Land and Resource Management Plan Ochoco National Forest and Crooked River National Grassland

United States Department of Agriculture Forest Service Pacific Northwest Region 1989

Caring for the Land.. .

~~ ~~ ~~ FElS APPENDICES A & I

TABLE OF CONTENTS

APPENDIX A Issues. Concerns and Opportunities

Page Introduction ...... A-I Issue Identification ...... A-1 Consultation with Others ...... A4 The Screening Process ...... A-5 How were the Issues Developed in the Public Involvement Process ...... A-6 Changes in Issues from Draft to Final ...... A-13 Issues to be Addressed by the EIS ...... A-I 6 How were the Issues Used in the Development of Alternatives ...... A-24

APPENDIX I Response to Public Comments

Page 1 Introduction Summary of Public Participation Activities ...... 1-1-1 Summary of Comments Received...... 1-14 Issues and Public Comment Summary ...... 1-1-6 Supplement to the DElS ...... 1-1-1 1 Responses to Public Comments ...... 1-1-12 Changes Made in Response to Public Comments ...... 1-1-13

2 List of Respondents ...... 1-2-1

3. Summary of Comments and Forest Service Responses Subject Area Index...... 13-1 Comments and Responses...... 1-3-6

4 . Comments from Elected Officials, Agencies and Indian Tribal Governments ...... 1-4-1

5 . Newspaper Articles Chronicling Publication of the Draft Documents and Supplement to the DElS ...... 1-5-1

I APPENDIX I

LIST OF TABLES

Table Page 1-1 Review Period Public Meetings...... 1-1-2 1-2 Forest Sewice Presentations ...... , ...... 1-1-2 1-3 Sources of Responses...... 1-14 14 WhoResponded ...... 1-1-4 1-5 TypeofResponse...... 1-14 1-6 How They Responded - Respondents Preferring a Particular Alternative...... ,. . . . 1-1-5 1-7 How They Responed - Respondents Preferring a Particular Alternative (Resource) ...... , ...... 1-16 1-8 Summary of Public Comment Received on the Supplement to the DEIS. . . . . 1-1-12 i

Issues, Concerns, and Opportunities The Management Team agreed to utilize interest Appendix A groups as a starting point. Individuals representing key interests of conservationists, recreationists, sportsmen, ranchers, timber industry, and government agencies were invited to identify preliminary issues that could be expanded or refined by a broader au- dience. These key interest groups met with the Forest Interdisciplinary Planning Team (ID Team) at six meetings held during the period of September 27 to October 2,1980. A total of 56 people attended Issues, Concerns, these meetings. From the meetings, 125 preliminary issues, con- and Opportunities cerns, and opportunities (ICO’s) were identified. TheID Team then consolidated theseICO’s into 60 issues and submitted this list to the public alongwith a request for response. A total of 338 copies were mailed to addresses on the Forest’s mailing list, 450 copies were distributed from our oEces, and another 2,000 were distributed through bulk mailings Introduction to the rural areas around Bums and Prinenlle, Oregon. This appendix covers the major steps taken to iden- In addition, public involvement was requested through tify public issues, management concerns and re- various news media. Newspapers, radio, and televi- source opportunities considered during the plan- sion participated as listed below: ning process. The appendix IS organized into five Media Title Origin sections: 1) the process used to identify the issues, Newspapers The Newspaper Prineville concerns and opportunities, 2) contacts and consul- The Central Oregonian Prinede tationswithothers, 3) thecriteriaused toscreen the The Burns Herald Burns issues down to the few selected to be addressed in the Environmental Impact Statement (EIS), 4) The Madras Pioneer Madras changes in the issues between the Draft and Final The Bulletin Bend EIS, and 5) a discussion of the issues and how they The Redmond Redmond were used to formulate alternatives. Spokesman Radio KRCO Prinevdle KBND Bend KICE Bend KZZR Burns Issue Identification Television KTVZ Bend During the Fall of 1980, the Forest began to identify The ID Team also conducted six public meetings to the principal issues to be addressed in the Draft gather additional public comment. These meetings Forest Plan. TheForest Management Team (Forest werein Prineville (two meetings) 11/12/80, Dayville Supervisor, District Rangers, and Forest Staff Offi- 11/13/80, Paulina 11/13/80, and Burns (two meet- cers) decided to try a fresh approach, without a ings) 11/24/80. Five other meetings were held for rehash of old issues from former Unit Plans. The Forest Service employees. previous issues were reviewed but not established as a base.

A-1 FElS Appendix A

Response from mailings and attendance at themeet- 10. To what extend should off-road vehicle use be ings was as follows: controlled? Mailing Responses - 164 11. Towhat extent should firewood be provided to Attendance at Public Meetings - 52 meet demand? Attendance at Forest Service Employee Meetings - 12. Howmuchhabitatshouldbeprovided forwild- 121 life species dependent on dead trees? 13. To what extent should the Forest and Grass- The ID Team used the information that was gath- land provlde for an expanded trail system? ered to consolidate the issues into resource or land ~ use topics. Seventeen issues were developed from 14. To what extent should the Forest provide for this exercise. Comments that were not clearlyrepre- winter sports activities? sented in these 17 issues were also evaluated by the The interdisciplinary team developed alternative ID Team. managementstrategiesbasedon theseissues.As the In January 1981, these 17 issues were submitted to alternatives were developed two of these issues the public for verification and ranking by intensity. were removed from the preceding list. They were Ranking the issues was useful initially, however, the the off-road vehicle use issue and the trail issue rankings were later dropped when they no longer (numbers 10 and 13). proved meaningful in developing the alternatives. The off-road vehicle use issue, as initially identified The 17 issues were condensed to 14 as a result of the in the public involvement process, was primarily an analysis of the public responses. These 14 issues are issue on the Crooked River National Grassland. It listed below. appeared at the time that the issue could be negoti- 1. What should be the level of timber produc- ated at the local level, outside the Forest and Grass- tion? IandPlans. During thevalidation effort between the Draft and theFmal, the publicandagency interest in 2. Howcan activitieson theForest and Grassland ORV use has increased. The Henderson Flat area benefit social and economic wants and needs of local communities? on the Grassland continues to a controversial area. In addition, some of the local citizenry has voiced 3. What is the appropriatelevel of livestockgraz- concern over resource damage by ORV's on other ing and intensity of range management? areas of the Forest and Grassland. 4. Howshould riparian areas be managed to meet The trail issue was also dropped as a separate issue. various resource needs? As the proposed trail system is closely tied with the 5. What road system should be provided to meet allocation of roadless areas, the two issues were public, commercial and administrative access closely related. On those trails (existing or pro- needs? posed) not part of the roadless area allocation issue, only minor resource interactions were identified, 6. Shouldhabitatbe provided for increased popu- with little affect to the overall management of the lations of big game? Forest and Grassland. 7. How much roadless recreation opportunity In April 1984, three public meetings were held to should be provided? update the issues and acquire additional informa- 8. Should the Forest and Grassland limit the em- tion on unroaded areas. The meetings were held in phasis placed onvisual resources to those areas Prineville (on April 2, 3, and 4) with 29 people of high scenic value? attending. 9. How much old growth habitat should be provided?

A-2 After those meetings, the Forest continued to use a ments received on the DEIS did result in the devel- variety of activities to keep its employees and the opment of a new alternative, Alternative I. In addi- local communities informed of the planning proc- tion, Alternatives B and C were modified. ess. We published periodic articles and special edi- A Supplement to the DEIS was prepared in re- tions in our Forest and Grassland report. We pre- sponse to two appeals that took issue with some of pared and distributed a Forest Plan Report. During themethodsusedinForest planningbythe National the summer and fall of 1985 we had multi-resource Forest in the Pacific Northwest. The appellant was media coverage, providing information and educa- concerned with how the “No Action” Alternative tion on Forest management. Through a networking was described, and the methods used to address process, each Management Team member has been Forest planning management requirements. The contacting key individuals in our local communities Supplement described a new alternative, Alterna- and informally discussing Forest management and tiveNC(nochange), andanalyzed alternativelevels the planning effort. of management requirements. The SEIS was pub- The Proposed Land and Resource Management lished in October, 1988, and the 90-day public re- Plan and the Draft Environmental Impact State- view period ended January 17,1989. The Forest re- ment were published in September, 1986. Notice ceived nearly 200 letters in response to the Supple- was published in theFederalRegister on September ment. The results of the public response period for 12, 1986. During the 90-day public review period, the Supplement are also discussed in Appendix I of 1,125copiesoftheDraft Plan andEIS weredistrib- this FEIS. uted. The Forest announced the availabilityof these Significant steps were employed during the last 3 documents through seven news releases and three monthsof final document preparation to insure that Forest Plan reports. Office hours were extended at direction in the Final Plan responded accurately to the Supervisor’s Office in Prineville. The Forest comments received on the Draft. Meetings were held six public meetings and 25 organizational, indi- held, and contacts made with selected groups, individual or agency meetings. Radio and television viduals, agencies and political leaders in order to: interviews, fliers, newspaper articles, and displays at the Jefferson, Harney and CrookCounty Fairs were Validate public responses received during the also used to inform the public of publication. process. A number of interest groups were active during the Insure that we correctly interpreted what was DEIS comment period. Of particular note was the said. levelofactivityby timberindustry, thecentral Ore- Insure thatwedid not misssomethingoroverlook gon Economic Development Council and a coali- stumbling blocks towards successful implementation of eight environmental groups. Two additional tion. groups were activelyinvolved in expressingopinions about the management of Lookout Mountain: snow- Set the stage for implementation of the Plan. mobile organizations and the retirement community. The activities of these groups appeared to play a significant role in soliciting additional public com- This networking followed our efforts in seeking ment, and in many cases, appear to have been a broad public review of our draft documents. During major source of information from which these com- this time, 39 meetings have been held with more ments were generated. than289citizens, and 69 interest groupsor agencies. During the 90-day public review period, 2,154 com- In response to this effort, when appropriate, adjustments were received. The results of the public comments were made to the final planning documents. ment period for the DEIS are thoroughly discussed This was intended to strengthen the Plan and build in Appendur I of this FEIS. The substantive com- a base of support for effective implementation.

A-3 FEE Appendix A

During public review of the Draft Plan, the issues of known issues. The goals of those agency plans were uneven age management and growing large diame- included in at least one of the alternatives devel- ter ponderosa pine trees were brought to the fore- oped by the Ochoco National Forest. front. To promote publicinformation and education Interest groups involved in the development of ison these issues in a contemporary fashion, a video sues, concerns, and opportunities were assembled entitled “Ponderosa Pine Management in Central periodically to keep them appraised of progress and Oregon” was developed. Presentations were given to acquire additional information or feedback from to local civic clubs, interest group meetings, and the them. The groups are: media. Conservationists - Local members of the Oregon NaturalResource Councilwere contacted. These contacts included, as a principal contact, the Central Oregon Conservationists. This group also included Consultation with Others the Blue Mountain Resource Alliance, the Grant County Conservationists, and the Central Ore- Several agencies and Native American Tribes were gon Chapter of the Sierra Club. involved in the initial issue development process. The most active of these agencies were the Oregon Recreationists & Sportsmen - Included are the Department of Forestry, Oregon Department of Ochoco Snow Sports Club, the Oregon State Fish and Wildlife, and the Bureau of Land Manage- Snowmobile Association, the Nordic Club, the ment. These contacts provided the identification of Oregon Hunter’s Association, and the Ochoco agencyconcerns that could be dealt with in the plan, Elk Hunters. provided information useful in the analysis, and Ranchers - The Crook County Stockmen’s Asso- allowed the coordination of management and plan- ciation was the organization most frequently ning efforts. contacted. The Grey Butte Grazing Association, Reviews of other agency plans, which could affect in their link to the management of the Grassland, was theonlyorganized adjacent landownergroup the Forest and Grassland Plans, were undertaken by the Forest. The followng plans were examined: frequently involved in plan development. Plans from Crook County, Deschutes Industry - Industryrepresentatives from the local County mills oftenparticipated. Theywere joined byrep- County, Grant County, Harney County, Jeffer- son County, and Wheeler County. resentatives from the Northwest Pine Associa- tion and the Western Forest Industry Associa- State Plans from the Oregon Forestry Depart- tion. The Associationof OregonLoggers alsowas ment, Parks andRecreation Division, StateCom- involved. prehensive Outdoor Recreation Plan, Depart- Government Agencies - The Forest contacted ment of Fish and Wildlife, and the Oregon Rec- reation Trail System. Crook, Harney and Jefferson Counties, the Governor’s Office, Congressman Smith and Sena- Bureau of Land Management Plans, including tor Packwood. the Brothers Grazing Management Program, Wilderness Study Proposals, and the John Day Area Plan were studied. Also reviewed were plans for the Warm Springs Reservation and the Central Oregon Economic Development Plan for fiscal years 1984 and 1985. The review of these plans did not identify any un-

A-4 The Screening Process Is it a prior decision which can’t be reversed? Is it outside of Forest Service jurisdiction? The preliminary issue, concern and opportunity comments were screened and consolidated in two Should it be dealt with at some other planning separate operations. The first process involved the level? 125 comments received from the interest groups Does it involve land use allocation? previously identified. These KO’s were run through a sct of screens. First, it was determined if the IC0 Is it operational in nature, a standard, guideline, could be immediately resolved by either the Forest or budgetary? Supervisor or District Rangers. Second, the deter- What is the source? From public or manage- minationwas madewhether or not the Forest could ment? and should address each of the ICO’s through the Are there common or similar aspects? planning process. Some suggestions were beyond the scope of this planning effort and comments of Categorize comments by 1) production of out- this naturewere screened out of the potential issues, puts, 2) use of resources, 3) a management prac- but wereshared with theForestManagement Team. ticeorprescription, and 4) management perform- The third screen was the resolvability of the ICO. If ance or policy. thesuggested issue was not considered resolvable in 2. Determine Action to be Taken on Issues and the forest planning process, it was referred to the Concerns management team for actionoutside the forest planning process, and dropped as a planning issue. Next, Consider in the planning process. issuestatements thatwere potentiallypart of alarger Transfer to management for action outside the issue were identified. For example, the amount of Forest planning process. timber available to the local mills could be considered a part of the larger issue of the level of timber Determine to be irrelevant. harvest which should be provided from the Forest. Each action was justified and documented. These issue components were retained and dealt with throughout the planning process. 3. Take Action The second process was to take the tentative issues Consider in planning process: develop as an issue that passed through the screening process and con- or concern, or deal with as a planning or process solidate them into likecomments byresourcegroup- criteria. ings. These consolidationswere then written by the Refer to management for appropriate action or ID Team into terms that would best reflect the con- response. tents of those groups. These steps reduced the 125 comments to 60 comments which were submitted to Determine to be irrelevant. the general public for their comments. The management concerns were then compared This second set of categorized comments was then with the public issues and incorporated with the evaluated using the following steps: issues, or classified into various non-issue categories, such as: administrative decisions, planning cri- 1. Evaluate Issues and Concerns teria, opinions, items required by Federal regula- Is it already required in the planning regulations? tion, items outside the scope of the planning process, items outside of Forest jurisdiction, statements, Can it be dealt with by the responsible official practices to be shown in prescriptions, and items without going through the planning process? that are part of the planning process.

A-5 FElS Appendix A

The results of the screening process are on the fol- Make reforestation a high priority. (C) lowing pages. Three categories are used to identify Do not conduct precommercial thinning except for how the issues and concerns were screened after mistletoe and insect control. (I) categorization by resource. Thelist represents those issues and concerns that were not eliminated, re- Stop wasting natural resources, such as wood prod- ferred, or resolved through the interdiscipliniuy team’s ucts. (I) screening process. Many of the issues were similar; Protect tree seedlings from animal damage. (C) an issue statement may be representative of many comments. Treated Differently by Alternatives Make more land available for timber production and harvest. (I) Utilize all availabletimber mortality in a timely man- How Were the Issues ner. (I) Developed in the Public Depart from non-declining even-flow timber harvest. (I) Involvement Process Use silviculture practices, such as fertilization and plantingof different species, to produce greater tim- Handled? ber volume. (I) Provlde more timber products. (I) Reduce the acreage of forest land available For timber harvest allocated to old growth. (I) Disposition of Issues by Eliminate burning as a slash treatment method. (I) Category Need more intensive timber management (enhance timber and other resources in balanced silviculture ’The lnltials I, C, or 0 denote whether an issue evolved from practices). (I) a public issue (I), a management concern (C), or an oppor- Launch an intensive reforestation program for fu- tunw (0) ture needs. (I) Should clearcutting be practiced on the Ochoco? Issue #1, Timber Supply and (1) Forest Management Do wtcreate management areas with no programmed harvest. (I) Deferred outside of Plan Consider re-use of tomahawk in treating thinning Clean up logging slash. This would soften the impact slash for firewood availability. (0) and create less animosity toward timber harvesting. (UO) Administer timber sales so as to insure fenceswill be left intact or repaired promptly. (I) We need some intermediate types of harvest and roadless combinations. (UC) Treated Same in all Alternatives We are getting good regrowth, but we’re cutting Sophisticated logging methods are not always needed. trees down faster than regrowth is occurring. (I) Analyze entire process to ensure continuity of implementation, end product, and follow-through. (I)

A6 \

Issue #2, Social and Economic Larch should be more available to permittees for fence posts. (I) Wants and Needs of Local Don't use Special Use permits that create an eco- Communities nomic impact on the grazing permittees. (I) Deferred Outside of Plan Skid trails supporting adequate grass should not be People too far from Central Oregon may set plan re-used for new entries. (I) priorities. (I) Treated Same in All Alternatives Treated Same in All Alternatives None Analyze costbenefit of producing timber and quantify effects on habitat and dispersed recreation. (I) Treated Differently by Alternatives Provide both a maximum and consistent supply of Treated Differently by Alternatives forage. (I) Correct the disparity between economic considera- Stop repeated timber harvest entries in the same tions given one resource vs. another. (C) specific areas which result in adverse economic im- Improve the social and economic condition of the pacts on the grazing permittee. (I) local communities. (C) Visual and riparian management objectives are too Maximize economic and social benefits to locally restrictive on grazing livestock. (I) dependent communities. (I) Reduce grazing restrictions to improve utilization Recognize community development needs and op- and palatability of forage for livestock and wildlife. portunities: a) increase employment, b) recognize (1) social impacts ofdecision made, c) increase National Utilize more range improvement practices to obtain Forest receipts to the County in real dollars, d) pro- better range conditions. (C) vide equitable distribution in employment increases or decreases, e) display impacts of actions on other Reduce the use of grazing systems which cause eco- lands and resources in the community. (C) nomic impacts on the rancher. (I) Too many dollars are taken out of the system by Provide more range improvements to manage the unroaded allocations. We need the payments to range, to meet resource management directions for counties generated by returns from receipts for use all resources (riparian, etc.), andstill maintainstock on local roads and for schools. (I) numbers. (UC) Emphasize uses that produce a dollar return vs. Develop more water systems. (I) those that do not. (I) Overgrazing is creating erosion. (I) Reduce cattle grazing (I) Issue #3, Livestock Grazing Whenever range improvements are carried out, commensurate animal unit months (AUMs) should and Allotment Management be made available. (I) Deferred Outside of Plan Assignment of other areas to wilderness would re- Livestock grazing should not be allowed on the For- duce forage production over the long haul. (I) est. (I) More knowledge and information is needed regarding grazing seasons anddistribution with associated effects on resources. (I)

A-7 FElS Appendix A

Issue #4, Riparian Area Issue #5, Transportation Management System Deferred Outside of Plan Deferred Outside of Plan Livestock enclosures of creeks (e.g. Silver Creek) Do not construct any roads across private land with- have not encouraged riparian recovery. (I) out permanent public access. (I) Repair damage to rockhound sites to prevent ero- Close roads which connect Forest lands with deeded sion. (I) land. (I) Bicycling could be a significant recreational activity Treated Same in All Alternatives on the Ochoco. Consideration should be given to All soils on slopes over 30 percent should not be this potential in road design, construction and re- lumped into one category of being highly erodible. construction. (UO) (C) Privateownersshould not close access toroads built Treated Differently by Alternatives with public money. (I) Provide the greatest balance of water quality and Involve public indecision to close roads, and inform quantity. (I) public before roads are closed. (I) Maintain riparian habitat which is healthy and im- Off-road vehicle use should be stopped when it cre- prove current degraded riparian habitat associated ates erosion or occurs on fragile terrain. (I) with streams, springs, intermittent streams, etc. (I) Accomplish recovery of riparian communities by Treated Same in All Alternatives 1990. (I) Roads should be constructed to the lowest standard (length and width) which allows protection of other Harvest timber in a manner to reduce stream chan- resources. (I) nel damage from high spring runoff and to increase summer flows. (C) Do not pave roads. (I) Do not use fences to restrict cattle grazing in ripar- Off-road vehicles should be permitted for resource ian areas. (I) administration only. (I) Place more emphasis on enforcing existing regula- Treated Differently by Alternatives tions pertainingtosoil, water, andwildlife resources. More roads are needed to provide intensive use of (1) all resources (C) Allow no more enclosures of riparian areas until Too much money is being spent on high standard results of riparian recovery are proven in exlsting road construction (I) closures. (I) Too many roads (I) Do not construct any more riparian enclosures. (I) Well-known established roads should not be closed More restrictions are needed concerning tractor to vehicular access; roads which have been closed and rubber tired skidder logging on wet soils. (C) should be reopened. (I) Keep logging disturbance to a minimum, such as re- Keep exlsting roads and rockhounding areas open using same skid roads. (C) for access by motor vehicles and the public. (I) Whenever possible, use gates for closing roads instead of tearing up roads. (I)

A-8

species. Others note that grazing increases are de- implement the riparian prescription. These figures pendent upon new water developments away from are included in Chapter 2 of the FEIS, Table 2-8, existing riparian areas which help to disperse use Range Improvements. Potential for individual stream and reduce riparian damage. The public felt the reaches to support willows, cottonwoods and other Forest needed to show site potentials for willows deciduous shrub and tree species will be determined and cottonwoods and to implement activitiesfor the on a site-specific basis in individual allotment man- protection of various plant communities. Some stated agement plam using riparian plant community guides thattheochoco National Forest needs to stopplant- published by the Pacilic Northwest Forest and Range ing “tough” poor nutrient grass for riparian protec- Experiment Station. tion. Erosion control seed mixes used on road cut and fill The OregonDepartment ofFish and Wildlifestated slopes commonly contain several species of grasses. that the information on livestock grazing was not Often one or two of these species are not as palat- sufficient in the EIS. Theywantedmoreinformation able as others to wildlife and livestock. The empha- on the management systems, condition and trend, sis in these instances is on using species that estab- actual use and improvement programs to evaluate lish quickly to hold the soil in place and which won’t effects of the grazing program. be immediately consumed by livestock and wildlife. The Columbia River Inter-Tribal Fish Commission Standards and Guidelines have been developed in felt that when management strategies and integrity the Preferred Alternative I to identify and protect fail to protect riparian areas, fencing will be used. threatened and endangered species and sensitive They ask how many miles of fence will be needed to plants. protect riparian areas. The Commission also questioned the record of compliance of cattlemen in moving their herds as frequently as is required. 0500-02.3 Grazing Effects The U.S. Environmental Protection Agency stated Two letters discussed the issue of threatened and that in prioritizing the development of Forest level endangered plants affected by grazing. Some com- plans, it would encourage making the allotment mentswere that affected threatened, endangeredor management plan one of the first. This is because it unique plants need to be addressed better by the will have a direct bearing on riparian areas, water Ochoco National Forest, or that the Forest should quality, and the protection of beneficial uses. plant grass so it will be available during peak season use. This, according to respondents, would allow Response: natural threatened and endangered species to de- The Draft EIS did not do a good job of covering the velop and remain strong and disease resistant. environmentalconsequences of livestock use on the Forest and Grassland. This area has received much Response: moreattention inchapter 4 of theFEIS. Additional Chapter4 of the FEIS evaluates the effects of graz- work has been done on identifyingneeded improve- ing by domestic livestock on threatened, endan- ments in riparian areas in Chapter 4. Watersheds gered and sensitive plant species. have been prioritized for improvement and allotment management plans scheduled for updating. Standards and Guidelines have been developed in Schedules are included in the Final Plan to show the FEIS alternatives to identify and protect sensi- these priorities, as well as schedules to show the tive plant species. Forage utilization standards in the projects and work necessaly to meet riparian pre- Final LRMP will allow good plant vigor and high scriptions. levels of plant species diversity. An evaluation was done for the final plan to estimate total miles of fence and water developments to

1-3-65 FEIS Appendix I

@0500-03 Raise Grazing Fees @0500-04 Management Eighty-four responses, including those of the EPA SIXcommentsdealt with the issue ofspecifie grazing and the CRITFC, commented on the fee aspect of management systems. the grazing program. Some comments were that the Ochoco National Some stated that the Ochoco National Forest is Forest failed to fully disclose specific grazing man- operating a cattle grazing give-away program and agement systems, and that issues and concerns need that it is undercharging cattlemen for the use of to he discussed on an allotment-by-allotment basis. publicly owned land. Some also remarked that the One reviewer felt theRockCreek allotment was not Forest Service is operating a program which costs covered adequately in the proposed plan. In addi- more than it returns to the Treasury. These respon- tion, some stated that the Forest Service needs to dents felt that the permittees should pay the full include ranchers in the management picture and costs of administration of the grazing program. display present and future grazing conditions. The Environmental Protection Agency felt that the increased costs in grazing management area should Response: not he included in “environmental” effects, but that Specific grazing management systems wdl not be these costs should be discussed as an economic outlined in the FEIS or Plan. Those decisions are issue. made in the individual allotment management plans in consultation with the affected permittee. They The Columbia River Inter-Tribal Fish Commission are site-specific and require on-the-ground analysis. stated that the Ochoco National Forest should No matter what grazing system is employed, each consider the factors that are involved in the trade- allotment will be monitored to make sure it is meet- off between Range and Timber management. The ing all resource objectives such as riparian area Commission also asked why the most productive recovery and wildlife habitat objectives. lands were allocated solely to range.

Response: @0500-05 Utilization Rates The issue of grazing fees is outside the scope of the Forest planning process. The grazing fee formula and AUM’s was set by Congress, and in 1985 the base level was There were 18 comments that discussed implemen- set by executive order. Legislation would be re- tation of the plan and utilization levels for grazing. quired to change the grazing fees. Even though the returns theForestServicegets in theformofgrazing Some felt that the Ochoco National Forest needs to fees do not cover the cost of administration of the show the effects of implementation of and utiliza- range program, the economic benefits of the pro- tion levels for the proposed plan in regard to the gram are realized in the local economy. range land. Others stated that the Ochoco should include maps showing allotment AUMs and a dis- The allocation of management areas in the DEIS cussion of the implementation process. and Draft Plan was misunderstood. Timber/range emphasis was not intended to be exclusive use The In addition, some felt that the Ochoco National FEIS and Final LRMP have changed this Manage- Forest should manage all areas with 40-80% utihza- ment Area to General Forest (Ochoco National tion levels and that the Forest should adhere to the Forest) and General Forage (Crooked River Na- AMP schedule Many felt all fencesshouldbeshown tional Grassland); these are both multiple use areas. on allotment maps and cattle should be removed from the Forest by October 15,1989.

1-3-66 Response: The Columbia River Inter-Tribal Fish Commission Increases and reductions in permitted AUMs are stated that as the overstory is removed and the generally handled through the allotment manage- understory thinned, the forested rangelands will be ment planning (AMP) process. This is an allotment- found more frequently in fair and good forage con- specific planning process involving interdisciplinary dition class. The Commission questioned whether it team approval and directly involving the affected is necessary to thin old growth timber stands to livestock permittee(s). Resource objectives are thinned tree farms just to provide grazing. CRITFC outlined, a grazing system designed, various range also noted that the Forest Service stated that range improvements planned, and a monitoring plan de- utilization standards will not exceed an average of veloped.Thisis alldone through theNEPAprocess. 50% on meadows, and less than 30% on slopes and A schedule for updating allotment management asked if this is a new standard or if it has been used plans will he in Appendur A of the Final Plans. before. They also question why, if it has been used before, the ranges are still in predominantlypoor to Forage utilization standards are in Chapters4 of the fair condition. Final Plans and are separated for riparian areas and upland areas. Utilization standards are set to allow Response: prescribed use of forage but prevent overuse that The FEIScontarns alternatives that showarangeof would degrade the forage resource or other re- AUMS from approximately 73,000 to 80,OOO. These sources. Utilization is measured in areas preferred estimates were based on timber harvest levels with by livestock because those are the areas where over- resultant availability of transitory forage and on use and resultant resource damage would occur if investments in structural and non-structured range livestock were not removed after prescribed use. improvements that make previously unusable areas Utilization standards are incorporated into allot- available for forage use. Allotment-specific analyses ment management plans which become a part of the were done to determine riparian improvement needs grazing permit. Compliances with the grazing per- and estimates on what range improvements would mit is normally handled by close coordination be- be necessary to make those improvements. The tween the permittee andForest Officer, but ifviola- Ochoco’s analysis indicatesit can meet the resource tions occur, action is taken against the permitee. ohjectivesof eachalternative and produce the AUM Forage use by domestic livestock is a legitimate use outputs indicated. It was not considered necessary of National Forest Lands as mandated in the Mul- to arbitrarily reduce AUMs to show a broader range tiple Use Sustained Yield Act and will continue. of outputs in AUMs. Forage utilization standards have been changed in the Final Plan and EIS and are now based on whether 0500-05.1 Utilization Rates and range is in satisfactory or unsatisfactory condition AUM’s and on management intensity levels. Old growth timber stands are not proposed to be thinned to There were 21 letters, including one from the Co- improve forage condition classes under the stands. lumbia River Inter-Tribal Fish Commission, which New plant community guides and forage condition had comments on the range of alternatives and guides are due to be published for the Ochoco AUM’s Some of the comments were that the Ochm National Forest in 1990. National Forest needs to show an adequate range of alternatives and range of AUMs in alternatives. Some requested information on the availability of @0500-06 Wild Horses range to livestock, as well as data on increase or decrease on an allotment-by-allotment basis. Some Fourteen letters commented on the issue of wild recommended that the Forest consider using sealed horses on rangeland. bids and enlarging alternatives for foraging.

1-3-67 FEIS Appendix I

Many thought that the Ochoco National Forest Also, some felt that by reducing grazing, the Forest should not promote or allocate rangeland for the wl1 improve water quality and quantity. They felt management of wild horses. Many felt that horses that, by reducing AUM’s, taking fences down and compete for rangeland with big game and that they phasing grazing out in 10-15 years, the Forest Serv- are adversely affecting the enwronment. In addi- ice would improve riparian areas immensely. tion, some stated that the cost of controlling wld The Oregon Department of Fish and Wildlife horses is wasted funds, or that there are no “true” (ODFW) stated that they cannot support any in- wld horses on the ONF or CRNG. crease in theForest grazing program. ODFWstated One respondent felt the holding pen at Big Summit that it isdifficult tojustibcontinuationoftheForest is inadequate, that the horses were improperly fed grazing program, considering the standards and straw,andthat atleastonehaddiedwhileheldthere. guidelines in the proposed plan. Response: Response: The Wild Horses and Burros Protection Act was Domestic livestockgrazingon the Ochoco National passed by Congress in 1971. The law spells out very Forest is and has been an important part of the local specific requirements for dealing with wild horses. grazing economy. It can also be a means for manag- The horses on the Ochoco NationalForest meet the ingvegetation, e g. reduction of vegetative competi- definitionofwild horses in the 1971 Act, and as such tion in tree plantations and fuels reduction to re- are managed as required by the law. The Wild Horse duce wildfire hazard. Management Plan [Forest Plan, Appendix G) sets Overuse of many riparian areas and some upland the herd size based on the carrylng capacity of the sites has occurred in the past and is dealt with in the area. Final Plans by specific utilization standards (see The corral used to hold wild horses between the Utilization Standards, Chapter 4, Section 2 and 3). time they are captured and the time they are trans- Monitoring(Plans, Chapters) will assureutilization ported to thewild horse facility near Burns, Oregon, standards are being met. is of pole construction and has been built with the AUM levels by alternatives in the vary due to safety of the horses in mind Horses are fed while FEIS the amount of investment in structural range im- being kept in the facility, and to the agency’s knowl- provements and the level of timber harvest. Some edge, no horse has ever died while in the facility. structural range improvements are designed to make forage available m areas where it is presently not available, due to distance from water sources or @0500-07 Decrease Grazing livestock distributionpatterns. This can increase the One hundred twenty-eight public responses, includ- overall level of AUMs available while still not ex- ing the one from the Oregon Department of Fish ceeding utilization guidelmes Other structural range and Wildlife, commented on the current levels of improvements are designed to control livestock use, grazing. such as many riparian areas. This will allow forage use to acceptable levels and restrict any further use. Some felt the Ochoco National Forest should con- This kind of intensive grazing management, when sider reducing or maintaining current levels of graz- properly done, can increase the amount of AUMs ing as a viable issue. Some felt that since the over- available, while at the same time not rehabilitating grazingof the 40’s and 50’s, the land has been trying degraded riparian areas to heal, and perhaps the Forest needs to justify the appropriateness of grazing by analyzing the adverse Timber harvest opens the tree canopy, allowng environmental impacts. These impacts need to be more sun to reach the forest floor, which may in justified by NEPA standards, according to some. some cases produce more forage. This potential increase in forage production is termed “transitory”

1-3-68 because it will be available for a period of time and 1960. When properly administered, livestock use then will decrease as the forest canopy closes. The can be compatible with other resource values and level of timber harvest in an alternative determines uses. The environmental consequences of grazing how much transitory forage may be available over are outlined in Chapter 4 of the FEIS; livestock use time. Transitory forage can increase the overall of the Forest and Grassland contribute to the social amount of AUMs potentially available. and economic well being of local communities. Alternative C in the FEIS shows fewer AUM's than are presently permitted (FEIS, Chapter E). This is because Alternative C invests very little money in @0500-09 Prohibit Grazing in structural range improvements and has a reduced Certain Areas timber harvest level, which doesn't provide much transitory forage. Also, theemphasis of this alterna- Ten letters commented on grazing in sensitive areas. tive is for less grazing. All the other alternatives in The public respondents indicated that they feel the the FEIS show either more AUMs than are pres- Forest Service should manage the Forest for the entlypermitted orthesamelevel as atpresent due to public, not just for livestock owners who use it for investments in structural range improvements and grazing. Some felt that the Forest Service should timber harvest levels with resulting transitory forage remove all livestock from the Forest. If this is not production. possible, some stated, then the Forest should keep cattle on grasslands, and keep cattle away from poodfair condition areas for at least five years. @0500-08 Stop Grazing on the Additionally, some respondents recommended Forest removing cattle from wildlife winter range, riparian and shallow soil areas, and recreational areas. There were 52 letters that supported stopping livestock grazing on the Ochoco National Forest. Response: Many felt that livestock grazing should not be per- The riparian prescription in the preferred Alterna- mitted on the Forest, and that grazing is destructive tive I is designed to improve riparian areas. Individ- to native plant species. Also, they felt that livestock ual allotment management plans dloutline whether use compacts the soil and reduces plant diversity. this will require livestock exclusion (short term or Some claim that a decrease in livestock grazing long term) or whether more intensive management would reduce undesirable and exotic plants, upland systems and additional range improvements will be degradation and noxious weed invasion. Therefore, needed to meet the riparian improvement objec- many felt, there should be a no grazing alternative tives. and/or a ten-year ban on livestock grazing. Utilization standards in Chapter 4 of the Final Plans have utiluation levels that vary depending on whether Response: or not the area is in satisfactory condition. Areas The alternatives displayed in the FEIS have a range that are not in satisfactory condition will have use of AUM outputs. There is not, however, an alterna- levels adjusted down so they can recuperate. In tive that eliminates livestock grazing from the Ochoco some cases, there will be total exclusion for enough NationalForest and Crooked RiverNational Grass- time to allow recuperation of areas in less than land, nor were there alternatives that eliminated satisfactory condition other uses from the Forest or Grassland. Livestock Almost all of the developed recreation sites on the grazing bas been a traditional and important use of Forest and Grassland are fenced to exclude live- the Forest and Grassland, and is one of the uses stock. Those that are not fenced will be if conflicts specifically mentioned in the Multiple Use Act of arise between recreationists and livestock.

