The
habitat and supporting riparian ecosystem functions needed by salmonids are believed to b ry
diverse and the abundance and survival of salmonids and many other aquatic species is closely
to die abundTce of large wood in streams. The BLM’s riparian management strategy
forests.’ Riparian and aquatic habitats must be managed to maintain or restore key functions
processes of aquatic and riparian systems.
r1 ’ ACt and meet state water quality standards. BLM must ensure that its plan
water quVU “’loti
Best Management Practices.
6. The BLM’s plan must support the Oregon Conservation Strategy.
The Oregon Conservation Strategy (OCS) should^used to hel^BLM m^e strangle decisions^
sSSE SHSissaaassassr
7. The BLM’s plan must support the Oregon Coast Coho Conservation Plan, an
outcome of the Oregon Plan for Salmon and Watersheds.
It is critically important for the
hea,,h on
Appendices - 953
FEISfor the Revision of the Western Oregon RMPs
Attachment: 08 Jan 1 (( Governor Letter
WOPR and Oregon NR Agencies Cooperating Status
1 2 Coequal Principles
January 10, 2008
Page 4 of 5
adiacent and downstream private and state lands and these benefits must be considered from a
landscape perspective. The BLM must continue implementation of the comprehensive
watershed conservation and restoration programs to restore ^ mainton t
XTSthedBLM Escape levd StrategieSt c^d
contracts and the Wyden amendment must also be used to support implementation o
restoration efforts in partnership with watershed councils and others.
8 The BLM’s plan must support State management plans for deer ^and other ^species
that balances habitat protection with providing suitable early successional habitat.
r* r,nA oiv ns well as other significant species with early successional habitat needs,
d"Sns in we*^ Oregon. Additionally, the Coastal Landscape Anab-srs and
early successional habitat. Strategies for biological diversity must 1“^ landscaie/regional
2SS with requirements for T&E species and OCS recommendattons for Late
Successional mixed conifer forest and other priority habitats.
o ThP RT M’s olam must contain a provision to formalize easement and other right-of-
’ ay documentarioi^wUh'oAer'resource^iigencies having management acrivides adjacent to
or on BLM-owned land.
Formalizing right-of-way provisions with state agencies through the planning process would help
" reeofbtion of, L compatibility with, BLM’s management plans.
10. The BLM’s lands must provide a sustainable mix of outdoor recreadonal
opportunities.
The O&C Act specifically directs BLM to provide “recreational facilities” as part of the mix c>f
to the Oregon P^l« and' ReCT^irnTl^^^dMi^s Statewhl^Cmnpreh^^h^^i^^MRKreation
PvS?feS^^
Appendices - 954
Appendix T - Responses to Public Comments and Comment Letters
Attachment: 08Janl0_Govemor Letter
WOPR and Oregon NR Agencies Cooperating Status
1 2 Coequal Principles
January 10, 2008
Page 5 of 5
H. Aggressive strategies must be implemented to control existing and prevent/eradicate
new invasive species on BLM lands.
Non-native invasive species are a serious threat to federal forests, as well as adjoining non-
federal lands. The BLM must create and implement comprehensive invasive species detection,
monitoring, and control strategies for BLM lands that also consider potential impacts to adjacent
private and public lands. The strategies must include an early detection and rapid response
JT£am tonew invasive species, aSd include the full range of tools to erad.cate and/or manage
invasive species.
12 The plan must address the interactions of forests and a changing climate; including
forest management strategies that can help in sequestering carbon or reduce overall
emissions into the atmosphere, as well as addressing the forest health risks mat may occur
due to global climate change.
Forests and forest products play an important role in maintaining a livable climate. Managing
and conserving forests and forest products can partially influence how much human-caused
carbon dioxide is added to or sequestered from the atmosphere. Management actions can be
implemented to influence future forest ecosystems so that they are better able to accommodate
the warmer climates they are likely to encounter. Oregon has stepped ahead of the J^eral
government in addressing this issue. Forests contain about 75 percent of the earth s biomass, so
fn a state like Oregon, with its highly productive forests, the per-acre potential for carbon storage
is among the highest in the world. The BLM’s plan needs to include adaptive management
strategies to explore options related to these issues.
Appendices - 955
FEIS for the Revision of the Western Oregon RMPs
RECEIVED
JAN 1 1 2008
BOARD OF COMMISSIONERS
408 SW Monroe Ave., Suite 111
P.O. Box 3020
Corvallis, OR 97339-3020
(541) 766-6800
FAX (541) 766-6893
January 9, 2008
Mr. Ed Shepard, State Director OR/WA
Bureau of Land Management
P.O. Box 2965
Portland, Oregon 97208
Re: Western Oregon Plan Revision EIS comments
Mr. Shepard:
We appreciate the opportunity to comment on the Draft Environmental Impact
Statement (DEIS) for the Revision of the Resource Management Plans of the Western
Oregon Bureau of Land Management Districts (WOPR). As you know, Benton County
is a cooperator separate from the Association of O&C Counties (Benton County is not a
member of the Association).
On behall ol Benton County, my comments will focus more on observations and
general recommendations rather than a specific alternative. My colleagues and I
represent diverse community interests and scientific opinion and have received
considerable commentary on the WOPR DEIS.
Management focused on forest health and resiliency should be a major factor
considered in any plan revisions. Management considerations must include looking at
the ecosystem as a whole with focus on soil dynamics, hydrology, water function, air
quality and multiple forest uses in addition to timber productivity. Healthy and resilient
forests can provide for multiple values including timber harvest. There is concern that
the focus on timber production greatly outweighs the functions that contribute to forest
health and resiliency; that these functions do not seem to be as important.
We recognize that the Bureau’s plan revisions are in response to a settlement
agreement centered on the 1937 O&C Act. We have not had the luxury of an in-depth
legal review or interpretations thereof. Nevertheless, we propose that an interpretation of
the Act should not be so narrow; the Act focused primarily on timber production,
overshadows other values so thus the difficulty in making the case that protecting
watersheds and streams and providing recreational opportunities have importance. I’m
Appendices - 956
Appendix T - Responses to Public Comments and Comment Letters
not convinced that the Clean Water and Air Acts and other
considered when interpreting the 1937 Act.
legislation should
not be
We acknowledge that harvest receipts, or county payments, are the lifeblood of several
hifh levek W u eVef1 ^,ef ’ * iS n0t Hkely that harvests would ^ restored to historic
th?th n haVC fmd 3 Way t0 reach a new comPact with the federal government
ax roll, PWV $Tk T ofucomPensation for significant land acreage exemptions from
tax roUs. We do not believe that timber harvest is the only answer. We also recognize
that this is outside the plan revision process.
i nofi thu ques*lon’ has enough time been given to assess the success or failure of the
994 Northwest Forest Plan (NWFP) for managing Westside forests in Oregon? We
suspect not. We know that the debate continues on whether or not O&C lands should be
managed under the NWFP; however, consistent forest management of federal forests
should be a goal for our federal agencies. Shared practices and current science can
enhance efforts. In my years in forestry research, I learned that longitudinal data are
needed to evaluate success or failure; that management prescriptions come from a
atl°n °f tnal a^derror ^ S°od science. I personally am not convinced that the
NWFP was given sufficient time. Instead it was caught in the middle of competing
political interests and litigation.
Finally, we are concerned that the debate over the preferred alternative or other
alternatives will not abate litigation. In fact, it may lead to more.
In the interest of cooperation we recommend:
o Plan revisions include multiple use sustained yield of forest ecosystem services
rather than management tightly directed at short-term economic return at the ’
expense of long term productivity of the forest as a whole, which might go further
in gaining support for plan revisions. In the work of the Federal Forestlands
Advisory Committee (for the Oregon Board of Forestry) we have struggled with
the complexities of managing the nation’s federal forest lands. There appears to
be some agreement, however, that restoring forest health and resiliency must be a
focus and that harvest as well as restoration is an important component of that
effort. Restoring forest health and resiliency will also help combat catastrophic
wildfire events. Stewardship and management can be synonymous.
o Expanding economic measures of success to include other values such as those
achieved by the requirements of the Clean Water and Air Acts, enhancement of
fisheries, recreation, and other forest products.
^ Addressing carbon storage; learning more about carbon pluses and minuses.
What is the optimum carbon balance?
3 Allowing more time and effort in implementing and evaluating the Northwest
Forest Plan to provide coordination between federal agencies with the hopeful
result of more stability and predictability regarding the management of federal
forest lands (including the 2.6 million acres of BLM managed forests in Oregon).
2
Appendices - 957
FEIS for the Revision of the Western Oregon RMPs
o
o
o
o
o
Proposing a selection of alternatives based
on a basin or province scale).
on specific landscape features (such as
Considering the potential consequences of climate change over time and how
forests should be managed in response to such change. Should there be some
adaptive management” strategies to consider climate change? And what might
Working to reach some agreement on the language we use in forest management.
This will not be an easy task, as it became very clear to me during the most recent
meeting of the Federal Forestlands Advisory Committee’s discussion on how to
define or characterize older forests. If industry and academic professionals
foresters and conservationists struggle over this, it is clear that the general public
will be confused and struggle even more.
Providing a public process to discuss and assign relative value to the many
dimensions of our forests. Certainly, the revenue produced to support local
government is important, but that dimension must be weighed and valued with
others such as recreation, habitat, clean air and clean water.
Building broader community support to reduce the polarization that has led to
litigation. It is important that there be parity of information - that is communities
need to hear aH sides of the debate and be asked to engage in finding solutions. I
don t think that we can ignore a political environment that also includes aesthetic
values attached to forests. We have to find a way to manage for diverse
community values.
We sincerely hope that you will find our comments useful.
Again, we thank you for the opportunity to comment. We recognize that there will be
another opportunity as the Bureau refines the proposed plan.
Sincerely,
Annabelle Jaramillo
Commissioner
cc. Commissioner Jay Dixon
Commissioner Linda Modrell
3
Appendices - 958
Appendix T - Responses to Public Comments and Comment Letters
Board of
Commissioners
JACKSON COUNTY
Dave Gilmour, MD (541) 774-6 1 1 7
Jack Walker (54 1 ) 774-6 1 1 8
Dennis CW Smith (541) 774-6119
Fax
(541)774-6705
Oregon
10 South Oakdale, Room 200
Medford, Oregon 97501
January 4, 2008
Ed Shepard, Director
Bureau of Land Management
Western Oregon Plan Revisions
P.O. Box 2965
Portland, OR 97208
RE: Follow up Comments from Jackson County on the Western Oregon Plan Revisions
Dear Mr. Shepard:
The Jackson County Board of Commissioners is submitting supplemental comments to those
submitted on December 6, 2007. We are enclosing a complete package so there is no need to find or
refer to our original submission.
Please note that the recommendations submitted on December 6th were pulled from the enclosed
report Recommendations from the Jackson County WOPR Core Group on the BLM Draft EIS
Western Oregon Plan Revisions. In retrospect, we realize it would have been more beneficial to
BLM to have the complete report, rather than just the recommendations. I would like to emphasize
that every recommendation contained in this report was agreed to by every member of our Core
Group, a diverse group of experts and stakeholders. This report and its recommendations was
adopted unanimously by the Board of Commissioners and is our official response.
Since submitting our official comments, a committee that advises the board on natural resource
issues submitted their response on the DEIS to the board for their consideration. Because this report
provides additional information and comments that support and adds to our recommendations, the
board decided to forward this report as well.
In addition to the reports mentioned above, I have also included the December 6, 2007 cover letter
from the Jackson County Board of Commissioners to complete the package.
If you should have any questions regarding any of the enclosed information, please contact Lin
Bernhardt, Jackson County Natural Resources Manager at (541) 774-6086.
Dennis C.W. Smith, Chair
Jackson County Board of Commissioners
c
TimReuwsaat
Appendices - 959
FEISfor the Revision of the Western Oregon RMPs
We thank the Medford District manager, Tim Reuwsaat, and his staff for their support and
assistance during this process.