1-3-69 FEIS Appendix I

Section4(d) (4) (2) ofthe Wilderness Act states that not highly palatable are not grazed heavily. There is grazing in wilderness areas, if established prior to no more large scale range improvement seeding designation of the area as wilderness, “shall be per- using non-native grass species planned on the Ochm mitted to continue subject to such reasonable regu- National Forest or Crooked River National Grass- lations as are deemed necessary by the Secretary of land. Agriculture.” It was stressed that therewould be no The Forest conducts a program in cooperation with curtailment of grazing permits or privlleges in an local extension agencies to control noxious weeds. areasimplybecauseitisdesignated aswilderness. As stated in Forest Service regulations (36 CFR 293.7), grazing in wildernesses ordinarily will be controlled under the general regulations governing grazing of @0550-02 Management livestock on National Forests. This includes the One comment was received from a respondent who establishment ofnormal range allotments and allot- feels that while the Ochoco N.E has not a single ment management plans. Under the direction of botanist on its staff and has had only one major Preferred Alternative I, livestock grazing in Wilder- botanical study conducted, it continues to destroy ness will continue. natural plant communities and to propose further Livestock use of big game winter range will be destruction. controlled in the individual allotment management plans. Monitoring of use will be done and spring and Response: fall green-up will be reserved for big game in some The Ochoco N.E does not employ a botanist perse, cases. Grazing systems will be developed that leave but does employ on a shared basis a forest ecologist adequate forage for wintering big game who is an expert on plant communities and species In addition, the Forest employs range conservationists, foresters, and wldlife biologists who are versed in basic plant taxonomy and botany. The Forest also consults with the Native Plant Society and other Subject Area 550 Native/ local interest groups in these matters. Chapter 4 of theFEIS analyzes theeffectsofvariousprogramson Introduced Plants plant communities.

@0550-01 Introduced Plants 0550-02.1 Management Two comments were received from respondents One comment was received from a respondent who who were concerned that the Forest Service plants was concerned that grazing may oftendestroy bene- introduced grass species for erosion control and ficial and increasingly rare plants in favor of other some range improvement projects. It was felt that species. the introduced grass species grow tall and tough and are not good forage species. Response: Proper grazing and management practices generally Response: should not result in this. Some of the impacts of Species of grass that are not native to the immediate grazing in the Blue Mountains seen today are a area are sometimes used for erosion control pur- result of practices that took place at the turn of the poses on road cut and fill slopes and other disturbed century. Chapter 4 of the FEIS analyzes the effects areas. The reasons are two-fold some introduced of grazing on sensitive plant species. species are easier to establish, and species that are

13-70 0550-02.2 Management One comment was received from a respondent who felt that Forest Service management was increasing brush and juniper to the detriment of grass, which causes deer and antelope to go to private land to feed. Response: The alternatives in the FEIS provide different allocations of land for big game emphasis. Big game winter range is to be managed to provide a cover Eorage ratio for wildlife needs. This will not, however, change the fact that some traditlonal big game winter range is off the National Forest and Grass- land; andunderwinterconditions,big game may end up on the private lands at lower elevations.

1-3-71 FEIS Appendix I

well as rare and endangered organisms. Motorized Subject Area 600 recreation IS incompatible wth these goals and objectives. Non-motorized recreation use is not gener- Research Natural Areas ally prohibited but it is also not encouraged. If non- motorized recreation use increased to a level where itnegativelyaffected thevalueof thearea as aRNA, @0600-01 Silver Creek it could be restricted. A letter was received from the Department of the Interior suggesting that it would be helpful to include a description of the features of proposed 0600-02.1 Management RNA’s. The USDI also noted that Silver Creek Forty-sixcommentswere received from respondents RNA is a name already used by the BLM and that whowere not in favor ofdesignatingany new RNA’s. the RNA cell need may have already been met. Some felt theywere totally unnecessaryorwere just on excuse for more mini-wlldernesses. Others felt Response: the ONF had proposed too many acres as RNA’s. Appendix E of the DEIS had a description of each proposed RNA and the plant communities they Response: represent. An establishment report is scheduled to Research Natural Areas are a nation-wide, multi- be prepared for each Research Natural Area and governmental agency program designed to preserve will give additional detailed information on plant representative samples of a wide spectrum of eco- communities and features. systems They are preserved in as nearly an undis- The BLM in Bums does have an exlsting RNA turbed state as possible for scientific and educa- called Silver Creek RNA. It is on the same creek as tional purposes. They are also important for pre- the one proposed in the FEIS but further down- serving genetic pools, biological diversity, and as stream. The two areas represent different “cells” baseline areas for monitoring Forest Plans. They are (plant communities). The FEIS describes Silver Creek not tied to the Wilderness Act in anyway and their RNAinFEIS Chapter3,andForestPlanChapter4 purposes are different from those of Wilderness. The size of RNA’s can vary considerably. They can be only a few acres but the average minimum size is @0600-02 Management usually 300 acres. It all depends on how many acres of undisturbed site are avatlable and how many acres Twenty-nine comments were received from respon- it takes to encompass the target vegetation types. dents who felt that RNA’s should be open to ORVI All the proposals in the DEIS were field inventoried ATVuse and all forms ofwinter and summer recrea- and the boundaries recommended by Forest Service tion. ecologists trained in the RNA program. Response: For some areas ORV/ATV use IS incompatible, for 0600-02.2 Management example, Research Naturalheas (RNA’s) aresites on which natural features and processes are pre- One comment was received stating that over-the- served in as nearly an undisturbed state as possible snow- machines should be specifically prohibited in forscientific and educational purposes. RNA’sserve theRNA’s and thattheonlynewtrails thatshouldbe as a standard or baseline for comparison with areas built In RNA‘s should be to conduct research. influenced by man, as tracts for ecological and envi- ronmentalstudy, and as reserves to protect typical as

1-3-72 Response: DEIS Preferred Alternative. Preferred Alternative Snowmobiles are not allowed in RNA's. These two I's proposal for RNA's is the same as Alternative E- concerns are covered in the management area pre- Departure. scriptions in FEIS Appendlx D, and Chapters 4 of the Plans. 0600-03.1 Plan Comments Three comments were received from respondents 0600-02.3 Management who felt there should be more RNA's. One respon- Twocommentswerereceived fromrespondents who dent stated that additional RNA's, including The felt that RNA's should be fenced to exclude live- Island, should be added. stock. Response: Response: Theideahehind theRNAprogram is to haveone for Livestock grazing is generally not allowed in RNA's each ecosystem or unique flora, fauna, or geology unless it is part of the particular RNA's charter or system represented on the Forest and Grassland. research purpose. Therefore, RNA's will be fenced Forest Service ecologists as well as other scientists to exclude livestock where necessary. Exceptions have inventoried the Ochoco N.F. and CRNG and would be those areas like the Island on the Grass- identified the potential RNA's as outlined in the land which is inaccessible to livestock due to topog- various alternatives in theFEIS. These are the areas raphy, or as mentioned above. that meet the needs of the RNA program. If other areas are found in the future that meet the need of a cell in the program they can be added. 0600-02.4 Management A comment was received from one respondent stat- 0600-03.2 Plan Comments ingthathewas awareofanother potential RNAthat has not been designated. A comment was received from one respondent stating that the plant community description for option Response: A of Haystack Butte RNA proposal was left out in Appendix E of the DEIS. The RNA program IS dynamic. Other RNA's can be added at a later date. Forest ecologists will be made aware of this additional potential RNA and will Response: review its chances for addition to the program if it The plant communities for option A were inadver- meets the needs of an unfilled cell. tently left out. Major vegetation types for the Hay- stack Butte proposal are described in FEIS Chapter 3. @0600-03 Plan Comments Twenty-nine comments were received from respon- 0600-03.3 Plan Comments dentswhowereinfavoroftheRNA's as proposedin the Preferred Alternative of the DEE The Pacific Northwest Research Station noted that in the description for the Island, mention was made Response: of 39 acres of CRNG and 160 acres of BLM land, Thealternativesin theFEIS containarangeofacres and that this was the first place the EISPlan distin- guished between the two acreages; elsewhere, it proposed for RNA's including the proposal in the appeared that the 199 acres is all National Grass- land.

15-73 FEIS Appendix I

Response: Many comments related to the harvest level were The above statement is correct. We have attempted from those who preferred a specific alternative. to clarify this in the FEIS. In the interim, the Island Fifty respondents preferred the harvest level of has also been designated as a national landmark by Alternative B or B-plus (a modification of “B” pro- the Department of the Interior. posed by industry). Thirteen indicated a preference for the levels in Alternative C. One person Pre- ferred Alternative E. Response: Subject Area 700 Timber The analysis in the FEIS explored a range of timber halvest levels from 13.9 to 24.4 MMCF (82-144 Resource MMBF). The major factors affecting this level are: land allocations (described as Management Areas), the existing timber inventory and expected growth @0700-01 rates. In the long run growth is much more impor- Harvest Levels tant than inventory. Since the forest is a dynamic (General), Alternatives system, the scheduling model is also dynamic and B,B+,C,E considers both growth and mortality by timber types to take advantage of both existing inventory and There were 670 letters wthcomments on the timber potential growth to make the best use of forest harvest level. These comments ranged from “don’t potential. cut anything” through “maintain existing harvest The Forestcannot maintain its current harvest level levels” to “increase ASQ.” There were comments and still provide the other values (wldlife, scenic requesting higher levels of old growth, visual re- value, recreation use, etc.) that many people expect sources, recreation, and firewood on the Forest. from the forest. In fact, any timber harvest level has Many of the comments related to the available tim- both positwe and negative effects on other resources. ber base requesting either a decrease or an increase The economy was an important issue but was weighed in the amount of land available for harvest. against other values in selecting a final alternative. Sixty-four respondents indicated a preference €or These comments were carefully considered in de- the harvest level prescribed in a specific alternative veloping the new Alternative. Some changes that have taken place since the DEIS to help address The Harney County Farm Bureau recommended these concerns are: that harvest should not be increased even temporarily unless such an increase could be sustained. 1. The application of uneven-aged management on about 100-120 thousand acres of the ONE The Crook County Courthouse desires that the This will make areas more acceptable visually ONF maintain or increase the amount of land managed for timber. for recreationists and still provide a moderate level of timber production. Some commented that timber harvest levels above Increased emphasis on a quality product (larger the established sustained yield are in conflict with 2. pine). This reduces the frequency of regenera- NFMA regulations. tion cutting and leaves more big trees in the The Columbia River Inter-Tribal Fish Commission forest. noted that the timber base has declined 14 percent Addition of the Summit Trail Corridor and from 1973 to 1982 and asks how harvest levels can be 3. maintained. other management areas, which will be managed to maintain unique qualities.

1-3-74 4. Parts of Lookout Mountain and the Rock Creek/ Response: Cottonwood Roadless area will be managed A new alternative, Alternative I (see FEIS Chapter for recreation and wildlife. This may involve 2), has been developed. The proposed harvest has some timber harvesting to maintain forest health. been changed from the Departure in the DEIS to a Other changes are described in the summary and sustained yield even-flow harvestschedule. Reasons elsewhere in the FEIS. These changes should help for changing were based on response to the DEE, maintain a sustained timber supply, reduce some of which favored the long term good of the forest and the negative impacts, and provide an equitable bal- local community stability. With increased intensity ance of uses. of management or by decreasing the level of departure, there is some opportunity to make a departure SeeChapters4ofthePlans formoreinformationon more acceptable. However, a sustained yield even- Old Growth, Firewood, Recreation, etc. Also see flow timber harvest schedule was selected based on response to board foot/cubic foot issue in the Rec- public input and a further review of the conse- ord of Decision and FEIS Chapter 4. quences. The ONF has explored ways of maintain- The harvest level at Snow Mountain stays much ing the harvest closer to the present level and will more constant with uneven-aged management than useagradual transitionwithin the firstdecadeofthe it did with the alternatives displayed in the DEIS. plan to reduce ASQ to the planned level of 19.3 TheONFisalsoworkingwith theMalheurNational MMCF (115 MMBF). See FEIS Chapters 2 and 4 Forest todevelop acombinedschedulefor theBurns for further discussion. Themajor negativeimpact of Area that will avoid abrupt changes in harvest levels this decision will be to reduce the dollar returns to in this area. the U.S. treasury in the first few decades. Alternative I calls for even-flow for the ONF on a decade by decade basis. There will be fluctuations in 0700-01.1 Departure timber sale from year to year based on budget and Four letters were received with comments favoring economic conditions. Harvest by district will be departureharvest. Thecommon feelingwas that the determined administrativelyconsidering biological, lowest level of timber harvest could be increased administrative, and social impacts. Sustained yield with more intensive management. by species is not intended nor is it practical. Harvest levels will consider local economies as discussed There were 304 letters containing comments op- under the reply to the ponderosa pine issue in this posed to a departure alternative, favoring sustained append=, but timber condition and Forest Health yield instead. Some felt that departure is short- (Chapter 4 of Forest Plan) will be the primary con- sighted and that future drastic reductions in the siderabon in determining the species mix. harvestwould disrupt the economy. Othersbelieved that departure harvest would result in an irretrievable loss of resources and cause severe ecological @0700-02 Species Mix damage due to erosion. Still others noted that departure violates NFMA regulations. 0700-02.1 Ponderosa Pine The Office of the State Economist pointed out that Management the short-term gain will not outweigh long-term costs of departure. Many respondents were concerned about the volume of ponderosa pine sold in the timber sale program. There were also concerns for management of other species.

1-3-75 FEIS Appendix I

The inherent value of ponderosa pine was one such to manage future stands with a larger component of concern. Enhanced harvest and regeneration of pine pine than occurs on most exlsting stands, with the were desired by many respondents. There was also intent of creating a species mix closer to what was concern regarding substitution for ponderosa pine here before fire protection (prior to 1930). This is by inferior species. In addition, some respondents particularly truein themixed conifer types. There is brought up theneed for studies as to replacement of no plan to remove pine overstory when the only pine stands after harvest by juniper and sagebrush understory is Douglas-fir or white fir. See Standard The Oregon State Forester comments that a steady and Guidelines in Chapter 4 of Plan - Timber for supply of ponderosa is critical to the economy of specific direction. Reforestation efforts have been very successful and encroachment of juniper and central Oregon and is opposed to any proposition of large changes in the species mix, especially a reduc- sage brush has not been a problem. See FEIS Chap- tion in ponderosa pine. ter2forproposed harvestlevelinponderosapineby decade. A related concern is the display of outputs in terms For the Plan, the volume growth of trees and annual of cubic feet instead of board feet. The discrepancy between the Resource Protection Act document, harvest level has been calculated in cubic feet. This which displays timber outputs in board feet, and the is a measure of sound wood volume in a tree. DEIS, which uses cubic feet, is questioned. Much confusion is created when attempting to convee cubic feet to board feet, or when estimating long Response: termgrowth in termsofboardfeet. Boardfeet, when The Ochoco considered a range of ponderosa pine referring to standing trees, is not a measurement but harvest levels in the first decade from 65 MMBF in an estimate of an end product. There are several Alternative C to 95 MMBF in Alternative B-Modi- rules for doing this and different rules can result in fied. The harvest level of ponderosa pine is a critical considerably different estimates. In addition there item to the local economy and also is currently the can be large differences in estimated volume of a major contributor to forest receipts from timber tree based on the length of logs it is bucked into. sales. Short term (next 5 decades) harvest level of There is also considerable difference in the ratio of pine depends on land allocation, harvest schedule, sound wood to estimated board foot volume for and existingvolume. The existing volume of pine is different size trees. For these and other reasons based on the 1982 inventory adjusted for harvesting most research is done in cubic feet as are all yield to the end of FY88.Sampling errorwas less than five tables for forest plans. For these reasons, cubic feet percent for the inventory. See FEIS Chapter 3 Cor has been used to control or project timber harvest volume by species group. Chapter 4 of the DraCt levels. Harvest can drop on a board foot basis while Planshows areductionof 14percent in totalvolume remaining stable on a cubic foot basis. An estimate and 18 percent in pine volume between 1973 and of board foot volume is shown for the first decade 1982. The long term level (beyond five decades) only. depends mostly on management strategy. The exist- The inventory reduction of 14 percent (shown in ing volume does not allow a continued sale of his- FEIS Appendur E) is what was expected from the torical levels (FEIS Chapters 2 and 4) of ponderosa previous plan. The standing inventory in expected to pine. The addition of uneven-aged management decrease for the next five to ten decades as overma- helps toevenout thesaleofponderosa pineovcrthe ture stands are replaced by younger stands. This will next five decades but at a level below that of the be accompanied by an increase in growth until an previous decade. To maintain future harvest levcls equilibrium is reached. See"Timber"in FEIS Chap- of ponderosa pine requires the harvest of stands ter 4 for more discussion of this. with other species now so that they can be regener- atcd with new stands of pine. The Forest strategy is

1-3-76 0700-02.2 Genetic Diversity that grazing and timber should be dealt with separately (e.g. timber should be favored overgrazing, or Six respondents expressed the need to maintain old slash if harvest prohibits cattle use). growth as a reservoir for genetic diversity. There were also several comments urging the seeding of domestic grasses after harvest to control ero- Response: sion and provide grazing. Diversity is a major concern of the forest. There were several new management areas added since Response: the draft to recognize more uniquesituations on the forest. The direction for management on the gen- There is a generally favorable relationship between timber harvesting and grazing as any removal of c eral forest has been changed to favor more uneven- aged management and longer rotations. Even-aged trees tends to increase forage production. Generally harvest units will be limited in size and distribution, it was conflicts with other values such as water quality, old growth, and recreation experience that resulting in greater diversity in stand age and structure than proposed in the DEE. There are also limited timber harvesting or grazing. The forest attempted to create a proper balance among uses as about 60,000 acres in riparian and recreation areas described in Chapter 4 of the Forest Plan. Emphasis that will have stands with extended rotation (150 to 300 years), and about 85,000 acres with no timber bas been given to water quality (enhance prescription used for all riparian areas) and unique scenic harvesting in designated old growth, RNA's, wilder- values, such as Stein's Pillar, in Alternative I. Areas ness, and roadless areas. See Chapter 4oftheForest Plan for exact acres and description of each area. available for timber production and grazing will be managed as intensively as is economically feasible. These areas serve as genetic reservoirs. Areas of conflict between hmber and grazing are in The Forest has about 2,800 trees in the tree im- slash disposal, grass seeding, and protection. See the provement program. Each major tree species is Timber section of FEIS Chapter 4 for more discus- represented in this program. Progeny from these sion Slash disposal guidelines were developed to trees have been planted in seed orchards and evalu- provide protection fromwildfires, and providedown ation plantations. This is intended to improve the woody material to insure future productivity. See genetic base as well as preserve a wide genetic base Chapter 4, Forest Plan, Standards and Guidelines for futureplantations. Thereis asignificant number for Woody Biomass for details. This should allow of natural trees in regenerated areas to further cattle access to most harvest areas but there will be expand thegenetic base. Thegeneticbase on future some slash and large down material left on the site timber stands will be at least as diverse as existing Grass seeding will generally not be done except for stands and in many areas more diverse. erosion control as it competes with tree seedlings and prevents the return of native species. Tree seedlings will be protected from livestock where @0700-03 Timber/Livestock necessaly hy temporary exclusion or individual tree Issues barriers Twenty-four letters were received with comments concerning the relationship between timber and @0700-04 grazing. Data Analysis Some felt that both timber and grazing should be Seven letters, lncluding the respomes from the Oregon deemphasized in the interests ofwildlife, recreation State Forester, the Oregon Director of Economic and scenic values. Others were of the opinion that Development, and the Columbia River Inter-Tribal proper grazing and timber practices were compat- Fish Commission, had comments dealing with yield ibleandacceptable usesofthe forest. Stillothersfelt tables as used in the DEIS.

1-3-77 FElS Appendix I

There were some questions as to the reliability of mortality from insects and disease, and growth ef- current inventories and harvest levels compared to fects of compaction are included in the tables, but levels on previous tables. the final impact of each cannot be separated. Some respondents felt that the plans for genetic These yleld tables show less net growth than does gains are not practical on low sites on the Ochoco researchor the previous yield tables.That is because National Forest. these are Forest specific yield tables that show the Growth rates of mature pine vs. second growth were best estimate of what can actually be produced on also questioned. The CRITFC felt that the drop in given sites with technologies available. This makes allowance for islands of nonproductive land within potential yields is due mostly to a change in the timber stands, trees left for snags, and local site managed yield tables. They also stated that the South- productivity. Research that was done on Pringle Central Oregonh’orthern California variant prog- Falls and in the Cascades was done on higher or nosis model may have been more appropriate to better sites and uniform stands where there were no reassess the accuracy of the Ochoco managed yield inclusions of low or nonforest sites. Consequently tables for stands similar to those on the Deschutes. research yields are higher than what would be ex- The Oregon Director of Economic Development pected on the average site on the Ochoco N.F. A does not support reducing the acreage available for common set of yield tables developed for the Blue full yield management. Mtn. Forests was used for the 1980 Plan. The ONF ison thedrierendofthisgroup sositesandexpected Response: yields are lower than the average for the four For- Yield tables were developed as described in Appen- ests Informal comparison between existing stands duc B, with more detail available in “Existing and and projected growth was compared and results Managed Yield Tables for the Ochoco N.F.,” an were similar. A separate inventory of managed stands unpublished document available at the Ochoco isplannedwth the next inventorywhich should give National Forest Supervisor’s Office in Planning a better basis to compare and adjust ylelds. A sensi- Records. The 1982 inventory was done to an accu- tivity analysis has beencompleted since thedraftwas racy standard of more than ninty-five percent. Vol- prepared. In that analysis, all managed yields were umes for each model component were projected increasedby20percent, and thisresultedinless than forward to 1994 (midpointof first decade) and acres a two percent increase in ASQ. This shows that by model component have been adjusted for timber existing volume and S&G, such as watershed con- sold since the inventory. This inventory was within straints, are the primary controlling factors and a one percent of the projected inventory, based on major change in managed yield tables have little 1972 inventory, with adjustments for growth and effect on ASQ. Growth on immature stands (Forest cutting. The ONF has a very high degree of confi- Plan Appendix G) is less than mature stands at dence in the inventory volume and the emsting yield present because most of the immature trees are not tables which were developed from inventory infor- yet merchantable but projected growth of immature mation. The inventory data was also used to cali- stands is several times that of the mature stand. See brate the growth model used for developing man- Table 4-3 (Annual Growth by Age and Timber agedyields. The Blue Mountain variant was used to Type) for more details. develop the basic yield tables as SORNEC was not Genetics gain is incorporated into the managed available at that time. Uneven-aged yield tables yield tables that call for planting (note: planting is weredevelopedlater andSORNECwasused. Some not planned on low site pine types). The genetics standard tables were compared between the two program is already in place and forest has been using variants and there was little net difference so basic plantingsfromselected trees forseveral yearsso this tables were not redone. Since growth rates for yield is not a new level of investment to be made. The tables are based on existing stands, the effects of Tree Improvement Plan is available at the Supervi- sor’s office for more information.

1-3-78 0700-04.1 Data and Table @0700-05 Reforestation Errors Thirty-seven letters contained comments on refor- Seven respondents pointed out inaccuracies, inade- estation, among them the responses from CRITFC, ODFW, the Oregon State Forester, and Crook quacies, or discrepancies in the documents. Among the respondents were the Environmental Protec- County. tion Agency, the Oregon Department of Fish and Most comments, including those of Crook County, Wildlife, and the Oregon State Forester. favored placing a growingemphasis on reforestation The following errors were commented on: in the future. Some respondents recommended planting species most adaptable to a particular area Table 2-8of the DEIS shows incorrect value for and increased research on super trees. current ASQ. Others suggested mechanical site preparation to Graphs on pages 35 and 39 do not agree. favornaturals. Apreference was indicated for auger Table 2-8 should show volume for each decade. planting over slit planting, and for protecting snags from fire during site preparation. There were also Table 3-25 on Page 89 of DEIS is in error. concerns that burned areas are not being reforested Table3-25ofDEISdoes not agreewithTable4- While many respondents have been impressed by 1 of Proposed Plan. reforestationefforts, some felt that recent favorable Sale program data incorrect in appendix A of growing conditions have made silviculturists overly Proposed Plan. optimistic. Others were opposed to intensive practices such as fertilization or spraying. Concems about Table S-2 and harvest level of 89 MMBF for E- nutrient cycles and gene pool reserve were not Departure in year 2030 is in error. adequately addressed for some respondents. Response: To some, planting and maintaining tree plantations did not seem economically justified. Tables have been corrected in the final documents. The graph on Page 35 was changed so MMBF is no The Oregon State Forester noted that the stocking longer shown. The long-term Sustained Yield Ca- standard of 50 to 75 trees is lower than State of pacitywas not calculated in board feet, nor can it be Oregon standards. calculated with the current data in the model The ODFW recommends that standards for reforesta- Crooked River Grassland acres are no longer in- tion in big game management areas should be driven cluded in these tables which should also improve by cover needs rather than harvest needs. readability. Table 2-8 did not show volume by decade as it would have complicated the table. This in- CRITFC stated that the certification process ap- formation by selected decades is available on Table pears to take sivyears instead of the mandatory five S-8 of the FEIS Summary. A new sale schedule is (site preparation within two years of harvest; plant- shown in Appendiv A of the Forest Plan. Contact ing within one year after site preparation; certifica- the Supervisor’s or District office for more details tion three years after planting). The council also on specific timber sales. questioned the status of a stand if it cannot be certified as revegetated. Table S-2 (now Table S-8) has been revised to display the new alternatives and Alternative I shows a much higher harvest level in the fifth decade than Response: did alternative E-Departure. This change is due Most of these concerns are covered in the Forest mostly to maintaining an even-flow and the empha- Wide Standards and Guidelines in Chapter 4 of the sis on producing larger trees in Alternative I. Plan for Timber, Diversity, and Forest Residue. Site

1-3-79 FEIS Appendix I

specific decisions on planting method, spacing, plant- of this Plan or Forest Regulations that all sales ing tools, etc. ,are made to comply with the Stan- produce a net return to the government. Examples dards and Guidelines and objectives for each Man- where sales may be deficit, or below cost, are: beetle agement Area. These are project level decisions. lolled lodgepole, where remamg merchantable trees Some projects such as fertilization, spraying, prun- are removed and slash is disposed of, and the area is ing, etc.wil1 require additional environmental analy- reforested; or sales in campgrounds to remove haz- sis and documentation. Theminimumstocking stan- ard trees. In each case the sale may be deficit but it dard was designed to meet the requirements of is the least-cost way of meeting the management NFMA Sec. 4. This is not the recommended level objectives for an area. Economics were considered that is normally obtained. It should also be noted in developing harvest schedule and selecting inten- that this standard is for trees 4.5 feet tall, not two- sity of management. It was also considered in deter- year-old seedlings as is the case with State of Ore- mining boundaries of management areas such as gon's requirements. Planting may be done if stock- Rock CreeMCottonwood Unroaded and Helicop- ing exceeds the minimum level and if the expense is ter. justified to meet the management objective for a particular Management Area. The planting program on the ONF has been very successful with an @0700-07 Land Suitability/ average survival after three years of about seventy percent. The areas requiring replanting have been Allocations less than five percent. Survival is generally better in Nineteen comments dealt with management and clearcuts than in areas with residual overstory. identification of land unsuitable for timber production. Most had questions concerning methods and guidelines used to classify land as unsuitable. A map @0700-06 Below Cost Sales and analysis of unsuitable lands was not included in the DEIS, and some desired one. Three letters, including one from the Columbia River Inter-Tribal Fish Commission, had comments There were also questions regarding present man- regarding deficit or below cost timber sales. All the agement of unsuitable land. Some, including the respondents were opposed to deficit sales. It was Columbia River Inter-Tribal Ksh Commission, urged that every timber sale make a profit, or at the questioned the amount of land classified as unsuit- very least recover costs. able -- only 0.47 percent of the forest. CRITFC voiced concerns that the Forest Service One reviewer suggested that timber land which will respond to the below-cost sale controversy by becomes unsuitable be traded for lands reserved for shortchanging mitigation needs to artificially im- recreation. prove its timber sale balance sheet. The council also noted that high-value ponderosa pine old growth Response: has kept most timber sales out of the deficit cate- The NFMA provides direction for identifying lands gory, but questions sales in the next decade or two if to be classed as unsuitable for timber production. the old growth is removed. The reasons for being classed unsuitable are described in Chapter3 of the =IS. No timber harvest- Response: ing is planned on unsuitable land. Unsuitable land The current timber sale program has a positive was identified on areas as small as two and one half return, and is expected to in the future. See Table 3- acres If they could be identified on aerial photos. 30 of the FEIS. Also, the Timber Sale Program These were ground sampled and other areas identi- Information System (TSPIRS) reports are available fied based on field experience and soil inventory. at the Forest Supervisor's office It is not the intent

1-3-80 About 11,130 acres have been identified as unsuit- mademoreclear in thenewPlanwhichdisplaysboth able because of regeneration difficulty. Much of the gross acres in a management area and the net acres most arid land has been classified as non-forest. of forest land. Thereforestation first-timesuccesshasbeen greater The acres in full productivity are based on land than 90 percent, and the lower sites have not been allocations and the management intensity from the the most difficult to reforest. There are several selected FORPLAN run. All lands allocated to examples of successful plantations on burns on low General Forest are available for full productivity, sites. So there IS very high probability that lands but there are a variety of yield tables and related identified as suitable can be reforested within five cultural practices available. A maximum economic years. return function (See Appendix B for more explanation) was used for Alternative I and also the Plan. The economics of timber harvesting and the ability This selects the combination of treatments that is to reforest is discussed under timber suitability in most cost effective such as some natural regenera- Chapter 4 of the FEE. The Ochoco has one of the tion and not thinning every available acre. This most economically efficient timber programs in the results in about one MMCF (4 to 5 MMBF) less nation, based on recent Timber Sale Reporting System reports. Thus, while the cost of timbermanagement ASQ than would a maximum timber function. and harvesting was not a limitation on timber harvest throughout most of the forest, it was a major consideration in developing management direction 0700-07.2 Lowsite Pine Lands for the unroaded areas. Two letters were received with comments concerning management of low site pine lands. The Colum- bia River Inter-Tribal Fish Commission questioned 0700-07.1 Allocations the Ochoco plan to harvest on sites producing 20 cubic feet or less, pointing out that other forests Four letters, including those from ODFW, the Ore- prohibit this practice. gon State Economist, and tbeDirector of Economic Development, had comments concerning acres Others requested a map of unsuitable areas and a available for timber harvest and in full productivity. summary by district of plant community types for pine stands. The Oregon Department of Fish and Wildlife pointed out that the proposed plan allocated 547,072 acres to General Forest, which is 52,000 more than the Response: suitable timber base. There are about 21,000 acres typed as low site pine and about 12,000 of these are classified as suitable. Otherreviewers, includingthe OregonState Econo- (Note: NFMA does not include productivity as a mist and the Director for Economic Development, criteria for suitability.) These are generally nearly question the implicationsof the reduction in land in flat ground with good access and high value pine full productivity from 423,000 to 262,500 acres. species. The management as shown in the Standards and Guidelines will insure continued productivity Response: and a positive economic return. Mature trees will There is some confusion concerning acres of gen- only be removed where there is existing regenera- eral forest. When this refers to land allocation as in tion. Type mapping was done at a four-inch-to-the- Table 2-2 in DEB, it refers to gross acres which mile scale and producing maps at this scale is not include nonforest land such as meadows, water, etc. practical. Maps are available at forest offices. See within the general allocation Other places, such as FEIS Chapter 3 for acres of low site land by district. DEETable S-2, “Lands with Timber Yield Reduc- The ONF does not have a summary of land class by tion,” refer to suitable timber acres only. This is community type. Also see response to suitability.

1-3-81 FElS Appendix I

@0700-08 Harvest Methods Many respondents, including Grant County, felt that thinning was not sufficiently emphasized. They Fourteen letters had comments conceming logging believe that thinning will increase the growth rate systems. Most respondents were concerned about and that thinning along roads will decrease vehicle/ environmental impacts and suggested helicopter big game accidents. logging, balloon logging, or the use of large rubber- tired skidders to reduce compaction. Some recom- Othersbelieve that thinningdefeats its OWTI purpose and that unthinned islands should be left to provide mended that no logging occur in riparian zones or near trails. cover. Some felt that a percentage of each sale should be left in an unaltered state. Others felt that the timber companies should do a better job of cleanup after harvest operations. Some felt that intensive management and new technologies should be utilized to raise the harvest level to the maximum, while others believe the Ochoco is Response: a fragile desert unsuited to tree farming. Providing areas for specific logging systems was not identified as a specific concern. However, the log- ODFW suggests that, under Standards and Guide- ging system does play an important part in many of lines, a screen of understory vegetation should be the other issues such as riparian areas, recreation, left along the edge of natural openings and along and protection of the soil and water resource. Gen- roads. erally, the selection of the logging system is a proj- CRITFCasks howmuchprojectedyield dependson ect-level decision based on the Standards and Guide- precommercial thinning. lines for the specific Management Area. The Plan has been revised since the Draft Plan to include Response: Management Areas that emphasize logging systems Chapter of the Forest Plan describes management that require little or no roadingsuch as helicopter 4 or activitiesappropriate to each management area. All shhelogging. See Chapter of the Plan for spe- 4 cost-effective silviculture treatments are planned cific direction for each management area. that are compatible with a specific area’s manage- Timber purchasers arerequired to remove all equipment objectives There is a section in Chapter 4 - ment and debris from any site of operations. Dis- Forest Health that describes appropriate action to posal of woody debris from logging is disposed of be taken in each Management Area to protect it based on contract requirements. These requirements from insect and disease. This recognizes that high vary from site to site depending upon such factors as levels of damage are acceptable in some areas such fire hazard, disposal costs, and the need for down as old growth. The selection of specific treatments woody material for soil productivity or wildlife needs. will be based on project level analyses along with direction from the Plan and may also include an See responses to biological diversity and forest residues comments for more information. Environmental Analysis. See Chapter 4 of the For- est Plan for planned treatment by decade.

@0700-09 Thinning Practices @0700-10 Even- and Uneven- Therewere 18letterswith commentsonsilvicultural Aged Management practices, among them letters from the Oregon Department of Fish and Wildlife, the Columbia Five-hundred thirty-four letters were received with River Inter-Tribal Fish Commission, and Grant comments regarding harvest methods, particularly County. the impacts of clearcutting on harvest levels and other resources.

1-3-82 Some respondents, including Crook County, were and other types of even-aged management are ac- opposed to clearcutting and felt that selective log- ceptable cutting methods under NFMA. See Ap- ging would result in a healthier forest ecosystem. pendix E for discussionof selection of harvest meth- Soil integrity and wildlife habitat were mentioned as ods. For impactsofharvestingonaspecificresource, possibly being harmed by even-aged management. see Chapter 4 of FEE. Others were opposed to clearcutting for aesthetic A further review was done of management in exist- reasons, orbecause they felt recreation suffers from ing roadless areas, and some areas will have timber clearcutting practices. harvestingwith little or no roading and uneven-aged Some respondents favored clearcutting for diseased management will be emphasized where appropriate. See specific direction in Chapter 4 of the Plan. or defective trees, or for a certain species of tree Harvest unit size and shape will meet direction in such as white fir, but not ponderosa pine. Chapter 4. Still others favored clearcutting everywhere, ex- There is very little intermingling of National Forest pressing a desire to see the forest shift toward even- land with other federal agencies so harvesting policy aged management. on the ONFshould not have major impacts on other The Oregon StateForester stated that frequency of agencies. entry is greater with selective logging and that this may contribute to more soil damage than clearcutting, depending on soil characteristics. @0700-11 Salvage Program Response: Forty-five letters were received with comments re- The Forest has reviewed the policy on even-aged lated to the timber salvage program. Among the management including clearcutting, and has pro- respondents commenting on this subject were the vided standards and guidelines to encourage un- Oregon State Forester, Crook County Courthouse, even-aged management where appropriate (see FJ3S Prineville City Council, CRITFC, and ODFW. Chapter4, Environmental Impacts, FEIS Appendix CRITFC stated that sabage should be counted toward D, Standards and Guidelines, and FEIS Appendur satisfying long-term sustained yield (LTSY) vol- E, Selection of Harvest Cutting Methods). New ume. yield tables were also developed that include more Crook County Courthouse recommended develop- intensive uneven-aged management than was used ment of a creditable system for salvage of bug-killed in the draft. The planned acres of clearcutting per or blown-down trees. decade have been reduced from 14,400 in E-dep alternativeto8,700inAlternativeI,and noclearcut- Prineville City Council suggested management of ting is planned in pine types unless noother alterna- the salvage program for maximum timber productive exists due to the presence of mistletoe or dis- tion. ease. The OregonStateForesterurgedaggressiveharvest There are many situations where clearcutting or of scattered ponderosa pine. some form of even-aged management is the only ODFW noted that impacts of salvage are extensive reasonableway to continue to grow timber. Some of on snag levels and large woody debris. these are areas with root rots, dwarf mistletoe, excessive fuel buildups and areas with white fir as the Other reviewers requested more firewood be made major species The on-site decision of cutting method available through the salvage program. Some rec- willbe made by qualifieddistrict personnel basedon ommendedsmall sales as a moreefficient methodof the Standards and Guidelines in Chapter 4 of the salvage. Still others felt that salvage should be lim- Plan (see Timber and Forest Health). Clearcutting ited to catastrophic events.

1-3-83 FEIS Appendix I

Response: acres are gross acres (timber and non-timber). The Salvage is part of the timber resource issue. The planned distribution of timber land is displayed in salvage program can conflictwith snag needs (Chap- Chapter 4 of the Proposed Forest Plan which shows ter 4 FEIS). All material not required for snags is a total of 495,006 acres available for some timber generally available for harvest. See Forest Stan- harvesting and 314,738 acres in general forest. See dards and Guidelines under the Timber and the Chapter 4 of the Plan, for acres planned for timber Wildlife sections for specific direction. The size of harvesting in the proposed action. sale and whether it should be used for firewood or sawlogs is an administrative decision to be made on a site-specificbasis.See appropriate District Ranger 0700-12.2 Timber and Wildlife for specific concerns. There were nine letters with comments concerning possible conflicts between timber management and @0700-12 Multiple Use wildlife. Opinions on this subject were unusually polarized. Management Some respondents felt that logging destroys wildlife habitat, that all old-growth hawest should be stopped, and snags should be maintained at the 100 percent 0700-12.1 Timber and level Recreation Others expressed a desire for less big-game allocation. They felt that harvest enhances the availability Six individuals expressed concerns about conflicts of forage for deer and elk, and that roadless areas between timber harvest levels or practices and rec- should all be open to harvest. These respondents reation. Most respondents felt that recreation and felt that protected old growth stands should not harvest are compatible, but that harvest should be exceed three percent of the total, or that a certain considered more important than recreation. Some amount of old growth needs to be harvested to felt that scenic qualities can be enhanced by proper sustain harvest levels. harvest procedures. There was apparently some confusion over acres Response: available for timber harvest. Some commented that The land allocations in the Forest Plan were devel- 780,000 acres was not acceptable. oped according to NFMA standards and multiple use and sustained yield principles. The location and Response: total acres in big game emphasis has also been changed Alternative I was designed to balance uses between as a result of comments and coordination with the timber harvest level and recreation use as directed in State Fish and Game Department. A mix of timber theMultipleUse Act andNFMA.Achange tomore and wildlife emphases have been provlded to mm- selective cutting and large diameter stands at final mize net public benefit for both timber harvest and harvest are two changes that were made in response wildlife. Specific management goals, objectives,stan- to public comment to help resolve this issue. dards and guidelines can be found in Chapter 4 of There were not 780,000 acres planned for timber the Forest Plan. harvesting in the draft plan. The general forest The NFMA (Sec. 6, g) requires the forest to “pro- terminology may have been confusing as the man- vide for diversity of plant and animal communi- agement area “General Forest” included both tim- ties...” The preservation of old growth is intended to ber and non-timber lands on both the ONF and the help meet this requirement. Areas have been desig- Crooked River Grasslands. In most instances the nated as old growth to meet the needs of old growth

1-3-84 dependent species. Attempts have been made to Area provides for an average merchantable stand limit theimpact on hmber harvestlevelsbydesignat- size of 18” DBH before final harvest for ponderosa ing old growth which occurs in areas which would pine stands rather than the minimum rotation age have high levels resource protection in any case from culmination of mean annual increment which insteadofdesignatingareas that couldhein General could occur on trees as small as 12” DBH. The Forest. The Old Growth designated acreage in each exceptions to this are when earlier harvesting is alternative is shown in FEIS Table 2-8. needed to meet some resource need other than Areas planned for old growth have also been re- timber, or where stands are threatened by insect or disease damage. viewed and are described in Chapter 4 of the Plan and areas are shown on map. The relationship be- Stands with trees smaller than 18 inches DBH may tween the timber program and wildlife is very com- he harvested during commercial thinnings. On the plex. See Chapter 4 of the FEIS for effects of timber Ochom National Forest, stands which are not thinned program on wildlife. are vulnerable to insect attack because individual trees in a fully stocked stand growvery slowly. Thin- ning redistributes the growth potential of the site so @0700-13 Timber Production the remaining trees grow faster and are generally healthier. With uneven-aged management, both regeneration 0700-1 3.1 Rotation Length cuttingandthinning takeplaceon astandduringthe same harvest operation. There were nme comments concerning rotation length and the methods used to decide when to harvest a tree or stand. 0700-13.1 Growth Some feel the forest is a crop, to be harvested when ready. For some this meant “mature or diseased.” Eight letters were received with comments on growth For others, a more tangible figure, such as 12 inches rates. Most felt that harvest shouldnot exceed growth in diameter, was the indicator to cut. hut should remain at a level slightly less than the growth rate. Response: There is not a common agreement as to when a tree Response: or stand is “mature.” A definition of maturity in The current growth on all timber lands is 14.6 MMCF “Terminology of Forest Science, Technology, Prac- or 79.7 MMBF from Appendiv E of the Proposed tice, & Products” is: “The stage at which a tree or Plan. This will change in the future depending on stand best fulfills the purpose for which it was main- alternative as shown on Table 2-8 of the FEIS. tained.” NFMA limits final harvest to stands that Growth in cubic feet is displayed here by alternative have culminated in average annual growth This for year 2030 and the Long Term Sustained Yield usually occurs on the Ochoco National Forest after Capacity. Similar values are shown for Alternative I. a stand age of 70 years. It was recognized that there The FORPLAN model is used as a tool to help is a local demand for larger material, and further schedule harvest so that the maximum level of har- analysis was done to compare economics, timber vest can be maintained within limits set by the stan- yields and effects on other resources if longer rota- dards and guidelines. As a general rule, the younger tions were used (see appendix B, sections 2 and 7). the trees in a stand, the faster the growth, so as In Alternative I, the General Forest Management volume accumulates on a stand the rate of growth decreases. A mature stand therefore will have high

1-3-85 FEIS Appendix I

volumebut little growth, and averyyoungstandwill @0700-14 Specifics a have high rate of growth but little volume. Part of the scheduling problem in managing the forest is to bring these into a proper balance. On the Ochoco N.F. growth rateswill increase through time as mature 0700-1 4.1 Catastrophic trees are replaced with younger trees. See Chapter Conditions 4,of the FEIS. During this time the inventory will decrease. CRITFC asked what constitutes a catastrophic condition and how the ONF will compensate if a high level of catastrophic damage occurs each dec- 0700-1 3.2 Fiber vs. Sawlogs ade. Ten letters were received with comments concern- Response: ing fiber or quality sawlogs. A catastrophic condition is when the mortality or Some reviewers felt that rotation length is too short. damage in a decade exceeds the level planned. It is They believe that increasing rotation length will possible, but not likely, that the salvage level would enhance the quality of timber products. be near but not over ten percent for several decades. Whenever a catastrophic event occurs that has the Others request that the Ochoco National Forest be potentialofeffecting future harvestlevels,then new managed for mature ponderosa pine only. FORPLAN runs would be made and a new harvest Still others want the value evaluated by species schedule developed. It is also planned to reinven- rather than by total wood fiber. tory at ten-year intervals and recalculate the harvest schedule based on current information. This would Response: ensure corrections for changes in tree mortality or damage. The analysis process that was used to determine harvest levels and product size considered size and species (ponderosa pine and others). Alternative I had an objective of maximizing PNV while meeting 0700-1 4.2 ldlewood Burn management objectives. Longer rotations were Therewasonecommentabout thegrowthrateof an considered and are required in many management area reforested on the Malheur National Forest in areas, but to require 200 year or longer rotation ages the late 1940's or early 1950's. The area was the would result in a 40 to 50 percent reduction in Idlewood burn, and the respondent stated that the harvest level. As a result of responses to the draft, trees are now only eight or nine inches in diameter. the objective on General Forest has been revised to include an emphasis on the production of quality Response: pine on General Forest. See Standards and Guide- lines for General Forest in Chapter 4 of the Plan. Your observation of eight to nine inch trees in 50 years is similar to the managed yeld table which This results in longer rotations and larger trees at predicts nine to 10 inch trees in 50 years, and 18 inch final harvest. Pine and other seral species will be emphasized on most of the Management Areas trees in 120 years. where timber harvesting is permitted. Mured conifer along with all other sites will be managed as intensively as is economically practical. 0700-1 4.3 Sold Sales One respondent mentioned commitments to timber sales made prior to the DEIS that are incompatible with the Land Management Plan. The person asked

13-86 for direction in the EIS addressing mitigation of harvest potential from the Forest based on the cur- prior commitments. rent Forest Plan, but decisions made in this plan do not constrain or restrict Congress’ ability to set Response: budget or outputs Congress may vary harvest levels The Plan does not change history. Each situation fromyear to year but historically this has been based will be reviewed based on direction for each Man- on the planned harvest level. Congress is influenced agement Area (M.A.).Iftheexistingconditionisnot by many factors in making its decision, as is the ONF compatible with goals for a M.A , than corrective in developing its proposed action. Congress also action may be taken depending on feasibility and establishes the laws governing sale of timber and funding. other products so, this is not an issue to be decided by this FEIS. The Forest attempts to hire well qualified people @0700-15Timber Economics and see that they have proper training and supervi- sion to do their jobs, but the regulations governing these decisions are outside the scope of this Plan. 0700-15.1 Budget All timber is appraised using standard appraisal Fourteen letterswerereceivedwhichhad comments procedures (see Forest SeMce Manual 2430, avail- concerning the budgeting and financing of forest ableatForest Offices). Noarbitrary adjustments are operations. made. However, the appraisal process does consider logging and other costs, so areas with high costs Some respondents stated that the ONF budget is (such as cable logging or very small volumes) will too commodity-oriented, and that the allowable cut have lower stumpage than a typical sale. was set by Congress based on economic and political pressures. Others were opposed to public-subsidized harvest 0700-1 5.2 Demand and Supply operations and felt that the timber industry should Twelve letters were received with comments dealing bear the full cost of logging, or that the ONFshould with demand and supply of timber. The letter from charge more for timber sales. the Oregon State Forester questioned the state- The Columbia River Inter-Tribal Fish Commission ments in the draft that claim local supply affects asked if the forest reduced prices as an incentive for stumpage price. He also feels that more analysis of harvesting old growth. assumptions used in demand curves (Appendix B) is needed. Some respondents expressed the feeling that the forest should favor local remanufactures when allo- The Oregon StateEconomic Development Depart- cating timber sales, or that cutting circles should be ment disagreeswith the prediction that demand will established. drop after the first decade. Other concerns included the desire for set-price Other respondents expressed the need for a model salvage sales without bidding, more coordination to forecast stumpage values and for better analysis between the Forest Service and BLM, and the need of timber volume available from state, private, and for more qualified personnel to mark and lay out other forest sources. timber sales. Still others pointed out that no reference was made to volume under contract. Response: The Forest, through the Regional and Washington The equation between local installed mill capacity Offices, provides information to Congress as to the and demand was labelled inaccurate by some.

1-387 FEIS Appendix I

Finally, some respondents believed the last-five- an 18 inch DBH tree than with a six inch DIB. The year average cut is the best measure of demand. Ochoco believes having larger quantities of small material available will be a reasonable utilization Response: standard. The harvest level as shown in Table 111-29 of DEIS is For more information concerning utilization stan- not a good indicator of local demand as this was dards, refer to the Pacific Northwest Region Plan, during the worst recession in the timber industry in available at the Ochoco National Forest Supervi- recent history. The current harvest level (1986-88) is sor’s Office. much higher than the 19751984level and is probably a closer reflection of demand. The harvest level from “The Forest Program For Oregon,” shown in FEIS Chapter 4, is lower than the planned harvest level in Alternative I (see FEIS Summary). Subject Area 750 Volume under contract has been removed from the inventory by the acres adjustment for sold sales so it Firewood is no longer considered in calculating future harvest. This does supply an important source of guaranteed supply of timber for the purchaser. Currently the @0750-01 Firewood volume under contract is about two years worth of sales. Two-hundred forty-seven respondents felt that firewood is a desirable by-product that should not go See Chapter 3 of FEXS for further details. unused or be burned up in slash piles. They also felt it helm to clean UD the Forest and urovides income to local communities. @0700-16 Management Some of the reviewers, among them the Crook Practices County Soil and Water Conservation District, felt that the allotments should at least stay the same if not increase. They also wanted the Forest to allow 0700-16.1 Utilization more time for woodcutting and to make the wood more available. There were two letters with concerns about the effects of utilization standards on outputs One Many people indicated that the general pubhc should concern is that projected outputs in the DEIS do not be allowed to cut larch for firewood. They also felt reflect the practices which actually take place. It was that the Forest should stop loggers from selling felt that the amount of timber actually taken out as logging truck loads as fuelwood. usable products is much smaller than that in the EIS. Some noted that there was a problem with the way Another respondent indicated that better utiliza- fuelwood demand is displayed. They felt that the tion of logging residuewould reduce the demand for amount sold probably exceeds what is cut. old growth timber. A few respondents felt that selective cutting would be more beneficial for firewood. They also felt that Response: the Forest needs to educate the public on how to use A utilization standard of a four inch DIB top and a smaller green fuelwood material. seven inch DBH was projected for future decades. One person indicated that the amount of firewood This is two inches smaller than is presentlyrequired. available should be reduced. This amounts to about one percent more volume for

1388 Response: Subject Area 800 Water Availability of fuelwood is an issue that concerned many people. However, what is acceptable fuelwood has not been defined so it has not been inventoried. Estimates of fuelwood that will be available @OSOO-01 Watershed by alternative (Table 2-8 of FEIS) were based on Four letters, among them the responses from the typical volume of cull material left after logging and EPA and the Oregon State Forester, had comments the normal mortality thatwould occur in thevicinity on watershed management. of roads. There is also a small amount from juniper and precommercial thinning. So, the level of timber Onerespondentstated thatinTable4-6andonpage harvest has the greatest influence on availability and 43 of the Draft Plan, the water yield values have no quality of fuelwood. Demand is equally hard to real purpose. The reviewerstates that this line should determine as it is basedonaccessibilityandqualityof reflect a measured output of the Plan’s objectives, available wood compared to cnst of alternativesources such as number of restored miles of fish habitat or of wood or other forms of heat. riparian areas resulting from changes in the timing, quantity,orqualityofrunoffdue to improvedwater- Chapter 4 of the Plan has been rewritten to provide shed conditions. In addition, this person suggested standards and guidelines for managing fuelwood. that the Mountain Creek Watershed and Bear, This attempts to make all wood that is not utilized Badger, and Willow Creeks should all be considered for commercial sawlogs available for fuelwood cut- highly sensitive due to the presence of anadromous ting except were it conflicts with the management fish. direction of a specific Management Area. Some items that have precedence over fuelwood cutting Another respondent asked how goals and objectives are snag requirements and road closures for big for watershed management are being met. game habitat. Also, a timber purchaser has the right EPA noted that DEIS Table 11-11 is apparently to all timber included in a contract and can process missing two watersheds; the agency stated that they orsell thoselogs asdesired, except forexport restric- understand there are 24 major watersheds on the tions, so a purchaser can sell logs for fuelwood It is Forest and Grassland (22 on the Forest and two on very possible that as demand and price for fuelwood the Grassland), but that twoseem to bemissing from increases, more logs will be sold for fuelwood. the table. The free use of fuelwood was under enabling legis- The EPA also stated that the streams on the Ochoco lation that allowed givingwood to settlers who were range in condition from poor to good in relation to dependent on National Forests for fuel. There are their natural potential, and that the Forest should several other legislatitive acts concerning disposal practice management on a stream-by-stream basis of forest products. The Region and Forest has con- to address individual problems or concerns. The siderable discretion on how this will be done. This Environmental Protection Agency also noted that policy is in the 2400 section of the Manual which is Cottonwood, Black Canyon, and Wind Creekdrain- available at theSupervisor’sor District offices. With ages arenot mapped in the DEIS, and asked if these the current demand for fuelwood, most is sold. This drainages are part of larger drainages; and if so, allows the recovery of some administrative costs which ones EPA further stated that an area analysis plus collection of money for slash disposal, refores- would be appropriate for all watersheds in which tation, and erosion control. But some free use mate- development is planned near important aquatic rial IS still available. See local district for availability. resources. And finally, the EPA requested a statement in the FEIS concerning the one existing instance of domestic use ofsurface water occurring on the Forest.

1-3-89 FEIS Appendix I

To ensure protection of current and future drinking ues are also employed in risk analysis at the project water supplies, the agency requested information level. on location, size, source, and municipality served, as A further discussion of watershed threshold values well as any instances of waterborne disease occur- and their use can be found in the Supplement to the rences and pertinent water quality monitoring infor- Draft Environmental Impact Statement for the mation. Ochoco National Forest in the discussion of Man- The Oregon State Forester noted an apparent dis- agement Requirements for Water Quality, and crepanqin the documents. TheForester noted that Appendiv.. F. Appendiv B states that watershed harvest disper- The watershed threshold values given in Appendix sion constraints will be between 17 and 23 percent, H of the DEIS and Appendix F of the FEIS are but that Appendix H lists these figures at 25 and 35 specific for each watershed and range from 25 to 35 percent, respectively. The Forester asked which set percent. The Forest weighted average threshold of figures is correct, and what the rationale is sup- value is 30.1 percent, which means that 30.1 percent porting these constraints when the Deschutes Na- oftheForestcouldbeinaharvestedconditionatany tional Forest satisfied this minimum management pointin timewithoutexceedingtheabilityofstreams requirement with a 58 percent constraint. on the Forest to absorb and recover from the effects of management activities and natural storm events Response: without long-term impact. Project level analysis is currently being used on the Forest at the project level, and is part of the NEPA The harvest dispersion constraints and watershed process. threshold values referred to above could be expected to differ considerably from those used on The Final Plan displays a corrected watershed map other Forests (e.g. the Deschutes NF) due to differ- showing 26 watershed divisions, 24 on the Forest ences in soils, watershed condition, and manage- and 2 on the Grassland. The Ochoco regrets any ment practices that have affected the landscape confusion this error may have caused. over the past several decades. Cottonwood, Black Canyon and Wind Creek drain- TheForest Planis built arounda processdesigned to ages are included within the watershed identified as assure that goals and conditions are being met. See John Day tributaries (see FEIS Chapter 3). chapter 5, Implementation, of the Final LRMP. Management of the uplands in a watershed will be The FEIS will include the information on domestic addressed chiefly through application of a cumula- water supply use in Chapter 3. tive effects model which measures the rate of harvest activity against a threshold based on watershed sensitivity. @0800-02 Upstream Watershed harvest dispersion constraints (FEIS impoundments Appendix B) refer to regeneration (clearcut) harvest limitations (17-23 percent) and overstory re- Four reviewers commented on upstream impound- moval limitations (50-67 percent) which were em- ments Three of the participants felt that upstream ployed in FORPLAN modeling to address the con- impoundmentscould and should be used to improve cem of the model planning unusually high levels of water quality, game habitat, riparian areas and rec- harvest in certain drainages (see Chapters 3 and 4, reation. They recommended the program be ex- FEIS). The values given in Appendix H of the Draft panded and stated that the Forest would benefit LRMP are watershed threshold values employed to fiom approximately 200,000 acre-feet of usable water. assure a more optimum dispersion of harvest activ- The other respondent felt that nature should be ity/effect over space and time. These threshold val- allowed to take its course along streams but stated

14-90 that upstream impoundments seemed to be benefi- flect the natural ability of each watershed to absorb cial from all aspects. Impacts (both natural and human caused) without suffering long term loss of resource values (or caus- Response: ing downstream problems). This model will be util- Forest experience with upstream or headwater ized to monitor harvest effects and changes inwater- impoundments has not been encouraging. They are shed (including riparian areas) condition over time. expensive to construct and maintain and to provide For more information on the use of this model an increased streamflow of just one cubic ft /sec. please refer to Chapter 3 and Appendix F of the requires the storage and release of nearly two acre FEIS. ft./day. More effective from a cost efficiency standpoint as well as providing better fish and wildlife habitat is the improvement of riparian areas which is @oSOO-04 Data/Analysis a key element of the proposed Forest Plan. One reviewer stated that the water yield values in Table IV-6 of the DEIS have no real value, and that @0800-03 Timber/Grazing the line should reflect a measured output of the Effects Plan’s objectives. The U.S. Fish and Wildlife Service suggested that Two letters were receivedwth comments on timber the statement in the Draft should address the range and grazing effects on runoff The reviewers ex- of yields from water wells and estimate the usage of pressed concern that, once the overstory vegetation ground water on the Forest. is removed, whether by timber harvest or livestock grazing, water flow patterns are likely to change, Response: adversely affectingwatercourses bothon and down- Water yield values given in DEIS Table IV-6 were stream from the Forest. The respondents were par- developed during the planning process as a possible ticularly concerned about spring runoff, and felt the tool in the development and evaluation of alterna- DEIS inadequately dealt with this aspect of water tives. Ultimately it was found that total water yield management. was not significantly affected by the alternatives Those responding suggested that grazing practices developed. The values are presented in Table Z-8 of will have to be drastically altered to protect the the FEIS, as it was felt this information might be of Forest from heavy snowpack runoffs. value to some members of the public. The iforma- tion requested on yields from wells has been in- Response: cluded in WATER, Chapter 3, FEE. It is recognized that timber harvest has the potential to affect the quality, quantity and timing of runoff (see Chapter 4, FEIS). However, analysis of the @OSOO-OS Monitoring various alternatives indicates they would affect the The EPA stated that Water Management Practices amount of runoff by less than 5 percent; in fact, several alternatives would actually decrease total should refer to the Monitoring Plan so as to describe the methods used for the attainment of goals and runoff. One area of concern remains the distribu- - objectives. tion or dispersion of harvest by watershed across the Forest. In order to assure an optimum dispersion of harvest effects, a model was developed to track Response: harvest activities (cumulative effects) over time and TheFEIS refers to the monitoring plan to show how area. Watershed thresholds were established to re- goals will be reached. See Chapters 5 of the Final Plans.

1-3-91 FEIS Appendix I

@OSOO-OS Flood The EPA also stated that the Plan and DEIS should have referenced the Oregon Forest Practices Act Onerespondent commentedon thehazardsofflood and Rules and indicated how they would be com- erosion. The comment was made that the ONF is plied with. already at the maximum runoff allowed by the state, and that Federal Regulation 36 CFR 219.27 directs Some respondents noted that violations of water the Forest to minimize hazards from flood erosion quality standards are mentioned in the DEIS, but and similar impacts to streams and wetlands. that only general guidelines are given for their cor- rection. The reviewersreyuested more specificstan- Response: dards be given for the areas withseasonalviolations. State regulations do not cover maximum water run- Several participants in the public review process off. However, Federal regulations (36 CFR 219.27) stated that reduction in shade has caused a rise in do require the Forest Service to minimize hazards sedimentationand temperature, causing some streams from flood erosion and Forest Service policy (FSM to fallbelowwater quality standards. Others felt that 252OAmend. @and FSMR-6Supp.37) reflects this Forest management activities have had a negligible shared concern. effect compared to natural processes. The wording “36 CFR 219.27--minimize hazards Some stated that since there are very few areas from flood erosion and similar impacts to streams where 50-75 percent shade is obtainable on the and wetlands” is now included in the FEIS Forest- Ochoco, and shade appears to be increasingslightly, wide Standards and Guidelines (see Appendix D). the Forest should keep the shade standards as they are at present. One respondent stated that the standard for stream @OSOO-07 Water Quality temperature in the DEIS fails to describe what temperature is to be maintained. Another renewer There were stxteen comments on water quality. asked what state water quality standards for tem- The majority of the respondents were concerned perature refer to--average daily values, daily highs, that the Ochoco NationaI Forest’s DEIS faded to etc. acknowledge and comply with State of Oregon and Federal water quality standards. Among those with Response: this comment were the Oregon DEQ, the Environ- Concerns focusing on the water resource ksue (quality, mental Protection Agency, the Columbia River Inter- quantity and timing) are shared by the Forest. Of Tribal Fish Commission, ODFW, and the Oregon primary importance are temperature and sedimen- Water Resource Department. tation (turbidity). The Watershed Improvement The DEQ further stated that there are no state Schedule is designed to correct a large measure of water quality standards for riparian zone condition, problems dealing with water temperature and sedi- as stated in the DEIS Table V-3. mentation by bringing all riparian areas up to an excellent condition (see response to Riparian com- ODFW asked, in addition to the above comment, ments, 0450-02). Sedimentation problems of the what was meant in the DEIS by “significant degrada- upland watershed level will be mitigated bydispers- tion of water quality.” mg harvest activities optimally over the entire For- The CRITFC asked whether the Forest anticipates est, by applying appropriate Standards and Guide- continuing management practices on those drain- lines, and by applying best management practices ageswhere standards are beingviolated, and if so, on (BMP’s) to deal with site specific situations and what legal basis the Forest justifies those activities problems. Forest Service policy makes allowances that increase or perpetuate those nolations. for short term devmtions from water quality standards (FSM 2526-6). However, it is ultimately the

14-92 task of Forest Service personnel, through project clear, it is wise policy to proceed with caution in planning and administration, to keep any short-term situations where risks of long term resource values impacts from becoming long-term cumulative ef- are high. fects inviolation of statestandards. Future activities a matter of explanation, harvest threshold values with the potential to affect the water resource will As serve as benchmarks reflectingwatershed condition be monitored and problem areas or activities identi- or sensitivity (see FEIS Chapter 4, and Appendix F) fied and brought into compliance. against which the Forest is able to monitor the rate With regard to shade requirements for Forest streams, of harvest activity to determine the level of risk of please refer to Chapter 4of the FEIS. The pertinent incurring long term impacts to watershed condition section states; “The requirements for shade along and water quality. “Eceeding a threshold value streams will generally correspond to provisions for does not, in itself, limit management options on the more than 80 percent of the surface shaded. Where Forest. It does, however, indicate the need to under- this is unattainable, 100 percent of the potential for take other specific mitigation measures to offset shade is the standard.” potential reduction in site productivity or long-term Theseshade requirements are necessary inorder for impairment of water quality” (DEIS p. 133). In the Forest to comply with State Water Quality Stan- order to meet management requirements for water dards as directed by the Clean Water Act (Public quality, the Forest must assure optimum harvest Law 95-217). dispersion, initiate the rigorous application of Best Management Practices, schedule an extensive pro- The State of Oregon Water Quality Standards with gram of Riparian Improvements, and monitor ac- which the Forest must comply under regulations of tivities carefully to assure resource objectives are The Clean Water Act, are maximum values; though met. All of these elements are key factors in the “management activities will include objectives for FEIS. reducing temperatures to levels that will improve fish habitat capability” (DEIS Appendiv D-59). Finally, it should be pointed out that increased timber harvest (or even harvest at current levels) does The Forest Plan FEIS makes reference to the not produce the highest present net value, due in Memorandum of Understanding between the De- part to overall higher mitigation costs. Identifying partment of Enwonmental Quality, State of Ore- the level at which the Forest is able to produce a gon, and the Forest Service, United States Depart- wide range of resource outputs (timber, water, rec- ment of Agriculture. Under this agreement, the reation, etc.) and still maintain a viable, functional Forest Service recognizes the State’s lead in water ecosystem is the basis of multiple resource manage- quality management, cooperates with and gives as- ment. sistance to State or designated area wide planning agencies, acts in compliance with the Forest Prac- Two nonpoint source pollution parameters, water tices Act, and coordinates with EPA (see 208 of the temperature and suspended sediment, are the major determinants of water qualityon the Forest. Higher Federal Water Pollution Control Act). water temperatures encourage the growth of cer- The fact that approximately 50 percent of the streams tain nuisance organisms such as bacteria, algae and on the Forest do not meet state water quality stan- fungi, that in turn affect the levels of dissolved dards for temperature and turbidity is an indication oxygen, pH, and turbidity, while producing undesir- to some that many of the watersheds are suffering able tastes and odors. The amount of shading in the cumulative effects of past management activities riparian areas determines the extent streams are including: road construction, timber harvest, and warmed by solar radiation. The riparian prescription grazing. While it is recognized that our understand- (Final Land and Resource Management Plan, Chap- ing of how management activities affect watershed ter4)contains thewater temperaturestandards and outputs (including sediment) is only just becoming the amount of shade necessary to meet those stan-

1-3-93 FElS Appendix I

dards. Special riparian area alternatives for meeting how implementation of a new Management Plan shade requirements were not examined individually will “magically” change actual practices into “best” because their effect on PNVwould be less than one practices. percent. Another suggested that the Forest attempt to meet Sediment yield is largely determined by the amount “optimal” management requirements rather than and erodibility of exposed soil in a watershed. Tim- minimum management requirements. ber harvest activities, including road construction, The EPA stated that the DEIS should have more slash treatment and site preparation, not only affect fully explained selection of BMP’s for a particular the amount of exposed soil, but also alter the timing activity, and howuncertaintywas factored into those and quantity of water leaving a watershed. Follow- selections. ing harvest actiwties, watersheds become more hydrologically sensitive for a period of time, with storm events producing more rapid and extreme Response: responses. This greater sensitivity to storm events The element that has the potential to bring about results in more energy being available to transport the actual implementation of effective Best Man- sediment to stream channels. Thus the primary ef- agement Practices is the monitoring plan. Monitor- fort in maintaining water quality is directed at the ing closes the circle between the Environmental timber harvest program and its effect on sediment Assessment process and project implementation. production in a watershed over time. Other water Monitoring tells the Forest how well it is doing and quality parameters will be monitored on a project is vital in bringing about change in how the Forest basis as needed. Serviceplans and carries out management activities. Table 5-3 (Plans Chapters 5) has been changed to Best Management Practices (BMP’s) used on the reflect new wording: “Any degraded riparian areas Forest are contained in the report “General Water found to be adversely affecting water quality will be Quality Best Management Practices,” USDA-FS, improved to assure that the water quality meets PHRNov. 1988.Acopyofthisreportison filein the state water quality standards.” Supervisor’s Office, Prineville, Oregon. “Significant degradation of water quality” is taken to mean any water quality parameter that does not @0800-09 Equivalent Clearcut meet stated Oregon water quality standards. Area On the Forest, there are two primary water quality parameters: temperature (as it is affected by shade) Nine reviewers commented on equivalent clearcut and sediment (both in transport as suspended sedi- area (ECA) or equivalent harvest area (EHA) (the ment or turbidity, as well as entrained in streambed two are used interchageably in the Plan/FEIS docu- gravels). ments). State of Oregon Water Quality Standards for tem- Some remarked that they had serious concerns about perature refer to point-in-time maximum values. watershed ECA and its use; they stated that they werenot awareofanyresearchonhowreliableECA calculations used in the DEIS were @0800-08 Best Management Several respondents stated that Table 3-11 in the Practices DEIS was suspect because it implied that some watersheds are capable of withstanding abuse while Three respondents commented on best manage- others arenot. Others felt that “watershed sensitin- ment practices (BMP’s). ties” in the table were poorly defined and should One reviewer stated that BMP’s are not used for a have been included in the glossary. number of reasons, and that the DEIS should address

1-3-94 Some felt discussion of ECA was double-talk to harvest must take place and require a higher bond to justify cutting more than the thresholdvalue of 30.1 encourage earlier harvest. Also, the cumulative ef- percent. They asked if the ECA includes the present fect model used by the Forest has the ability to system of roads, extent of compacted sites, grazing, evaluate this situation and its effect on ECA for mining, or theorientationof a clearcut, commenting various alternatives during the planning process, in that a clearcut on a slope into a stream is more time for corrective action to be taken to mitigate or destructive than one on a flat area. avoid potentially damaging situations. CRITFC and the Oregon DEQ asked what criteria Equivalent Clearcut Area (ECA) calculations are a are used to derive ECAvalues, and how ECAvalues method of keeping track of arange of harvest actiw are determined and implemented for a specific ties, including: clearcut, overstory removal, thin- watershed. nings and uneven-aged management. As part of the cumulative effects (CE) model, ECA yields a pic- One person said that the meaning of Table 4-16 ture of the rate of timber harvest or vegetative (ECA) was not clear. The reviewer asked that labels management over time. Other morestaticelements, or legends be added to the text to explain the values in the table. e.g. roads, grazing, stream channel condition, soils, fishery values, and slope, figure into the develop- Some respondents felt that the limitations on the ment of watershed sensitivity levels reflecting the amount of area harvested in watersheds should be physical condition of a particular watershed (see reduced or the Forest Service should get the legal chapter 3, FEIS, and Appendix E and G). Water- authority to control harvest schedules. These re- sheds have a natural ability to absorb impacts, natu- viewers pointed out that two or more sales within a ral or human caused, up to a certain level or thresh- single watershed, each harvesting near maximum old. Above this threshold, longer term damage to ECA, could cut out in one year, adversely affecting watershed resources may occur. water quality. They stated that the Forest Service is For each sensitivitylevel assigned to a watershed on gambling with soil and water resources. the Forest, a harvest threshold value was established. When ECA is plotted against this threshold Response: value a cumulative effects analysis of the rate of The concept of watershed sensitivity is discussed in harvest activity againstwatershed conditions ismade Chapter 4 of the FEIS and in Appendices E and G. possible. Should a condition arise when the ECA Watershed sensitivityratings are based on a number exceeds the threshold value, it is an indication that of factors including: soil type, channelcondition and watershedvalues maybe at riskand that steps should fishery values. These ratings reflect the existing be taken to reduce this risk either through mitiga- physical condition of thewatershed and its suscepti- tion or rescheduling of harvest activities (FSM bility to damage from human activities and/or natu- 2405.13). ral events. Sensitivitylevels were established to work wthin the natural ability of a watershed to recover Additional uses for this cumulative effects analysis from the impacts of human activities and natural include assuring an optimum dispersion of harvest events with no long-term resource damage. These effects on watersheds on a District or the whole sensitivity ratings will be evaluated over the life of Forest. Also, cumulative effects analysis provides a the Forest Plan and will be readjusted as necessary benchmark, management activities versus water- in the future. shed condition, which can be evaluated against in the future for purposes of monitoring the effective- The fact that two or more timber sales, sold at nessofmanagement prescriptions andbest manage- differenttimes,couldcut outwithinashort period of ment oractices. time with possible negative impacts to the watershed IS a recognized problem. However, new timber Reference to Table IV-16 is made on page 133 of sale contract regulations shortentheperiod inwhich the DEE. The table has been corrected in the FEIS to make it more readable.