Sincerely,
Dave Gilmour, Commissioner
c Tim Reuwsaat
enclosures:
1) WOPR Core Group Consensus Recommendations
2) Jackson County WOPR Core Group
Appendices - 960
Appendix T - Responses to Public Comments and Comment Letters
Recommendations to the Jackson County Board of Commissioners (BOC)
on
The BLM’s Western Oregon P!an Revision (WOPR)
INTRODUCTION
dMRAO T,tMan?£ment *ubc°mmittee of •he Natural Resources Advisory Committee
(NRAC) is aware of the results of an effort supported by the NRAC to provide the BOC
wtth recommendations on what feedback to provide the BLM on its Draft
T u Sk ,emtm <DE1S) °n 8,6 WOPR- ™s subcommittee of the
NRAC has traditionally been the principle provider of recommendations regarding
™TrBOC Z, a f6 f ackn0Wled8in«tha, *0 recommendations
opimons about the DEIS, this subcommiftet beHeL^touhe BOC shotifd a'lw ” t°L'
retina FOcSt Mana«emem Subcommittee of the NRAC is composed of 5 members- Two
DroDe^|0oene'0na t™**™ (°.ne of whom owns and manages a small woodland
fn theSn ’if’ 8 T 8 "Professional” forestof who has extensive experience
m the field one small woodland owner, and one person well versed in water quality
npanan and fisheries matters. These five members met and discussed specific
recommendations that ate being forwarded to the general membership of the NRAC for
submission to the BOC as additional input. ai membership ot the NRAC for
inpm thaUhe BOc'may inPW “ n°' me“' * ““ 01 “”tea‘ «■»
Timt^n ss: S' ,he wopr: wi,dr-
F°rnSt Mana®ement Subcommittee will comment on these same subjects and in
addition will comment on the WOPR’s relation to the O&C Act of 1937. J “
COMMENTS OF THE SUBCOMMITTEE^
and haS n° additions to the “Statements” contained in the
Core Group s submission to the BOC with regard to Wildfire.
WOPR^rlber MamaaCllle"1- ,he subcommi"“ offtK the following: Although the
OPR recogmzes the uniqueness of the forests of most of the Medford District bv
applying different harvest methods to timber stands south of a line thru Grants Pass most
reviewers were not convinced that there is enough explanation in the DEIS as to tow the
harvest methods will differ. This subcommittee does not disagree with any olfte
statements on this subject from the Core Group. We recommend that the BLM more
fully describe how it would recognize that more partial cutting, selective cutting and
thinning be done on Medford District forests, and generally, in what places- and
ana^ze the effects on the condition of the forests and the Allowable Sale Quantity
(ASQ). If that, in essence has already been done, then it needs to be better displayed.
ti 7«
Appendices - 961
FEISfor the Revision of the Western Oregon RMPs
None of the alternatives provides information on the relationship between forest
productivity (growth per acre per year) and the ASQ. Based on information obtained
lrom a BLM specialist well versed in growth and yield on the Medford District,
alternative 2. still does not harvest all the growth occurring there. (Alternative 2.
produces the highest ASQ of all the alternatives). The O&C Act says that timber harvest
should be based on the principle of sustained yield. Producing more fiber than is
harvested leads to build up of biomass, which leads to high fire hazard, which leads to
increased fires and loss of timber and habitat, and as a result, also a loss of wildlife and
decrease in water quality. This can cause a net loss to human society as well as the
natural environment.
This subcommittee recommends that the BLM more fully describe the
relationship between the growth of harvestable timber (especially on the Medford
District) and its actual planned harvest under the various alternatives.
Di "harv®stabIe timber” for our purposes, and based on Medford
acresM7J^00fllY^Iftft<K"eS^M’aC!fa^e l** ‘he District- By the forested
acres, 788,000 X 300 board feet/acre/year = 236.40 million board feet per year
y“,L“Ve 2' = l3I # mi"i0n b°ard ^ ->e -stained
The subject of Socio-economics in this presentation is dealt with in relation to
adherence to the O&C Act. The Core Group statements on this subject have been treated
by this subcommittee under Timber Management ahnv«. The O&C Act determined that
forest production would be dominant in managing the O&C forests. This has been
upheld in a court decision. The O&C Act included “providing a permanent source of
timber supply protecting watersheds, regulating stream flow, and contributing to the,
ggonomic stability of local communities and industries. . ” (underlining
(A pertinent discussion of this subject is contained in the “Critical Commentary” of the
osephme County Report of the Select Sub-Committee regarding the WOPR on page 9 of
refer to if) ^ ^ ^ ha°dS °f the Jackson County BOC, and they are able to
* n?Te?^at CVen Under the hiShest ASQ level alternative, (Alternative 2.)
only 54% of the BLM land base is available for harvest
,ha‘ ,he BLM CXplain its relia"« on Alternative 3. to comply
^5* “* of.Cour, f "'h«' ‘ong rotations in that plan restrict timber
fi ni v, ! horvest and revenues to the Counties. This may be a subject where
the BLM can deviate front the preferred alternative to achieve a higher level of
harvest and revenues by including more acres in the forested land base.
Wildlife
miff 1S SUuTS ' which iS focused on forest management issues, has no specific
concerns with the DEIS on wildlife issues. None of the alternatives seems to have a
detrimental effect on Wildlife in general. We offer no comment on this subject. The
statements from the Core Group cover any concerns we may have.
^ater issues in the DEIS are not of significant concern to this subcommittee. The Core
^PSt,ated thatjhe nPanan buffers should be determined on a site-specific basis. The
IS indicates a formulaic approach. This may be due to the difficulty of incorporating
Appendices - 962
Appendix T - Responses to Public Comments and Comment Letters
cost'efferti™ .Tdn “'f 31 ;ef,eCtS S"e specifics' Although possible to do, it may not be
so sweta DE°S P 8 'f iS S°' h Would be “P** for BLM to
Note: This same difficulty might be the reason the BLM apparently did not model a
partial cut/selective cut analysis for timber management in the Medford District It would
be instructive to find that out from the BLM when it responds to input
We agree with the Core Group recommendations.
Summary
It is hoped that the BOC will value the perspective of a more focused group whose
membership is heavily weighted toward a professional approach to the suhjecf This
^geraent Subcommi«“. is par. Of the (NRAC) that is an official
advisor to the BOC. Those professionals have spent their careers considering the very
questions raised by the WOPR DEIS and have observed the results of various
2“"? af°nS °n ?he The other members, who are no, “pmfessional
oresters also have on the ground experience that is a cut above the perceptions on
natural resource issues of the general public. It is in that spirit that we submit our
recommendations to the NRAC for further submission to the BOC.
Appendices - 963
FEISfor the Revision of the Western Oregon RMPs
Recommendations
From the Jackson County WOPR Core Group
On the BLM Draft EIS Western Oregon Plan Revisions
December 4, 2007
Prepared for the Jackson County
Board of Commissioners by
Lin Bernhardt, Jackson County
Natural Resources Manager
Appendices - 964
Appendices - 965
FEISfor the Revision of the Western Oregon RMPs
Recommendations from the Jackson Countv WOPR p
O" ‘he BLM EIS Western <££
INTRODUCTION
Purpose
jTkson cor Board °f ' cc™****, „f
Western Oregon Plan Revisions (WOPR) °n, Bur“*u of Land Management’s
consideration in their response to the BLM xt TT Pr°V'ded '° ,he bmTdtor
areas addressed in the WOPR contams recommendations on key
Background
The BLM released their draft environmental impact statement <T>FT<a ™ m
management of public lands in Western Oregon in August of 2007 The DF^ i
Xr: r impac,s * £
takes place under one region-wide ElS^St^ ^onsttem bm Ind ^
A^*mafa®ment f°r WeStem BLM
°° years‘ fhe deadline for comment is January 11, 2008.
'r r a,loca,ions and —
goals of providing a susmtoL flow of , n to better meet ,he agency’s dual
conservation of federally listed^fish andwikUife^pecle^ ^Mosfland^n the^n^
LrXXrSmTh8 °fthe °~ Cal^Sstr'omaf^e
timber"^ betw“m aLTmfvT *“•* productio"’ •«* ^
sustained yield for the pZise of mo^d™ ” conibrmit>' ™th the principle of
protecting watersheds, regulating stream Z* pe™ane"t.a°'!rce of Umber supply,
of local communities and industries and ’a- d contnbu,lng 10 the economic stability
must also meet Provrelrng recreational facilities.” The BLM
Act and Clean Water Act f laws such “ the Endangered Species
Dis,rict adop,ed as a resu,t 1 «*
the livability Of the area for county residen
Appendices - 966
Appendix T - Responses to Public Comments and Comment Letters
Wildfire Protection Pian
local issues in their plans and has rem.^ct^ • ' The BLM promises to address
PROCESS FOR GATHERING INPUT
Developing a Stripy
jkckkss- ,LhinbBe^ deve,oped a « *»
The strategy was r BLM'
Adviso^Otmmitt^fNRAC^Theij^^^Qj'^^5011
strategy at a work session on September 2, 2^7°mm,ss,oners endorsed the proposed
Establishing the Core Group
members as well as experts and representatives from key areas NRAC
compfet^^t'c^me^^rr^e^App^dix'A111!^11' a"d economics. For a
well as their demonstrated ability to collaborae^WhenTart^08?11 ^ expertise as
themselves and not for anv oreanizatinn th., ' «... n participating, members spoke for
those organizations w 11^ subSp th^f fe “ ^ many of
working8for toe U.S InldtoL^ T™*** ^ ^ L^’
“SteBT i,SHPUbliC Par,idpa,i°n pro«“ f-toe toPR. Iff;
tacilitate the meetings and assist with the process. d 1
areas. (Given the exnansiveness of th* tvcic a V. . agreed to focus on five key
essential to lintT, toe”) Sose r as tocluld^ T*” ** C°mment’ “ Was
economics, wildlife, and water quality " mana«ement- aocio-
The Core Group was briefed by BLM on the wopr t .
to adopt a hybrid of the alternatives listed. ’ since BLM is likely
Page 2 of 7
Appendices - 967
FEISfor the Revision of the Western Oregon RMPs
Expanded NRAC Workshnp
variety of interests,. All NRAC members were invited as wei afrlTr” “ eVen f f
and members of other groups who would potentially have an interest in oXTff^a ’
mt
The meeting began with a background presentation hv RT M eiofr t-u- r-
«3^Lwtr0fteriC C™e fTOm b°th indUSt0, rePresenta'i''« as wdl as™
Developing Recommendation «
- Core group
statements/recommendations for each ofthe five kev area/ Wh.u u u
the aaeetin^m^b^revfewe^the^forTc^lMcy^AH m^^r^confirmed'th6^0601 *°
s^“rsfefup has -^“u?„; ,he
of recommendations ^ °f ’ 11,6 concePte discussed precedes each set
CORE GROUP RECOMMENDATIONS
Wildfire
could be very different from what is descritedTn tteDEIS^i^ h'*' a"alysis
r;jrfd b“r ion °f - - sr
Page 3 of 7
Appendices - 968
Appendix T - Responses to Public Comments and Comment Letters
£ S' f r hrest leVdS as Wdl as -lues, 1,
and finest resiliency mlTT? **■' forest
forest types in the Medford District. °U d t&ke mt° account the different
• The management p!an should reflect the fW ti,,#
. £ °iStriCt th3n C,SeWhere - the planning area. ** *"
fu tu r^ha^esMevds^n d I th er va hies!46^ °°d °f “ “d * — «
• The management plan should focus to a greater extent on i,w„„ *• u
“ ,o ‘Jr?-'*10” n« -» ?regti„n:;;„!r„;rhVr”e
• The n|nCy h u T*** an<l maln,ailli,1g or improving forest health,
method r^ceTre riskand PreSCr|P,ions’ ">a"agrment scheme, and
epical fores, types i„ ^ ^ f°r **
Timber Management
^SSSSSta.