13-95 FElS Appendix I

Equipment modification along with use of desig- Subject Area 820 Soil nated slud trails or logging on snow, are all techniques that are being explored to reduce soil compaction damage. However, each method has its @0820-01 Compaction drawbacks and limitations. Three letters were received with comments on soil The Forest agrees that soil should receive high compaction. CRITFC remarked on the DEIS state- priority during project planning and implementa- ments that no more than twenty percent of an activ- tion.SeeChapter4oftheFEISforthediscussionon ity area can be compacted to a degree which de- evnironmental consequences. grades vegetative productivity, that cable logging is estimated to increase soil bulk density on ten percent of an activity area and tractor logging on thirty @0820-02 Productivity percent; and that it was previously stated that a Forest-wide average of twenty percent soil compac- One respondent stated that, until such time as better tion would be allowed for activities. From this, information becomes available on lost sod produc- CRITFC infers that, if this degree of compaction tivity, the following ECA thresholdsshould be used constitutes the predicted compaction level, then high, ten percent, medium, twenty percent, and; with a twenty percent threshold of variability from low, twenty-five percent. the predicted level, compactionwouldhave to affect twenty-four percent of the activity area before ac- Response: tion would be taken. At this point in time the watershed threshold (EHA or ECA) values provide the Forest ulth a bench- One reviewer asked whether compaction caused by mark against which it can evaluate the riskor effects partial cutting can’t be largely offset by equipment of harvest and management activities. These thresh- modification, and how much has been done in this old values will be monitored against effects on the area such as requiring the use of large-rubber-tired ground, and can be raisedor lowered in the future to skidding devices, managing placement of skid roads, assure resource values are protected. etc. The other respondent suggested that soil effects should receive the highest priority throughout proj- @0820-03 Sedimentation ect planning and implementation, and that emphasis should be placed on prevention of compaction and Eight letters, among them the responseof CRITFC, displacement in relatively undisturbed areas. had comments on sedimentation. One person stated that the Transportation section Response: of Riparian Management, PLRMP (“Road drain- The soil management guideline (Plan, Chapter 4) age will be designed and maintained to eliminate any which states that, “no more than 20 percent of an influx of road sediment runoff directly into riparian activity area can be compacted or displaced to a areas”), is not realistic. The comment is made that degree which degrades vegetative productivity,” refers many roads are located in draw bottoms, and the toapoint intimeoneyear afterthe activityhas taken only place the roads can drain IS into the riparian place; and may include mitigation such as ripping zone. and tilling to bring compaction levels with the 20 Another respondent stated that the low soil/water percent guideline. This is an average value and values in DEIS Table B-VIII-7 and elsewhere do includes a 20 percent variability factor meaning some not reflect the true value of the Forest’s soil re- sites may be at 16 percent while others will be at 24 source. percent.

1-3-96 Another reviewer requested that a value be as- Sediment production is closely tied to timber har- signed to potable water with relatively steady sea- vest, since it is the only real variable from among the sonal flow and low suspended sediments. This per- range of alternatives. Roads, generally recognized son felt the entire Forest Plan showed a bias by not as the major source of sediment, change little from recognizing that water maybe asvaluable an output alternative to alternative. More stringent grazing as timber. utilization standards will be applied to all alternatives for riparian areas. The Forest no data from One participant stated that the value of sedimenta- has which to make estimates on sediment production tion should be based on how much money must be from grazing or mining. The process for calculating spent to remove it from spawning beds. sediment production and delivery to stream chan- CRITFC asked what the effects of different amounts nels is available in the Planning Record, which is on of road building, cattle grazing, and mining on sedi- file in the Supervisor’s Office. mentation are. The Council also requested that the methodology for calculations of sediment production and delivery to stream channels be made more 00820-04 Specifics clear in the final documents, and should include formulas and references. Two letters hadspecificcommentsonsoils. TheEPA asked where on the Forest the high-clay soils are Response: located. The other respondent stated that if logging The wording in the Final LRMP has been changed could benefit a particular site, balloon or helicopter to read “directly into stream channels.” logging might be used to protect fragile soils. The Forest shares a strong concern for maintaining Response: soil productivity and water quality values. Forest- The FEIS contains a description of the location of wide Standards and Guidelines contain a number of the high-clay soils (see FEE Chapter 3). For the criteria designed to protect soil and water. The best most part, they arelocatedon southernexposures as management practices (BMP’s) described in Chap- buried soils on north and east exposures. For a ters 2 and 4 of the FEIS (also Appendix G) have also detailed description of the location of clay soils, been developed to assure soil and water resources there are copies of the Forest Soil Resource Inven- are maintained. tory available at the Supervisor’s Office. The soil and water values used in the economic Alternative logging methods, including the use of analysis of the various alternatives were taken di- helicopters, are viable options and have been used rectly from the 1985 RPAprogram assessment, and in the past to protect and minimize effects on other have been designated for use in the planning proc- resources (see also Plan, Chapter 4, mitigation ess. The value assigned to sediment reduction (i.e measures for soil). reduced soil erosion) of $6.OO/metric ton and maintaining water quality of $0.20/acre ft. (FEEAppen- dur B, Section 4) are considered by many to be unrealistically low. 00820-05 Plan Comments Any land management plan is a blend of resource One respondent asked why soil loss is considered an values and outputs involving tradeoffs between a output (Table IV-6 and elsewhere in the DEIS and range of objectives. It is felt that by adhering to the PLRMP). standards and guidelines and management prescriptions that resource values will be adequately protected.

1-3-97 FEE Appendix I

Response: Response: The soil loss values given in FEIS Table 2-8 provide The Forest has reviewed ground cover standards relative comparisons of erosion levels. They are not and feels the range given (FEIS Appendiv D) is looked upon as a positive output. adequate to maintain soil productivity in riparian areas (see FSM 9/83 R-6 Supp 45--effective ground cover by erosion hazard class). @0820-06 Erosion Standards for maintaining soil and vegetation in a Eight responses were received containing remarks condition which promotes infiltration of precipita- on erosion. Among the letters were those from tion (Le. reduced compaction and surface erosion) ODFW and CRITFC. are contained in the Final Plan, Chapter 4 (soil management in riparian areas). Several of the respondents registered opposition to clearcutting, stating that this practice is very condu- The wording “36 CFR 219.27--minimize hazards cive to erosion and destructive to the environment. from flood erosion and similar impacts to streams Some commented that the Forest Serviceis directed and wetlands” has been included in the FEIS For- by Federal regulations to minimize erosion impacts. est-wide Standards and Guidelines Others said there is nothing wrongwith clearcutting Removal of vegetation from the Forest, namely as long as it does no harm to the environment, and timber harvest, reduces evaporation transpiration. that in fact the practicecreateswildlife and livestock As a result, sod molsture values are hgher in clearcuts forage, however, they agreed that clearcutting in the than under adjacent stands of mature timber. This is wrong areas can harm streams through erosion. the reasoning that is used to calculate the changes in Most of the comments pertained to ground cover runoff predicted in FEIS Chapter 4. Increased tim- and its relationship to erosion prevention. ODFW ber harvest yields greater runoff; though overall stated that the standard for ground cover in riparian differences are less than five percent. areas should be 80 percent. CRITFC asked how it Although clearcutting appears more destructive, was established that 40 to 60 percent ground cover soil damage is concentrated and because of this is will be sufficient to prevent significant erosion, and often easier to correct; e.g. reducing the compaction on which streams flowing through grazing allot- damage from heavy equipment through tilling. On ments does ground cover exceed 60 percent. the other hand, partial cuts or salvage logging must Others stated that 60 percent should be specified in cover large areas of land with many miles of skid the FEIS as theminimum basalgroundcover area to trails. The choice is between concentrated impact effect proper infiltration of precipitation. One re- (with clearcutting) or extensive impact to the land =ewer mentioned the requirement m the 18970rganic with other forms of harvest. Which method is better Act to provide favorable conditions of streamflow, or worse overall often depends on site characteris- andstated that theamountofvegetationneededfor tics and stand condition. precipitation infiltration was not alluded to any- The majority of degraded stream reaches on the where in the Plan. Forest are the result of the cumulative effects of a One respondent blamed neither logging nor Iive- number of activities (including road construction, stock for erosion. This person stated that the vast timber harvest, grazing, etc.) that have taken place majority of erosion occurring on the Ochoco in the over the last several decades, and are seldom the past 23 years took place in February of 1979 as a result of a single activity. The cumulative effects result of storms and runoff. model in use on the Forest analyzes the risk of entering watersheds at various levels of management in conjunction with a major storm event.

1-3-98 of State Smoke and Visibility Plans, this Forest Subject Area 830 Air abides by the spirit of these plans in continuing to reduce emissions from our activities. The recently completed Environmental Impact Statement (EIS) @0830-01 Air on Managing Competing and Unwanted Vegeta- tion emphasizes human health issues. The Forest Eleven letters, among them the responses of the incorporates this more comprehensive guidance on Environmental Protection Agency, the Oregon public health concerns in the FEIS and Forest Plan. Department of Environmental Quality, and the Improvements in smoke abatement technology will Oregon State Forester, had comments on air qual- be utilized as they develop. ity. Most, including the agencies mentioned above, were concerned about the detrimental effects of Since the adoption of the Oregon SIP, the Forest prescribed fire and slash buming on air quality. The has been in full compliance with the regulations on agencies all referred to the Oregon State Implemen- protection of visibility and the goals of reducing tation Plan (SIP) and asked if the Ochoco was in smoke emiisions. The FEIS AppendixD and Forest compliance With it. Plan Chapter 4 have been updated to reflect the newly approved SIP. DEQ and othels expressed concerns over the amount of Total Suspended Particulates (TSP) from pre- During the 1977-78 baseline period, the Ochoco scribed fire. Most respondents expressed a desire to National Forest’s share of the Bend-Madras Basin see prescribed fire used less frequently. Some sug- TSP load was 9,200 tons. From current levels of gested that all slash and debris be ground back into around 13,000 tons it should continue to drop to the soil. approximately 9,000 tons by the fifth decade. For this reasonitwasdecided thatfurtheranalysisof this Long-term effects of air pollution, such as acid rain issue was not needed. and health effects, were addressed by some. The EPA stated that smoke from woodstoves causes While most of the draft alternatives did in fact show serious wnter air pollution. an increase in TSP in the first couple of decades due to increased harvest levels, none of the alternatives The State Forester noted that the DEIS failed to proposed a level out of line from that of thebaseline state that prescribed fire reduces fuels buildup and period. The range of expected TSP production is the riskofwildfire. Theletter from the Forester also well within the range of error of the estimates. made the statement that forest smoke will originate in the Ochoco whether prescribed fire occursor not. Statewide, TSP emissions from Forest Service prescribed burning are being reduced. This reduction The DEQ commented that if projected annual and occurs because many Forests are burning fewer daily air pollution emissions do not exceed those of acres and most Forests are burning a smaller per- the baseline period (1977-78), then this issue should centage of forest residues by employing tested and not be analyzed further. proven techniques to reduce emissions. See Chap- ter 4 of the Forest Plan for details on mitigation Response: techniques employed on this Forest. The Forest is concerned about the health and dis- comfort impacts of smoke. Prescribed fire is con- The DEIS did fail to mention that prescribed fire is ducted in accordance with State Smoke and Visibil- one tool used to assist in preventing uncontrollable ity Plans to avoid and minimize these impacts on the wildfire. That oversight has been corrected in Chap- public. Although currently outside the jurisdiction ter 4 of the FEIS.

13-99 FEIS Appendix I

the protection, administration or utilization of Na- Subject Area 900 Land tional Forest land. The Ochoco has not identified any lands for possible purchase or condemnation. Landswithin theOchocoNationalForest havebeen @OSOO-01 Land Ownership grouped into the following ownership categories: Adjustment and Exchange 1. Areaswhere Congress has directed theForest Service to retain Federal lands and to acquire There were four comments concerning Land Status. non-Federal lands for a designated purpose. One respondent stated that the Fbrest Service should Scenic Rivers fall into this category. recommend the acquisition of lands by exchange or 2. purchasewithwilling private landowners to produce AreaswhereNationalForestownershipisnec- essary to meet management objectives. Feder- a consolidated block of Federal land. ally owned lands will be retained, and non- Another felt that the Forest Service should not use Federal lands will be acquired as the opportu- condemnation or exert pressure on landowners to nity or need arises. Riparian areas and lands acquire private inholdings. with wilderness values fall into this category. Still another opinion was that land ownership ad- 3. Lands allocated for commodity production, justments should give a high priority to riparian where the lands would be managed to provide areas, lands adjacent to wilderness, and lands along similar types of output regardless of owner- inventoried Wild and Scenic Rivers. ship. Federal lands may be retained, or they Finally, one reviewer stated that the lands desig- may be used to acquire lands in Categories 1 and 2. However, lands in this category wdl not nated for exchange in the proposed Steelhead Falls Wilderness Area should be identified for acquisi- bedisposedofifthatwouldresultmabreachin tion. a solid block of Federally owned land. Private lands within this category may be acquired in Response: order to consolidate Federal ownership. The Ochoco National Forest and Crooked River 4. Small, isolated blocks of National Forest land National Grassland goal is to achieve the land own- which do not amtam special features, and which ership pattern that best supports resource needs and are expensive and difficult to manage. These reduces administrative costs. The Ochoco will ac- lands will be used to acquire lands in Catego- quire or dispose of lands onlywhen it is clearly in the ries 1,2and3.Disposal of Category4landswill public interest. Changes II~land ownership should have priority over the disposal of lands in Cate- reduce administration and protection costs or im- gory 3. prove resource conservation and production. 5. Areas where more intensive study adplan- Land exchanges are the most common method of ning are necessary to determine the optimum land ownership adjustment, and most land exchanges land ownership pattems. Federal lands in Cove- in which the Ochoco participates are actually initi- Palisades State Park are included in this cate- ated by the private landowner. The purchase of a gory. piece of property will he considered only when the Refer to the Standards and Guidelines Section of possibilities of exchange, donation, or the acquisi- Chapters 4 of the Final Plans, to FEIS Chapter 4, to tion of a partial interest have been exhausted. Con- Appendix G of the Grassland Plan, and Appendvr D demnation will be used only when all other methods of the Forest Plan for more detaded in€ormation. of acquisition fail and the property is required for

1-3-100 Subject Area 920 @0920-02 Guides One person noted that the Plan allows for a com- Special Land Uses mercial guiding and outfitting concern in the Black Canyon Wilderness, and requested information on setting up such a venture. @0920-01 Utility Corridors Another stated that commercial outfitters and their There were four letters with comments on Special attendant stock animals should be carefully regu- Land Uses. Among them were the responses of the lated and monitored on Forest lands, particularly in US Department of theInterior, the OregonDepart- Wilderness Areas. This respondent felt that preser- ment of Energy, and the Bonneville Power Admini- vation of natural resources should take precedence stration of the US Department of Energy. over commercial uses of the forest. One respondent stated that the DEIS faded to address the environmental consequences of visual impacts Response: resulting from transmission systems. The Oregon Outfitter/guide permits will be awarded in the Black Department of Energy commented that the DEIS Canyon Wilderness onlywhen the permitted activity should address the effects by alternative on siting of w11 meet the management objective of prowding a transmission lines and pipelines. wlderness experience. If an application for an outfittedguide is received, the activity will be analyzed The US Department of the Interior and BPA rec- through the NEPA process to determine whether a ommended that existing and planned utility corri- permit should be issued. dors be designated and addressed as required by Section 503 of the Federal Land Policy and Manage- If a permit is issued, the outfittedguide will be re- ment Act of 1976. quired to comply with certain restrictions, as identified in the analysis to maintain wilderness qualities Response: and objectives. Refer to Chapter 4 of the Plan, Standards and Guidelines, for use restrictions. The Proposed Land and Resource Management Plan has been modified to identify an allocation for utility corridors (Utility Corridors Management Area, Chapter 4, Grassland Plan) This management area will provide for limited additional facilities. No further corridors are planned. This is true in all alterna- Subject Area 930 Energy tives. A proposed transmission line would cross private land only within the Forest boundary. Because the @0930-01 Leasing National Forest would have no legal jurisdiction Four letterswere received with comments on energy over this corridor, it is not designated as a manage- leasing. ment area. One respondent suggested that all National Forest Electric transmission lines involve large, negative lands be withdrawn from appropriation under the visual impacts. For technical reasons, these lines energy leasing laws. cannot be buried. The natural gas transmission line is buried. Another wanted leasing prohibited in areas allocated to old growth, SPNM recreation, or areas Refer to Chap!ers 3 and 4 of the FEIS for more considered for Wild and Scenic River or Wilderness information. classification.

1-3-101 FEIS Appendix I

Still another respondent was unhappy that 80 per- detail the technical aspects of the proposed activity, cent of the Forest was proposed for oil and gas lease the location and magnitude of any potential surface availability, stating that many areas not in wildemess disturbance, and the rehabilitation measures that have uses incompatible with oil and gas leasing. will follow the activity. To insure that rehabilitation Finally, one respondent suggested that a general work is performed, a bond based on the cost of that overview of constraints on oil and gas leasingwould work wlll be required before any surface-disturbing prepare the public and managers for issues which activities are approved. activation of the leases will initiate. The Standards and Guidelines Section of Chapter 4 in the Final Plan lists the lease stipulations required Response: for each management area. Chapter 4 of the FEIS, The Forest Service recognizes the importance of Ennronmental Consequences, also discusses the responsible energy development to the nation’s effects of oil and gas development. economy and security. The Ochoco National Forest seeks to facilitate the environmentally sound development of oil and gas resources. @0930-02 Data Incorrect On the Ochoco National Forest, wilderness areas The Oregon Department of Energy and DOGAMI are the only areas withdrawn from mineral leasing. commented on energy potential on the Ochoco. In other areas, stipulations are attached to leases to assure that development will be compatible with The Department of Energy disagreed with the con- other resource values. clusion in the DEIS that 90 percent of Ochoco lands are prospectively valuable for oil and gas resources, The most restrictivestipulation requires “no surface citingwhat that agency calls alackofconclusivedata occupancy.” When a leaseis issued with this stipula- in the draft. tion, no road building, seismic testing, drilling, pipe- DOGAMI contradicted the statement in the draft line construction, or any other use of the surface is allowed. However, oil, gas or geothermal deposits that the Forest and Grassland have no known geothermal resources The letter stated that DOG- below an area leased with a “no surface occupancy” geothermal maps show a warm water spring stipulation may be tapped by directional drilling AMI’S on the Forest. from outside the restricted area. The management areas on the Ochoco where the “no surface occupancy” stipulation will be attached to all leases in- Response: clude old growth, roadless areas, Scenic Rivers and A mineral potential report was prepared for the the North Fork Crooked River Wilderness Study Final Plan. This report classifies approximately 54 Area. percent of the Grassland and 92 percent of the Forest as prospectively valuable for oil and gas, Other, less restrictive, stipulations are also attached based on USGS information. to mineralleases. For example, aseasonal use stipulation may be used to protect wildlife during critical The report also classifies all of the Grassland and times of theyear. Asetback stipulation may be used Forest as favorable for the discovery of thermal to keep operations and facilities away from roosting water suitable for direct heat applications. This clas- or nesting sites. sification is based on a Oregon Department of Geology and Mineral Resources report which shows a warm In addition, lessees and operators are responsible water spring on the Snow Mountain District. for the proper rehabilitation of disturbed lands. Even after a lease has been issued, operations wll not be allowed until a surface use plan has been approved. The surface use plan must describe in

1-3-102 A computerized list of mining claims is maintained Subject Area 940 and updated quarterly at the Regional Office. This list classifies each claim as lode, placer, tunnel or mill Minerals site. The reports and list of claims are available for review at the Supervisor’s Office. @0940-01 Plan Comments Mineral development and production, mineral potential, past production, current mineral withdraw- Letters from the US. Department of the Interior, als, access restrictions, and the process used to ap- the EPA, the Oregon Department of Geology and prove or modify operating plans are discussed in Mineral Industries (DOGAMI), and the U.S. Bu- Chapter 3, “Affected Environment” of the FEIS. reau of Mines were received with requests for more The mineral potential of each roadless area is dis- information to be included in the EIS. cussed in Appendix C of the FEE. The environmental effects of mining on water quality and cul- The EPA requested that a list of mining claims tural resources are discussed in the minerals section classified as lode or placer mines be added. of Chapter 4, “Environmental Consequences” of TheDepartment ofthehteriorwanted information the FEIS. conceming mineral development and production, The FEIS does not identify new sources of mineral thevalue of past production, and projected mineral resources or predict future demand for minerals. demand. USDI and the Bureau of Mines recom- Rather, it defines broad areas favorable for the mended the following information be added to the occurrence of mineral deposits. Ultimately, the exact documents: a discussion of how minerals are af- nature, extent and location of any new resourceswill fected by each alternative; a list of current mineral be determined by industry through self-initiation withdrawals and acres involved; definitions of access under the 1872 Mining Laws. restrictions for locatable minerals; and mineral potential for locatable and leasable minerals, including adetaileddiscussionofthemineralpotentialofeach roadless area. Along with DOGAMI, USDI recom- 0940-01 .I Plan Comments mended that a mineral potential map and mineral The USDI stated that Federal law gives claimants inventory be added. DOGAMI also noted that ]as- the statutory right to develop their mining claims, peroid being mined may be an indicator of a hot and that the Forest Service has the responsibility to spring gold mine accommodate mineral development on lands open DOGAMI and the EPA stated that the potential to mineral development. environmental impacts of mining on water quality DOGAMI felt that a bias against mineral produc- and cultural resources should be discussed under tion was evident in the draft Plan. The agency stated mineral exploration. that a different set of standards was used for miner- The EPA also commented that the process through als than for other resources. The example given was which operating plans are approved or disapproved the fact that dollar values were placed on campers in sensitive areas should be described. using the forest, but none was given for mineral exploration. Response: DOGAMI also felt that the planning team had a Two mineral potential reports, one covering the minimal background in geology and mlneral ~sources, Grassland andonecovering theForest, werewritten because there were no geologists or minerals per- to be used as input to the final Plans. The presence sonnel listed as preparers in the draft. ofjasperoids (agate, jasper or thundereggs) was one of the criteria used to determine mineral potential.

1-3-103 FEIS Appendix I

Response: reviewer asked if this indicated that ecological bal- It is true that Federal law gives claimants the statu- ance can be purchased if the mineral potential is tory right to develop their mining claims. The For- great enough. est’s goal for minerals and energy is to “provide for and facilitate the exploration, development and Response: production of mineral and energyresources in coor- Mining can have a negative impact on the environ- dination wth other resource objectives, environment. Reasonable and practical measures aimed at mental considerations and mining and leasing laws.” minimizing or mitigating these impacts are included The Forest will respect the rights of mining claim- in operating plans. In addition, when it is appropri- ants andwll accommodate mineral development on ate to do so, operating plans are used to limit impacts the Forest. until it is certain that valuable minerals are present at a site. However, this is not meant as an indication The evident bias against mining in the Proposed that ecologcal balance can be purchased fthe mineral Plan and DEIS is unfortunate. A geologist was in- potential is great enough, but rather as recognition cludedon the interdisciplinary teamwhich prepared of the balance between the statutory rights of a the Final Plan and FEIS. The geologist used avail- mining claimant and the need to protect the envi- able references to prepare two mineral reports whch ronment. were used as input to the Plan. These reports are listed in the references and are available for review Although mining is allowed on 95 percent of the at the Supervisor’s Office. Forest, it is concentrated on approxlmately 10 percent of the land (the areas wth moderate or high In the Final Plan, a dollar value was placed on mineral potential). Most mining on the Ochoco mineral leasing. Avalue was not placed on locatable National Forest is lode (hard rock) mining, which mineral exploration and development. It was de- generally has less effect on water quality than placer cided that such values cannot be accurately pre- mining. Any predicted impact on water quality is dicted because the discovery and development of addressedin the operating plan. At present levels of mineral resources will be initiated by industry under activity, mining has a minor cumulative effect. In- the 1872 Mining Laws. A value was not placed on creased levels of actlvlty would require a new analy- mineral materials because almost all mineral mate- sis of envlronmental effects. rial produced is used on Forest Service roads or provided free of charge to other government agen- Refer to Chapter 3 of the FEE,“AffectedEnviron- cies. ment,” for a discussion of operating plans and to Chapter 4 of the FEE, “Environmental Conse- quences,” for a discussion of the environmental 0940-01.2 Plan Comments impacts of mining. The EPA letter contained the comment that mining will be allowed on 80-90 percent of the Forest and @0940-02 Monitoring questioned the statement in the draft that mining would have a “minor effect on the water resource.” Requirements The EPA stated that many small mines could have a The EPA recommended that the plan include water large cumulative effect, particularly if road building quality monitoring requirements for sites with the increased due to mining projects. potential to affect water quality Another respondent commented on the statement The Columbia River Inter-Tribal Fish Commission in Chapter IV of the DEB which says, “The level of noted that management plans for mineral develop- control (of mining activities) depends on the min- ment include reclamation requirements, but stated eral potential of the scenic and riparian areas.” The there is no indication of monitoring required of the

1-3-104 miningcompany, and asked if monitoring is the sole other areas, measures are included in operating responsibility of the Ochoco. CRITFC also asked plans to assure that development will be as compat- what the Forest-wide goal for reclamation consists ible as possible with other resource values. of, and whether it implies restoration to natural Operating plans are developed and approved on a appearance. case-by-case basis. The operating plan must describe in detail the technical aspects of the proposed Response: activity, the location and magnitude of any potential The Plan requires that water quality be monitored surface disturbance, and the rehabilitation meas- before, during and after selected projects. As appro- ures that will follow the activity. To insure that priate, mining activities will be selected for this rehabilitation work is performed, a bond based on water quality monitoring. In addition, water quality the cost of that work will be required before any will be monitored as part of minerals activities surface-disturbing activities are approved monitoring. Refer to Chapter 5 of the Plans, “Im- plementation of the Plan,” for monitoring require- Chapter 3 of the =IS, Affected Environment, dis- ments. cusses the mining law and operating plans. The degree to which reclamation can restore the The development of common variety materials (for landscape to its original appearance depends on the example, gravel and sand) is governed by the Mate- type and size of development. For this reason, recla- rials Act of 1947, as amended. The Forest Service mation is addressed on a case-by-case basis in the has the authority to develop these sources, and operating plans. Monitoring required of the mining mining claims may not be located for these materi- companywill be addressed on a case-by-case basis in als. As stated in Chapter 4 of thePlans, thesesources the operating plan. will not be developed in riparian areas.

@0940-03 Prohibited Areas @0940-04 Withdrawals Four letters had comments on mineral extraction in The U.S. Department of the Interior stated that the general. Some respondents wanted all mineral ex- definition of withdrawals needs to be reviewed. The traction and processingprohibited in nparianzones. agency noted that staking of new claims and estab- Others suggested it should be prohibited every- lishment of new leases may be prohibited depending where on the forest. on the individual withdrawal, but that development of leases and claims established prior to the date of Response: withdrawal is not necessarily prohibited. The Forest Service recognizes the importance of WGAMI stated that, in cooperation with the BLM, mineral resources to thenation’seconomyandsecu- that agency has identified a potential gold mineral- rity. The Mining Law of 1872, as amended, grants ized area just to the south of Haystack Butte, and the right to locate and develop mining claims on that this areashould not bewithdrawn from mineral public Iands. The Ochoco National Forest seeks to location or leasing. facilitate the environmentally sound development DOGAMI also said that a mineral inventory should of mineral resources. be completed before areas are chosen to be Re- On the Ochoco National Forest, wilderness areas, search Natural Areas. the Ochoco Divide Research Natural Area, Delint- ment Lakeand WaltonLake Campgrounds, Ochoco Response: andRager Ranger Stations, and astrip of land along Withdrawal is defined as the withholding of an area Highway 26 are withdrawn from mineral location. In of Federal land from settlement, sale, location, or

1-3-1 05 FElS Appendix I

entry under some or all of the general land laws for develop thunderegg and gemstone deposits on public the purpose of limitingactivities under those laws in lands. This prevents recreational rockhounders from order to maintain other public values in the area. digging in these areaswithout theclaimant’s permis- Most of the withdrawn areas on the Ochoco Na- sion. To prevent this problem, two rockhound clubs tional Forest are withdrawn from the mining laws, have located claims which are open for free public but not the mineral leasing laws. Wilderness areas use This option is open to any club interested in are withdrawn from both the mining and mineral maintaining claims leasing laws. In either case, valid existing rights (leases and claims established prior to the date of withdrawal) are respected. TheDepartment of theInterior has the authority to make, modify or revoke withdrawals. The Chief of Subject Area 1000 theForest Service reserves the right to concuror not concur on all withdrawals involving leasable miner- Transportat io n System als. The Forest Service makes recommendations to the Department of the Interior (Bureau of Land Management) on withdrawals involving locatable @I000-01 Road Closures minerals. Before an area is withdrawn, both the (Permanent and Seasonal), Forest Service and the Bureau of Land Manage- ment assess the mineral potential and analyze alter- Road Density natives to withdrawal. Ninety-five letters were received with comments Refer to Chapter 3 of the FEE,“Affected Environ- concerning road closures. The majority of the re- ment,” for a discussion on withdrawals. spondents recommended that the Ochoco under- take an aggressive road closure plan to protect the environment, improve conditions for wildlife, and @0940-05 Rockhounding insure cost-effectiveness of the transportation plan. Most felt that the Forest has built too many roadsin There were two letters with comments on rock- the past and that any new roads built for timber hounding. One respondent stated that more lands harvest should be closed immediately upon comple- should be held open for rockhounding. The other tion of harvest activity. expressed concern that incidental non-commercial rockhounding is considered a mining activity. It was Some suggested a system of temporary or limited suggested that the Ochoco take action to makesure road closures, with harvest access allowed but other non-commercial rockhounding and mineral collec- access denied. Others wanted roads closed only tion remain as such. during hunting season. Still others indicated that roads closed and replanted could add to the timber Response: base. Rockhounding on National Forest lands does not One respondent recommended closing feeder roads require a permit or mining claim as long as the on a rotating basis to provide areas for non-motor- activitydoes not conflict withexistingrights, and the ized recreation and big game habitat. specimens are collected for personal, noncommer- Many other respondents disagreed wth road clo- cial use. If the specimens are sold commercially, the sure Some felt that public land should be open to all activity is considered mining, not rockhounding, and membersofthepublicatalltimes Othersstatedthat the mining laws or mineral sales laws apply. the elderly and handicapped would have no access Individuals have the statutory right to locate and to the National Forest if road closures took effect.