the harvest Th
that this might reduce the Allowable Sale Quantity (ASQ). However odSr ' “P reC°8niZed
oturP W°Uld inCreaSe thC ASQ' a',h0U8h * is “*»<"» <0
Emphasizing management for objectives would allow a larger nortion nf i a
* oTf;r=;‘^,ShOU'd m0gre ,he diS,inrt t>l'- aa« ecology
OI tne Medford District as compared to other parts of the western Oregon
planning area. The management plan for the Medford District should8 rely
more on thinning and partial cuts. •'
Where regeneration harvests are appropriate, there should be retention of
,"ee?e’sW° " d£b"S ““ iMtadi"* "^—ds and rep“,ive
• More volume could be cut in reserves with prescriptions that emphasize
forest and ecosystem health and fire resiliency. P
Page 4 of 7
Appendices - 969
FEISfor the Revision of the Western Oregon RMPs
Socio-Economi r<
There was considerable debate on this topic. It was noted that m u-
being grown than proposed to be cut in Alternative 2 and that th t ^ 15
significantly increased. One member suggested that the BI M !h t \
much is merchantable and accesstb.e
^ mana8”8 “ f°r habi“’ or
group generally favored site-specific potion"
s h o u 1 d ^ o°in o r e t o ^ dd rel T s ma 0 fame t e^ ^ Th^ COUM helP P3y ^ W3y’ and the DEIS
• ma~ - — -
‘ creation,
• The management plan should promote the supply and utilization of small
d~,:r T‘ bi0maSS " i,h *h£ *»al »f ccZLie v“ The ptr
hat nahl H ""'“r,i,nte of coliahoration and incorporate anguage
eonlh„ra«ve: C”C0Ura8eS ** *° <”*«' <■ -eh ? §
Wildlife
r:“^rentation was of “• ^ shouw » » timbh:sroup
Page 5 of 7
Appendices - 970
Appendix T - Responses to Public Comments and Comment Letters
and lack of green tree retention in some alternatives. reserves
FsTh Speciea Sh,°,UEd be manaSed on a landscape scale to prevent new
.SA listings and additional set asides, and should include a safety nd for
conifer-associated rare species based on reliable da“a " f°r
Water
S3E1—
sasSSSSSSr
an impact if it were included within the setback while nn7 \ ! h would not create
eas“ed8ed “ may n°‘ ^ PraC,iCal' “V ««* • ^determined criteriaTh^d be
While it was agreed that there should be no significant impairment of water quality
that he ^Vu^concemedabo^^pactno^t^t Equality ^sin^the exa^kTof the0^
logging that took place at Big Butte In general the omL examPle oflhe
C;,“, fish -
One member felt that buffers should be protective not iust of e^hlidw r u u
yearns, but streams .ha, have tbe potenL for fish p isence
been observed. If stream conditions could be altered tha, would allow Ish in me fi ,
proC,ecationP 8 “ CU'Vert’ “ W3S agreed that those *«“>« should receive equal
Page 6 of 7
Appendices - 971
FEISfor the Revision of the Western Oregon RMPs
The impacts of roads on water quality, the need for better road design, addressing
deferred maintenance, and restoring/mitigating existing roads to reduce impacts on
sedimentation, were also mentioned as concerns.
• Riparian buffers should be determined by specialists on a site-specific basis
when necessary, based on predetermined criteria for proper functioning
conditions. The resulting buffers should be sufficient to avoid significant
impacts to water quality or fish habitat, including increases in temperature
and sediment, or reductions m large wood recruitment and current and
future shade.
Streams with the potential for fish (salmonid) presence should be afforded
equal protection to similar streams with fish presence.
Potential impacts from new and existing roads should be minimized. BMPs
s ould be deployed and monitored and deferred maintenance made a high
priority. 6
FINAL REMARKS
All members of the Core Group stayed at the table throughout the process. This does not
Tar^ thV67 Tmber attended every meetin§’ however, every member reviewed and
agreed to the final recommendations.
Jlfprf?UP d?e?]i"ed.that1 none of the alternatives were acceptable as written and a new
alternative should be developed that incorporates the above recommendations. The
management plan for the Medford District must take into account the high fire risk and
rent forest types in this area. The group supported maximizing harvest levels to
support jobs and the economy while managing for fire resiliency, forest health and
ecological values. ’
The members were appreciative of the BLM staff that made themselves available for
presentations and questions throughout the process.
Page 7 of 7
Appendices - 972
Appendix T - Responses to Public Comments and Comment Letters
APPENDIX A
Jackson County WOPR Core Group
Ed Kupillas (NRAC, Society of Professional Foresters)
Craig Harper (NRAC, RVCOG )
Paul Kangas (NRAC, Society of Professional Foresters )
Kathleen Donham (NRAC, League of Women Voters)
Frank Lang (NRAC, biologist)
Ron Fox (SOREDI)
Darren Borgias (The Nature Conservancy)
Max Bennett (OSU Extension forester)
Brett Fillis (Rogue Valley Fire Chiefs Assoc., J. C. Fire Plan Executive Com.)
Jude Wait (Lomakatsi)
George McKinley (Jefferson Sustainable Development Initiative)
Bob Jones (Medford Water Commission)
Appendices - 973
FEISfor the Revision of the Western Oregon RMPs
KLAMATH COUNTY
Home of Crater Lake
Klamath County Commissioners
305 Main Street, Klamath Falls, Oregon 97601
Phone:541.883-5100 Fax: 541.883-5163
Email: bocc@co.klamath.or.u.s
AI Switzer, Commissioner John Elliott, Commissioner Bill Brown, Commissioner
Position One Position Two Position Three
January 4, 2008
Mr. Edward W. Shepard, State Director
USDI Bureau of Land Management
Western Oregon Plan Revisions
PO Box 2965
Portland, OR 97208
RECEIVED
JAN 0 9 2008
Dear Mr. Shepard:
The Klamath County Board of Commissioners provided comment on your Western
Oregon Plan Revisions on October 30, 2007. Since that date we have become aware of
the possible implications of the United States Supreme Court’s decision in “National
Association of Homebuilders v. Defenders of Wildlife” of June 25, 2007. This decision
states that Section 7 of the Endangered Species Act’s “...no jeopardy duty covers only
discretionary agency actions and does not attach to actions that an agency is required by
statute to undertake once certain specific triggering events have occurred. .
In our October 30 comment we encouraged a larger allocation of acres to timber
production than the 48 percent your Alternative Two indicated while generally support-
ing your selection of Alternative Two as your Preferred Alternative. The recent Supreme
Court decision now reinforces the requirements of the original O&C Act to manage the
O&C lands primarily for timber production for economic benefit of the counties in which
the O&C lands lie.
We continue to encourage timber management and production on a far larger acreage
than suggested in your Alternative Two and perhaps a larger acreage than the 66 percent
indicated in your Alternative Three. We maintain that land may be managed under the
rotation age regime (90/140 years) you suggest in such a manner that essential habitat for
listed and other species is protected, if not enhanced, while a large volume of valuable
forest products is produced. The ten-year allowable sale quantity indicated in Alternative
Two, 7,270 MMBF, could be safely exceeded if more acres were available for wood
harvest, keeping growth and cut in balance over the span of the decadal planning period.
Appendices - 974
Appendix T - Responses to Public Comments and Comment Letters
Page 2 - DEIS letter
As always, it’s essential that all resources and species be considered as land management
plans are written and executed. We believe it is entirely possible to engage in careful,
long-rotation timber management on the largest land-base possible that protects and
enhances all resources without excluding commercial use from large portions of public
land.
We are very interested in your response to our comments and others that consider the
effects of the Supreme Court’s decision. We encourage the production of a new Preferred
Alternative that takes this decision into consideration and includes far more economic
timber production in Oregon’s timber-dependent counties.
We very much appreciate this opportunity to comment on your Revision of the Resource
Management Plans of the Western Oregon Bureau of Land Management Districts.
Very truly yours.
Appendices - 975
FEISfor the Revision of the Western Oregon RMPs
Appendices - 976
Appendix T - Responses to Public Comments and Comment Letters
ASSOCIATION OF O & C COUNTIES )S ~/Z^
Re: Western Oregon Plan Revision EIS comments
Mr. Shepard:
The Association of O&C Counties represents the interests of Counties in Western
Oregon within which lie the BLM managed O&C lands and Coos Bay Wagon Road
(“CWBR”) lands, including the 16 Counties which are formal cooperating agencies in the
BLM’s Western Oregon Plan Revision (“WOPR”) process. This Association has
represented County interests in the management of these lands for over 80 years. We
have reviewed the WOPR draft EIS and provide the following comments:
BACKGROUND:
The O&C Act requires that O&C Lands “which have heretofore or may hereafter
been classified as timberlands, and power site lands valuable for timber, 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 . . . 43 USC §1 181a.
The Act identifies two mandatory actions over which the BLM has no discretion: (1) If it
is timberland, it must be included in the “timber base”; and (2) if it is in the timber base,
it must be managed for sustained yield timber production. There remains, of course, at
least some discretion in how the BLM implements the second of these requirements
there are a variety of ways to satisfy the requirement for sustained yield timber
production.
When the WOPR process began, it was presumed that the Endangered Species
Act (“ESA”) “trumped” the O&C Act in some respects. Specifically, it was presumed
that the O&C Act mandate to manage all timberlands for sustained yield had to stand
aside if such management was inconsistent with the ESA’s section 7(a)(2) requirement
that “each Federal Agency shall, in consultation with . . . [the Secretary of Interior or
Commerce] insure that any action authorized, funded, or carried out by such agency . . .
is not likely to jeopardize the continued existence of any endangered species or
COMM. MIKE PROPES, VICE-PRES
POLK COUNTY COURTHOUSE
850 MAIN STREET
DALLAS, OREGON 97338
(503) 623-8173
COMM. DOUG ROBERTSON, PRES
DOUGLAS COUNTY COURTHOUSE
ROSEBURG, OREGON 97470
(541) 440-4201
received
JAN 0 2 2008
KEVIN Q DAVIS, LEGAL COUNSEL
SUITE 1600, BENJ FRANKLIN PLAZA
ONE S.W. COLUMBIA
PORTLAND, OREGON 97258
(503) 517-2405
ROCKY McVAY, EXEC. DIR
16289 HWY 101 SOUTH, SUITE A
BROOKINGS. OREGON 97415
(541) 412-1624
FAX (541) 412-8325
Email: rocky@blupac.com
COMM. TONY HYDE. SEC.-TREAS.
COLUMBIA COUNTY COURTHOUSE
ST HELENS, OREGON 97051
(503) 397-4322
DAVID S. BARROWS, LEGIS. COUNSEL
1201 S.W. 12TH AVENUE, SUITE 200
PORTLAND. OREGON 97205
(503) 227-5591
December 20, 2007
P.O. Box 2965
Portland, Oregon 97208
Ed Shepard, State Director OR/WA.
Bureau of Land Management
Appendices - 977
FEISfor the Revision of the Western Oregon RMPs
Association of O&C Counties
December 20, 2007
Page 2
threatened species or result in the destruction or adverse modification of habitat of such
species which is determined ... to be critical . . . .” 16 USC § 1536(a)(2). It was
presumed that the creation of reserves from which timber was not harvested, otherwise
impermissible under the O&C Act, was permitted if necessary to avoid jeopardy to a
listed species. The corollary presumption was that O&C lands, if designated as critical
habitat under the ESA, could be withdrawn from timber production and placed in
reserves for the benefit of listed wildlife species. All of these presumptions were wrong.
In June 2007, the United States Supreme Court reversed the 9th Circuit Court of
Appeals in a case that limits the scope of the ESA. The case did not involve the O&C
Act, but its holding directly affects the extent to which the BLM may respond to the “no
jeopardy” and “no adverse modification” requirements of the ESA. The key holding in
the case is as follows:
“§7(a)(2)’s no-jeopardy duty covers only discretionary agency
actions and does not attach to actions . . . that an agency is required by
statute to undertake once certain specific triggering events have occurred.
This reading not only is reasonable, inasmuch as it gives effect to the
ESA’s provision, but also comports with the canon against implied repeals
[of other, earlier, conflicting legislation] because it stays §7(a)(2)’s
mandate where it would override otherwise mandatory statutory duties.”
Natl. Ass, of Homebuilders v. Defenders of Wildlife, No. 06-340 (June 25,
2007). (Emphasis in original.)
This holding specifically controls the scope of the ESA’s “no jeopardy”
requirement, but it should also be read to control the scope of the “no adverse
modification” requirement, since both requirements are in the same sentence of ESA
§7(a)(2).
This new Supreme Court decision alters the legal framework for the development
and selection of alternatives in WOPR. Since the O&C Act says all timberlands must be
managed for sustained yield timber production, the BLM may not create reserves on
O&C or CBWR lands to avoid jeopardizing a listed species, or to avoid adversely
modifying critical habitat, since section 7(a)(2) of the ESA does not impliedly repeal the
O&C Act’s nondiscretionary mandate to implement sustained yield forestry on all
timberlands. What remains subject to §7(a)(2)’s “no jeopardy/no adverse modification”
requirement is the BLM’s exercise of discretion in choosing the particulars of the
sustained yield timber management it will employ. The BLM can and must seek to avoid
jeopardy and adverse modification, but its effort in that regard must be consistent with
the discretion allowed it under the O&C Act. This occasion is also a useful reminder that
the BLM may only use its discretionary authority in contributing to the recovery of listed
species pursuant to §7(a)(l) of the ESA. Thus, the limitations on the BLM are the same
Appendices - 978
Appendix T - Responses to Public Comments and Comment Letters
Association of O&C Counties
December 20, 2007
Page 3
for both contributing to recovery and avoiding jeopardy under the ESA — the scope of
discretion under the O&C Act limits and defines the BLM’s obligations under the ESA.
The 9th Circuit Court of Appeals decision in Headwaters v. BLM. 914 F.2d 1 174
(9th Cir. 1990) is the controlling interpretation of the O&C Act and the BLM must follow
it. The opinion in that case identifies the purposes and goals of the O&C Act, which are
the guideposts for identifying the extent of the BLM’s management discretion. The
opinion in that case at pages 1 183-84 provides as follows:
1. The term “forest production” in the O&C Act means “timber production.”
Timber production is the “dominant use” for O&C lands.
2. “Exempting certain timber resources from harvesting to serve as wildlife
habitat is inconsistent with the principle of sustained yield.” (Emphasis added.)
3. “The purposes of the O&C Act were two-fold. First, the O&C Act was
intended to provide the counties with the stream of revenue which had been
promised but not delivered . . . Second, the O&C Act intended to halt previous
practices of clear-cutting without reforestation, which was leading to a depletion
of forest resources.” * * * “Nowhere does the legislative history suggest that
wildlife habitat conservation or conservation of old growth forest is a goal on a
par with timber production, or indeed that it is a goal of the O&C Act at all.”
(Emphasis added.)
The O&C Act says that timber on the O&C lands shall be managed with the
timber thereon sold, cut and removed on a sustained yield basis “for the purpose of
providing a permanent source of timber supply, protecting watersheds, regulating stream
flow, and contributing to the economic stability of local communities and industries, and
providing recreational facilities.” The Headwaters decision makes clear, through
reference to the legislative history, that protecting watersheds, regulating stream flows,
and providing recreation facilities were the expected outcomes from sustained yield
timber management rather than separate goals that could compete with sustained yield
timber management. Nevertheless, these projected outcomes are clues to the kind of
management that BLM was expected to undertake to implement the sustained yield
mandate of the O&C Act.
The limits of BLM’s discretion are ascertained by reference to the terms of the
O&C Act, on its face and as interpreted in the Headwaters decision, as well as by historic
interpretations given the O&C Act by the BLM itself. For example, in a 1939 press
release, less than two years after the O&C Act became the management mandate, the
BLM’s predecessor agency had a Chief O&C Forester, the equivalent of the BLM State
Director, who described the newly adopted sustained yield forestry program in these
words:
Appendices - 979
FEISfor the Revision of the Western Oregon RMPs
Association of O&C Counties
December 20, 2007
Page 4
“This assures the continuous production of timber for the employment of Oregon
industries without the danger of exhausting the timber supply and without the
danger of destroying the tax base of the counties.” Press Release, March 31,
1939, W. H. Homing, O&C Chief Forester.
In 1940 the O&C Chief Forester elaborated, saying that “[a]ll the lands best suited for the
growing of timber will be retained in public ownership and kept at work producing crops
of timber. Continuous production of timber of commercial quality in the largest possible
amount is the goal.” W. H. Homing, The O&C Lands and their Management, an
Important Advance in Forest Conservation (1940).
All of these indications suggest that the BLM’s discretion when implementing
sustained yield is narrowly bounded. The limited discretion under the O&C Act was
preserved by Congress as recently as 1976, when Congress passed the Federal Land
Policy and Management Act (“FLPMA”), which redefined the management direction for
nearly all lands in the United States under the jurisdiction of the BLM, with the telling
exception of lands managed under the O&C Act. FLPMA, P.L. 94-579, is a multiple use
statute under which all uses for the land are given equal consideration, and the BLM has
broad discretion to choosing the mix of uses it will adopt for lands managed under
FLPMA. But Congress specifically preserved the dominance of timber production on the
O&C lands by adopting section 701(b) of FLPMA, which says that “[notwithstanding
any provision of this Act [FLPMA], in the event of conflict with or inconsistency
between this Act and the . . .[O&C Act and Coos Bay Wagon Road Acts], insofar as they
relate to management of timber resources, and the disposition of revenues from lands and
resources, the latter Acts shall prevail.”
In 1986 the Interior Solicitor was asked if the BLM had authority to implement a
plan for the protection of spotted owls. The legal opinion differentiated between lands
managed by the BLM pursuant to FLPMA, and lands managed pursuant to the O&C Act.
The Solicitor’s opinion describes the difference as follows:
“The freedom conferred on the Secretary under FLPMA is limited in one
important way on certain federally-owned timberlands in western Oregon. There,
any decision about managing northern spotted owls must be measured against the
dominant use of timber production. * * * In deciding whether to establish a
program for managing northern spotted owls on O&C timberlands, the Secretary,
then, must decide if it is possible to do so without creating a conflict with the
dominant use there — timber production. If the Secretary can manage northern
spotted owls and still produce timber on a sustained yield basis in the O&C
timberlands, the O&C Act in no way will preclude him from making that choice.
* * * The converse, of course, also obtains. If a program for managing northern
spotted owls conflicts with producing timber on a sustained yield basis in O&C
Appendices - 980
Appendix T - Responses to Public Comments and Comment Letters
1 1
Association of O&C Counties
December 20, 2007
Page 5
timberlands, the O&C Act will preclude the program’s application to that realty.”
Gale Norton and Constance Harriman, Associate Solicitors, Memorandum to
James Cason, Deputy Assistant Secretary for Land and Minerals Management
(October 28, 1986).
The Association of O&C Counties does not, in these comments, offer a
convenient description of the exact range of discretion we believe is consistent with the
O&C Act, now that the constraints of the ESA cannot be viewed as a separate, modifying
source of management authority by the BLM. It is clear that creation of reserves in
which sustained yield timber production is not practiced is not allowed, but otherwise the
boundary lines defining the BLM’s discretion are not brightly drawn. Our comments
below are guided by the purposes and goals of the O&C Act, as they are described in the
paragraphs above. The BLM’s discretion is defined by these same purposes and goals.
Minimum Harvest Levels
There is a continuing debate about whether the O&C Act specifies a minimum
harvest level, and if so, what the minimum harvest level is. The O&C Act, 43 U.S.C.
§ 1 1 8 1 a says the following:
“The annual productive capacity for such lands shall be determined and declared
as promptly as possible after August 28, 1937, but until such determination and
declaration are made the average annual cut therefrom shall not exceed one-half
billion feet board measure: Provided , That timber from said lands in an amount
not less than one-half billion feet board measure, or not less than the annual
sustained yield capacity when the same has been determined and declared, shall
be sold annually, or so much thereof as can be sold at reasonable prices on a
normal market.” (Italics in original, underlining added.)
This language equates the “sustained yield” with the “annual productive capacity”— the
two terms refer to the same thing. This strongly suggests that “sustained yield” is not
something that is administratively determined by application of policy decisions from a
wide range of discretionary options. Rather, it appears that that “sustained yield” — the
annual productive capacity — is determined primarily by reference to biological factors
associated with tree growth and mortality.
In Portland Audubon v. Babbitt. 998 F.2d 705 (9th Cir. 1993), one question
presented was whether an injunction on timber sales pending compliance with NEPA was
appropriate. The BLM argued that an injunction would prevent it from achieving a
harvest level of 500 mmbf, which it argued was compelled by statute. The 9th Circuit
said that the O&C Act “has not deprived the BLM of all discretion with regard to either
the volume requirements of the Act or the management of the lands entrusted to its care.”
The Court rejected the BLMs argument that NEPA did not apply, based on the Court’s
Appendices - 981
FEISfor the Revision of the Western Oregon RMPs
Association of O&C Counties
December 20, 2007
Page 6
understanding that NEPA “applies to all government actions having significant
environmental impacts, even though the actions may be authorized by other legislation.”
Id. at 709. This interpretation of NEPA is no longer correct with regard to
nondiscretionary actions. See Dept, of Transportation v. Public Citizen, 541 U.S. 752
(2004). Moreover, the 9th Circuit’s statement in Portland Audubon about the BLM
having at least some discretion under the O&C Act does not answer the question about
how much discretion exists, nor does it definitively answer the question about minimum
harvest levels that the BLM must attempt to achieve under the Act.
The 2003 Settlement
In August, 2003, a settlement agreement was reached in American Forest
Resource Council v. Clarke that requires the BLM to revise six resource management
plans in Western Oregon that are associated with the Northwest Forest Plan. The
settlement agreement requires that at least one alternative be considered for each plan that
does not utilize any reserves except as required to avoid jeopardy under the ESA. In
addition, all new plans must be consistent with the O&C Act as interpreted by the 9th
Circuit of Appeals in the Headwaters decision. The U.S. Supreme Court’s Homebuilders
decision establishing that section 7(a)(2) of the ESA does not modify or amend other,
nondiscretionary statutory mandates, supercedes the settlement agreement in certain
respects. To the extent that the settlement agreement can be read as suggesting that
reserves are permissible on O&C lands to avoid jeopardizing listed species under the
ESA, the settlement agreement is no longer consistent with applicable law. The second
requirement of the settlement— that all plan revisions be consistent with the O&C Act as
interpreted in the Headwaters decision — remains effective as a matter of contract, as well
as a matter of statutory law.
EIS GENERAL COMMENTS:
None of the alternatives as presently written in the draft EIS meet the statutory
requirements of the O&C Act. Management that would occur in LSMAs under
Alternatives 1 and 2, and in LSRs in the No Action Alternative, would not provide timber
production on a sustained yield basis. Instead, significant amounts of O&C and CBWR
land would be set aside and reserved for the conservation and recovery of species listed
under the ESA. Alternative 3 contains no wildlife reserves, but is designed to maintain
and promote a mature and structurally complex forest on BLM lands across the
landscape. The rotation ages proposed under Alternative 3 were selected, not by
reference to the goals and purposes of the O&C Act, but for the purpose of benefiting
wildlife, which is not a goal of the O&C Act at all. Under Alternative 3, timber
production on a sustained yield basis would be significantly limited to achieve the overall
goal of an old growth forest. While extended rotation ages might be permissible on some
parcels, their widespread application under Alternative 3 is out of compliance with the
Appendices - 982
Appendix T - Responses to Public Comments and Comment Letters
Association of O&C Counties
December 20, 2007
Page 7
purposes of the O&C Act. Viewing the landscape as a whole, one cannot say that timber
production would be the “dominant use” under Alternative 3.
We believe that deficiencies in the alternatives and the draft EIS can be corrected
in the final RMP/EIS without doing a supplemental EIS. This can be achieved by
modifying Alternative 2 to incorporate the U.S. Supreme Court’s limitations on the reach
of the ESA, and correcting certain other existing inconsistencies with the O&C Act. All
information and data necessary for final EIS analysis is currently available in the draft
EIS. The following are suggested changes for Alternative 2:
1 . Maintain existing LSMA allocation boundaries identified in Alternative 2, but do
not withdraw or reserve these lands from sustained timber production. Instead,
develop long term rotation age strategies within the LSMA boundaries that would
contribute to the conservation and recovery of federally listed species, while also
providing for regeneration harvesting on a sustained yield basis. We suggest
using the long rotation ages contained in Alternative 3 within the areas currently
identified as LSMAs, and using landscape targets for regeneration harvest within
LSMA boundaries similar to requirements in Alternative 3.
2. Develop timber management objectives within LSMA boundaries that maintain
and promote the development of suitable habitat for federally listed ESA species.
Examples include thinnings and partial harvests that would hasten development of
structurally complex forests within the LSMA boundaries. All timber harvested
within the LSMAs is in the timber harvest base and the volume should be
included in ASQ calculations.