1-3106 Some stated that they would agree to road closures The access closures and restrictions, provided in the only in certain areas and in very wet seasons. A few Standards and Guidelines and Travel Map, provide reviewers supported the road construction plans in a range of road densities to meet a variety of man- Alternative B-Plus or E-Departure. agement area prescriptions and user needs. In some Several respondents, among them the EPA and areas, such as big game winter range, most of the ODFW, commented on road density. roads will be closed (1 milehection) during the winter months when the area is critical to big game. Varying opinions were voiced concerning mad density. During huntingseasons a number of roads in several Recommendations ranged from less than one mile areas within the Forest and Grassland are closed, per square mile to more than the four miles per under the green dot system. Other seasonal and square mile proposed in the draft Plan. Most felt limited closures will occur to reduce resource dam- that current road density is too high and is having age, to provlde for public safety, and/or to reduce adverse effects on wildlife and recreation. maintenance costs. The road density objective un- A few respondents stated that road densities are der the Preferred Alternative for general forest/ especially high in sensitive areas such as draw bot- general forage areas will be three miles per section. toms. New local roads will be managed to meet identified ODFW noted that the Plan stated 4.1 miles of road objectives and will be closed or deactivated if there exist foreachsquaremileofdeveloped area, but that are no defined objectives for use after the initial since most of the road mileage is in the southern purpose is served. Roads closed for future intermit- two-thirds of the Forest, the road density there is tent use (Maintenance Level 1) will be blocked to probably as high as 5-7 miles per section. eliminate unwanted use and will receive the mmimum maintenance treatment to prevent erosion. The EPA said that, as the phrases “short term” and Roads with no foreseeable use will be rehabilitated “long term” are defined in the glossary, increases in to meet the prescription for the management area. road density could create impacts in a period of time shorter than “short term.” The environmental consequences of the road management direction by alternative is discussed in One respondent stated that the amount of mileage Chapter 4 of the FEIS and the miles of roads by in the proposed planwould not allow Forest recrea- category and closures are displayed in Table 2-8 in tion to keep up, let alone to grow. Chapter 2. Response: The Forest and Grassland recognizes the need to @I000-02 New Roads and balance access wth the needs of other resources. The Standards and Guidelines in Chapter 4 of the Road Standards Forest and Grassland Planswill providedirection on Therewere 59 comments concerning new roads and how on- and off-road access would be managed. A road standards. Travel Map has been developed for the Forest and Grassland which incorporates the direction from Most, including the Crook County Soil and Water theplans. It clearly displays howandwhere access to Conservation District, recommended no new road the Forest and Grassland could be gained. The construction unless absolutely necessary. The County discussion of access in the Plans and the FEIS is suggested the Ochoco limit permanent road build- supplemented by Appendix D which provides fur- ing and put more emphasis on temporary roads. ther information on how the travel map was devel- Many respondents were displeased with what they oped and how access management for the Forest perceived to be the economic loss occurring through and Grassland will be implemented.

1-3-1 07 FEIS Appendix I

the road construction program. They felt the timber companies should bear the full cost of road con- Subject Area 1100 - struction. Protection Some encouraged searching for new harvest methods that would not require road building. Those that did not recommend a halt to road con- @I 100-01 Toxic Chemicals struction for themost part suggested that theForest and/or Catastrophic Accidents lower its road standards to lessen the impacts on wldlife of high-standard roads. Some, on the other Four respondents, including the EPA, noted that hand, wanted a greater degree of maintenance on none of the draft proposals addressed toxic chemicals and/orcatastroDhiceventssuch as oilspilk. The existine0 roads and hieher0 standards for new roads. respondentswantei toknowiftheForest6ad aplan One person noted that in the draft Plan and EIS, for such events, and whom to contact in an emer- forest access did not decrease significantly even in those alternatives with lower harvest levels. gency.

Response: Response: The amount of new construction and reconstruction of existing roads is closely related tdtimber harvest. The Forest Plan does not deal directly with this The amount of road needed per acre harvested concern. Instead, the Plan is tiered to the Pacific varies in response to many factors, e.g., logging Northwest Region’s Environmental statement for system used, topographic relief, and environmental Vegetation Management (1988), and all achons under factors. Severalyears ago theForest Serviceadopted the plan are required to be in compliance with new guidelines for establishing road design stan- NFMA regulations 36 CFR219.27 (b). In addition, dards by service level which assures that the mini- all Federal agencies are required to be in compli- mumstandards toserve the resourcewll beutilized. ance with the Renewable Resource and Conserva- Alllong-term roads are used formore thanone year. tion Act (RCRA), and the RCRA amendments. Someof the road costs can be considered an invest- The Forest also has an emergency spill plan which ment for future uses. relates not to activities conducted by the Forest or Grassland, but to transport ofmaterialson highways Roads normally deteriorate because of use and weather impacts. This deterioration can be reduced through the area. through adequate maintenance or restriction ofuse. Emergency procedures and RCRA requirements All system roads will be maintained to at least the for spill maintenance plans have been incorporated basic custodial care required to maintain drainage, into the final documents. See Appendix H of the protect the road investment, and minimize damage Forest Plan and Appendix L of the Grassland Plan. to adjacent land and resources. This level is the normal prescription for roads that are closed to traffic. Higher levels of maintenance may be chosen Subject Area 1110 Fire to reflect greater use or resource protection. New roads and total miles needed for all alternatives are discussed in Chapter 4 of the FEIS. @I 1 10-01 Fuel Buildup Eighteen letters were received with comments on fuel buildup. Most of the respondents were concerned that allowing slash and down material to

1-3-108 accumulate creates a fire hazard. Most encouraged Activity residues hazard abatement is an integral allowing firewood collection to help mitigate the part of project level planning and is one of many dangers. Many commented that grazing should be residue management goals considered in the For- allowed over much of the Forest to cut down on fuel est’s Residue Management Plan. buildup. While the Forest will have a younger average stand Even-aged management was also targeted by some age under a managed situation, the mosaic of stand as a cause of serious fire hazards. Some felt that ages will help prevent catastrophic insect outbreaks, selective cutting would reduce the danger, stating disease, and the resultant increased fire hazard asso- that organisms of like age are more susceptible to ciated with large areas of older stands. Younger disease and fire. stands certainly are at higher risk in the event of fire, but only if the residues are not managed at an Some respondents felt that any areas closed to log- acceptable level of risk ging are fire hazards. They recommended that dead and diseased trees be harvested wherever they occur The cultural resource oversight has been corrected to reduce fire dangers. in the discussion on fuel treatment options for buried disturbed sites (see Chapter of the FEIS). One respondent suggested leaving more fuel for risk 4 analysis.This, accordingto the reviewer, would help The common denominator requested is forest resi- the Forest to formulate a better plan to coordinate dues. The first two subjects (particulates and slash fuels management. burning) are related in that the second produces the first. They are discussed together in the section on Another respondent commented that broadcast Air Quality in the FEIS, Chapters and The burning is permissible for disturbed, undisturbed, 3 4. change in amount (acres) ofburning over time gives and surface-buried cultural resource sites, but was an indication of expected change in atmospheric left out of the fuel treatment options for buried visibility due to the amount (tons) of smoke particu- disturbed sites. lates produced. The third subject, salvage firewood, One reviewer was confused by the tables and text is a method of residue treatment emphasizing utili- covering disposalofForest residues by burning. This zation rather than disposal, and the most common person wished to know what the common denomi- unit of measure IS cords. nator is between particulates, described in “thou- The Forest has developed additional direction in sand tons;” slash burning, described in “acres,” and new sections in the FEIS and Plan which deal with salvage firewood, described in “cords.” Residue Management. A number of new analysis techniques are coming on linewhich will assist in the Response: risk analysis as well as the economic analysis in- The Forest shares the concern over potential fire cluded in such decision making. See FEIS Chapters hazards mentioned in the above comments. New 3 and 4, and Forest Plan Chapter 4 for further sections have been added to the FEIS and Forest discussion. Plan which help address this issue. These will help guide the forest residue management. Forest residues accumulate through natural proc- @1110-02 Prescribed Burning esses. These conditions will be monitored and when conditions approach maximum acceptable levels Nineteen letters contained comments on prescribed identified in each management area prescription, fire. The majority of the respondents were in favor appropriate treatments will be instituted. This will of continuing or even expanding the prescribed maintain a mosaic of residues providing an accept- burning program, stating that the Forest and Grass- able fire risk and meeting other ecosystem needs. land are in dire need of large-scale treatment. Some included Wilderness and Research Natural Areas in

1-3-109 FEIS Appendix I

their recommendations. In addition, many felt that comments above and can be found in FEIS Chapter the Forest Service should allow naturally occurring 4, and Forest Plan Chapter 4. The detailed decisions fires to burn out on their own. on the proper application of prescribed fire are carried out on a case by case basis in the project Others, however, registered opposition to the pre- planning environmental assessments under the broad scribed fire program They felt that slash burning guidelines of the Forest Plan. See Chapter Forest destroys many trees unintentionally, and that broad- 4, Standards and Guidelines, and Management Area cast burning is simply too destructive to soils and Prescriptions. vegetation. Some stated that prescribed fire encourages non-native plants to be introduced to burned Prescribed fire will not be used in mured conifer old areas. growthuntil adequate research provides thedesired vegetation description. This wll most likely occur One respondent suggested removal of only 25-40 within the next planning period (next ten years) and percent of the volume per acre than is the present thus will not be a major departure from experienced practice, and treatment of the resultant slash. This, fire history in this type of stand Moderate use of it is felt, wdl be far less disturbing than removing 12- prescribed fire is being allowed in ponderosa pine 20 MBF per acre and burning 35-60 tons per acre of old growth since this species is seral and will disap- slash all at once. pear in the absence of fire (see Chapter 4 of the One respondent noted that the old growth defini- FEIS). It is likely that a variety of treatment pre- tiondoes not include anunderstory description, and scriptionswill evolve due to the different vegetation that it is necessary to knowwhat structural charac- types involved. teristics and vegetation the Forest is attempting to produce within each plant community before applying a forage and/or fire treatment prescription. @I1 10-03 Risk Management Response: There were four letters with comments on fire sup- Fire is a natural process of recycling and renewal in pression The respondents were unanimous in sug- local ecosystems. However, because of the random gesting that all areas on theForestshouldbe open to nature of its occurrence it sometimes conflicts with road building for fire access. One reviewer stated the timing of management Realizing late in this that areas for wildlife winter range without roads century the importance offire in ecosystem mainte- become fire hazards and will prove difficult to pro- nance and its usefulness as an economicallyefficient tect from fire. means ofvegetation and residues control, the Forest now “prescribes”theuseoffireinterms ofwhen and Response: where it will occur. Fire suppression access has been considered in the transportation planning for the Forest and is com- Used initially in reducing activity fuels, it has be- mensurate with the values at risk and the manage- come wdely used locally in treating “natural” fuel ment objectives of each Management Area. accumulations in order to mimic historic fire cycles which allowed for the establishment of “large” di- The Forest has developed additional direction in ameter old growth pine stands on so much of the new sections in the FEIS and Plan which deal with Forest. Residue Management. A number of new analysis techniquesarecomingonlinewhichwillassistinthe Thediscussionson thesesubjectsin theFEIS, Chap- risk analysis as well as the economic analysis inter 3 and 4, and in the Forest Plan, Chapter 4, have cluded in such decision making. See FEIS Chapters been expanded in response to the above comments 3 and 4, and Forest Plan Chapters 2, 3, and 4 for to clarify the points raised. New sections dealing further discussion. with Forest Residues also relate to some of the

1-3-110 1 10-04Fire Protection basis in comparison with the objectives (including @I maximum area at FIL I11 per decade) for the Man- Three respondents, among them the Oregon State agement Area(s) involved. See FEIS Chapter 4, and Forester, commented on fire protection. Forest Plan Chapter 4 for further discussion on this The State Forester remarked that the Oregon topic. Department of Forestry supports the Forest Serv- ice’s policy of applying aggressive suppression action to wildfires that threaten life, private property, public safety, improvements, or investments. Subject Area 1120 One reviewer stated that the Plan needs to place more emphasis on low-impact Wilderness manage- Pesticides ment, including fire control. The person stated that he was angry to find a cat line in the Bridge Creek Wildemess Area that had been used for fire suppression. @1120-01 Prohibition The third respondent stated that the 100 acre per Three letters were received with comments on pes- decade maximum for burning seemed arbitrary and ticide and herbicide use. Concerns were voiced about recommended that acreagesburned be decided on a the effects of pesticide use on non-target species case-by-case basis. and long-term effects on the environment. Some felt that pesticides and herbicides should be prohib- Response: ited, or that if they do again become legal, a rigorous set of application guidelines and monitoring safe- Protection of life, property and investments is a guards should be implemented. common concern of all wildland fire protection ’ agencies and will continue to he the Ochoco’s primary policy direction to minimize losses and cost of Response: suppression. InDecember of 1988the Regional Office published an Environmental Impact Statement entitled The fireline mentioned in the Bridge Creek Wilder- “Managing Competing andunwanted Vegetation.” ness was cut several years prior to the designation of This document sets forth the direction for all Na- the area aswilderness. Since that time rehabilitation tional Forests in the Pacific Northwest Region for requirements have been instituted on all such sup- Vegetation Management. Pesticide and Herbicide pression techniques, even those outside of wilder- use are dealt with in that EIS, and Vegetation ness areas. This fireline has been brought to the Management activities on the Ochoco will comply attention of the District, and rehabilitation will be with those guidelines. The projected outputs from carried out as necessary. this plan do not depend on the use of herbicides, The maximum acceptable burn acreage per decade although the availability of herbicides would lower is a function of the size of the Management Area, reforestation costs in some cases. Insecticides may the probability of occurrence of a fire at Fire Inten- be used to control insects but this is not the pre- sity Level (FIL) 111 in that Management Area, and, ferred method. See response to Insects and Disease, given that occurrence, the likely area burned at that and also the Forest Health section in Chapter 4 of FIL prior to containment of the fire. It also takes the Plan. into account how much impact such an area of intense burn will have on the management objectives for the Management Area in question. Each fire, as it occurs, will be dealt with on a case-by-case

1-3-1 11 FElS Appendix I

harvest level when necessary as a result of cata- Subject Area 1130 strophic events. Insect and Disease The basic strategy for insect and disease control is to prevent damage by managing stands through species Control and stocking manipulation. Diversity in size and species is one of the keys to this (see discussion on Diversity) It will take several decades to get stands @I 130-01 Diseased Trees and in the desired condition, but in the long run this should prove the most effective control. Spraying or Insect Control other direct control measures may he used if within There were many comments on the management of the direction for the management area and sup- the Ochoco National Forest as it related to insects ported by an EA or EIS. This would be a back-up and disease. measure, and spraying has been planned or included in costs considered necessary for projected outputs. Thirty-four letters contained comments on insect There are Entomologists and Pathologists available and disease control. Among them was the letter to help in on-site evaluation and/or treatment rec- from the Oregon State Forester. ommendations. Most of the comments, including that of the State EfEects of‘ insects and disease on timber yields have Forester, were to the effect that the Ochoco should beenmcorporatedintheyield tablesbybasingyields, place more emphasis on insect and disease control. including mortality and defect, on historical data. Some felt that controllmg damage from disease and The effects of individual pests cannot be isolated, insects is vital to maintain sustained yield. Others nor will this reflect the loss that will occur in a stated that disease will spread if action is not taken specificyear, but should be a fairly accurate estimate quickly. of losses over a rotation. Some respondents were against clearcutting because theyfelt that even-aged management contributes to insect and disease problems. One individual felt that the public should he edu- Subject Area 1140 Law cated conceming the need to depart from normal harvest practices when dealing with insect and dis- Enforcement ease problems.

Response: @I 140-01 Enforcement The effects of each of the alternatives on insects and diseasearecovered under “F0restPests”inChapter Two comments were received concerning Law En- 4of the =IS. The Forest PLan has been rewritten forcement. to include Standards and Guidelines for treating One respondent felt the best way to improve condi- each major forest pest group (see Forest Health, tions for big game would be to enforce existing laws, Chapter 4). These guidelines are specific to each especially those dealing with road hunting and using Management Area. The actual on-the-ground activ- CB radios to track animals, and to increase fines for ity will depend on a project-level analysis which will poaching be guided by above direction. These and the Timber guidelines encourage the prompt harvest of dead The other respondent wanted the entire Forest and dying material when compatible with direction opened up to hunting. This person suggested a less for the management area, and allow varying the complicated program of law enforcement, desiring a more positive relationship between Forest Service personnel and the public. The individual also stated Subject. Area 1200 that the Forest should review some of its rules for appropriateness. Economic Considerations Response: Poaching, road hunting and the use of radios are violations of exlsting state game laws. The Forest 01200-01 Local Economics Service has a Memorandum of Understanding with the Oregon State Police, in which the role of each One hundred respondents, including the Oregon agency in game law enforcement is identified. In Labor Market Economist, saidtheydidnotfavorthe effect, it states that the Oregon State Police will Preferred Alternative, or any alternative that would have the primary role of enforcing game laws. The harvest less than 130-137 MMBF, because they Forest Service agrees to monitor and report known believed that it would cause significant problems or suspected violations. due to unemployment, low payments to counties, The primary objective of any law enforcement pro- and other economic problems. gram is to prevent violations. Response: One way the Forest Service attempts to do this is The Ochoco National Forest compared the results through public education. Another is the prosecu- of all the alternatives to the “current situation,” that tion of those individuals found to be in violation. is, an average picture of the communities over re- Most Forest Service field employees receive 40 hours cent years. The results do not predict any major of law enforcement training. The subject empha- changes under the Preferred Alternative I. In fact, sized most heavily is making a law enforcement the prediction is for a slight positive change. contact in a positive, safe, effective manner. Like all law enforcement agencies, the Forest Service reports violations to a prosecuting body, in this case 1200-01.1 the US. Attorney’s Office. Appropriate action is Mill Modernization then determined by that office. The Forest Service Seven respondents pointed out that the wood prod- has no controlover actions taken by the U.S. Attor- ucts industry has been, and is, mqdernizing. The ney’s Office, but Forest Service personnel are work- State Economist states that any economic estimates ing with that office to improve the situation. which are based on old data regarding technology Most Forest Service regulations are imposed by are questionable estimates. Some parties say that an Congress or by the Secretary of Agriculture They attempt to maintain employment levels by increas- are therefore outside the scope of the Ochoco Na- ing harvest levels will not work. tional Forest Plan. Occasionally, the Forest Super- visor may impose specific, local regulations. These Response: are intended to assist in managing unique, local The Ochoco National Forest has added asection to problems which may arise. These generally relate to Chapter 3 of theFEIS whichdlscusses millmoderm- special fire prohibitions or road closures for re- zation. The IMPLAN model has also been updated source protection purposes, and are required to be to reflect 1987 mill performance (see Appendiv B, reviewed annually. Section 5).

13-113 FEIS Appendix I

1200-01.2 Timber Sale statement that combining the government and the manufacturingsectors overstated the importance of Projections timber to the county economies. The State Economist and the Director of the State Economic Development Department questioned Response: whether the projections from timber sale revenues The data is derived from the 1985 Business and might be too high. One question was whether all Employment Outlook, JTPA Districts 10, 12, and sales would sell. Another question was when the 14. The statement which was challenged was ques- harvest would occur and the receipts come in. tionable and has been withdrawn. Response: From past experience, the Ochoco projects that it 1200-01.6 Local Log Sales will have no problem in selling its sales. Receipts One participant discussed the topic that Willamette may come in at uneven rates, but the average re- Valley mills purchase central Oregonlogs. The basic ceipts are accurate. point was that the Forests of central Oregon are big enough to meet theneeds ofcentral Oregon, butnot big enough to meet the needs of Valley mills also. 1200-01.3 Errors Questions were asked such as: The State Forester pointed out that in DEIS Table -Why should local Forests increase harvest levels III-4, there is an error in Deschutes County’s popu- when there is no guarantee that the increase will lation The population of 65,300 is reported as 15,300. produce local jobs? -Could the local Forests restrict log sales as has been Response: done in the Lakeview area? The error has been corrected in the FEIS (FEIS Chapter 3). -How can central Oregon enable its wood processing industry to compete more effectivelywith Valley sawmills and remanufactures? 1200-01.4 Data/Analysis Response: The State Forester’s Office commented that DEIS The question of who successfully bids for local logs Table1114 displayed incomes for the affected coun- is a valid one. Some of the eastside Forests, such as ties and the State. but not the U.S. This was deemed the Deschutes are more affected than the Ochoco misleading. NF, but effects on the Ochoco NF are likely to increase. Chapter 3 of the FEIS contains a discus- Response: sion of the effects of the Ochoco NF statewide, as InformationfortheUnitedStateshasbeenincluded well as on local economies in the FEIS Chapter 3 text. The Forest participates inone programwhich tends to favor local firms: the small business set-aside program. The U. S. Department of Agriculture is 1200-01.5 Data/Analysis authorized to participate in such programs with the The State Forester’s Office referred to the analysis SmallBusiness Administration (Small Business Act, of county economic bases as reflected in DEIS Fig- 15 U.S.C. 631). Participation tends to favor local ure III-3. The Forester wanted to know the source smallbusiness because moredistant smallbusinesses of the data. The Office also disagreed with the are less likely to bid on sales.

1-3-114 The policy of the Forest Servicewhich underlies this to long term community stability. See Forest re- program is that small businesses should have the sponses to Departure Harvest under Timber, and opportunity to purchase a fair share of the timber responses to Community Stability under Social sales off National Forest lands The small business Considerations. “fair proportion”of the annual timber sale program is determined by the Regional Forester and provided to the Forest as part of the timber program. 1200-01.8Small Business The Forest Supervisor maintains a continuing record of sale volumes purchased by large and small Impacts businesses. The record provides the basis to deter- One reviewerstated that theeconomicimpact ofthe mine if there is a need for a set-aside program in the proposed Plan is understated, especially for small area during any six-month period. businesses. Hestatedthat moreanalysisof theeffect Speaking more generally, the Ochoco National Forest upon small businesses IS required by Public Law 96- does not intend to be involved in programs which 354, the Regulatory Flexibility Act. tend to favor local mills. Being a National Forest, it is obligated to all the people of the nation The Response: needs of central Oregonians have been specially Public Law 96-354 applies to governmental agen- addressed in this document and in other ways, but it cies who generate regulations which might apply to is not felt proper that the ONF give special prefer- small businesses, small not-for-profit organizations, ence to local residents. It is believed that the best or small governmental bodies. Sice the Forest Service way to serve competing bidders from near and far is does not regulate in this manner, the law does not to sell the timber in an open market fashion. apply to it. In a similar way, many local residents can explore Nevertheless, the Forest Planning process under ways to benefit local wood processors in competi- the National Forest Management Act has much in tion with Valley wood processors, however, it is not common with the provisions of Public Law 96-354. appropriate for the ONF to be involved in these Regulatory agencies publish proposed new regula- discussions. tions in the FederalRegister; this corresponds to the Draft EIS which was released in 1986 and which was also referred to in the Federal Register. Comments 1200-01.7 Departure Harvest are solicited from the public in both processes. And those comments help to shape the regulatory agency’s One respondent pointed out that 25 percent mon- final regulations, just as the Final EIS is shaped by eys are assumed to rise and fall with timber reve- the comments listed in this Append=. nues; whereas the two do not necessarily move in the same directions or at the same rates. The comment was directed toward the fact that the DEIS Pre- Economic Impacts ferred Alternativewas a Departure; it said that the @I 200-02 25 percent moneys, in particular, would decline in There were 23 comments addressing the issue of the third decade and beyond, depriving the commu- employment multipliers. The concern was that the nities of a stable economic base. multipliers used were too low. The Ochoco NF multiplier was said to be only 1.5, when comparable Response: multipliers range between two and three. It is true that 25 percent moneys may move differ- Two respondents made their own estimates of the ently than timber revenues. Elsewhere in this Ap- effect of the Preferred Alternative. The DEIS esti- pendix, there are comments regarding the Depar- mated that the Preferred Alternative would pro- ture, and also concerning the Forest’s commitment

1-3-115 FElS Appendix I

duce an additional 63 jobs and an additional $0.3 contain data which could be used to compute a millioninpayroll. BrianLong, aneconomist hiredby multiplier. the Central OregonEconomic Development Coun- Tounderstand the question ofmultipliervalues,it is cil, projected aloss of289 jobs and $5.8million. (Mr. first necessaly to define what a multiplier is. IM- Long’s estimate of the combined effects of the draft PLAN (or any input/output model) classifies em- plans of the Ochoco NF and the Deschutes NF was ployment into the following three categories. a loss of 317 jobs and $6.5 million). Jim McClain of the Northwest Forest Resource Council predicted a Direct employment--the employment involved loss of 118 jobs and $2.0 million. Other reviewers in creating products which Will be exported from quoted these figures and preferred them to the the local economy or purchased for final con- Ochoco NF estimates. sumption within the local economy. Examples would be exported molding, exported 2x4’s, or Stateofficialsvoicedconcernsabout themultipliers. 2x4’s purchased locally for new construction. Two Labor Economists, the Director of the State For the local wood products industry, 99+ per- EconomicDevelopment Department, and the State cent of employment is involved in preparing Economist all said that the multiplier should range exported products. between two and three. The Director of the State Economic Development Department predicted a Indirect employment-the employment involved loss, not a gain, in employment. indirectly in creating the above products. Mill- work operations buy dimension lumber from Response: sawmills, who buy logs from loggers, who buy Two questions are addressed here. One is, What is gasoline from local operators, and so on. the correct employment multiplier? The other is, Induced employment--The employees involved Whatwill be the effect of theDraft Preferred Alter- in the above activities will purchase goods and native on income and employment? semcesfor their households, thereby producing The DEIS never reported a value for employment employment in trade and service sectors. multipliers. The multipliers as computed by others Any change in employment will produce direct ef- were deduced from data in the following tables: fects, indirect effects, and induced effects. The defi- Table IV-2--Employment changes by alterna- nition of the input/output model multiplier is criti- tive, decade 1; cal. it is the ratio of the total effects to the direct effects. Table IV-3--Employment changes by alternative, decade 2; The terms “direct effects” and “indirect effects,” as defined above, are different from the way in which a Table B-V-3--Employment changes by alterna- person might use them in a non-technical sense tive by county, decades 1 and 2; and They are also different from the way that they are Table B-V-1--Employment per unit of Forest used in Tables IV-2, IV-3, and B-V-3. For Alterna- output. tive E-Departure, for example, the timber harvest declines slightly. This results in some lost jobs in the Table B-V-1, for example, states that 1 MMBF of wood processingindustry,which in turncauses other ponderosa pine will produce eight wood products jobs to be lost. Tables IV-2, IV-3, and B-V-3 refer to jobs and four jobs in other industries. The concern these losses as “direct effects” and “indirect ef- expressed is that this implies an employment multi- fects,” but the use of these terms is technically plier of 1.5. This is perhaps a reasonable conclusion wrong. Thechange in thewood processing industry, from the informationgiven However, the line labels herecalled “direct effects,”isactually the sumof the in the table were misleading. The table, when cor- direct effects and the wood processing portion of rectly labeled and correctly understood, does not the indirect effects (about two-thirds of the total

13-116 indirect effects). This change should be re-labeled 1200-02.1 Current Situation as “Employment Changes in the Wood Products Industry Due to Changes in the Timber Harvest When reading the following discussion it should be Level.” The change called “indirect effects” is the remembered that the DEIS was published in 1986, remaining portion of the indirect effects plus the and the public comments were written the same induced effects. The correct label for this change year. In discussion of what should constitute the would be “Employment Changes in Non-Wood- “current situation,’’ the data used were the most Products Industries Due to Changes in the Timber recent available at the time. Harvest Level.” Six respondents took issue with the Ochoco NF These terminology changes are significant. If the definition of a “current situation.” Some respon- values reported as “direct effects” were truly direct dents, including the Director of the State Economic effects, the data would indicate an employment Development Department, recommend the use of multiplier of around 1.5. But the true direct effects the Potential Yield level of 137 MMBF. An econo- are smaller than those shown, and the multiplier is mist hired by the Central Oregon Economic Devel- therefore larger. opment Council recommends the 1984-1986 har- vestlevelof 147MMBF. The OregonStateForester The same type of confusion has occurred concern- takes a different approach and recommends basing ing Table B-V-1. The figures in this table show that the “current situation” on the average 1976-1985 1 MMBF of ponderosa pine produces eight jobs in employment level. the wood processing industry and four jobs in other industries. Simdarly, 1MMBFof other species produces fourwood processing jobs and two other jobs. Response: This has led some to say that the multiplier is only This is an important question because changes in 1.5. But because the eight jobs include both direct employment and income are determined relative to and indirect effects, the multiplier will be larger than the “current situation.” The “current situation” used 15. in the DEIS was the 1984 harvest level of 127.3 MMBF. Employment multipliers were not shown in the DEE Neither was the “direct effect” data which would The Ochoco agrees that to use a single year as the allow the multipliers to be computed. However, the “current situation” is not appropriate. The wood employment multiplier, when computed, is 2.0. This processing industry has traditionally gone through is at the low end of the range mentioned by all the cycles. In addition, in recent years, it has been af- reviewers. Since the county economies aresmall, it is fected by resource use debates, lawsuits, and other considered that this value is reasonable. actions which affect timber harvest levels To examine a short period of time is to invite unreasonable The second questionwhich needs to be addressed is results whether the DEIS estimates of employment change are realistic. The key question here is what harvest TheForestdoesnot believe thatuseof thepotential level should be used as a comparison point. Mr. Yield level is appropriate because it does not reflect McClain and the Director of the State Economic a‘lcurrent situation.”The 1984-1986figures, though Development Department compared the harvest current at the time, were also known to be abnormal under the Preferred Alternative to the Potential due to the recession recovery and the repurchase of Yield of 137 MMBF. Mr. Long used the 1984-1986 timber under the timber buyback program. The average level of 147 MMBF. We agree that if these concept ofcomparing to employment levels is inter- were the proper levels to use, there would be a esting, and the long time frame is appropriate. sizeable loss in employment and income. But we do However, employment levels include many factors not believe that these are appropriatecomparisons. beyond the control of the National Forest. Thisquestion isdealt with under the topic“‘Current What is needed is a measure that reflects actual Situation’ economic level used in IMPLAN.” conditions over a period of several years -- long

1-3-1 17 FElS Appendix I

enough toevenoutcyclical conditionsorothershort The jobs 1abeledh”abeled as “Timber, Indirect term effects. The ONF has chosen to use the aver- Effects” are not jobs in the wood products industry. age harvest over the years 1980-1988, which repre- Rather, they are jobs in other industries which are sents a harvest level of 110.7 MMBF. affected by changes in the wood products industry. The total change in non-wood processing jobs is: -19 (Crook County, “Timber, Indirect Effects”) 1200-02.2 Recreation-Related +59 (Crook Cty, “Recreation, Wildlife and Range Effects”) Employment + 15 (Harney County, “Timber, Indirect Effects”) Four reviewers, among them the Oregon State Of- +22 (Harney, “Recreation, Wildlife and Range Effects”) fice of Economic Analysis, the State Economist, and the State Labor Economist, said that employment gains associated with recreation --in particular,with +71 Total change in non-wood-productsjobs fishing -- appear to be too high. Response: 1200-02.4 Effects on An error was discovered in the Draft in the estima- Recreation tion of employment due to fishing. As a result, employment levels for all alternatives were too high One reviewer questioned the effects on “recrea- and have been recomputed. tion-related industries.” The respondent pointed out that the effects included many economic sectors that were not directly related to recreation. 1200-02.3 Employment/lncome Response: Change The line label perhaps should have been more ex- One comment concludes that based on DEIS fig- plicit. When jobs directly caused by recreationists ures on employment change, the figure containing increase or decrease, other economic sectors are the change in incomeiswrong. Looking at Table IV- affected. The total effects caused by recreation ac- 2, the letter states that there would be 69 lost timber tivities were termed “recreation-related.” See the jobs at $24,200 per year, and 59 gained recreation discussion of multipliers for more discussion of jobs at $18,000 per year. The computed loss in problems with line labels in some tables. income over one decadewould be over $11 million, even before multiplier effects were computed. 1200-02.5 Non-Cash Benefits Response: One person wrote that non-cash benefits such as Table IV-2 was misunderstood -- partially due to recreation, fishing, and hunting were given mislead- confusing line labels. See the section on multipliers ing high cash values and included in the economic for a fuller explanation. The change in wood prod- analysis. Two respondents believe that the “amen- ucts jobs would equal: ity” values are too low. -50 (Crook County) +23 (Harney County) Response. The cash benefits associated with amenity outputs are derived from gains or losses in jobs and the -21 Total change in wood productsjobs income resulting from those jobs. Therefore, they are true cash benefits.

13-118 The derivation of these benefits is an involved mat- of the 1982 data were examined and concluded to he ter. The Forest Service started with an economic accurate enough to meet the needs of the planning modelulth 528 economic sectors. For a given activ- process. ity -- twelve hours spent hiking in Wildemess, for example -- the anticipated expenditure for each sector was computed. (For example, twenty cents 1200-02.8 lmplan wll he spent on dairy products.) For each area analyzed -- for example, Crook County -- expendi- Two respondents stated that the IMPLAN model tures were totaled for all the existing economic should span Crook, Harney, Jefferson, Grant, and sectors. Wheeler counties. According to the respondents, this would allow better estimation of the effects of The value associated with, say, an RVD would de- the wood products industries and consumer expen- pend on the expenditure per sector, and the criteria ditures. for including that sector’s expenditures. Values can run higher or lower depending onwhat assumptions Response: are made. The Forest believes that this analysis is AnIMPLANmodelshoulddeterminethe “hounda- accurate and adequate. ries” of a local economy and he sized accordingly. The Forest treated Crook County, Harney County, and Wheeler Countyas threedistinct economies for 1200-02.6 Wheeler County two reasons Three reviewers, including a State Labor Econo- Consumer expenditures are well “hounded” by mist, stated that effects on Wheeler County should county lines. Neither residents of Fossil, nor he computed because the 25 percent moneys are a residents of Burns, do much shopping in Prinev- significant contribution to the county’s budget. ille. To some extent, county lines serve as good Response: boundaries for the wood products industries. Wheeler County was modeled in the FEIS analysis. Little or no timber from Crook County is milled (See FEIS Chapter 4, and Appendix B Section 5.) in Harney County. Nearly all the timber remilled in Harney County comes from Harney County. 1200-02.7 IMPLAN It is true that wood processing stretches far beyond county lines. The IMPLAN models go to some Three comments said that IMPLAN analysis should length to capture these effects. For example, for he redone using the 1982 IMPLAN model. The timber harvested in Harney County, the models IMPLAN work was criticized because it was based distinguish between the following: on data that was as much as nine years old. Timber milled in Harney County, Response: Timber milled in Crook County, The 1982 IMPLAN model (Version2 0) was used in Timber milled neither in Harney County nor in the FEIS. This model incorporatesvarious improve- Crook County; ments over IMPLAN 1.1. More importantly, it was based on 1982 data rather than 1977 data. Timber milled In Harney County and remilled in Harney County, and The Ochoco felt that 1982 data was still not current enough for adequate analysis. Information for the Timber milled in Harney County and remilled in wood products industrywas obtained privately from Crook County. the area’smills and updated to 1987. The remainder

1-3-1 19 FElS Appendix I

The Ochoco National Forest believes that the to present the effects in enough detail to describe IMPLAN models constitute a good model of the the impacts of all the alternatives, including the area, and represent reality muchmore closely than a Preferred Alternative. multi-county model. 1200-02.1 1 Economic Analysis 1200-02.9 Employment Two comments questioned the DEIS projectionthat Changes Harney County would gain jobs during the first Oneindividual requested the calculation of changes decade, while Crook County would lose employ- in employment and income for the year 2030. ment. One of these comments came from the State Economist. Response: Response: IMPLAN, like any input/output model, assumes that the economy modeled will stay the same. It In the new Preferred Alternative, which schedules allows for no technology change or any other changes harvests differently, there is no significant differ- in thebasic industrialstructure. Especially given the ence between the effects on Crook and Harney rapid rate of modernization in the wood products counties. industry, the ONF does not believe that changes in employment or income that were projected out to the fifth decade would be valid. 1200-02.12 Capacity Four letters referred to capacity. One recommended that mill capacity be considered in estimating im- 1200-02.10 Economic Analysis pacts on -employment Ten respondents requested that additional economic analysis be performed. Some thought that impacts Response: on employment and income should be done in greater Mill capacity has no direct effect on employment. It detail, or that more analysis should be done. One represents no historical level of employment and is reviewer suggested comparing employment levels therefore not an appropriate number to use for a to what would happen if the mills ran at fullcapacity. “current situation” comparison. The subject of mill Othersrequested additional analysis of recreational capacity did not play a part in the selection of the or foragevalues. Still others desired additional stud- Preferred Alternative. ies on impacts on service industries and small businesses, and on county and school budgets. Some requests for further analysis related to the value of @I200-03 National Economics inputs such as recreation or forage. One comment expressed the concern that while PNV calculations seem to be major influences on Response: FORPLANoutputs, they are not responsive to the The Forest believes that it has used appropriate ICO’s. This respondent requested that the relation- values. See the section on “IMPLAN values associ- shipofFORPLANPNVcalculationsto thenational atedwithamenities”f0rfurther informationon how concern of economic efficiency be addressed in depth these values were obtained. Most of these comments request additional detail or Response: additional analysis of the effects of the Preferred Economic efficiency is a major planning criteria Alternative. The Ochoco National Forest attempted addressed in NFMA and its implementation regulations. The major use of PNV is not the control of

1-3-120 FORPLAN outputs, nor is it directly related to @I200-05 Multiple Use ICO's. PNV is used 1) to ensure that scheduled activitiesand practices arc cost effective, 2) to select Management the most efficient activities and practices to achieve One comment expressed the concern that PNV is a a set of goals and objectives, and 3) as one of the validcomparatoronlyifit can accuratelyaccount for decision criteria in deciding which alternative best all priced and unpriced, market and nonmarket, and maximizes Net Public Benefits. direct and indirect costs and benefits. The respondent stated that the costs and benefits described as being evaluated in the economic analysis are not all @I200-04 Timber Economics significant factors applicable to decisions based on One comment was received stating that PNV analy- multiple use resource management of public lands. sis promotes the liquidation of old growth ponderosa pine by discounting future value. Response: It is true that all critena important to the decision Response: maker are not part of economic efficiency analysis Of all benefithost analysis techniques, Present Net (PNV). Appropriate methods to quantify certain Value (PNV) isconsidered themost appropriate for nonpriced values (for instance, visual quality, old land management problems of this scale. Economic growth, and snag habitat) have not been developed. efficiency analysis using PNVdoes associate a time These values need to be considered in qualitative valuewith money. Put another way, a dollar today is and subjective terms. worth more than a dollar ten years from now. As a PNV is considered a valid comparator because it result, given the choice of harvesting a high value puts many of the priced resource values, both mar- product today or in the future, PNV analysis will ket and nonmarket, on similar terms for the purpose choose to harvest today. of comparison. However, both market and non- In the DEIS, only Alternative H-Departure was market priced resources have factors besides eco- designed and developed with the main objective of nomic considerations.As with unpnced values, priced resources should also be evaluated qualitatively. mmmizing PNV. The ob~ectivesof all other alternatives were based on public issues, management Therefore, PNV should be, and is, only one of the criteria used to evaluate resource outputs. concerns and opportunities (ICO's).The maximiza- tion of PNV was the criterion then used to assure NFMA regulations charge the Forest Service with that each alternative had the most economically identiljing the alternative which comes closest to efficient combination of outputs and activities needed maximizing net public benefits (NPB). NPB repre- to meet its objectives. sents the overall value to the nation of all outputs In the FEE, three alternatives (I, B-Modified, and and positive effects (benefits) whether they can be quantitatively valued or not. Net public benefits GModified) incorporate uneven-aged management include both priced and nonpriced resource out- for ponderosa pine. Alternative I also incorporates puts, less all costs associated with managing the area extended rotation ages for ponderosa pine. These objectivesslowthe rateofharvest forlarge diameter All priced outputs and all costs associated with managing the Forest are included in the calculation pine and increase the size of pine that will be man- of PNV. The net subjective values of the nonpriced aged in the future. outputsmustbeadded tothisinordertoarriveat the Refer to Chapter 2 of the FEIS for a description of overall NPB of an alternative. The Forest then the Alternatives and to Appendix A of the FEIS for chooses the alternativewith the greatest NPB as the a description of the quantified indicator of the is- Preferred Alternative sues. Append= B, Section 8 of the FEIS displays the

1-3-121 FEE Appendix I

major criteria used to compare the alternatives’ 121 5-12.1 Community Stability responsiveness to the ICO’s. PNV is only one of these criteria. Eighty-two respondents stated that a declme in harvest levels would undermine community stability, both See Forest Response to Multiple Use Comments, now and in the future. 0350 and 1300-10. Response: The Forest recognizes the importance of community stability. Community and economic stability concerns were specific considerations in the devel- Subject Area 1215 opment of the Preferred Alternative (Chapter 2, Social Considerations FEIS). The results of all the alternatives were compared to the “current situation,” that is, an average picture of the communities over recent years. The resultsof this comparison predict aslight increasein @I 21 5-01 Future Generations benefits to local communities under the Preferred Thirty-nine respondents commented on the eco- Alternative I over the present. logical and/orsocial need for oldgrowth, older trees, wildlife, streams, recreation and wilderness. The Columbia Rwer Inter-Triial Fish Commission stressed @I 21 5-03 Lifestyles - Elderly, the need for fish habitat. Many rewewers feared that Handicapped poor decisions would harm their resources for future generations. Fifteen respondents said that more consideration should be given to the elderly and handicapped. Response: (Many of these comments were made in connection The Ochoco National Forest is aware of the need to with access to Lookout Mountain, and some of the manage all the Forest’s resources with long-range comments referred to snowmobiles. Refer to these goals and objectives in mind. The Ochoco National specific discussions in the Recreation section.) Forest has attempted to meet these goals through the forest planning process, and will continue to Response: plan for the future of all Forest users, keeping in The Forest Service has been seelung to increase the mind the needs and desires of all Forest users. opportunities available to elderly and handicapped people Forest offices have been barrier-free for several years, and now barrier-free facilities are @I 21 5-02Community Stability being provided on the Forest and Grassland. Ninety-six respondents, among them the Crook The ONF has provided barrier-free day use facilities County Soil and Water Conservation District, said at the Walton Lake area. By summer, 1989, a bar- that a primaryconcern in Forest Planning should be rier-free fishing platform is scheduled for comple- the economic stability of the affected communities. tion at the lake. The Forest and Grassland Plans will provide other barrier-free trails and campsites in Response: future years. Communitystabilityis a specific requirement for the selection of the Preferred Alternative.

1-3-122 @1215-04 Lifestyles Response: The ONF compared the results of all of the alterna- Two respondents stated that firewood availability is tives to the “current situation,” that is, an average essential to their way of life. picture of the local communities over recent years. The results predict aslight increasein incomeunder Response: the Preferred Alternative (I), and the Forest can see Firewood levels wll be difficult to maintain over no reason why this alternative would cause taxes to several decades (see Chapter 4 of the FEIS for increase. details on firewood and how it relates to other activities and goals). Nevertheless, the ONF recognizes the historical, current, and future importance of firewood and will attempt to meet that need. See response to Firewood comments, 0750-01. Subject Area 1230 Budget a1215-05 Lifestyles - Native Americans @1230-01 Budgetary One respondent questioned whether the predicted effects of the alternatives on Native Americans and Concerns Hispanics would in fact occur. He stated that, in Two respondents expressed concern about the large Harney County, only five percent of Native Ameri- increase in proposed budgets over historic levels. cans were employed in wood products jobs, and a similar situation exlsted for Hispanics. In addition, Response: the respondent claimed, less than three percent of The Ochoco National Forest understands that the minority people would be affected by increased large difference between the planned budget amounts federal budgets under the EEO program. shown in the draft and the average budget levels of the past mayseem unreasonable. Those differences Response: are part of the reason that our process included the The Forest has reviewed its data and it appears that use of a “draft.” The information was a first attempt the above comments are accurate for Harney County, to figure the costs of all thevariables includedwithin and for CrookCounty aswell. Comments relating to the document for such a long time frame. In this the EEO program have been modified, and the rest effort each resource area staff was asked to provide of the predictions that were on DEIS pp. 102-103 the truecost of the total effort required to insure the regarding employment effects on American Indians highest quality products and services. Allowing for have been deleted in the FEIS. factors including federal budget levels, inflation, consumer price indexes, wage rates and emerging technological advances made some inputs hard to @I21 5-06 Taxes substantiate in the early phases. With implementation some of the figures will undoubtedly fluctuate, One hundred sixty-one respondents said that they but the experience will give the Ochoco a sounder did not want any alternative that would increase basis for comparison. taxes or decrease income. See Chapter 5 of the Final Forest Plan for Budget Proposals.

1-3-123 FElS Appendix I

sider for funding in any individual year. The long @1230-02 What if the term nature of our planning effort is really a plus in Proposed Budget Fails displayingthis range of opportunities on a longterm basis. This process is called the PROGRAM to Materialize? BUDGET. Nationally the program budget process is an incre- Sixteen letters contained comments regarding ef- mental process designed to provide the budget in- fects of federal budget practices on Forest budgets. formatlonnecessaIy to implement Forest Planswithin Several references were made to the Gramm-Rudman various constrained funding levels and/or rates of act and how it may affect funding for the Forest implementation. Each Forest submits a level known Service. In particular, the viability of non-revenue- as “Implement Forest Plan” for a specific year and generating projects such as water development, range the total need for the decade. Forests are not con- and forage production, fisheries, and trails were strained in funding; however, they must be able to questioned. Some suggested that the Ochoco at- accomplish implementation wthim current work force, tempt to maximize receipts while providing a sus- skills, and envlronmental requirements. Forests also tained yield in order to offset future budget con- submit a list of programs or projects that can be straints. foregone. This list of programs can be up to a forty percent reduction in individual years and includes Many other respondents were concemd about future an accelerated program of up to ten percent. These availability of funds. Several asked which programs would be cut orreduced if funds were not forthcom- lists are used for priority setting to develop program levels to meet Regional constraints. The Regional ing from Congress. One reference was made to Office then submits these varying levels to the Region 4 National Forests in Idaho which have a 25 Washington Office Headquarters. Typically five to percent constrained budget altemative in their DEE. seven levels are submitted. Forest plans will be It was felt that the Ochoco’s planning documents implemented to the extent practical within funding failed to consider the possibility of future cutbacks constraints and targets tied to planssubmitted to the in funding in any of the alternatives. Washington Office. Each Forest’s information goes Particular areas of concern were the budgeting of forward to the Washington OfficeHeadquarters for reforestation projects and forest recreation. use in the Explanatory Notes that are sent to Con- gress. This program is updated to better reflect the CRITFC recommended that timber and grazing national and local economic conditions each fall. quotas be tied to both budget and environmental goals, so that ifeither of the latterwere not met, the Using a broad spectrum of alternatives, long time allowable cut and AUMs would drop respectively. frames, and detailed information produces a product that negates wide program swings in any individual year, but allows Congress to adjust national Response: budgets to meet the nation’seconomic condition. In Aswith all agencies of the Federal Government, the the case of the Forest Service, Congress can do this Ochoco National Forest is subject to varying budget with detailed knowledge of economic opportunity levels based on national economicconditions. These and resource effects. budget levels are submitted to Congress as part of the program for the United States Department of SeeChapter5oftheForestPlanfordetailsconcern- Agriculture. Congress sets the final program dollar ing Budget Proposals. and output levels for all Federal Agencies. To prevent wide swings in any agency’s program, the Congress requires a range of opportunities to con-

1-3-124 @1230-03 Livestock Concerns Subject Area 1275 One individual cited an article in Fishing and Hunt- zgNews magazine which stated that the Ochoco Indian Rights National Forest’s Range Management Program loses approxmately $360,000 per year. The reviewer questioned the proposed increases in Range expen- @I275-01 Rights Adequately ditures in the DEIS in light of this deficit. Addressed Response: One respondent felt that the issues important to The figures available when the Ochoco National Native Americans hadbeen adequately addressed in Forest published its draft planning document did all the alternatives in the DEIS. The observation not contain adequate data to do accurate cost bene- was made that since less than five percent of the fit analysis. The Forest Semcebegan to address this Native American workforce is employed in timber- problem area in cooperation with the General Ac- related lobs, the likelihood was low that Native counting Office as directed by Congress in October Americans would be affected by any of the alterna- 1984. The initial effbrt is detailed in “TIMBER tives in terms of employment. SALE PROGRAM INFORMATION SYSTEM (TSPIRS), Final Report to Congress. This program Response: systematically addressed Forest Service cost centers Five percent may be the national average, but in to identify elements similar to private industry. This CrookCounty the percentageis much higher due to resulted in a financial statement that provides a the presence of Warm Springs tribe members. clearer look at investments, operation costs and In addition to the relationships between Native revenues in a short- and long-term framework. The American employment and harvest levels of the process presents a consistent depiction of the cost/ ditferent alternatives, the ONF tried to address Indian benefit relationship. This “new” tool provides an treaty rights, the American Indian Religious Free- opportunity for the Forest Service manager to in- dom Act (AIRFA), cultural resources and burial vest dollars where the greatest benefit is available. sites with the rights and interests of the Native The success of this program has led to “All Resource American community in mind. As the Forest and Accounting.” The concepts refined in TSPIRS are Grassland Plans are implemented, the ONFencour- now being applied to all resource areas. Reports ages the public to continue to assist us in meeting should be available in 1990 or 1991. treaty obligations, handling AIRFA issues, identify- Even though the returns to the Forest Service from ing cultural areas important to Native Americans, grazing fees do not cover administrative costs, the and providing input to all cultural resource manage- benefits to the local economy are deemed to out- ment activities. weigh those costs. All programs administered by the Forest Service do not necessarily make a profit, nor would it he practical to expect them to. See Chapter 5 of the Final Plans for details on budget proposals.

1-3-125 FElS Appendix I

Subject Area 1300 Response: Planning on the National Forest is directed by law Planning Comments UndertheNationalForest Management Act of 1976. Other laws relating to management of resources on the National Forest also contain provlsions that are required to be incorporated into National Forest @I300-01 Planning Planning; for example, the National Environmental Policy Act of 1969,EndangeredSpecies Act of 1973, Wild Horses and Burros Protection Act of 1971, 1300-01.I Planning in General Clean Water Amendments to the Federal Water Pollution Control Act of 1972, etc. The process and There were 59 comments on planning in general. procedures for National Forest land and resource Some renewers felt that the Forest has been man- management are described in part by Federal Regu- aged well in the past and that this planning process lations CFR part 219 -Planning, theForest Service is merely changing for the sake of change. They NEPA implementation regulations, policies, and wanted the Ochoco to find an acceptable plan and procedures; FSM 1900; and specific procedures, stick with it. policies, and guidellnes contained in Forest Service manuals, handbooks and the 1984PacificNorthwest Manyweredispleasedwith thebulkof theDEIS and Draft LRMP. They felt that the documents were Regional Guide. wordy and redundant and that the public was not The subject of planning for management of the given adequate time or notice to review the DEIS. National Forest resources is by nature a large, com- Theplanningdocuments were alsosaid to be far too plex and technicalundertaking involving manydisci- complex (especially the sections on Economics and plines and varied political, public andlegal interests, FORPLAN modeling) for the average reader to which requires dealing with a wide range of natural grasp. resource issues over time. It follows that planning Several peoplestated that the analyses were flawed, for the National Forests requires, by law and regulations, following certain procedures. Documentation or that the quality ofworkin preparing the planwas poor. Some claimed that data were omitted or con- of information, processes, results, and decisions is one of these procedures. Satisfying legal require- clusions did not follow from the information presented. ments sometimes results in redundancy and the struc- turing of documents in a manner which may not Others felt the process was adequate, and that the always contribute to ease of understanding or reada- documentswere professional andwell done. Several bility. complimented the ONF on the DEIS and Draft Given the above comments on planning document Plan. preparationand format, complexity canbe expected Some commented on the Forest Service personnel to vary based on the particular individuals, interest who worked on the plan. A few felt the document groups, or agencies rewewing them. Summaries, was a waste of money and a way to “make work” for tables of content, indices, figures, tables, andglossa- Forest SeMce employees. Others thought the Ochoco ries have been included to assist document review- could be run better wth fewer employees. Still others. Materials and documents were edited to assist ers stated that they were confident the personnel readability and reduce volume. A reviewer’s guide now in place would come to the best conclusion for was also published to assist readers. Intentions are all concerned. to continue to improve readability and understand- There were also a few comments urging a plan that ing in the FEISLMP. would benefit the majority.

1-3-126 1300-01.2 Planning Analysis 1300-01.3 Planning Six public responses, including that of the U.S. Coordination Department of the Interior, commented on the Some letters, including that of the Grant County analysis issue of the planning process. Court, stated that they would like to see more coor- Some felt that given the limitations ofcurrent scien- dination and cooperation in planning between adja- tific knowledge and computer technology, scientific cent Forests. The Grant County Court recommends uncertainty is a fact of life in National Forest Plan- that no single Forest Plan be implemented until all ning. In addition, some stated that attempting to area Plans have been finalized. combine objective, quantifiable resource data with Reviewers noted that in order for State agencies to subjectivevalues and public interests invalidates the agree on an alternative which satisfies their con- modeling They believed that subjectivevalues process. cerns, the alternative must recognize and incorpo- have no place in computer modeling. rate State objectives utilizing statewide programs Some comments indicated that the DEIS should be and policies. They feel, therefore, that the alterna- more understandable in its descriptions of modeling tive must consider the effects, on a regional basis, of used to evaluate various solutions, more explicit as implementation. to the value of linear programming in making deci- The Oregon Division of State Lands commented sions, more accessible in its use of “planning docu- that the Forest had not addressed the effects the ments” which were not provided to reviewers, and Plan will have on similar resources managed by the should use more widely accepted meanings of Eng- Stateor adjacent private lands. They stated that the lish words and phrases. Federal Government, as the major landowner in a The U.S. Department of the Interior stated that the geographical area can, with its management poli- Plan should make it clear that the development of cies, enhance or stifle the economy, or alter the new research questions and methods will, in most development of that area. cases, not be a consequence of project level identification and avoidance activities. They stated that it Response: will come largely through broad-based planning Forest Service planning is conducted on several studies, non-project survey, and data recovery proj- hierarchical levels. ARegional Guide (1984),as well ects. as a Vegetation Management EIS (1988) and other The Office of Economic Analysis stated that each plans, were prepared to give broad overall guidance Forest should circulate its alternatives for comment to planning on National Forests in Region 6. In prior to malung computer runs. This, they feel, will addition, various Forest SeMce manuals and hand- allow for a cost-effective method of examining a books exist which provide coordinating directives. wider range of alternatives. The Pacific Northwest Region conducted an “Ag- gregate Analysis” of alternative outcomes for vari- Response: ous resources based on the draft Forest Plans. This The planning process data base and modeling as- analysis dealt, for instance, with regional timber sumptions are described in detail in Appendix B of supply and provided an overview of the effects of theFEIS. Additionalinformationiscontained in the alternative courses of action. On a more local basis, Planning Records on file at the Forest Supervisor’s National Forests did coordinate on location of Office in Prineville, Oregon. management area boundaries and development of certain standards and guidelines.

1-3-127 FElS Appendix I

Agreat deal of attentionwas given to consistency in @I 300-02 Monitoring/ dealing with certain issues between adjacent For- ests. Other agencies, such as the BLM and Bureau Implementation/Mitigation ofReclamation,were involved throughout the proc- Several respondents, including the U.S. Environ- ess. mental Protection Agency, indicated that the For- Finally, theForest has worked closelywith the State est’s monitoring system was not intensive enough. of Oregon and other agencies in the development They suggest that it be more frequent than once and selection of a final alternative. This involved a every three to five years if the habitat for wildlife and great dealof coordination and interactionwith State anadromous fish is to be protected before signifi- Agencies and the Governor’s office. The Gover- cant damage occurs. nor’s office provided a State-wide view for the proc- Some, including Governor Vic Atiyeh, suggested ess. that the definition of monitorrng be improved by adding a clause that will indicate certain deviations as a trigger for revision of management practices. 1300-01.4 Planning Others, among them the Oregon Water Resource Coordination Department, remarked that there is no timeframe for the measurement of riparian improvements and The Columbia River Inter-Tribal Fish Commission that aspects of the Plan which pertain to meeting noted that the Forest Service coordination with Federal or Statemandated standards or regulations Pacific Northwest fisheries enhancement activities should be mentionedso the publicwill bebetter able is required by law, and that the Ochoco National to monitor the results of the program. Forest DEIS and proposed Plan do not reflect the consideration of these processes required by the The revlewers suggested that the monitoring and NFMA. evaluation program of the Forest Plan should be expanded to provide greater detail by species and The Commission further suggests that, to adequately monitoring objective. In addition, some felt that assess the environmental impacts of its actions as threatened, endangered and federally listed species required by NEPA, the Forest Service must study should be added as an action and effect to be moni- and disclose the cumulative impacts of all 17 Forest tored. Plans in the Region on the Columbia River anadromous fish runs and the four Columbia River treaty Many, among them the State Forester, stated that tribes. theOchoco had provided averygoodframeworkfor its monitoring and evaluation plan. However, they felt the plan needs to be improved in the following Response: areas, funding of the monitoring process, flexibility The Forest Service has coordinated its planningwith of the plan to accommodate growth factors when the Columbia River Inter-Tribal Fish Commission they are greater than forecasted, and monitoring of (CRITFC). The Ochoco National Forest and Crooked logging operations. Rwer Nabonal Grassland are involved with the Forest Service’s “Rise to the Future” incentives, and the Others felt that compliance withstandards andguide riparian and wildlife habitat improvement projects lines or management prescriptions is generally not scheduled in the Plan reflect this. The ROD specifi- monitored, and that the public will not be able to tell cally mentions theForest’s agreementwith CRITFC if the Forest Service is trying to meet Plan objec- to involve them early on in the scoping phase of tives. In addition, they stated themonitoring plan, as projects potentially affecting anadromous fisheries. presented, will not accomplish its presumed objective because monitoring compliance with many LMP objectives is not addressed.

1-3-128 One person indicated that the monitoring surveys Themajor concern of the respondents seemed to be should be conducted by independant technicians that the Forest Service implement a plan with the under contract in order to insure the highest level of needs of the majority in mind. impartiality. One individual suggested that the Ochoco combine the best policies of forests all over the world into its Response: program. Monitoring is required under NFMASec. 6(8)(l)(c). Themonitoringprocess isdescribedinChapters5of Response: the Plans. The environmental analyjis (NF,PA) prows Under the requirements of the National Environ- is tied into the monitoring and implementation mental Policy Act (NEPA) and the National Forest program. This process provides for public involve- Management Act (NFMA), a range of alternatives, ment.Significantamendment orrevision to the Plan which might realistically be implemented, is required as a result of monitoring will include public involve- to be considered. Eleven such alternatives were ment and publication of a decision notice. analyzed in the draft (DEIS); in addition, another alternative was presented in a Supplement (SEIS) to thedraft. Representedwere arangein alternative @I300-03 Management management plans, from intensive timber manage- Strategies (Alternatives) ment to emphasis on noncommodityresources with reduced timber yields. Other alternatives attempted There were 91 letters with comments concerning to portray a more “balanced mix” of resources and alternatives in general. Most respondents expressed outputs. Three alternatives incorporated “depar- displeasure with either the number of alternatives tures’’ from even-flow of timber. The departure or the range of resource outputs in the alternatives. alternatives maintained high levels of timber supply Some felt that eleven alternatives were far toomany for the forest product industry during the decade to and confused the issue. Others were unhappy with follow. the major discrepancies between the Forest Service The complexities of planning requirements, and the alternatives and those proposed by private industry. difficulty and frustrations in understanding the al- These respondents wanted an alternative that em- ternatives, are reflectedin the above range of public phasized timber yields and commodity outputs. comments (also see comments under 1300-1 Plan- Others asked that the Forest SeMce not allow har- ning). Likewise the Forest Service’s problem of vest levels to determine management strategies. attempting to meaningfullyapply publiccomment in They recommended that the Forest be managed decision making is demonstrated by the range of with an emphasisonwildlife and biologicaldiversity. responses above. Comments specific to particular Many of these respondents expressed disappoint- alternatives are addressed under other 1300 head- ment wth what they considered the narrow focus of ings. the planon timber and beefproduction. Somestated In the Final, the Forest Service has reduced the that any Forest Service alternative would be better number of alternatives considered in detail. Alter- than an alternative proposed by the timber industry. natives in the Draft, which received little, if any, Most respondentssimply stated that the alternatives publicsupport or interest, have been treated under failed to satisfactorily deal with the issues and that asection of the FEIS entitled, “Alternatives consid- they could not support any proposed alternative. ered, but eliminated.” (See FEIS Chapter 2.) Six Some, however, were pleased with the way the is- alternatives are analyzed in detail in the Final. The sues were responded to in the DEIS. decision to present the six particular alternatives in the Final is based on NEPA requirements, legal considerations and public input.

1-3-129 FEIS Appendix I

The Final Preferred Alternative, Alternative I, is a Response: new alternative. It represents an amalgamation of Alternative B in the Draft Plan and DEIS was de- new information, parts of thedraft alternatives, and signed to attempt to meet Regional Guide 1980 incorporation of public comment. The formulation RPA timber and range program targets. The alter- of the Preferred Alternative involved changes which native’s focus was on intensive management for were primarily in response to public comment (see timber and range, but other resources were man- Chapter 2, FEIS). The Final Preferred Alternative aged at minimum levels. To meet the RPA target all is within the decision constraints for alternatives as available forested lands were planned to be man- identified in the DEIS. aged intensively for timber production in this alternative. In addition, another similar alternative was developed - Alternative B-Departure. It was found @1300-04 Management that even with departure harvest, neither altema- Strategies (Alternatives B+, B, tive could meet 1980 RPA timber targets for all 50 years while simultaneously meeting other RPA ob- B-Departure, B-Modified) jectives. With the exception of Alternative H-De- There were 106 comments on Alternatives B, B- parture, Alternatives B and B-Departure offered Departure, and B-Plus (the timber industry alterna- the greatest timber yields of any considered in the tive). Draft. The vast majority of the respondents indicated a The forest products industryused Alternative B as a preference for Alternative B-Plus on the grounds basis for its own plan, called Alternative B-Plus. This that it emphasized timber and commodity produc- alternative was strongly supported by the timber tion. They felt that only B-Plus would permit the industry lobby and local communities through form economy of Central Oregon to survive. letters and organized efforts (see Public Comment Analysis, Appendix A). A few were opposed to B-Plus because they felt it would deplete the resources in the region, damage Timber industry officials and personnel of the Ochoco the environment, and reduce big game populations. National Forest met and formulated a modified B- Plus alternative, calledB-Modifiedin theFinal Plan. Some Preferred Alternative B, feeling it offered a B-Modified is an amalgamation of parts selected by balance between commodity and amenity produc- industry from Alternative I and Alternative B. It tion. represents an entirely new alternative and is fully A feyrmmmended B-Departurewith amendments addressed in the FEIS and Final Plan. In reality, to balance near- and intermediate-future timber industry’s final version of Alternative B-Modified is yields and to ensure strong emphases on community more closely related to Alternative I than to Alter- stability. native B. The Crook County Soil and Water Conservation In terms of numbers alone, Alternative B-Plus re- District suggested the Ochoco implement a combi- ceived themost positivecomments. This was a result nation of Alternatives B-Plus and E-Departure. of intensive organized efforts by the forest products industry. The questionable aspects of this alterna- Someexpressedconcern that the formletters sentin tive, and its poorly developed nature (except for the by those preferring the timber industry’s alternative section on timber harvest) were recognized by the (B-Plus) would receive less consideration from the industry, as ewdenced by the formulation of Alter- Forest Service than would other forms of response. native B-Modified in the FEE.

1-3-1 30 None of the B alternatives discussed above (B, B- tion organizations and indiwduals. There are envi- Departure, B-Plus) were selected for the reason ronmental benefits associated with alternative C, that, while they provided high short-term economic but implementation could be only done with very benefits, they did not represent balanced or equi- high costs and radical change to established local, table resource mixes and they had potentially unde- social and economic settings In the Forest’s opin- sirable environmental and socioeconomic effects ion, Alternative C does not provide a balance be- over time. Options would be reduced with the adop- tween environmental considerations and the eco- tion of any of these alternatives and the risk of nomic realities of dependent communities, and there- irreversible environmental effects was high. fore was not selected. It is presented in the FEIS as one of the final alternatives after being modified to See Chapter 1of this appendix and 1300-17 Public include uneven age management and legislated Involvement Responses in this chapter for Public Participation information. changes such as classified Wild and Scenic Rivers.

@I300-05 Management @I300-06 Management Strategies (Alternative C) Strategies (Alternative D) Many respondents favored Alternative C because A letter was received from one respondent suggesting that Alternative D comes the closest to true they felt the reduced harvest levels would help heal multiple use and protection of basic resources. the land from the many years of overbarvesting. Also, many felt that this altemative best protects the Forest’s natural values, such as riparian areas and Response: wildlife, and would decrease the harmful effects of Alternative D emphasized fish and wildlife, espe- grazing. cially big game. Timber and range outputs were significantly reduced, as was scenic and unroaded Some felt that this Alternative would provide a recreation. In emphasizing one resource, wildlife suitable mix of recreational and commercial uses of habitat, the alternative failed to incorporate other public lands. Furthermore, many stated that this resource management opportunities. Reasons for Alternative comes closest to meeting NFMA re- nonselection were similar to those described under quirements. Alternative C Many felt that this alternativewouldmaintain steady Old Growth. Reviewers said that Old Growth is a unique resource, and should be protected until fully @1300-07 Management understood. Strategies (Alternatives E, E- Some opposed Alternative C because it would limit Departure) commodity production and would cause undue stress and hardships on local communities that depend on Some respondents favored Alternative E because the timber production. they felt it reflects a wise allocation of land, good objectives and sound management practices. They Response: alsonote thatit preservesgreater than97percentof Alternative C was the conservation community’s the employment base and provides a lessened long- Preferred Alternative. It emphasized amenity or term economic impact on local communities while non-monetaryvalues. A newspaper flier supporting still protecting the natural environment. this alternative was widely distributed by conserva-

1-3-131 FEIS Appendix I

Many respondents Preferred Alternative E over E- vides the best basis fromwhich tocreate theForest’s Departure because they felt it meets the overall and the State’s Preferred Alternative. However, environmental needs prudently. Some felt that any they noted that Alternative G needed some revi- departure from even-flow would cause long-term sions to make it a more useful alternative. These social, economic and environmental impacts. included retaining current levels of timber harvest Some, including Richard Kuczek, Labor Market for a stable local economy; improving riparian zone Economist for Wheeler and Grant Counties, stated management,wildlife habitat and livestock manage- that they favored Alternative E-Departure on the ment conditions; compliance with approved State grounds that it provides fairly high levels of non- and Federal plans for air and water quality stan- market resources while maintaming current timber dards, and maintenance of the current levelof semi- primitive motonzed and non-motorized recreation harvest levels for the first decade. trails as presented in Alternative E. Others, including Governor Victor Atiyeh, opposed Alternative E-Departure because they felt it does Response: not reflect a real balance between environmental Alternative G was the State of Oregon’s original concerns, recreation and the economy. In addition, preference for an alternative among those displayed they suggested that it is not compatible with State in the draft subject to the above modifications. Smce goals and does not maxlmize net public benefits. then the Forest Service has continued to work closely Some people stated that this alternative avoids and incooperationwith thestate to assure that both controversial decisions by proposinga massive over- agencies are in accord with the Preferred Final utktion of the Ochoco’s resources whichwill result Alternative. in a future crash where Forest utilization must be drastically decreased to allow recovery. The State developed its own alternative and held publicmeetings in April 1989. Therewere no signX- A few indinduals opposed Alternative E because cant differencesbetween the State’s alternative and theyfeltitistooextremeandbenefits theForest, but the Forest Service Alternative I in the FEIS. not the people who use it.

Response: @1300-09 Management Alternative E-Departure was the draft Preferred Alternative. There was strong public opposition to Strategies (Alternative H) departure (see response to Timber Comments, 0700- Some public respondents favored Alternative H. Ol).Nearlyallsegmentsofthepublicfelt that depar- They claimed this alternative has the best mix of ture harvest was inappropriate. Using the public timber, wildlife, water and recreation. Some also felt comment, new information, and additional analyses, this alternative provided the most use for the most the Forest Service created Alternative I - the Pre- people while maintaining natural resources. ferred Alternative in the Final Plan. The changes and reasons for change are summarized in Chapter Response: 2 of the and Section 4 of the ROD. FEIS Alternative H emphasized management of timber and range resources in a manner that yelded the greatest economic returns with minimum attention @I300-08 Management given to other resources. It did not represent a Strategies (Alternative G) balanced mur and was rejected in the selection of a final for reasons similar to those given under the A fewrespondents, particularly thestate of Oregon comments on the B alternative. in its original response, felt that Alternative G pro-

1-3-132 @1300-I 0 Management Other recent legislation, such as the Oregon Wil- derness Act and the Oregon Wild and Scenic Rivers Strategies (Multiple Use) Act, both affecting the Forest and Grassland, are There were 363 comments conceming Multiple Use. further examples of changes that have taken place which the Forest Service, in order to act responsibly, Many felt the Ochoco has been managed primarily must respond to. New information on Forest refor the timber and cattle interests and that commod- sources is available, and the Forest Service is re- ity production should be secondary to environmental quired to update its plans for timber management and recreational concerns. These comments favored everydecade.Thesearebut afewexamplesoftbings minimaldevelopment and greateremphases on Fish that have changed or continue to change. National and Wildlife and other nonconsumptive uses of the Forest and Grassland management is not static. Forest. Planning and management are required to be flex- Others were of the opposite opinion. They felt that ible and dynamic. commodity production should be stressed on all Second, the Plan and FEIS alternatives represent available acres. They commented that the Forest different ways the Forest and Grassland may be shouldbeopen forpublicuse, notclosedasaprivate managed. Different resource mixes, emphases and playground Some cited the Multiple Use Sustained outputs are reflected by the alternatives. In the Yield Act and a requirement for the maintenance of selection and preparation of the FEIS, the ONFhas aviable timber industry. Others stated that, in order attempted to take a multiplicity of factors and con- to serve the greatest numbers of people, commodity cerns into account. In theForest’s judgement, Alter- outputs had to be stressed on the Ochoco. native I represents a “balanced mlx” of resources, Still other respondents expressed the desire for a emphases, and outputs for the Forest and Grassland balance between commodity and amenity outputs. that is truly a multiple use alternative. It is certain Some of these indiwduals stated that past Forest though, that not every interest group or user group practices have been adequate and should not be will be satisfied. Most will demand more, such is the changed. Some stated that some harvest is accept- nature of allocation of resources on publlc lands. able, but clearcutting is not. However, making those demands under the auspices of “multiple use” is a corruption of the mean- Response: ing and intent of multiple use management. The issue of definition and application of multiple use is addressed in response to comments under 350-Multiple Use. @I300-1 1 Standards and The above comments raised two other commonly Guidelines expressed viewpoints relating to multiple use man- Some felt that the Standards and Guidelines were agement strategies and planning: 1) don’t change well thought out and very implementable. things, keep them as they are; and 2) management, or the Plan, is biased toward timber and range. Several respondents stated that Standards and Guide- lines have two separate and distinct meanings. In First, the Forest Service is required by law - the addition, they felt these meanings are not carried National Forest Management Act of 1976 - to pre- over into the Plan, which gives no indication as to pare plans for the management of the National which requirements are mandatory standards and Forests. The regulations or requirements for those which are non-mandatory guidelines plans require that certain alternatives be considered, furthermore, certain things are required to be Some stated that meadow protection was not ade- done differently than they are in existing plans to quate and that the subjective guidelines were not meet the intent of the law sufficient.