3. The Secretary, apart from the WOPR process, should eliminate critical habitat
designations on O&C and CBWR lands. The BLM cannot participate in a system
of reserves on O&C and CBWR lands. USF&W, at the direction of the Secretary,
should revise its proposed critical habitat designation to account for the BLM’s
non-discretionary mandates under the O&C Act.
4. Allow for green tree retention (legacy) trees within LSMA boundaries.
5. Establish continuous field survey and monitoring systems within LSMAs for all
federally listed species. Determine whether a location is “actually occupied”
based on confirmation of the physical presence of species using the site for
nesting, roosting, or foraging (owls) or nesting (murrelets), but excluding
locations where there are sightings of transient, dispersing birds.
6. Protect all sites (inside and outside of LSMAs) that are actually occupied by listed
species by delaying regeneration harvest of sites for so long as sites are actually
occupied. See definition of “actually occupied” in comment 5.
Appendices - 983
FEISfor the Revision of the Western Oregon RMPs
Association of O&C Counties
December 20, 2007
Page 8
7. Allow salvaging in LSMAs for economic purposes with retention of legacy trees.
8. In areas south of Grants Pass and in the Klamath Falls resource area of the
Lakeview District, apply uneven aged timber management principles where
feasible to all BLM lands. This practice would reduce fire hazard and the acres of
high severity fire when wildfires occur in these areas. It could also benefit
suitable habitat conditions for ESA listed species.
9. Include in the sustained yield timber management base all Congressionally
designated Wild and Scenic Rivers that have a scenic or recreation classification.
Exclude only those rivers with a Congressional wild classification from the timber
base. Include in the timber management base all rivers that have not been
Congressionally designated. Any protections for riparian areas along Wild and
Scenic rivers included within the timber base would be those riparian protections
generally applicable for the land use allocation of the surrounding lands.
10. Withdraw O&C and CBWR lands located in the National Landscape System from
sustained yield timber management only if they have a Congressional designation
requiring protection.
11. Include all lands adjacent to the Coquille Tribal Forest in the sustained yield
timber management base.
12. Maintain all other features for Alternative 2
13. Develop a sub-alternative for Alternative 2 that eliminates LSMA boundaries and
establishes the maximum harvest that can be maintained in these areas without
exceeding the amount of new growth.
SPECIFIC DRAFT EIS COMMENTS:
SUMMARY:
1 . P. XLIV— Add a footnote regarding the Homebuilders decision by the U.S.
Supreme Court, and explain that the ESA’s requirements under section 7(a)(2) are
not applicable to agency actions over which the BLM has no discretion under the
O&C Act.
2. P. XLVI— Rewrite Alternative 2 summary consistent with the recommendations
described above in these comments under the heading EIS General Comments.
Appendices - 984
Appendix T - Responses to Public Comments and Comment Letters
Association of O&C Counties
December 20, 2007
Page 9
3. P. XLIX— Rewrite Figure 1 and Table 1 as they apply to Alternative 2, so that
they reflect the revisions to Alternative 2 recommended above.
4. PP. L-LXVI— The summary of environmental consequences should be rewritten
to reflect changes recommended for Alternative 2. In addition, the Marbled
Murrelet section (p. LVIII) should be totally rewritten based on detailed
comments presented below for Chapters 3 and 4.
5. P. LIII — Reconsider whether environmental justice considerations should be more
extensively discussed. For example, Douglas County experiences very high
levels of impacts depending on which alternative is selected by the BLM. At the
same time, Douglas County has high levels of poverty, so that impacts from the
BLM decisions will be experienced disproportionately by low income
populations. While the median income in Douglas County rose 4.5 percent in
2006, the number of people living in poverty in Douglas County also rose at the
same time, from 1 1 .8 percent to 16 percent of the total population. There was a
corresponding increase in the number of children living in poverty, so that
currently more than 25 percent of all children in Douglas live in poverty, a
shocking and disturbing statistic that might be sufficient to require a fuller
environmental justice analysis.
CHAPTER 1— PURPOSE AND NEED
1 . PP. 3-6 — ' The purpose and need for the plan revisions should be revised to
accurately reflect the law following the Supreme Court’s Homebuilders decision.
For example, on page 6, the current text states: “The statutory requirements of the
O&C Act are limited by other statutes providing for the need to conserve listed
species and the habitat they depend on, not jeopardizing listed species and not
adversely modifying critical habitat . . . This is no longer an accurate statement
of the law and must be revised. Other, similar statements should be modified as
well.
2. P. 10 — The last sentence of the 4th full paragraph states as follows with regard to
the O&C Act: “Nor does it establish a minimum level of harvest or a minimum
level of receipts.” We agree that the O&C Act does not mandate a minimum level
of receipts, but it does mandate a minimum harvest level. We request that you
quote in full the second full paragraph of 43 U.S.C. §1 181a. We recognize that
the decision in Portland Audubon v. Babbitt. 998 F.2d 705 (9th Cir. 1993) states
that the BLM does not completely lack discretion with regard to harvest levels,
and that therefore an injunction to compel compliance with a procedural statute
was not precluded by the O&C Act. But that is a limited holding (see discussion
above) that cannot be said to eliminate the minimum harvest level requirements
stated in the Act as they are applicable to the BLM.
Appendices - 985
FEISfor the Revision of the Western Oregon RMPs
Association of O&C Counties
December 20, 2007
Page 10
2.
P. 1 1— The section describing the ESA must be corrected to reflect the Supreme
Court’s ruling in the Homebuilder’s case. It is no longer true that section 7(a)(2)
requires the BLM to take actions that are inconsistent with the O&C Act’s
nondiscretionary mandates. As with obligations under section 7(a)(1), the BLM
may only respond to section 7(a)(2) in ways that are consistent with the
requirements of the O&C Act.
3.
P. 23— The section titled “Endangered Species Act Section 7 Consultation” must
be rewritten to reflect the Supreme Court decision distinguishing between
discretionary and non-discretionary actions proposed by an action agency.
CHAPTER 2 - ALTERNATIVES:
1.
PP. 43-44— National Landscape Conservation System section should be re-
written to include only those management actions that are consistent with the
O&C Act or specific Congressional designation. For example, on
Congressionally designated Wild and Scenic rivers with a scenic or recreation
classification, timber harvest is allowed, and lands with such classifications
should be a part of the timber base for sustained yield calculations. Only sections
of rivers with Congressional wild classifications are properly withdrawn from
timber harvest. The BLM lacks authority to withdraw O&C and CBWR lands
from timber production on an interim basis while Congress is considering
eligibility of candidate areas for inclusion in Wild and Scenic system.
2.
P. 45— Management actions associated with the Mt. Hood Corridor need to be re-
examined for consistency with the O&C Act. Unless Congressionally designated,
timber harvest should not be excluded.
3.
PP. 46-47— Management objectives and management actions associated with
federal and state listed plant species should be rewritten to reflect the Supreme
Court decision regarding Section 7 of the ESA. The BLM should consider
strategically placed green tree retention as a means of protecting localized plant
populations in harvest units.
4.
PP. 60-61 — Management objectives and management actions associated with
listed wildlife species must be rewritten to reflect the limitation on the ESA in
light of the Homebuilders decision.
5.
PP. 65-75— The discussion regarding the No Action Alternative and Alternative 1
should make clear that excluding the LSRs from sustained yield timber
production can no longer be justified as being necessary to comply with the ESA.
Appendices - 986
Appendix T - Responses to Public Comments and Comment Letters
Association of O&C Counties
December 20, 2007
Page 1 1
6. PP. 76-89 — Alternative 2 discussion needs to be modified and rewritten to
incorporate the Supreme Court’s ruling in the Homebuilders case. The discussion
must distinguish between the Agency’s non-discretionary and discretionary
actions. (See the 13 specific suggestions discussed above for Alternative 2 in the
section labeled ”EIS General Comments.”)
CHAPTER 3— MARBLED MURRELET, AFFECTED ENVIRONMENT, PAGES
297-308
1 . Table 90 identifies 890,000 habitat capable acres of BLM land within the
planning area that could potentially become nesting habitat for Marbled
Murrelets. Additionally, 373,000 acres are identified as nesting habitat available
today. Table 90 fails to accurately portray the effected environment from a
landscape perspective within the planning area for the species and should be
modified to include the following information:
a. Add a column that identifies total federal and state habitat capable acres
within the planning area that could potentially become nesting habitat for
the species. Show percentage of total habitat under BLM administration.
b. Add columns that break down total federal and state capable acres by zone
1 and zone 2, and show percentage of acres under BLM.
c. Add columns that break down total available habitat by ownership within
the planning area by zone, distinguishing between mature and structurally
complex forest, and showing percentage of BLM acres in each.
2. All BLM forest acres capable of growing trees within zone 1 and 2 are included
as habitat capable acres for Marbled Murrelets. No other factors were included
for determining suitable habitat for nesting other than growing a mature and
structurally complex forest on BLM lands in proximity to a marine environment.
The EIS fails to adequately describe the many other factors that must be
considered in determining the capability of O&C lands to support nesting by the
species. The effected environment section for Marbled Murrelets needs to be
rewritten to include the following information:
a. The Marbled Murrelet recovery plan and proposed critical habitat rule
have identified that the species requires large contiguous blocks of mature
and structurally complex forest habitat with low amounts of edge and
fragmentation and located far from human activity for successful nesting
and fledging of young. BLM’s checkerboard and fragmented land
ownership is a significant constraint on the ability of BLM lands to
contribute to the recovery of the species by providing nesting habitat
Appendices - 987
FEIS for the Revision of the Western Oregon RMPs
Association of O&C Counties
December 20, 2007
Page 12
meeting these criteria. Large patches of structurally complex forest
habitat with low amounts of edge do not exist on these lands.
b. O&C and CBWR lands are located across the landscape in a checkerboard
pattern with mostly private industrial lands in zones 1 and 2. Most mature
and structurally complex forest habitat has been eliminated on private
lands. In addition, regenerated forests on most private lands are planned
for timber harvest prior to obtaining the forest characteristics of an older
forest. Suitable habitat loss on private lands must, therefore, be
considered permanent.
c. Large contiguous blocks of forests within zone 1 and 2 are located on the
National Forest lands and on the Tillamook and Elliott State Forests
d. Marbled Murrelets are very sensitive to fragmentation and reproductive
success is adversely affected by fragmentation. Large amounts of edge
and fragmentation also result in increased populations of nest predators;
increased visibility and vulnerability of flying or nesting adults to potential
predators; and changes in microclimate regimes that stress the species.
e. The EIS (page 302) states that Marbled Murrelets nest in landscapes with
large stands with less edge and farther from logged areas. It further states
that patches of suitable nesting trees of only a few acres with only a few
nesting trees are thought to be capable of supporting Marbled Murrelet
nesting which is contrary to the large contiguous block requirement stated
above. Is this a conclusion based on scientific evidence or is it just an
opinion based on little to no evidence? The EIS should provide support
for this statement.
3. The EIS does not adequately describe occupancy and actual use by the species on
BLM lands in zones 1 and 2. Occupancy is determined by survey protocol that is
based on the behavior of the species, but there is no discussion about actual use.
Questions need to be answered about what nesting activities have actually been
confirmed on the BLM lands. A source of information on this subject can be
found on page 52 in the Marbled Murrelet recovery plan. For areas of known
occupancy and use, the EIS should provide a detailed description of suitable
habitat that includes size of stand, amounts of fragmentation, stand and nest tree
characteristics and the occupied parcel’s relationship to these criteria. Also, the
EIS should describe whether nesting and fledging of young was successful or, if
not, what caused failure. As an example, the recovery plan identified the “Valley
of the Giants” (BLM) as an active but failed nesting area. This is an old growth
parcel laying in a fragmented checkerboard ownership that contains some of the
Appendices - 988
Appendix T - Responses to Public Comments and Comment Letters
Association of O&C Counties
December 20, 2007
Page 13
oldest Douglas Fir trees in the Coast Range. Nest failure occurred because of egg
predation.
4. In areas determined to be occupied by survey, what protocol was used for making
a determination? Provide information in the form of a table and narrative
showing occupied acres determined by different protocols. For example, the
Coos Bay district had identified 19,775 acres as occupied by original protocol
used until 2003. 1 ,447 acres have subsequently been added with a new protocol
through 2006. Are acres identified under the old protocol still valid? If so, why?
In addition, what documented follow-up studies based on field examination have
been conducted on occupied lands that confirm that these areas are actually being
used for nesting or have stand and nest tree characteristics that allows the parcel
to be suitable for nesting.
CHAPTER 3— EFFECTED ENVIRONMENT (Miscellaneous Comments)
1 . P. 262 — Neither Bureau Sensitive Species, Bureau Assessment Species nor
federal candidate species on O&C and CBWR lands can receive management
protections that are inconsistent with sustained yield timber management..
2. P. 317 — Bureau Sensitive Species on O&C and CBWR must be managed
consistent with sustained yield timber production under the O&C Act.
3. PP. 422-424 — The section concerning the National Landscape Conservation
System should be revised to make clear that management within these lands will
include sustained yield timber production under the O&C Act unless specific
areas have received a Congressional designation that precludes such timber
management.
4. Add a discussion of environmental justice for rural counties. The discussion
should focus on levels of poverty and economic impacts on those at or near the
poverty line that would result from each of the alternatives.
CHAPTER 4 -ENVIRONMENTAL CONSEQUENCES. PAGES 473-793
All sections in this chapter need to be revised to disclose environmental
consequences resulting from addressing the Homebuilders decision by the Supreme Court
as described above and other recommended changes identified above for Chapters 1
through 3. Significant modifications need to occur in sections on Socio-economics,
Timber, Botany, Wildlife, Fire and Fuels, and the National Landscape Conservation
System. The section on Environmental Justice should be updated with statistics more
current than the 2000 census data used in the draft EIS. There should be additional
discussion of how those living at or near the poverty line are affected by the employment
Appendices - 989
FEISfor the Revision of the Western Oregon RMPs
Association of O&C Counties
December 20, 2007
Page 14
prospects associated with each alternative, and how those populations are affected by the
level of county services that would be available or not, depending on the shared timber
receipts associated with each alternative.
CHAPTER 4— MARBLED MURRELET PAGES. PAGES 674-682
The environmental consequences analysis is deficient and its conclusions are not
supported by existing scientific data that can be found in the recovery plan or the critical
habitat rule. The results described in the draft EIS are based on the growing of trees into
mature and structurally complex forests on 891,000 acres of BLM lands within zones 1
and 2. Suitable nesting habitat, quality and quantity, cannot be based solely on this one
factor. This analysis needs to be rewritten to reflect a more accurate depiction of the
BLM lands’ physical and biological capabilities to provide suitable nesting habitat for the
species. (See comments above for Chapter 3, Marbled Murrelets.) The analysis in the
EIS must address the affects of each of the nesting habitat issues listed below. Analysis
of these issues must examine effects from a landscape perspective, as well as from the
more limited BLM ownership perspective:
1 . BLM’s checkerboard ownership pattern and its ability to provide large contiguous
blocks of mature and structurally complex forest habitat for nesting is limited.
Use as a foundation data described on pages 13, 17, 68 and 183-191 of the draft
EIS. For example, page 189 states that BLM’s ability to influence resource
outcomes often depends upon the amount and location of its land ownership in
relation to a particular resource. In addition, page 191 states that most of the
BLM lands comprise less than one-third of a 5th field watershed. By contrast,
most of the lands managed by the Forest Service are in large contiguous blocks.
2. The BLM’s ability to provide habitat with low amounts of edge and
fragmentation, far away from human activity that has suitable nesting
characteristics is limited.
3. Marbled Murrelets are very sensitive to fragmentation and reproductive success is
adversely affected by fragmentation. Given BLM’s scattered ownership in zones
1 and 2, how does this affect BLM’s ability contribute to conservation and
recovery of the species? Conversely, given the large contiguous blocks managed
by the Forest Service, how does this affect its contribution to recovery?
4. Environmental consequences associated with reserving occupied sites based
solely on survey needs to be addressed. Are these occupied sites being actually
used for nesting or does the area really offer potential based on the above factors
and requirements for suitable nesting habitat?
Appendices - 990
Appendix T - Responses to Public Comments and Comment Letters
Association of O&C Counties
December 20, 2007
Page 15
5. Increases/decreases in Marbled Murrelet nesting habitat for any alternative must
be based on the habitat requirements of the species and not just on the capability
of growing trees overtime. Tables for zone 1 and 2 should be developed to show
suitable nesting habitat (quality and quantity) overtime by ownership at the
landscape level.
VOLUME 3
1 . PP. A930-A932— Add a complete discussion of the Homebuilders decision by the
U.S. Supreme Court and how it affects nondiscretionary actions by the BLM.
2. PP. A933-A934 — Add a discussion of the savings provision in FLPMA
preserving the dominance of the O&C Act with regard to management of timber
resources.
3. P. A931— ' The discussion of Portland Audubon includes the following statement:
“The Court also found that the O&C Act did not establish a minimum volume that
must be offered every year notwithstanding any other law.” What the court
actually said was the O&C Act “has not deprived the BLM of all discretion with
regard to either the volume requirements of the Act or the management of the
lands entrusted to its care.”
Thank you for considering our comments.
THE ASSOCIATION OF O&C COUNTIES
Kevin Q. Davis, Attorney for the Association
cc: Dick Prather
Appendices - 991
FEISfor the Revision of the Western Oregon RMPs
100
RECEIVED
JAN 0 2 m
Martha Schrader
Chair
Lynn Peterson
Commissioner
Bill Kennemer
Commissioner
C lackamaS
COUNTY
Board of County Commissioners
Public Services Building
December 20, 2007 2051 Kaen Road I Oregon City, OR 97045
Edward Shepard
ORA/VA State Director
Western Oregon Plan Revisions
Bureau of Land Management
P.O. Box 2965
Portland, OR 97208
Re: Western Oregon Plan Revisions
Dear OR/WA State Director Shepard:
We, the Clackamas County Commissioners, have reviewed the Draft Environmental Impact
Statement (DEIS) for the Revision of the Resource Management Plans of the Western Oregon
Bureau of Land Management Districts. We appreciate the work that has gone into the WOPR
process over the past few years, including scoping, development of alternatives, and the
detailed analysis of effects described in the DEIS. The workshops, open houses, and web site
information available since the release of the DEIS and the extended comment period are
evidence of your commitment to informing the public and cooperating agencies while giving
adequate time for thoughtful commentary.
After review and consideration of anticipated effects of each proposed alternative, we would like
to lend our support to Alternative 2. Of the proposed alternatives, we believe that Alternative 2
best meets the intent of the O&C Lands Act of 1937 for these lands to be managed in
permanent forest production under the principles of sustained yield providing economic benefit
to local communities. We believe that Alternative 2 proposes a management scheme that will
grow and produce forest products in a sustainable manner while protecting other resource
values such as wildlife, fish, and clean water. The income to Clackamas County via payments
from timber receipts is important for providing some local county services in our county as well
as the other O&C counties. We have adopted a resolution in support of Alternative 2, a copy of
which is included and which has been transmitted to the Association of O&C Counties.
While we support the selection of Alternative 2, we would like to point out some particular
concerns we have identified through discussion with County staff and citizens.
Concern 1: Identification of revenue replacement for the Secure Rural Schools and
Community Self Determination Act safety net payments is important.
Clackamas County is supportive of identifying revenues to replace the anticipated
loss of Secure Rural Schools funding, but it is also important that projects be
implemented in a way sustainable to both the timber harvest and the other
resources the forest provides. We would ask the BLM to encourage all of the
O&C counties to continue to look at other potential sources of revenue including
revenue generated through tourism and recreation.
Concern 2: Revenues from the timber harvest on BLM land could be processed under
“Stewardship Contracts” and would not be returned to the Counties.
p. 503.655.8581
F. 503.742.5919 I www.co.clackamas.or.us
Appendices - 992
Appendix T - Responses to Public Comments and Comment Letters
mmm.
While we recognize that stewardship contracting is a good tool in the right
situation, we are concerned that it would reduce the revenue generated from
timber harvest and thus reduce the portion of revenue returned to the Counties. If
stewardship contracting is used to implement some resource management
projects, the Counties should still receive an equal amount of revenue as they
would have with a traditional timber sale.
Concern 3: Protection of endangered species habitat and improving forest health is
critical.
Clackamas County supports harvesting of timber when it is balanced with
science-based protection of endangered species. Managing of public forests
should be conducted in a sustainable and ecologically sound manner. We
strongly support and encourage focusing on thinning of plantation stands, which
would help to address fuel reduction concerns in fire-prone and over-stocked
plantation areas.
Concern 4: Adequate riparian buffer areas are important for protection of fish, wafer,
wildlife, and soil resources.
While we support Alternative 2, we are concerned that the minimum riparian
widths may be applied to all projects. Each forest management project should be
reviewed on an individual basis so that the appropriate riparian corridor width is
applied to each site. We have particular concern in areas of unstable slopes and
soils. It is important that the minimum protection width is not relied upon as the
standard, but instead the appropriate protection be applied on a site-by-site basis.
Concern 5: Timber harvest on properties adjacent to small private landowners can be
controversial.
Some of the BLM-managed lands in Clackamas County are in smaller tracts
scattered in the western foothills of the Cascades. Many of these tracts border
properties owned by private, rural landowners. As you know, these neighbors can
be very sensitive to management activities, especially timber harvest. An article in
the August 16, 2007 Clackamas County Weekly section of The Oregonian titled
“Living - for now - in paradise" described some of the issues arising from
management of small BLM parcels in the rural landscape of eastern Clackamas
County. Our Clackamas County Forest Program has made it a point to contact
and work with neighboring landowners when proposing timber harvest on our
county-owned forest lands. This has been a successful strategy for several years.
We suggest that Salem District planners employ this strategy when proposing
timber harvest on BLM-managed lands adjacent to smaller, private landowners.
We would be happy to provide contact information for those adjacent landowners
in Clackamas County to Salem District planners.
Thank you for extending the public comment period and giving us the opportunity to comment
on the DEIS. We look forward to finalization of the western Oregon resource management plan
revisions and subsequent implementation of the selected alternative.
Martha Schrader, Chair
Clackamas County Board of Commissioners
Appendices - 993
FEIS for the Revision of the Western Oregon RMPs
BEFORE THE BOARD OF COUNTY COMMISSIONERS l?2°
OF CLACKAMAS COUNTY, STATE OF OREGON
In re: New BLM Resource Management
Plans for O&C and Related Lands
in Western Oregon
2007-622
Resolution No.:
Page 1 of 3
~ . , whEREAS, The BLM is revising its land management plans for western
NortKst^st PlanSandan ^ ^ C°mPriSeS ab0Ut 10 P6rCent °f the area covered * the
... , WHEREAS, most of the planning area is governed bv the O&C Art of iq^7
which requires the BLM to manage for permanent forest production to provide economic^ ^benefif to
fatties"1 The draft 'n^!n bTO!ec*"ra,erSheds’ re9dlati"9 -""•"*<>«* and proving Lreatn
acuities. The draft plan analyzes the potential impacts of three management alternatives, and
foot ^f h t WHEREAS, the BLM’s Alternative 2 would produce about 727 million board
J. _ r rlth HhS annual|y- >n perpetuity. Receipts from sales of this timber would replace about 94
Determination AcSil f ^ ^ ™hen the current Secure Rura' Schools and Community Self
Determination Act safety net payments terminate in the near future, and y
. . . .. , WHEREAS, the O&C lands were once in private ownership but were taken
npmpnt °m- federal government, and thus removed from county tax rolls. To compensate fifty
90 directly t0 the 1 8 western °regon Counties- to be used as ’ ^
services and recratiop6 oat SUCh aS ,lbran®s’ law enforcement, corrections, public health
services, and recreation. O&C revenues provide a substantial and irreplaceable part of the
discretionary budget for this County, and p ine
. WHEREAS, the BLM’s proposed plans are the result of the most detailed
and co^nPraha^sl'/e analysis ever completed on federal lands in western Oregon The analysis is
supported by the latest biological studies, updated resource data, and new modeling tools, and
di . r. WHEREAS, the BLM and U.S. Fish and Wildlife Service have ensured that
the BLM s draft plans, the Northern Spotted Owl Recovery Plan, and the draft Critical Habitat Rule
are consistent At least 46 percent of the forested BLM lands would be reserved To^ ^perpeSe
e°rtrtititS W'|th ° d grov^h characteristics, and the remaining 54 percent would provide substantial
add 1 acreage of mature and structurally complex forest, while being managed with care to
reau remartsrof'fh»T HS d "“hc re?laced bV new 9rowth Alternative 2 meete all the
requirements of the Endangered Species Act to protect and help recover all listed species of fish
and wildlife as ; well as complying with all other environmental laws such as the Clean Water Act
and Clean Air Act, and protecting recreational opportunities and facilities.