13133 FEIS Appendix I

According to the US. Environmental Protection of the Ochoco, the domlnance it would be accorded Agency, the annual budget will influence the level of in this allocation violates multiple-use management projected outputs and Plan implementation. How- requirements. ever, they feel that certain categories of activities Somestated that Management Area 1 isnot suitable should not be excluded at the expense of others. In for the Ochoco National Forest because it empha- particular, they felt the mitigation measures and sizes the rights of the cattle and timber industries Standards and GuideIines designed to protect or while minimizing the rights of the public at large. enhance resources should not be tabled while other Some expressed concern that too much Manage- goals are met. ment Area 1 would mean too much clearcutting and Some doubted, based on the current economic situ- too much -grazing. - ation and past project costs, that very many projects Afew reviewers suggested the Forest needs to rec- would be cost effective over the long term. Others ognize the unportanceof the roaded “General Forest” felt, however, that it is quite possible such projects area for recreation and establish guidelines to man- may be necessary to mitigate some of the other age for this. negative effects which will appear as the character of the Forest lands change. Response: Response: In the Final EIS, the Forest has continued a similar allocation termed MA-22 General Forest Under Standards and Guidelines, and management area requirements of the NFMA, “suitabdity” is a factor prescriptions, are given in Chapters 4 of the Forest that must be considered in planning and allocation. and Grassland Plans. There are numerous direc- For the ONF, 533,177 acres have been determined tional statements in the Plans representing Stan- to be suitable, as per for timber manage- dards and Guidelines, which deal with all resources. ment purposes. About 93 percent of this area has The distinction between a standard being an abso- been allocated to General Forest [MA-22) in Alter- I lute or mandatory requirement, as compared to a native I, subject to requirements to provide protec- guideline, has not been made by the Forest Service. tionofotherresources. Theserequirements havean estimated opportunity cost in terms of allowable The “MR’s,” or Management Requirements, are sale quantity (ASQ), which contradicts the above standards or guidelines which deal specifically with comments and assertions that the General Forest is NFMA requirements. They are the ways that the being managed to the exclusion of other multiple legal requirements of NFMA have been incorpo- use values. rated into the planning process. The distinction is thatstandards andguidelines areestablished tomeet Refer to 350 Multiple Use and 1300-10 Manage- management objectives, whereas management re- ment Strategies comments (the converse of those quirements carry the additional necessity of meeting represented here) and theForest Response to those NFMA legal requirements. This is described in de- comments. tail in Appendix F of the FEIS. @I300-1 3 Environmental @I 300-1 2 Management Areas Effects/lmpacts (MA 1) Some comments indicated that with population growth Many respondents stated that they oppose the in- and resulting heavier recreational use of the Forest, clusion of any National Forest lands in the Draft conservation becomes increasingly important for Management Area 1 prescription. They suggested both economic and social reasons. that, while timber production is an appropriate use

1-3-134 ,

Others stated that they have watched the National several important issues, contrary to NEPA regula- Forest being destroyed year after yearwith an “irre- tions. versible, detrimental impact” due to lazy manage- Several respondents felt the DEIS should have in- ment and poor conservation practices. cluded objective guidelines describing the analysis Some noted that they felt the goal of a management criteria which will be used to determine whether a plan should be no degradation of the resource. resource management activity will require a cate- Others noted that the DEIS should reflect a more gorical exclusion, an environmental analysis, or an environmental impact statement to comply with conservative approach to irreversible commitments of National Forest resources. They felt that un- NEPA. avoidable adverse effects vary by alternative and A few people indicated that, from a procedural should be compared as objectively as possible in the standpoint, the DEIS was inadequate in several DEE. Also, they felt the irreversible commitments areas, includingunavoidable adverse environmental of theDEIS should acknowledge that the adoption effects, short term uses of the environment and of a departure alternative is an irreversible commit- maintenance of long term production, and irrevers- ment of future options. ible commitment of resources. Response: Response: In the preparation and selection of a final alterna- A full range of Alternative plans were analyzed me, retaining options and minimizing environmental through theNEPAprocess-12in theDEIS and6in effects (particularly irreversible and irretrievable the FEIS. The environmental consequences and ones) were taken into consideration. The effects of comparisons of alternatives were analyzed in detail the proposed action and alternatives on the envi- in Chapters 4 and 2 respectively. A full range of ronment have been taken into account throughout alternatives €or each resource activity, such as ORV the planningprocess in alternative formulation, and use or grazing, was not investigated. However, a allocation selection, Standard and Guideline devel- “benchmark alternative” with minimum levels of opment, and in mitigation and monitoring proce- grazing and other resource uses was formulated and dures (see Chapters 4 and 5 of the Final Plans). used in the analysis process. The planning process Adverse effects that cannot be avoided and irrevers- was issue-driven, and alternatives, allocations, and ible and irretrievable commitment ofresources were standards and guidelines were developed to address dealt with in the FEIS Chapter 4. the issues identified. The Plan is intended to be programmatic in nature, and as such it generally does not deal with project specific decisions. @1300-14 NEPA, NFMA, and The process and documentation for preparing the RPA Comments, MR’s Plans closely followed the NEPA and NFMA requirements. Worst-case analysis generally relates to proposed 1300-14.1 NEPA Requirements projects or actions that are specific or singular in nature. For the multiplicity of issues addressed in Several respondents indicated that the Draft Man- theForest and Grassland Plans this is simplyunreal- agement Plan andDEISwas not in compliancewth istic. Worst-case analyses are generally not con- either NFMA or NEPA. One indicated that the ducted in Forest planning unless specific issues emerge DEIS does not present a worst-case analysis as is where such analysis is necessary or implied. No such required by NEPA regulations. issues were determined to exist for the Forest or Some remarked that the draft document fails to Grassland. present a full range of alternatives in regard to

1-3-1 35 FEIS Appendix I

1300-14.2 NFMA, Management tion alternative. The respondent felt that this does not allow the publrc an opportunity to make an Requirements unbiasedcomparisonto determine the true resource Many reviewers felt that the Forest needed to pro- trade-offs and resulting economic losses or gains. vide sufficient background to explore various ways to mitigate projected harvest reductions and that Response: the Plan should discuss the individual impacts of The Forest prepared and displayed two “no action” each Management Requirement. alternatives in the draft--Alternative A and “Cur- rent Direction with NFMA.” In the Supplement to Some felt that the “minimum” Management Re- the DEIS the Forest described still another “no quirements in the Plan were more like “maximum” action” alternative which was a continuation of requirements and should be revised to be realistic management under existing plans, particularly the and show a minimum need. In addition, some said 1979 Timber Resource Plan. The latter alternative they were unable to find where Management Re- is not implementable, since it does not incorporate quirements MRs are described in full or summary all legal requirements. The No Change Alternative form. has also been described in Chapter 2 of the FEIS. A few felt that the EIS alternatives did not include variations ofh4R’s. In addition, many felt the Forest must look at a range of alternatives for MRs. @I300-1 5 National Grassland Some commented that the Forest should have ex- Management amined altemativeways to achieve theobjectives of the MR‘s in the most cost-efficient manner. 1300-15.1 Grassland Plan Response: Management requirements that are specified in Many felt the Forest and Grassland should not be NFMA were discussed and analyzed In the draft in included in the same long-range plan. Some felt the the DEIS Appendix B, pages 59-61. Additional in- Grassland should be separate as it is almost com- formation and analyses on management require- pletely a forage producing area with very little tim- ments were also given in the Supplement to the ber. DEE, pages 17-34. In these analyses, alternative ways to achieve the requirements or objectives, and Response: the opportunity costs in timber yields, were exam- The Forest Service recognizes the validity of the ined and displayed. Detailed information on man- above comments. There are some good reasons to agement requirements is presented in Appendix F treat the Forest and Grassland separately. of the FEIS. Some of the laws and requirements for management of the National Grassland are different from those for the National Forest, and the resources on the 1300-14.3 No Change Forest and Grassland are also different. The Na- Alternative tional Grassland and its management were over- shadowed by the National Forest in the Draft. Spe- One person noted that NFMA requires the devel- cifics for the Grassland were difficult to separate opment of a “no action” alternative, and that the from those of the Forest in the documents. Impor- Region, including the Ochoco National Forest, has tant resources and uses occurring on the Grassland chosen to include new scientific information and weresimply overlooked in theDraft. TheDraft Plan “management requirements” in the current direc- recognized only eight management units or areas for the Grassland; the Final Plan now recognizes 15.

1-3-136 Two separate plans have been prepared in the Final, resource values and management occurring on the one for the Grassland and one for the Forest. The Grassland. two plans and processes for their development are treated under a single EnvironmentalImpact State- ment and Record of Decision. @1300-16 Analysis (FORPIAN) 1300-15.2 Grassland Management 1300-16.1 FORPLAN Many respondents felt that the Crooked River One comment questioned the analysis used in the National Grasslands is a unique resource deserving planning process. This respondent stated that the of multiple use management. However, they felt the information needed by the public to evaluate the grassland is managed mostly for cattle grazing and validity of the FORPLAN calculations was not pro- should be managed to provide wildlife and all other vlded in the DEIS and suggested that the FEIS resources. provtde a more understandable explanation of how Some felt that the Grassland has a long way to go linear programming was used to influence. planning before it returns to its natural balance. However, decisions. others felt that at present the Ochoco National The respondent asked that the EIS identi@ the Forest and Crooked River National Grassland IS, objective constraint values used and the validation managing the grasslands reasonably well. for their use. He pointed out that only a few model- In addition, some commented that the livestock ing constraints were quantified or objectively de- industry pays for the usage of the Grasslands, not fined in the DEIS. only through grazing fees, but by water and land He also suggested that the EIS contain a “bench- developments which help the entire multiple use mark” which drives the linear programming model program. to minimize “unavoidable adverse impacts.” Response: This respondent also addressed the size and effi- ciencyof analysis units.Thequestion ofwhethera3- Nationalgrasslands areestablished under the provi- acre analysis unit could be efficiently managed, or sions of the Bankhead-Jones Farm Act which re- managed at full intensity, was raised. quires management to maintain and improve soil andvegetation cover, and todemonstratesound and Finally, the respondent suggested that the way in practical principles of land conservation and mul- which the weaknesses of the computer models were tiple use (36 CFR 213.1). This law applies to the overcome should he explained in the EIS. Grassland only, not the National Forest. Other laws affecting the management of public lands and re- Response: sources also apply to the Grassland. There is no legal requirement to develop detailed The National Grassland has a complex ownership documentation of FORPLAN models so that the pattern. Resourcesare frequently managed incoop- public could review and interpret all outputs, calcu- eration with State and other Federal agencies. The lations and options used. Documentation of this Final Grassland Plan has 15 management areas, nature presently exists in the FORPLAN Users which reflect a diversity of uses, resources, and Guide and Mathematical Programmer’s Guide, which management prescriptions, in order to attain or are available for review in the Ochoco National maintain desired future conditions. The Plan deals Forest Supervisor’s Office. Probably the best means with all resources, and truly reflects the multiple of communicating information of this sort to inter-

1-3-137 FEIS Appendix I

ested publics would be through small group meet- These types of constraints are documented in ings rather than through additional technical docu- “FORPLAN Version 1: Mathematic Programmer’s mentation. Guide,” which is available for review in the Ochoco The usefulness and appropriateness of FORPLAN National Forest Supervisor’s Office. and other linear programs is well documented. Ex- Benchmarks were used in the planning process to cellent reviews of FORPLAN can be found in establish the maximum and minimum resource out- “Proceedings of the Workshop on Lessons from put levels. This range of output levels defined a Using FORPLAN,” and “The Genesis of “decision space” in which a range of altematives FORPLAN.” Dennis Teeguarden, in his paper, addressing the ICOs was developed. Thus, it would “FORPLAN: An Evaluation of a Forest Planning be difficult to develop a benchmarkwhich measured Tool,” stated: adverse impacts. Because the term “adverse im- A simulation or optimizing model such as pact’’ is somewhat subjective, the decision as to FORPLAN, creatively used by knowledgeable which alternative best meets this criterion would be based on individual preferences. persons, provides a powerful tool for Forest planning. However, the nature of the planning The basic units used in FORPLAN are referred to as problem makes it unlikely that any single model analysis areas. They represent aggregations of many will ever satisfy all the requirements It is proba- individual non-contiguous mapping units with iden- bly best to think of the planner/decision-maker tical delineators. The mapping units which make up as operating in an ennronment of several differ- an analysis area are considered homogeneous in ent models or processes. Some, such as terms of costs and yields (See Figure B-3-1 in the FORPLANor input-output models such as IM- Appendix B of the FEIS). Without reference to PLAN, d be quantitative and objective in nature, these individual units, analysis areas, and therefore while others are qualitative and subjective. FORPLAN analyses, lose site specificity. Thus, it is useful, if not essential, to have a computer Appendx B describes the major Ochoco National system that canprovidea frameworkwithinwhich to Forestplanningproblems in relation to the inherent address the analytical requirements of both NFMA weaknesses of linear programming. A summary of and NEPA There are limitations and weaknesses the analyses undertaken to help remedy these short- associatedwith all models, and no model is a perfect comings is included. representation of reality. As a result, they must be used and interpreted wth care. The bottom line is that any model is just a tool. The decision makers 1300-16.2 Present Net Value must use various tools and professional judgement in managing the Forest. One comment expressed the concern that while Present Net Value (PNV) calculations seem to be There is no requirement to display the value of the major influences on FORPLAN outputs, they are constraints used in the FORPLAN model. Only the not responsive to the ICOs. This respondent re- purpose andeffect of aconstraint mustbediscussed. quested that the relationship of FORPLAN PNV Constraintvalues are included in the FEISwhen this calculations to the national concern of economic helps in understanding the purpose or effect of the efficiency be addressed in depth. The concern was constraint. also expressed that PNV does not address the na- Some constraints (for example, Legal Policy and tional interest of ensuring that theForest and Grass- Management Requirements #1 and #2) are inter- land is managed in a financially prudent manner nal to the FORPLAN model. These constraints while the quality of the physical environment is were comprised of complex mathematical formulas protected and enhanced. and would be of value to only a few individuals.

1-3-138 Response: 1300-1 6.4 FORPLAN Analysis Economic efficiency is a major planning criteria addressed in NFMA and its implementation regula- One comment addressed the marginal effects on tions. The major use of PNV is not the control of “willingness to pay.”The respondent stated that the FORPLAN outputs, nor is it directly related to value of an output should be greater in alternatives KO’s. PNV is used 1) to ensure that scheduled that produce less of that output. For example, the activities and practices arecost effective, 2) toselect respondent felt the value of semiprimitive, nonmo- the most efficient activities and practices to achieve tor& recreationvsitor days (SPNM RVD’s) should a set of goals and objectives, and 3) as one of the be higher in Alternative E than in Alternative C, decision criteria in deciding which alternative best because Alternative E produces fewer SPNM RVD’s maximizes Net Public Benefits. Similarly, it was felt that the value of timber should be greater in Alternative E than in Alternative B. Thus, PNV does not directly relate to the quality of the physical environment. Instead, Standards and Response: Guidelines are used to protect and enhance the The Ochoco National Forest and Crooked River environment Only if a practicewas built into or left National Grassland used a horizontal rather than a out of an alternative due to high costs or the cumu- downward sloping demand curve in its analysis. In lative effects of selection of cost-effective practices other words, regardless of whether the Forest offers would PNV indirectly interfere with maintaining or one board foot or one million board feet of timber, enhancing the environment. oroneSPNMRVD orone thousandSPNMRVD’s, the value per unit of output will be the same. Eco- nomic principlesdo suggest that supply and demand 1300-16.3 Tradeoff Analysis for a-given product w~llinteract in the marketplace One comment addressed the use of tradeoffs in and influence price. However, the Ochoco National FORPLAN analysis. The respondent interpreted Forest is only one supplier. Therefore, the derived tradeoff as meaning a positive or negative change in demand for any one product also depends on the PNV and ASQ, and objected that increases in PNV supply of that product from other sources. or ASQ are actually benefits, not tradeoffs. He also The assumption made for timber is that the demand pointedout that anumberof tradeoffs, includingbig for timber is great enough to consume any quantity game numbers, RVDs, fish numbers, riparian habi- that the Ochoco National Forest could offer. In tat, water quality, andsoil retention, were not evalu- addition, the Ochoco National Forest will have a ated. minimal influence on current prices because of the mobility of logs and timber purchasers and the re- Response: sponse of other owners to opportunities created. Appendix B does consider tradeoffs involving crite- The value of an output wdl not vary between alter- ria besides PNV and timber outputs. Increases in natives when supply exceeds demand. This is the PNV and ASQ are benefits, not tradeoffs. This has case with SPNM RVDs in Alternatives C and E for been clarified in the FEIS. the first and second decades. Appendix B analyzes the effects of major resource objectives on PNV and ASQ. It is correct that the effect of raising or lowering PNV or timber volume 1300-1 6.5 Opportunity Costs on other resources is not displayed in a similar fashion These effects are disclosed in Chapters 2 One comment addressed opportunity costs. The and 4 and in Section 8 of Appendlx B of the FEIS. respondent pointed out that the DEIS did not explain how the opportunity costsweregenerated, nor did it address opportunity costs in terms of other

13139 FEIS Appendix I

resourcevalueslost for eachincrementalincreasein @I 300-1 Public Involvement PNV. 7 Response: 1300-1 7.1 Administrative The explanation of how opportunity costs were generated has been included in Appendix B, Section Appeals System 7 of the FEIS. One respondent stated that the environmentalists Appendur B displays all tradeoff comparisons and will be forced to use legal and other coercive meth- sensitivity analyses required by Regional and Na- ods to handle what should have been addressed in tional direction. Opportunity cost analysis for re- the planning process. sourcevalues based on incremental changes was not performed. Response: It has been the intent of planning analysis to define Within the newly revised Administrative Appeal resource output decision space and to identify the procedures, (CFR36-217andCFR36-251 Febru- significant opportunitycosts associated with various ary, 1989), opportunities for negotiatinghediating legal, policy and discretionary constraints imposed public concerns of line officer decisions is encour- in the process of formulating benchmarks and alter- aged. In addition, the appeal procedures continue to natives. Because of the uncertainty of basic data provtde a formal review of these line officer deci- such as production coefficients and future prices, a sions. Individuals still not satisfied can seek relief good deal of sensitivity analysis and trade-off analy- through the judicial system. sis has heen incorporated in the FEIS. The purpose of such analyses has been to provide information that can be used to explain the PNV differences 1300-1 7.2 Administrative between alternatives and to identify the implica- Appeals tions of using uncertain information in decision System malung. Because of the time pressures involved in The Grant County Court expressed the feeling that Plan completion schedules and the overwhelming anyone who has the opportunity to participate in volume of potential analysis that could be conducted, this planning process, and does not, should not have efforts have been focused on providing the public the option of appealing and holding up the implem- with relative opportunity cost information where entation of the Plan. To allow this, according to the major resource trade-offs occur. Court, is essentially to say that the planning process PNV is dependent upon the interactions of all priced is not sufficient, and negates the purpose of having and non-priced resource outputs, not the other way a Plan in the first place. around. In order for PNV to vary, one or more of the resource outputs must vary. Response: The USDA Forest Serwce’s Administrative Appeal The Forest has examined and displayed the type of procedure is a process open to all American citizens information which might address this concern in a to ensure that they have an opportunity to formally more quantitative and objective manner. For ex- contest line officer decisions. Under the revised ample, Section 8 ofAppendurB displays some of the appeal regulation (February 1989), the appeal of keynon-pricedoutputsalongwithPNVofthealter- individuals who have not participated in the plan- natives. It also displays the PNV and certain priced ning process or the discussion of pertinent issueswill and non-priced outputs both as an absolute value not be given the same merit in an administrative and as a percent of the maximum. appeal as those who have participated in such processes

1-3-140 1300-17.3 Public Information The push for cooperative funding and/or staffing of programs previously sponsored solely by govern- Some respondents recommended that the ONFstart mental agencies alone is well understood by the aneducational programin theschools, similar to the National Forest and the Ochoco has been working Smokey Bear program, to teach children that the very hard to promote cooperative partnerships. public domain is for everyone to enjoy and that all groups must work together to keep it beautiful, productive, clean and available for all. 1300-17.4 Public Involvement One reviewer felt that the Forest needs to get more Methods people involved in the management of the forest through stewardship programs, meetings, vldeos and One person felt that an issue of this magnitude environmental education news items. requires theForest Service to actively pursue public comment by malung contact not only with interest Response: groups, but by makmg the entire process more vis- The Ochoco National Forest has sponsored several ible to the people it will affect the most. environmental education activities involving school Some respondents felt that the Forest should listen age children. The 1988 Crook County Fair included to a broad spectrum of citizens, not just from those an educational program involving twelve different who are supporting special interest groups. organizations and agencies, entitled “Safety Town,” which was visited by over 400 children and their Response: parents. The Forest also has coloring contests and The Ochoco National Forest and Crooked River Learning Tree instruction activities with school age National Grassland have held over thirty meetings children. The Forest’s Smokey Bear fire prevention with the public, involving individual citizens as well program and Woodsy Owl anti-vandalism campaign asvarious interest groups. The Forest has a planning are highlyvisible and are effectivemeansof teaching newsletter which was sent to about 2,600 people on youth to respect and appreciate our public lands. theplanningmailing list. (Themailing list is madeup In addition, the ONF is very interested in seeking of those people who responded to the Draft Envi- and establishing partnerships and public involve- ronmental Impact Statement or Draft Plan and also ment in management activities. In February, 1989, includethose agencies and elected officials required the Forest met with representatives from more than under NEPA) The ONF also disseminated a great 20 different special interest groups and concerned deal of information with the help of the media. See citizens toseekandestablisb betterways toincorpo- the Introduction to this Appendix. rate public involvement in annual project planning Additionally, the Forest encourages all interested The Crooked River National Grassland has been individuals to participate in annual project planning cooperatively involved with several private and activities and to get on the Forest Plan Report governmental organizations in riparian enhance- mailing list. The ONF does not promote any one mentandreceivednationalrecognition in 1988from group over another and everyone’s opinion is given the American Fisheries Society. thorough consideration by Forest officials. The Forest also has Adopt-A-Campground programs and on the Prineville District, a local eques- trian group is contributing to the development of a 1300-17.5 Public Involvement horse camp. Through a cooperative effort with the Oregon Army National Guard, there are nine rec- One individual believed that the process the ONFis reation-related projects that were be completed on undertaking WIII prove in the end to be one of the the Big Summit Ranger District in mid-June 1989. best processes that have been undertaken in regard

1-3-141 FEE Appendix I

to the stewardship of the National Forest. The re- designing the final Preferred Alternative. See sum- spondent believed this process will for the first time mary and chronology of the Public Involvement actively involve the local community to a large ex- process in the Introduction to this Appendix. tent. Response: 1300-17.7 Public Involvement - The ONFhopes that the land management planning Local Other process will prove to be a beneficial practice as it vs. relates to resourcemanagement and involvement of Some respondents felt that the community closest to all publics. the Forest being considered in the plan should be taken into consideration before those who do not live in the community. 1300-17.6 Public Comment A few felt that most of the input should come from Period local groups that derive a living from Forest lands, and not from the special interest groups from large The OEfice of Economic Analysis felt that each metro areas Forest should circulate its alternatives for comment prior to making computer runs. The agency feels One person felt that the Ochoco National Forest that this will allow for a cost-effective method of people are listening to the wrong people and don’t examining a wider range of alternatives. seem to care about what happens to the local economy. Response: Prior to development of altematives, the Forest Response: identified issues, concerns, and opportunities (ICOs) The Forest Service realues the importance of the as defined by the public through the public involve- National Forest and Grassland to the local economy ment process. TheICOswere an integral part of the anddoesnottake that relationshiplightly.However, creation of the wide range of altematives offered in the National Forest and Grassland is a National theDraftEnvironmenta1 Impact Statement (DEIS). forest or Grassland and managed according tolegal mandates. The Forest must consider all public The frameworkfor each alternativewas conceptual- comment and give thorough consideration to each ized by the Forest Management Team (FMT) and person andlor group regardless of proximity to the the Interdisciplinary Team (ID Team). The com- forest or whether the person(s) or organization puter model was built to reflect the objectives that responding are from an urban or rural area. the FMT and ID Team have established for each alternative. Throughout the entire analysis process, there was ongoing retinement of the computer model, and hence of the various alternatives. Alternatives could have heencirculated for publiccomment prior to computer analyses, but until the analyses had beencompleted, theforestdid notknowtheoutputs and environmental consequences in enough detail tofullydefine thea1ternative.k aresult, theForest chose to do a more detailed analysis prior to circula- tion of the alternatives for public comment. After formal publicreviewof thedraft forest plan in 1986, publiccomments havebeen used to a great extent in

1-3.1 42 Appendix I

Response to Public Comment

Section 4 Comments from Elected Officials, Agencies and Indian Tribal Governments 7.w- . llDt- - United States Department of the Interior I&-

OFFICE OF E\\ IRO\hlEXThL PROJFCT RE\'IEW .II The Forest's mOJW god 8s to identify Cdturol renources rn advance of timber sales ond 300 \ E \ILLT\OllhH STREET. SLITE 1692 --I other oroiects and to ovoid or mitiwale impacts to those determined to be stsnificont. PORTL4\D. OREGON 97232 This approach .I considered necerr&y for ;orr.p.oonce with the Nat.ona Env.rbnmen?ol Policy Act (NEPA) and the No!.onal H toric Prerervotion Act (PIHPAI. The content of the Plon .mdm Inat this w.ll be me Forest's Dr.mori CJ.ILIOIresource ocI.v.1f for lne next decode. January 20, 1987 The DES, however, indicates thot the Forest IS currently exploring cdt~rdresource planning beyond the project level. Thrs type of plonnmg has become increasingly useful, ER 86/1&34 ond we recommend that it be mmrporoted tn the Plan (16 an equolly important god This IS become of the growing management problems osocmted with project-by-prolect identification and ovoidonce of cultural reiour~es. The plocement of the Forest's Dove Ritterrbocher resources m brooder planning contexts will eventually allow more crmcol approirols of Forest Supervisor resource significance and Invertigation/protectlon needs Ochoco Notional Forest P.O. Box 490 NEPA, NHPA, ond attendant regulations state that Federal agencies have on offirmotive Prlnewlle, Oregon 97754 responsibility to protect and enhonce dl cultural resources within their Jurlrdlctlon. This rerponribility con best be served through comprehensive planning at both Forest and Deor Mr Ritterrbocher: Stole level^ We encouroge the use of overviews, predictive models, and rompling to identify cultural resource topics relevant to Ochoco Notional Forest ond logicol The Deportment of Interm nor reviewed the Droft Envmnmental lmpaci Slotement environmental oreos that require survey beyond the prop3 level The use of there (DEW ma Proposeu Lona ond Resource Monogrment Plan (PLRAIP) far the Ochoco methods coordinated with the State Historic Prerervotion Officer's (SHPO) statewide P.01 ono. Forest and Crook& R VCI Nalronal Crarrlond. Oreaon The followrno comments goals and priontm, w#II result m the contexts necessary for evoluoting the Forest's ore provided for use and consideration when preparing +he f&I documents cultur~lresources and planning their long-range treatment.

GENERAL COMMENTS For eoch Management and W!ldernerr Areo, the Plan should discuss affirmatively whot will or will not be done to Identify, ewlwte, protect and interpret cultural resources Fish and Wildlife Resources For most of these oreor, wlturol reiource~ore not mentioned. It should 0110 exploln the baris of the following statements made rn reference lo several of the oreor '"Do not In consultotion with state biologists and coupled with field mpections, the Fsh ond enhance or interpret cultural resources," "Avoid enhancing and interpreting culturol Vlildlife Service (F'WS) believer that excersive livestock grazing now occurs ~nvar~ovs reJOUrCeE." oreor of the forest and grarrlond. This hos resulted tn unocceptable IDII~S to fish and wildlife habitat, especially tn the riparian areas. Eight of the eleven monogement olternotwer, including the "preferred alternative" would increase even further the Wild and Scenic Rivers excessive amount of grazing (AlJMd which already OCCUIS. FWS recommends that the existing AUMr be reduced and conrideroble effort be directed toword restoring degroded No units of the Nationol Pork System will be adversely offectcd by the proposed action habitat Fencing riporion zones should be a priority tn such habitat re~toration. However, the Notional Pork Service has certoin rerponrcbilttaes for Wild ond Scenic Rivers and IS the Custodian of the Notionwide Rivers Inventory, which was conducted The FWS has initiated (1 formal consultation regarding threatened and endangered species under the authority of the Wild ond Scenic Rivers Act. under Section 7 of the Endongered Specter Act of 1973. A biological opinion IS being prepared ond will be forworded to the Ochoco Notional Forest under separate cover. The propored plon rtotes tho1 segments of the Deschutes, North Fork Crooked, and momstem Crooked Rivers which hove been "inventoried ruitoble for closrificotion (is Cultvrol Resources scenic or recreational rivers will be protected until Congress resolver their status." We suggest thot you recommend, in the final EIS and Plon, designation of the rivers found Bored on (1 wlturol resource review conducted by the National Park Service Interagency ruitoble for ~nclusionin the Wild and Scenic River system Until such time os Congrcrr Archeological Services (IAS), the PLRMP IS extremely deficient ~n detail obout how acts an the recommendation, we concur with your proposal to estoblirh specid Ochoco National Forest intends to identify ond plan for the protection of Its cultural manogement ~rovi~ion~for there rivers lo preserve their eligibility ond suttabiltty for resources We note that the DElS contains more of the type of information we would derignotion expect lo find in the Plon. The Plan stater that 1,700 sites have been identified 10 the Forest, the management of which should require substonlid planning However, the Plon'r treatment of cuI1uroI resources suggests thot they may not be accorded the same Mineral Resources level of monogement planning (IS other environmental resources. A mineral potential map IS needed. It should be at the same scole (IS the olternotive maps for direct camporiron with the alternatives. The Okanogan Notionol Forest 2

1-4-1 timberlfirewood sales should be mode. PLRMPIDEIS contams o good example. Illustrations and (I more detailed discussion of mineral potentiol for each of the roadlers areor in the appendices are needed It doer not appear that the proposed land use plan addresser utility corridors os required by Sec. 503 of the Federol Land Policy ond Monagement Act of 1976. Planned ond A discussion 8s needed ~n the DEI5 of how minerals ore affected by each of the existing corridors Identified by the Western Regmol Corndor Study (May 1980) ore not alternatives The DEI5 from the Wenatchee Notional Forest, Woshington, provides o addressed in the Plan, nor ore mops provided. The Ochoca National Forest should good example of pom-counterpoint discussion of how minerals affect other resources coordinate utility corridors with the ELM since utility he% etc., poss through both and how decisions offecting other resources wdl, in turn, affect mmerols. junsdmtmns An updote to the Corridor Study IS expected to be issued by the Western Utility Group in eorly 1987. A narrative section on minerals, containing history of development and mineral production, value of post production, prolected mineral demond; and current operatlons Discussion m the Plan of firewood ond timber sales coordinated between USFS and BLM 8n locatoble, leaseable, and salable minerals IS needed The Beaverhead Nottono1 Forest would asmt the public's understanding of land use mterrelotsonrh>ps More effective PLRMPIDEIS hor one of the best exompler combined sales could be accomplished ond cumulative effects better onalyzed for the public. A list of current miner01 withdrawals, ocrer involved, and mineral potentlo1 for locatable and leaseable would be useful The best example 1s m the PLRMPIDEIS for the Los Padres Notional Forest, California. SPECIFIC COMMENTS

The meaning of existing access for locotable minerals should be clarifmd. It should be DES noted thot although an mea moy hove many access restrictions because of 0 lack of - roods, rough terrain, etc , o clam" does hove the stotutory right to develop reasonable Poue 73, Veuetation The discussion of "sensitwe" plants fails to use the cotegorier for and good occerr to claims If necefmry. Recent court cases hove demonrtroted that Federal listing. The Oregon Noturol Heritage Doto Bore categories ore not necerrardy excessive restrictions on (ICCBSS to mining claims may constitute unlawful taking of comporoble. This section should reflect the Federd slotus I" addltm to that listed m private property, the mining claim, without just compenrotion. the March 1985 Data Bare:

The documents ocknowledge thot tlie continuing emphasis on protection of other resource Specres 3-5 __Allium modidum A. leianthm A tolmei lot h llum are"lm"ed m ond amenity values can place increased restrlctionr on mineral exploration and abundance", thu:&h&3%-& r$r: development. However, It would be helpful to also point out the rerponrlbilitier of the Specler Io: -Colochortus Ion eborboutr & IS Federol Candidate 2 (- Forest Service to accommodate mineral development on londr open to mineral ReqlrterSeptember. development tn order to comply with Federol mining lows Specter I I. ollomio macrocol x 1s Federal Candidote 2 (Federol Reqirter 3Gmer*

Woter Resources The BLM's Prineville District Office lists several other threatened and endangered T8Elsensitive plant species on public lands. We urge coordination with Burns and The statement should address the range of yields from t6e water wells and estimate the Prineville District Office botanists regording inventory of species which moy also be uroge of ground woter on the Forest. The current quolity of ground woter should be present on the odjocent Dchoco Notional Forest. addressed The Plon indicotes that at fee campgrounds drinking woter quality 11to be momtored. The statement and plan should also mdtcote momtoring plonr for other Reference IS mode lo the possible need for monitoring category 4 plonts. Monitoring ground-woter sources of drinkmg woter made ovailoble to visitors ond staff on the Forest TgElrensitwe plont species did not appear to be directly referenced tn the plan. and Grosslond. Effects of changes under IhePlan, such (1s increased vlsltatmn, should be dlscurred ~nterms of potentid impacts resulting from disporol of solid Waste generated Paw 79, Cultural Resources The DEE should explain the post, current, and planned wlthin the Forest treatment of "lithic scatter" sites, (1 class of resource that has been determined eligible fbr the National Register of Historic Placer

Hozardr Poue 83, Minerals and Enersy Resources. The Bureau of, Miner has suggested o modification of Toble 111-17, using percentages rother tho" ocreoger. This may make It This are0 hos been repeotedly subjected to the effects of volcmwm, both tephra folk and easier to env~sionthe comportran and comprehend the effects eoch alternative may hove flows Londrlides, both volconicolly induced and otherwise, do occur ~n thls reglon. on mineral re~owcei. Sample tables hove been provided to the Forest under reparote There potentiol horordr should be evaluated. coyer.