... WHEREAS, Clackamas County has asked the BLM to consider and address
management^ans'03 dUnn9 ^ C°UrSe °f finalization of the astern Oregon resource
CCP-PW25 (3/94)
Appendices - 994
Appendix T - Responses to Public Comments and Comment Letters
BEFORE THE BOARD OF COUNTY COMMISSIONERS
OF CLACKAMAS COUNTY, STATE OF OREGON
In re: New BLM Resource Management
Plans for O&C and Related Lands
in Western Oregon
200 7r 62 2.
Resolution No.: ~ ~ w
Page 2 of 3
Concern 1 : Identification of revenue replacement for the Secure Rural Schools and Community
Self Determination Act safety net payments is important.
Clackamas County is supportive of identifying revenues to replace the anticipated
loss of Secure Rural Schools funding, but it is also important that projects be
implemented in a way sustainable to both the timber harvest and the other resources
the forest provides. We would ask the BLM to encourage all of the O&C counties to
continue to look at other potential sources of revenue including revenue generated
through tourism and recreation.
Concern 2: Revenues from the timber harvest on BLM land could be processed under
“Stewardship Contracts' and would not be returned to the Counties.
While we recognize that stewardship contracting is a good tool in the right situation
we are concerned that it would reduce the revenue generated from timber harvest
and thus reduce the portion of revenue returned to the Counties. If stewardship
contracting is used to implement some resource management projects, the Counties
should still receive an equal amount of revenue as they would have with a traditional
timber sale.
Concern 3: Protection of endangered species habitat and improving forest health is critical.
Clackamas County supports harvesting of timber when it is balanced with science-
based protection of endangered species. Managing of public forests should be
conducted in a sustainable and ecologically sound manner. We strongly support
and encourage focusing on thinning of plantation stands, which would help to
address fuel reduction concerns in fire-prone and over-stocked plantation areas.
Concern 4: Adequate riparian buffer areas are important for protection of fish, water wildlife and
soil resources.
While we support Alternative 2, we are concerned that the minimum riparian widths
may be applied to all projects. Each forest management project should be reviewed
on an individual basis so that the appropriate riparian corridor width is applied to
each site. We have particular concern in areas of unstable slopes and soils. It is
important that the minimum protection width is not relied upon as the standard, but
instead the appropriate protection be applied on a site-by-site basis.
Concern 5: Timber harvest on properties adjacent to small private landowners can be
controversial. Some of the BLM-managed lands in Clackamas County are in smaller
tracts scattered in the western foothills of the Cascades. Many of these tracts border
properties owned by private, rural landowners. As you know, these neighbors can
be very sensitive to management activities, especially timber harvest. An article in
the August 16, 2007 Clackamas County Weekly section of The Oregonian titled
CCP-PW2S IVW)
Appendices - 995
FEISfor the Revision of the Western Oregon RMPs
BEFORE THE BOARD OF COUNTY COMMISSIONERS
OF CLACKAMAS COUNTY, STATE OF OREGON
In re: New BLM Resource Management
Plans for O&C and Related Lands
in Western Oregon
Resolution No.: ^OQ
Page 3 of 3 - - ~-
“Living - for now - in paradise" described some of the issues arisinq from
CounT O^rL^3'' BLn ParJeLS in the rUral ,andscaPe of eastern Clackamas
County Our Clackamas County Forest Program has made it a point to contact and
owned fnrP^H1 T When proposin9 timber harvest on our county-
owned forest lands. This has been a successful strategy for several years We
suggest that Salem District planners employ this strategy when proposing timber
be^nnv,tnBnrM"r!Iana91d '? ? adjacent to smaller, private landowners 9 We would
sSSn ^ landOW"ers in Clackamas
NOW, THEREFORE, be it resolved that:
.. Clackamas County supports Alternative 2 in the BLM’s draft Dlans and
nn9^h a* BthM t0 Se'e?t Alternative 2 as the BLM’s final plan, and to proceed alwStolS as
possible in the completion and implementation of its plan revisions A coov of this Resolution -shall
be transmitted to the Association of OSC Counties for submSio Ration shall
ADOPTED this 20th day of December, 2007.
CCP-PW25 13/94)
Appendices - 996
Appendix T - Responses to Public Comments and Comment Letters
KLAMATH COUNTY
Home of Crater Lake
Klamath County Commissioners
305 Main Street, Klamath Falls, Oregon 97601
Phone:541.883-5100 Fax: 541.883-5163
Email: bocc@co.klarnath.or.us
£57
A1 Switzer, Commissioner
Position One
John Elliott,
Position Two
Chairman vise ? Bill Brown, Commissioner
Position Three
October 30, 2007
NOV 0 2 2007
1 *
ale Director's Office,
RECEIVED
fJOV OS 2007
Mr. Edward W. Shepard, State Director
USDI Bureau of Land Management
Western Oregon Plan Revisions
PO Box 2965
Portland, OR 97208
Dear Mr. Shepard:
The Klamath County Board of Commissioners strongly supports your selection of Alternative Two from the
array of four alternatives presented in your Draft Environ-mental Impact Statement for the Revision of the
Resource Management Plans of the Western Oregon Bureau of Land Management Districts.
We appreciate your extensive social-economic analysis and wish to comment on the economic impact of federal
forest management decisions.
Historically, the western Oregon counties, including the O&C Counties, derived a large percentage of then-
economic well being from the wood products industry. That is what we do here. The temperate forests of
Oregon are among the most productive in the world and still have the potential to provide large volumes of
commercial wood to meet local, regional and world wood needs. At present, federal forests support nearly half
of the nation’s standing softwood inventory but supply less than two percent of the nation’s wood needs. The
“wood famine” predicted at the end of the 1 9th and beginning of the 20th centuries has not occurred, nor is it
likely to. Globally, there is plenty of wood. The United States has found it easy to satisfy its wood needs from
non-federal domestic forests and, increasingly, from foreign sources. About a third of our softwood use is now
sourced from outside the country.
Your proposed alternative would be a small but very positive step in a return to U.S. wood self-sufficiency
while at the same time securing economic stability for the large part of rural Oregon that is uniquely situated to
produce high value wood products.
Appendices - 997
Il FEISfor the Revision of the Western Oregon RMPs
BLM DEIS Response-page 2
The BLM manages 16% of the saw timber in western Oregon and as recently as the 1970s supplied a similar
fraction of the area’s timber harvest. That harvest has now fallen to just over three percent of the total harvest
from the western Oregon planning area, with predictable effects on local economies. The Secure Rural Schools
Act funded the timber-dependant counties on an interim basis but the rest of the nation hasn’t, nor should it
have, the patience to continue to fund rural western counties within whose boundaries exists the huge wealth of
the federal forests, including the O&C lands.
We strongly support a resumption of intelligent, productive timber management and production on all of the
federal forestlands and certainly on those administered by the BLM in western Oregon. We also encourage
wood production on a far larger portion than the 48% land use allocation under Alternative Two. Regeneration
cutting should be prescribed only on those forest types that require such management and a more diameter-
diverse regime prescribed elsewhere, and outside the 48% allocated to timber manage-ment, to maintain visual
values, habitat for the largest number of native species and to produce the most fire resistant landscape possible.
We appreciate that the BLM has not used nor has it proposed artificial diameter-limit cutting and can remove
trees of all values across the diameter spectrum to meet the needs of the forest and economic realities as well.
It’s time to do much more of that.
We believe that the American people, and Oregonians in particular, would be displeased if they were fully
aware of the asset value of the federal forests and the actual economic return they provide the taxpayers.
Currently, the economic return from the federal lands is negative. Costs exceed returns while the counties in
which the federal lands lie curtail or eliminate services to their citizens while the huge value of potential federal
timber production and sale remains generally untapped. It didn’t use to be this way and doesn’t need to be now
or in the future. We are approaching a time when the rest of the planet will tire of the U.S. sitting on its timber
wealth while other nations supply our needs.
Absent a sustained and productive timber management and sale program on the O&C and other western Oregon
BLM lands, we strongly encourage sale of at least half of the O&C lands to the private sector as described in the
proposed National Forest and Schools Stabilization Act written by the boards of commissioners of the Oregon
O&C counties and published on December 8, 2006 (copy attached).
We appreciate this opportunity to comment on the DEIS and request that our remarks be included in your
comment record.
Appendices - 998
Appendix T - Responses to Public Comments and Comment Letters
ff/, z.
NATIONAL FOREST COUNTIES AND SCHOOLS STABILIZATION ACT
A Proposed Safety Net Solution
December 8, 2006
The expiration of the county and schools safety net, PL 106-393, is a source of grave and
growing concern among counties and school districts not only in Oregon, but in 39 other
states representing 780 counties and over 4,000 school districts. There has been
considerable bi-partisan effort over the last two years to find an acceptable budget offset
for an extension of PL 106-393, but no solution has been found, and there appears to be
none on the horizon. Counties and school districts nationwide are beginning to
implement budget cuts that will eliminate thousands of jobs and reduce services and
classrooms dramatically.
Conventional thinking has proven inadequate. It is clearly time for creativity and
leadership to identify a bold but reasonable solution to this problem on a long-term basis.
The Association of Oregon and California Railroad Land Grant (O&C) Counties Board
of Directors offers this proposal for your consideration. Not only is there a pending crisis
for schools and counties, but there is also a new effort to recover the spotted owl and the
marbled murrelet. Timing is extremely important for all efforts of this kind, and our
proposal takes these events and circumstances into account.
The proposal must be viewed in the unique historical context of the O&C lands. The
revested O&C Railroad grant lands and related BLM lands in Oregon contain
approximately 2.4 million acres, and approximately 80 billion board feet of standing
timber. The revested O&C Railroad grant lands were originally ah in private ownership
for many years, having been conveyed to the O&C Railroad Company in exchange for
construction of a railroad. But the lands were not re-sold by the Railroad Company to
actual settlers as Congress intended, so after decades of ownership by the Railroad they
were taken back (“revested”) into federal ownership, with the intent the federal
government would sell the lands in small parcels so that they could again be returned to
the private sector. That resale program was eventually converted to a retention and
management program, but unlike national forest lands, Congress mandated that the O&C
lands be managed for timber production on a sustained yield basis for the benefit of local
communities.
While solutions are scarce, the problems are easy to state: Counties and schools
nationwide need a permanent source of funding to replace decades of reliance on shared
timber receipts. Oregon’s schools, in particular, need funding assistance. Oregon
Counties in the region of the O&C lands are in a particularly dire situation, as they have
depended on shared timber receipts from national forest lands for road funds, and
separately they have relied on shared receipts from the O&C lands to support general
county services of all kinds. Over the last 15 years these historic programs have been
Appendices - 999
FEISfor the Revision of the Western Oregon RMPs
undercut by drastically declining timber receipts, while battles continue to rage over the
associated environmental issues and proposals to insure permanent protection for forested
wildlife habitats. The proposal offered by the O&C Board addresses each of these
problems, including solutions to problems on both a local and a national scale.
The proposal is to permanently protect approximately 1.2 million acres of O&C and
related lands as wildlife habitat, and to sell the remaining O&C lands to generate funds
for the creation of four permanent trust funds. Approximately 1.2 million acres would be
permanently set aside and managed for recovery of the spotted owl and marbled murrelet
and other environmentally sensitive species, far in excess of the amount of O&C land
currently designated as late successional reserves under the Northwest Forest Plan. This
would create one of the largest single additions to protected lands status within the Untied
States in the last 30 years. These protected lands would remain under the jurisdiction of
the BLM and a trust fund would be established to ensure resources for management of
these protected lands.
The remaining O&C lands would be sold into the private sector in an orderly fashion
over a period of time. There are approximately 80 billion board feet of timber on the 2.4
million acres. In rough terms, one-half of that volume (40 billion board feet) at $300 per
thousand board feet (which is a very conservative estimate of value) would produce
approximately $12.0 billion. The lands returning to private ownership would retain
public access for hunting, fishing, and other recreational pursuits, and would remain in a
permanent timber production status.
The revenues from the sale of O&C land and timber would be used to create a trust fund
(Fund A) of approximately $4.0 billion for a permanent extension of a safety net similar
to PL 106-393, benefiting all states, counties and school districts that have national
forests within their boundaries. Payments to counties based on historic shared receipts
from the O&C lands would be removed from the safety net and treated separately. The
investment earnings of Fund A combined with ongoing Forest Service receipts would
produce about the same amount of revenues for national forest schools and counties as
have been provided in recent years by PL 106-393. A separate trust fund (Fund B) of
approximately $4.0 billion would be created to provide on-going revenues for the general
funds of the O&C counties, with investment earnings generating annual payments
approximately equal to amounts currently being provided by PL 106-393 to the O&C
Counties. In addition, a third trust fund (Fund C) of approximately $3.0 billion would be
created and specifically dedicated to education in the state of Oregon to be managed and
administered by the state legislature and Governor. A fourth trust fund (Fund D) would
produce investment income for the BLM’s continued management of the 1.2 million
acres of preservation lands. Fund D would be funded with the balance of the land sale
proceeds in excess of the amounts necessary for Funds A, B and C. Fund D would likely
be capitalized with not less than $1.0 billion.
This proposal is not the first of it kind. The BLM has sold many parcels into the private
sector over the years. Indeed, most of the western two-thirds of the country that is in
private ownership is land that was once owned by the federal government In fact — as
Appendices - 1000
Appendix T - Responses to Public Comments and Comment Letters
described above, these very lands proposed for sale were themselves once in private
ownership and would have remained that way but for unique twists of history. Currently,
there are two separate but similar proposals in congress (S 3772, and S 3636/HR5769)
that are the inspiration and model for this proposal, albeit on a smaller scale. The
pending bills would result in BLM land sales in Utah and Nevada and expansion of
wilderness areas in both states. The Washington County Utah Growth and Conservation
Act of 2006, HR 5769 and S 3636, and the White Pine County Nevada Conservation,
Recreation and Development Act of 2006, S 3772, are just two examples in along history
of federal land sales and consolidation of federal ownerships to achieve preservation
goals.
This proposal, if implemented, would produce several very desirable results. First, of
course, it would produce the resources to capitalize the trust funds. This would create
stability for schools and counties in our resource dependent communities all across the
country, with particular emphasis on support for schools in Oregon. It would also lead to
a predictable source of timber for a healthy, viable industry in western Oregon. Job
growth in the industry in Oregon would be substantial. And although it would make use
of only one -half of the current O&C land base, at least those lands would fulfill the intent
of the O&C Act. At the same time, the endless battle over management of the O&C
lands would end, with substantially more acres in a permanently protected status than are
currently protected as late successional reserves. Funding would be readily available to
insure that the BLM’s ongoing management of the preserved O&C lands could
accomplish the recovery of threatened and endangered species as rapidly as science,
technology and nature would permit.
To restate the proposal in simplified form:
THE PROSPOSAL
1.2 million BLM acres in the O&C region placed into a reserve and managed by BLM
under FLPMA excluding Sec. 701(b), the O&C Act savings provision. The O&C Act
would be repealed.
1.2 million BLM acres in the O&C region sold to the private sector for permanent timber
production with public access retained at the current level.
The 1.2 million acres retained by the federal government would provide recovery for the
spotted owl and its habitat as required, as well as protecting other high value
environmentally sensitive areas including stands of old growth timber.
The 1.2 million acres sold to the private sector for permanent timber production would
capitalize four trust funds.
Trust Fund A equal to 33.3% of the total sale of the 1.2 million acres returned to the
private sector would go to an irreducible Secure Rural Schools and Communities Self-
Determination Act (National Forest counties and schools) trust fund.
Appendices - 1001
FEISfor the Revision of the Western Oregon RMPs
Trust Fund B equal to 33.3% of the total sale of the 1.2 million acres returned to the
private sector would go to an irreducible O&C Land Grant Counties trust fund.
Trust Fund C equal to 25% of the total sale of the 1.2 million acres returned to the private
sector would go to an irreducible Oregon school trust fund managed by the legislature
and Governor.
Trust Fund D equal to 8.4 % of the total sale of the 1.2 million acres returned to the
private sector would go to an irreducible trust fund in favor of BLM to manage the 1.2
million acres of lands retained in a federal reserve for the benefit of the spotted owl and
high value areas including old growth.
A commission or council similar to the Congressional authorized “Forest Counties
Payment Committee” or the “Military Base Closure Commission” would be created to
identify the O&C RR grant lands to be sold and returned to private ownership within one
year of authorization, with the recommendations implemented by congressional action.
Appendices - 1002
Appendix T - Responses to Public Comments and Comment Letters
citvof f
AT YOUR SERVICE
PUBLIC WORKS FIELD OFFICE
1410 20th Street SE, Bids #2 • Salem, OR 97302-1200 • (503) 588-6063 • Fax (503) 588-6480
Western Oregon Plan Revisions
P.O. Box 2965
Portland, OR 97208
SUBJECT: COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT (EIS)
U.S. Department of the Interior Bureau of Land Management:
This letter shall serve as the City of Salem's formal comment on the U.S. Department of the
Interior Bureau of Land Management's (BLM) Draft Environmental Impact Statement (EIS) for
the Revision of the Resource Management Plans of the Western Oregon Bureau of Land
Management Districts.
The City of Salem provides drinking water to over 180,000 customers and relies on the
predictable high quality source water from the North Santiam River as its primary source.
Therefore, the City's primary concern with any management plan affecting land within the
North Santiam River watershed is the resulting impact on downstream water quality. The City
has generally been in support of the current Northwest Forest Plan management techniques
and believes that the work being conducted by BLM staff in the Cascade Resource Region
follows the guidelines and meets the goals of the current plan. However, the City is concerned
that the Draft EIS for the revised Resource Management Plan deviates from previous water
quality protection goals of the Northwest Forest Plan. The United States Department of
Agriculture Forest Service (USFS) has published the "First-Decade Results of the Northwest
Forest Plan"* 1, which found that watershed conditions overall did improve slightly in this short
period by adhering to the current plan.
Research published in the Draft EIS suggests that if there is more than 25-100 feet of filtering
strip between unprotected soil surfaces, there is usually not a risk of transporting sediment to
streams2. The City believes a greater stream buffer width is needed to ensure that sediment is
trapped in the forest floor duff and vegetation. Belt et. al. (1992) reported that filter strips on
1 First-Decade Results of the Northwest Forest Plan. www.fs.fed.us/Dnw/Dublications/otr720/Dnw-otr720.Ddf
1 Oregon State Office, 2007. Draft Environmental Impact Statement for the Revision of the Resource Management Plans of the Western Oregon
Bureau of Land Management Districts. Volume 1. Pg 373.
January 8, 2008
r -ceiveo
JAN 0 9 2008
❖ ADA Acommodations Will Be Provided Upon Request ❖
Appendices - 1003
FEISfor the Revision of the Western Oregon RMPs
Western Oregon Plan Revisions
1/8/08 - Page 2
the order of 200-300 feet are generally effective in controlling sediment that is not
channelized3. In addition, the City is concerned about the potential impact on sediment load on
watershed streams by increasing the number of acres of regeneration harvest. The No Action
Alternative would continue regeneration harvest at 60,500 acres, where Alternative 2 increases
regeneration harvest to 143,400 acres. A portion of these cuts would disturb previously
protected stream filter strips and potentially adversely affect stream water quality. Stream bank
erosion has been shown to increase 250% over pre-harvest levels after clear-cutting, but only
32% over pre-harvest levels where buffer strips were utilized (Belt et.al., 1992).
The City of Salem is concerned that this revised plan proposal reduces the protection of water
quality in the North Santiam River watershed. The City believes the revised plan fails to
adequately protect water quality for Salem's drinking water source by reducing stream buffer
widths and increasing regeneration harvesting volumes. The City would prefer that BLM
continue to use current stream filter strips similar to the distances in the No Action Alternative.
The findings in the USFS Northwest Forest Plan report are encouraging, but it will take BLM's
current forest management and more time for the forest to gain complex structure to see the
full potential of benefits to water quality and habitat.
Sophia Hobet
Water Services Manager
KMD/SCM:G:\FILES\CHRONO\2008\SH 010808 Comments on Draft Environmental Impact Statement.docx
3 Belt, G., O'laughlin, and Merrill, T., 1992. Design of Forest Riparian Buffer Strips for the Protection of Water Quality: Analysis of Scientific
Literature. University of Idaho, www.uidaho.edu/cfwr/pao/oaar8.html
Sincerely,
Appendices - 1004
Appendix T - Responses to Public Comments and Comment Letters
loH
NOV 2l 2007
City of North Bend
Post Office Box B • North Bend, OR 97459-0014 • Phone: (541) 756-8500 • FAX: (541) 756-8527
November 1 3, 2007
Edward W. Shepard, State Director— BLM
P.O. Box 2965
Portland, OR 97208
RE: DEIS Western Oregon Resource Management Plan Revisions
Dear Mr. Shepard:
The North Bend City Council met in regular session on November 1 3, 2007 to formally
discuss the Draft Environmental Impact Statement (DEIS) for the Revision of the
Resource Management Plans of the Western Oregon Bureau of Land Management
Districts. We are writing at this time to express our support of Alternative 2 which is
described in the DEIS. City of North Bend representatives have taken the opportunity to
review the DEIS summary, attend local forums and tour BLM lands. It is our
understanding that The DEIS provides for four management options ranging from "no
action” to three specific alternatives. It is clear that Alternative 2 would have the most
favorable impact on the local economy and would result in revenues equal to
approximately 94% of the lost O & C revenues to counties. Alternative 2 provides for
protection of fish, wildlife and the environment while allowing for restoration of our
timber economy. Cutting timber reduces the need for federal subsidies and Alternative
2 , simply put, makes sense.
For decades, timber has been the backbone of our economy and growing trees is one
of the things Oregon does best. This is one of the most important issues facing our
communities today and we urge the adoption of Alternative 2. We appreciate all that
has been done to present this information to our community so that we remain
informed. Thank you for the opoqilurwTy'to comment.
Rick Wetherell, Mayor
City of North Bend
cc: Senator Gordon Smith
Senator Ron Wyden
Congressman Peter DeFazio
Senator Joanne Verger
Representative Arnie Roblan
Appendices - 1 005
FEISfor the Revision of the Western Oregon RMPs
^o7
CENTRAL
POINT
RECEIVED
Oregon
OFFICE OF THE MAYOR
SEP
August 30, 2007
Department of the Interior
Bureau of Land Management
P.O. Box 2965
Portland, OR 97208
The City of Central Point, Oregon supports active torest management that returns at least 90 to 95% or
receipts to Jackson County Government for the following reasons andvsupports Alternative 2 of the EIS
four alternatives:
• Central Point is directly and indirectly affected by whether the county can maintain a level of
services that provide public safety, libraries and critical human services. In Jackson County,
without a safety net or adequate timber harvest, our County Sheriffs Deputies will be reduced,
our libraries remain closed and critical health services reduced or eliminated.
• Alternative 2 proposes to harvest only 60% of the annual growth of about half of the land, yet
will provide 94% of the revenue needed which is about $16.9 million each year.
• 1 consider myself to be an environmentalist and am concerned about livability in Jackson
County because many of our businesses depend on tourism. Option 2 still has full protections
of the Endangered Species Act, the Clean Water Act, the Clean Air Act and the National
Environmental Policy Act. Only 48% of the 2.5 million acres of O & C lands have active
management and the rest is restricted management or environmentally protected. It also
provides for restoration of forests after catastrophic events.
• Alternative 2 restores numerous wood products industry jobs which pay good wages and help
the economy in small rural towns, like Central Point.
• It is for these reasons that the City of Central Point supports the Alternative that restores at least
90% of funding for the counties and protects the environment and that appears to Alternative 2.
Hank Williams, Mayor of Central Point, Oregon
755 South Second Street • Central Point, OR 97502 • 541 .664.3321 • Fax 541 .664.6384
Sincerely,
Appendices - 1006
GUO U.S. GOVERNMENT PRINTING OFFICE: 2008 — 776-069 / 21006 Region No. 10
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