Poqe 107-1 I I, Riporion (Fisheries). Described mitigation measures tend to emphasize Coordinalion with other Federol Auencies expenwe, structural techniques. Consideration or in~l~sionof more preventive techniques such (IS no-cut buffers, careful and minimal rood construction, IoCotion While the plan ond EIS reflect coordination ~n some programs, provision for oddtttonol criteria for roods, etc., IS suggested coordtnatwn with the Bureau of Land Management BLM) regarding utrhty corrldorr ond a 3 features of those RNAs proposed for designation. We olso suggest thot a discussion on Plons for manogement actions neor streomr should conrtder the effects on flrherler, manogement objectives, constraints, and other manogement-related information be water quality, etc., rather than stream closs dergnottonr alone. In Eastern Oregon, mcluded for each RNA. A reference to both Appendix E (Appendix Volume) and Clors 111 streams often used by flrh durmg port of the year for rpawmng Thtr are 1s Appendix E-l (PLRMP volume) would also assist the reviewer. especially true for anadromous fish (steelhead in portwlor) tn the John Day wotershed. Closs IV streoms can have indirect affect ftsherner of streams to which they ore an on Sdver Creek Reseorch Naturol Area IS a name olreody used by BLM We wggefl tributmies. communication with the Qurnr QLM District Office to see If RNA cell needs hove already been met by QLM. Page 144, Culturol Resources Assumptions and lnteroctms The PLRMP and the DEIS differ ~n regord to the Forest's proposed use of Its !dentofled sltes. The DEIS $totes thot Pa e 43, Cultural Resources. The bascc charocter of the Inventory Plan needs to be the expanrion of recreatton facllmer would see "a concomltont ~ncreosebn cultural ex;lamed. This should be more than 0 schedule of surveys done nn connectmn wlth resource tnventor#es" and "on mcreose I" apporlun~tmto enhance and nnterpret tamher soles. eh.~~~ The~~~ lnventorvI Plon reDreSentr an ODPortunlty for the Forest 10 slgnificonl culturd resource rites for publx educotmn and enjoyment In a11 but one Instance, however, the Plon speciflcally excludes Monogement Areas from opportunmes consult with the SHPO and implement field investigations bnd studies that are bared on and/or will result in brooder planning contexts. Thlr approach IS recommended tho1 to enhonce and interpret srtes far the pubk beneflt. Thcr oppwent confltct rhwld be IO resolved. the Forest con better understand the significance of its numerous c~lturolresources and be more selective about funding their protectlo" and management Pose 145, Cultural Resources, Transportatron. Thls Jectm should address the mdkrect Pa e 44, Ecosystem Monoqement. It unclear whether threatened and endangered plant negative mpacts of improwng mceii in oreq especially those previously for from 1s rp&r ore included ~n monitoring activities under item 12. Table V-2 apparently mods These effects on cultural resources, in the form of artlfoct collecting, vondoltrm combiner both plant and animol species, making it diffmult for the reviewer to Ilooting) ond modvertent domoge, ore not hmtted rtrlctly to recreotlonal use of the dtfferentiate possible plans to monitor TMlrensitive plants. forest. The Forest's plan to survey lineor historic or ethnohstoric features in them entirety should prove nncrearmgly useful for planning purposes (IS projects intersect them Po e 44 and App. D-l&2 Item 7. This stotement Impljer thot the applicable Native m the future Amhan group will only 6. contocted !f reinterment In-place IS not possible. The issue Paqc 152, ArrJmDIlonr ond Interoctmr The defmtlon of wtthdmwols needs to be would be more in line with Oregon State Low and the American Indian Religious Freedom Act if statement "b" followed "c" The Native Americans should be contacted I" any rev ewrd Stak.ng of ner clams ond eriablirhment 01 new leorer moy be prohhted dealing with (I prehmtoric burial or cremation. Nottfncatlon of the Oregon State depending upon the mdwdvol wtharawal. Development of leorer ond c1a.m~eriob.srhea core Historic Preservation Officer and the Oregon Commirrbon on Indian Serwcer IS Io the dole of witharowol 81 not necerrar IY Droh.b.ted. oeoendmo on tne woe and .. approprmte OCtlO". specifics of the individual wtthdrowol. .. Po e 49. Mmns Claims The sentence concernnng approvol af mining ocllv8tleS stater Paqe 178, Irreversible or Irretrievable Commitment of Resources We ogee with the "A:proval wdl be given when the Forest's concerns are mitigated cn (1 responsible ond Statement that "continued ovoidonce of cultural resource sites ..tends to undermme responsive manner." To Clarify this section, the text could reflect tho1 Federol low glver efforts to ocqwre doto whch would expedcte future site evaluattom." However, we do ClaimontS the statutory right to develop their mining CIoIms. not ogree that doto recovery should be the excluswe, or even prtmory method, to generate doto for the monagement of the Forest's cult~ralre~ourcei. Whenever doto Explaining what the words "responsible" and "responsive" mean would dso be helpful. recovery IS conducted srtis, the opportunities for domg such work the future, wtth on on There words, and phrases such os %I much as possible;' found throughout the mineral improved technology, ore precluded The evoluotm phase prtor to doto recovery be can discussions, lack clanty. most efficiently and economically served by intenrnfytng feld efforts to properly ldentlfy the chorocfer of each site discovered during survey and establlshmg Forest-wde, by Pose Threotened, Endongered ond Sensitive (Plant) Species regional, and/or State-wide historic (or prehlstorc) context* for compmatw purposes. 56, Items 1-2. It would seem thot field examinations would be importont erpeccdly where no Proposed Land and Resource Monoqement Plon (PLRMP) senrltlvespecies are shown by existing doto, the absence of dolo moy be due lo (10 are0 never having been mventoried. Also, periodic reinventory may be necessary smce new Paqe 13, Vegetation Cross-referencing to the DEIS, poge 73, dmcurslon of senatwe sensitwe species ore continuously be" added to lists. plontr would orsirt the reviewer. Item 1. Rore Plan1 S~rveyforms are ava.loble from tne Oregon Ngl~roltleritags Dolo Pose 27, Desired Future Conditions of the Forest and Crarslond. The Plan should moke It ElheDola Dare IS the "central file" lor 0.1 threolrned and endcngerea plant una nnimnl nformotinn Oreoon and woula oe (I ae~o~storylor I informat On. P% ~~ on~ ~~~ In cleor thot the development of new research questions and methods will, m most cases,

I- 4- 3 United States Department of the Interior token to1 prevent undue and unnecessary degradation of the wilderness volues, the rights accorded holders of valid unpotented mining claims should be recognized in this OFFICE OF THE SECRETARY dircvrrion. WASHINGTON, D C 2W40 A endix C-l Paw C-3. Under the paragraph heading "Cullw3 of Excess Numbers -torwP the document indicates ... mature horses wdl probably never develop into gentle soddle horses." We suggest this stotement be revlsed as follows "Any perron interested m acquiring (I mature wild horse should realize that In Reply Refer TO: some of these awnols may never develop into a gentle saddle horse." BH-~~IIAM

A endix C-l Page C-5. Public Law 92-195, as amended, (commonly called the Wold F&Romutd Horse and Burro Act of 1971) permctr the humane Use of motor vehcles and Owcroft by authorized officers, except that no motorized vehbcle other than a Dave Bttersbacher, Forest SlpeNrsor helmpter con be used for pursuing ond gathering. U.S. Department of Agriculture Forest Service Ochoco National Forest, P.O. Box 490 Pnnevme, Oregon Y7754 ~. recorded within the Forest; discussed which ore coniidered important in relation to Dear Mc,Rittersbseher: recent research; exploined the evduotion process used when such resour~es ore idemfled; listed how many of the 1,700 sites, structures or classes hove been determined Thlr IS In regani to yaur tPaffimttal of September 11, 1986. requertmg the Departmat elqlble for the Notion01 Register m consultotion with the SHPO, and specified how of the hterlor's review end Comments on the draft environmental statement end rignifcirnt sites ore being and will be protected. proposed land and P~SOUPC~management plan concerning the OObocO National Forest and Crooked River National Gmasslard, Oregon

APPENOICES Ths u to lnfcrm yar that the Department will have comments but wIu be mble to reply within the allotted t" BS we have just re2ened yarr tmffimittaL Please constder thls Smce several appendices duplicate sections of the PLRMP, comments mode on the letter as a request fuan extension of time m which to comment on the statement. PLRMP are also relevant m the corresponding appendtx. Our commentsshwld be available .%baitJanuary 19, 1987. -MAPS Sincerely yours, Management Area No. I I IS not delectable on the Alternative mops. While ex!rtmg Forest recreation sites ore shown (0% port of the base mop legend), proposed stel ore not, thus the impact of monagement on future recreation sites connot be wruoltzed. Both existing ond plonned rites could be shown by use of symbols on the 112 inch i I mile maps. Ftgure IV-4 (poge 64 ~n the PLRMP) doer not show Monagement Area No. I I either, probably due to the scale.

Thonk you for the opportunity to comment on your Proposed Plon and Draft EIS Smncerely,

ChorlesS. Polityko 0 Regional Environmental Officer

1-4-4 United States Department of the Interior 2 BUREAU OF MINES & WESTERN FIELD OPER*Tl(INI CENTER 6. It also needs a 11st of current mineral mthdrawals. acres inwlved, E*% 160 ,ED AVENUE and mineral potential for locatable and leasable. The best example SPOKAWIE WAIIIINGTON 99202 is the Los Padres National Forest, California. Decenber 18, 1986 We have reviewed rmst of the forest plans of the far western Unrted States and have noted certain methods of presentation that are improvements over other forest plans. The followlng are offered as suggestions for improvement.

1. We suggest a nwdrfication of table 111-17, as shown on enclosure 1, using percentages rather than acreages. We feel it IS easier to envision the canparison and canprehend the effects each alternative may have on mineral resources. Mr. David Rittersbacher Forest Supwi sor The potential classification Consists of Rve parts, with a range Ochoco National Forest from high potential to very low potential based on current howledge. P.O. BOX 490 The availability classification Consists of four categories. including Pnneville, Oregon 97754 withdrawn. specific legal protection measures. special mnagemnt conditions, and standard operating conditions. Dear Mr. Rittersbacher. 2 Expand your Evaluation Criteria for Nonenergy Minerals such as that SLBJECT: DRAFI EIIV1ROhE:ENTAL IMPACT STATMEIIT (DEISI AND PROPOSED LAND AND frm the Wallowa Whitman, National Forest, Oregon (enclosure 21. RESOURCE WIAGEENT PLA'I FOR THE OCHOW l,ATIONAL FOREST AhD CROWED RIVER IIRTIONAL GRASSAIID, OREGON (1920 LMPI 3. Provioe a ocfinition of access restrlccion categorrcs such as that irm the Beaverhead t!aclonal Forest, Montana (enclosure 31. The OEIS and Proposed Land and Resource Managemnt Plan have been renewed by this office and are found to have the following deficiencies. Overall, the documnts are quite good, wth most minerals issues being treated well with respect to their abundance on the forest. We sincerely hope you 1 The report needs a mineral potential map. It should be at the incorporate our Suggestions in your final EIS and mdify the documnts same sale as the alternative maps for direct canparison with the accord1 ngly. alternatives. The Okanogan National Forest in Washington is a good example. Sincerely. 2. It needs Illustrations and a more detailed discuss~onof mineral potential for each of the roadless areas in the appendices.

3. It neMl a diwdssion w go along "itn table 1V-20 of OH minerals are affected bY each of the alternatives. and a section in the Minerals Involvemnt Section simdry chat cmpdres h3w minerals fare by all of tne alternatives. Branch of Engineering Studies 4. It needs a point-counterpoint discussion of how minerals affect Enclosures (31 other vesources and how decisions affecting other resources mll, in turn, affect minerals. The best example to date is the DEIS fvm the Wenatchee National Forest, Washington. 5. It needs a narrative section on minerals. containing history of development and mineral production, value of past productlon. projected mineral demand; and current oprations in locatable, leasable. and Salable minerals. The Beaverhead National Forest is one of the best examples.

1-4-5 -. I I1 111 IV V I I1 I11 IY Y Total acres 579,789 425,032 1,142,700 0 0 216,257 376,288 1.382.040 173,036 0 of potent7al -

A 12 16 17 0 0 0 0 16 58 0 B 27 2 40 0 1 4 12 7 0 Alt. 1 C 8 2 40 0 0 0 8 1 0 D 53 80 75 0 0 99 95 6 34 0

A 0 0 16 0 0 0 0 6 58 0 8 16 2 30 0 2 5 8 1 0 Alt. 2 C 29 45 42 0 0 54 58 34 17 0 D 55 52 40 0 0 45 36 52 23 -0 Department of Energy Bonnewlle Power AdmlnlmsUDn P 0 Box 3621 Pdand. heeon97208 Category A DLC 2 6 116

1. Uilderness areas. U,.bl.C" SI 2- Ufld and scenic rivers 3. Sites for faciiiti.< Mr. Dave Rittersbacher Forest SuperYlsOr Oehoco Natzonal Forest Category 8 P.O. Emx 490 Statutes or executive orders require specific Prmevllle, OR 97754 protection or mitigation measures. D~*IMI. RLttersbacher 1. Proposed wilderness areal. 2. Congressionally mandated wilderness areas. Bonneville Power Admrnlstrarlon (BPA) has revleued the Proposed Land and 3. RARE I1 Further Planning areas. Resoume Mensgcnenr Plan and Draft Envlron~entellnpact SCsCenent (ElS) for 4. T & E Species. rhc Gc Offer the ~~~~ Ochoco Nariannl Porcsf nnd Crooked River Naflonnl Gmraland. 5- Roadless (Type I) dispersed recreation areas. following comments for your consideration. 6. Culturally significant areas. Category c 1. Of nBrtIcu1ar immrtance to BPA IS the deslgnatlon Of borh ellstlng Special conditions exist on lands whtch require and planned rransporrarmn end vrilrcy corridors. We could find no special lease stipulations or plan of operation eorrldors on the EIS and Plan maps listed 88 "designated," nor was there conditions. any mention of corridor designatlo" m the text. Ueelgnstlon of corridors should help avoid B proliferatroo of rights-of-way and should facilitate Big game winter range. ,he *,IDl" rleveloomenr ;li ..,_ nrdsr,"__.__., .~~~~. ~~~ ~ future "tlllty.. p*Olect*. merefore, 2s Elk calving area. we request that you add thrs nfomtlon to both documenrs. 3. Riparian area. Category 2. To BSS~SLyou m corridors, we have enclosed B markedup D Standard lease stipulations and plan of operation conditions apply. Proposed Alternative (Alternatlve E) Hap illvstratlng exxstlng BPA traomm8mn grid lines as well as Central Electric Coop and Paclfle Power 6 Light a. (PP6L) lines. mese lines should be shown on che other alternative mps also. Most of these fr~n~mse~mlines were not shown on the Land Adpstment Hap m Appendrx 81. BPA has no nev prolects m Its Cmrrent 10-Year Plan that would affect your Management Plan. You mght want to conmet utilities m your area for information an their plans or concerns.

3. It IS dlffleulr to identzfy m the Plan and EIS vhlch management areas are considered "avoidance" Or "exclusion" areQB for energy tranSmlsslOn corridors. It would be desirable to have this information sumsrrzed m one section of the docments

4. We recononend that the Plan and EIS address renrvaole energy resourcee avch as wid, hydroelectrle, geathermal, small hydroeleetclc, or hvamass. You could identify the type and amount of potentla1 reso~rcesand the conflicts that may be assoelated Vxfh resource development. BPA has mfomation available on Northwest energy reso~rces,which we could prov'de to you.

Enclosure 3 1-4-7 US ENVIRONMENTAL PROTECTION AGENCY REGION IO %- 2 1200 SIXTH AVENUE SEATTLE WASHINGTON 98101 5. me proposed alternative does not appear to have any adverse mpscta on exletmg or planned tr8n810399100 projects, therefore, we find ~f satisfactory from the corridor planning atandpamt. CEC 2 s :::j If you should have any qmeetions on these comments or need more detalled mformatron on planned and eniatmg transmission eorrldars, please contact Ey&QIlls 443 John Hooson, of the D~vismnof Land Resources, Office of Engvneermg and Constrnctmn, at 230-3299 (FTS 429-3299). Mr. Dave Rittersbacher Thank you for the opportunity to partlezpate m the scopmg process. Forest Supervisor Ochoco National Forest P.O. BOX 490 Prineville, Oregon 97154 Dear Mr. Rittersbacher: In accordance with our responsibilities under Sectlon 309 of the Clean Air Act and the National Environmental Policy Act, we have reviewed the Draft E"Cl0tl"R Environmental Impact Statement and Proposed Land and Resource Hanagement Plan Proposed Alternatives Map (DEIS and Plan) for the Ochoco National Forest (ONF) and the Crooked River National Grassland (CQNG). The ONF and CRNG are located ~n central Oregon and include 955.100 acres. The preferred alternative upon which the Plan is based provides for intensive timber management and grazing for parts of the forest. Big game habitat as well as developed and dispersed recreation would be emphasized. Geothermal. oil, and gas leasing would be permitted.

Bared on our review, we have rated the DEIS EC-2 (Environmental Concerns- Insufficient Information). The basis for our rating is summarized below with details included in the enclosed review report. Our report IS divided into three secttons providing gelieral and then specific comments on each document. Also enclosed is an explanation of our rating system for draft EISs. Our primary concern is that the Plan be consistent with Oregon's adopted Statenide Water quality Hanagement Plan for Forest Practices required by the Clean lkter Act. The Plan and DEIS Should reference Oregon's FoPest Practices Act and Rules and indicate how they will be complied with in the Plan. This is necessary to ensure that appropriate coordination occurs between the ONF and CRNG and Oregon's Departments of Environmental, Quality and Forestry and that beneficial uses are protected.

In PaPtlCUlar. standards and ouideliner for Fisheries and liater need to be mare fully disciasedldeveloped in the Final EISlPlan. These issues are presently discussed as a Subset of the discussion on RIparian areas. In addition, standards and widelines for RIP need to be more fully discursedldeveloped with-regard to how the Oregon State Implemeitation Plan would be met.

The details of OUP comments are included in the enclosed review report. several of the items identified in this Peview were discussed in the meeting we had with pur staff in Seattle on November 13, 1986, and in subsequent telephone conversations. Th,s interaction has been useful for us in becoming familiar with issues on the ONF and CRNG.

1-4-8 2 U.S. ENVIRONMENTAL PROTECTION AGENCY REVIEW REPORT ON THE DRAFT The intent of our COmentS is to be Constructive. Ue are confident that ENVIRONMENTAL IMPACT STATEMENT AND PROPOSED lAND AND RESOURCE by addressing our concerns and Comments the ONF can present a Final EIS and Plan which clearly shows that important resources will be adequately protected MANAGEMENT PLAN FOR THE OCHOCO NATIONAL FOREST AND CROOKED RIVER while providing ONF personnel Hith the necesswy flexibility to manage day to day activities on the ground. NATIONAL CRASSlAND, OREGON

Thank you for the opportunity to review this OElS and Plan. If you have GENERAL COMMENTS any questions about our review, please contact Ann Uhrich of our EIS and Energy Review Section at (FTS) 399-5512. Process DeSCrietion

Sincerely, The primary Output of the National Forest plannlng PVOC~SS16 the Land and Resources Management Plan (the Plan). and the heart of the Pian is the forestvide standards and guidelines and the mre localized management area prescriptions There. in addition to the existing minimum management nLjkT& requirements (MMRs). ret the backdrop against which gwds and services are Robert S. Burd produced on the Forest and Grassland Director. Uater Division A ready knowledge of these three things at the Outset (standards and guidelines. prescriptions, and MMRs) would greatly facilitate the readers' Enclosure understanding of the Plan Hence. a summary of how they are similar andlor how they vary would be helpful This might be appropriately put in the Plan in Chaoter 1 under "Puroose." or in the Draft Environmental Impact Statement cc Office of the Governor, State of Oregon (DEIS)' in Chapter 1 under "Planning Process" USFS, R-6 USFS. R-1, 4 The DEIS and the Pian rely heavily on subsequent environmental analyses Oregon DEP and data collection for pinpointing specific impacts from forest activities USFUS In order that we can be assured that the environmental effects of the selected NHFS alternative are acceptable. we need to have a complete picture of the forest BLN management process There are a number of elements within the forest Oregoq Forestry Dept. management process that we believe are very important in minimizing adverse OOFU environmental impacts. particularly water quality effects They include CRITFC TUS A data base of existing conditions from which technical experts and thecanjudge expected effects and levels of uncertainty of SC the predictions IEPLC (Osborn) Braun Bert Manaqement Practices (BMPs) and management area prescription development

Selection of BMPr for a particular activity [Environmental Assessment (EA) preparation1 and how uncertainty is factored into selection Thorough on-site inspection and administration. verifying that a particular activity is occurring consistent with BMPI and as prescribed in contracts. leases. or permits Monitoring after the completion of an activity to determine whether predicted impacts were exceeded

1-4-9 2 3

Domestic and Irrlqation Water Supplies 6 ReDalrinq damage caused by adverse effects that exceeded predlctians According to discussions with the ONF planning staff, only one Instance 7 UDqradinq BMPs or prescriptions ta correct inaccurate predictions of domestic use of surface water (actually. spring water) occurs on the National Forest To ensure that any current and future drinking water The DEIS and Plan did a good job of describing the available data base ruppller are protected, information on the existing source should be included and best management practices (BMPs) In general. the monitoring and in the Final EIS, Including location, size. source. and municipality or number

of DeoDle served A statement. as~~ to~~ the~ ~ lack of anv other nuhlir

The DEI5 notes that increased grazing (p 131) and exceeded threshold FiiherlerlFirh Habitat levels on individual watersheds (p 133) could each have negative impacts to water quality under the preferred alternative. but that these impacts "should Chapter 111 of the DEIS Provider a very good overview of existing be offret by the fairly high level Of mitlgatlon proposed " The DEIS then knowledge Of the Status of fish habitat and fish population on the ONF by very aptly makes the statement that "thls points to the need to develop and drainage However, since ripwian areas and flrhery impacts are dlrcurred administer an effectlve monitoring plan to assure that minimum management together in Chapter IV, it would be helpful If one more column was added to requirements are met and that an effective level of mitigation is undertaken" Table 111-13. to be called "Present riparian condition " Appendix A-4 In the (p 133) With this In mind. we believe the discussion Of water quality Plan identifier one of there drainages as being in "poor" cmdition (Bear mnitoring and evaluation in the Plan (p 106) Should be expanded For Creek). but the condition Of the other drainages In Table 111-13 Is not example. when and how would projects be selected to receive mnitoring and Identified The condition of all the drainage should be Included in the FInal mitigation' Also. monitoring helps assure standards and guidelines are met. EIS not just minimum management requirements Chapter IV of the DEIS Presents a good descrlptlon of the impacts to The adequacy of the monitoring plan to assess environmental Impacts, and riparian areas and to fish habitat resulting from the various alternatives methods to en:ure that the dsPesimentP are used in management decisions. are ( pp 107-111). but the heading for the section is simply "Riparian " It key factors 10 EPA's ability to evaluate the adequacy of Forest Plans and should either be "Riparian an6 Fish Habitat." or perhaps "Fish Habitat" should EISs The monitoring plan together with the standards and guldelines should be discussed Separately In its own section The latter Would probably be m$t serve to highlight how the Plan will be implemented The Final Plan should appropriate slnce fish habitat is not solely a function of riparian condition. clearly outline how monitoring will be carrled out such that mid-course but is also closely tied to water quality (and water quality IS a function of correctlons can be made in fOreSt management This serves as a system of timber management. grazing maoagement. ORV use. sanitary facility management accountability. reduces anxiety for any Uncertainties in predicting Plan at recreational facilitles. aod mining management as well as riparian area impacts. and maker it clear to the public how the plan will be Implemented condltlon) As the uncertainty in being able to protect against water quality and fish habitat effects increases, a higher level of monitoring becomes necessary We agree with emphasis being placed on undertaking fish habitatltiparian improvement projects It Should also be emphasized that flSh habitat Improvement work, while Imllortant and potentially very successful. does not take the place of avoiding Impacts to the greatest extent Practicable from the beginning 4 5 It Is unclear how land was allotted to management areas 13 and 14 Grazing (riparian areas) Since they are not mapped. they should be described in the text. at least in terms of the distance from each stream type, etc The ONF and CRNG provide a significant amunt of livestock grazing in the Pacific Northwest Region It is not surprising. then, that certain range We are pleased that the DEI8 considered not Only presently utllired fish management problems exist Several specific allotments are identified where habitat on the ONF. but also included potential fish habitat Of the 200 obligated AUM's exceed the estimated carrying capacity (Plan. Appendix F) and miles of streams that have potential for additional cold water fisheries, how impacts due to overgrazing. particularly in riparian areas. are discussed in many miles are part Of the John Day or Deschutes River drainages (and the DEIS (e 9 . p 107, 123, 130) Though damage to soll, vegetation, and therefore potential habitat for anadromous fish)' Also. if Bear Creek water quality is mentioned as accurrlng. specific problem areas are not presently supports anadromous fish, would It not follow that the Crooked River identified Of the drainages listed In Appendix A-4 of the Plan, it can be drainage (which Includes Bear Creek) 1s also of importance to anadromous fish inferred that most Of those are degraded because Of grazing related rather (though admittedly perhaps not as great as the other two major drainages)? Is than timber related impacts Adverse impacts related to grazing would there mare potential habitat for anadramus fish in the Crooked River drainage? therefore seem to be rather widespread

Four Of the streams llrted In Table 111-13 Of the DElS (Badger. The Final €18 should identify the areas where grazing related water Cottonwood. Black Canyon. and Wind Creek) are not listed In Aooendix A-4 of qUalitY or Other riparian area problems enist A table YhlCh combines the the Plan, which lirts~streamrwith riparian areas to be nraintilned or enhanced data presented in Appendix A-4 with those of Table 111-13 (DEIS. p 78) would for fish production Are they sub-drainages Of Streams listed in Appendix A-4 then nlcely suffice as a summary of how the anadromous fish habitat would be or were they inadvertently Omitted' maintained or improved We note that alternative C has the greatest potential far increasing In general. domestic water supply watersheds and anadromous flih habltat habitat capabllity for rainbow trout and steelhead (p 108) The preferred should be managed for particularly high levels of protectlo" Where it IS alternative. E-Departure,E-Deoarture. would also Increase capability.caoabilltv. but not~~ nearlynearlv~~ as determined that impacts to these beneficial user have occurred or would be much as alt&natibealternative cC While It is realized that alternativealte&tive C primarilyprimariiy-~ unavoldable, serious consideration should be given to defining grazvng as an attains Its level Ofof habitat capability goals by reduction in harvest level incompatible use and livesto~kshould be excluded The ONF is to be commended and livestock grazing (DEIS, p 135). Other differences between the two for recognition and incorporation of this fact via plans for fencing. ar alternatives appear to mainly relate to the number of improvement projects. dercrrbed under Riparian Enhancement (DEIS, p 150) The U S Bureau of Land Which can be summarized as follows Management (ELM) Conducted a fencing study along Camp Greek (tributary to the Crooked River) Which was highly successful (I) NO doubt such a strategy Alternative could be successful on the ONF and CRNG as well Rlparlan Area ManaQement The importance of riparian zones to water quality and fish and wildlife E-Depar ture c habitat quality greatly exceeds the actual area occupied by riparian - vegetation Any evaluation of the cost effectiveness of timber harvesting or Fencing 300 ac 500 ac grazing in these areas should reflect this fact It Is essential to carefully explain how activities such as timber harvesting and livestock grazing can be Beaver Transplants 50 100 made compatible with other riparian area resource values (e g . protecting and enhancing water quality and fish habltat potentlal). keeplng in mind that it Rock Structures 50 1 DO may not be possible to replace these other resource values elsewhere on the Forest Woody Material 300 so0

Log weirs 300 500 - - 1.000 ac 1.700 ac

I. ~ ~ -.---.... s than for alternative C

1-4-11 6 7 It was gratlfylng to see Riparlan Area management standards separately Forest land managers that provide flrewwd have a unlque opportunity to presented In the Plan It Is also commendable that those dralnages llsted as educate the public regarding fuelwwd use and alr pollutlon through the permlt rensltlve are the same ones to be malotained or Improved to "excellent" process Pamphlets discussing the arrociatlon between woad stoves. air rl~ld~idnconditlon However. the ImDlicitlon that fair to excellent rl~arlan pollution. and health concerns. or provldlng tips on efflclent wwd stove c&dltlonS vlll automatically result In gwd Smlt habltat andlor streak operatlon. for example. could be distributed with fuelwoad permltr If meeting State water quality criterla (DEIS, p 93. App A. p 30) are appropriate llterature Is not readlly avallable. we would be happy to provide aswmotions that will need to be confirmed via the Dlanned monitoring examples that are being used elsewhere progrim Hence. we believe the dlscusslon of riparian mnltonng ani evaluation In the Plan (pp 105-106) should be expanded FOT example when and The Plan should provide wre guidance on minlmizlng air guallty Impacts how would drainages be selected to receive mnltoring' from slash burnlngs (p 43) How does the ONF propose to meet the Oregon SIP (e g . regulating timing and amount of slash burning. etc )' The Plan should It is apparent that several dralnages need to be Improved such that they describe the measures to be used to assure that peak air quality impact could even meet MMRs Wl11 thlr effort be undertaken first, and then episodes will be kept to a minimum. as well as those to be used to assure that Implementation of prescriptions 13 and 147 If so, this should be stated in average annual emlssions do not enceed standards the Plan Also. as proposed, timber harvest and grazing would be allowable In essentially all rlparlan areas as long as Standards and Guldelines (and Cumulative Impacts prercriptlons 13 and 14) were met We would Submlt that this. again, points to the need for monitoring and mitigatlon programs that are bulft into the We have discussed the use of "area analyses" with other national forests budget process for the forest For example. the Plan stater that addltlonal and generally support their use It appears that much of the detailed water developments would be constructed "where analysis shows these analysls we belleve to be necessary. but whlch the Forest Plan does not developments to be cost efficient" (p 67) Since additional water provlde and can be mlssed by individual project evaluations. could be developments may very well be Critical to the success Of rlparlan performed at this level of study Area analyses would be the most appropriate prescriptions (p 94). we propose that serious consideration should be given to vehicles far evaluating the cumulative effects of many slmllar actlvltler. and funding such developments from thir standpoint the combined effects of different types of activities, occurring In d falrly large area and over a perlod of tlme Mlnlns Because detailed and speclfic analysis of cumulative Impacts 15 extremely It ir well to state In the standards and guidelines that management or Important, the Final Plan should discuss In some detall the process far operatlng plans will be developed for each area where a mineral rairce Is to asresslna these effects For examole. far how lame an area (2nd Order be~. develooed.~~ ~ ~, .~. and~ ~ llst~~ the~ ~ Item~~ ~ to~ be covered in such olans (Plan... D 49) drainage;?) would such analyses be' performed' Whai period Of tlme between rlo.cver. for locatdole mlncrals #e neilive the Plan sh&ld IOCILOC dter projects would be considered' Would all activltles pwduclng redlment In the qJallty monltoilng reqLirementr for sites .Itn me potential to affect "ater area be Included (e g , tlmber harvest. plus roads. mlnes. gra2ln4. etc)> HOW u.dliti and beneficial sei Ilater aialltv ronltorlnu data may ne neeoed to will multiple Ownership dralnages fit Into these analyses' -will documents be ensur

Which streams have fallen below state water quality standards' For 131 Will grazing increase by 9% -7 Elsewhere 10 87. is cited for Which Itream segments, and for what parameters' the first decade The riparian acreage in alternative D totals 19.400 acres Is this 133 We underrtwd the NF to have 22 major watersheds. not 24, as stated correct' We understood 19.000 acres to be the maximum total here

The riparian area in alternative E totals 20.500 acre$ Is this 177 Increased costs In grazing management are not really "environmental" correct7 effects Can we assume that stream condition categories "fair" through Glorrary "excellent" meet state water quality standards. but that "poor" does not' 195 Is "acceptable riparian condition" the equivalent of "fair" or "gwd" (p 68)7 74 It is OUT understanding that there are 24 major watersheds on the ONF and CRNG. 22 on the forest and 2 on the grassland Is this 201. 211 Guidelines (p 201) and standards (p 211) have two separate and Correct' distinct meanings here. as well they should However. we do not find these meanings carried over into the Plan. which glves no 75 TWO watersheds are apparently missing from Table 111-11 Also. indication as to which requirements are the "mandatory" standards since there are about 800 miles of streamside areas (p 68). and which are the "non-mandatory" guidellnes We believe that the eSsentially all of the streams would appear to be potentially Plan Wauld be improved if it reflected these definitions suitable for trout Is this correct' 204 It would be helpful to add a sentence as to how MMRs differ from 78 CottanMood. Black Canyon. and Wind Creek drainages are not mapped an other standards described in the Plan p 74 Are they part of larger drainages? If so, which ones7 204 The definition of monitoring might be improved by adding a clause 82 Of the 800 mining claim currently located on the forest. how many such as " and to use identified deviations as a trigger for are placer nines7 Drift claims? revision of management practices andlor plan revision "

87-88 The text mentions six roadless areas. but the figure (p 88) shows SPECIFIC COMMENT5 ON THE PLAN eight Which is correct^ 1 It is recognized that the annual budget Will influence the lwei of 89 In Table 111-25, line IV appears to be in error Should it not be projected outputs and plan implementation. however. certain as folloYs 575.375 - C(31.072) + (23.551-12.425)l - 533,177 categories of activities should not be excluded at the expense of others. In particular. mitigation measures and standards and 94 Acreages for ailderners areas listed here do not agree with thore on guidelines designed to protect or enhance resources should not be p 4 of the DEIS. nor with numbers presented in the Plan tahled" while other Plan goals are met 95 Column 2. paragraph 3. last Sentence This sentence seems to have lost part Of its meaning 104 It is our understanding that. as of this writing. the state of Oregon has not completed revising its existing SIP for managing air quality The text implies there is currently no such plan

1-4- 13 10 11 2 In priorltizing the development of forest level plans, we would encourage making the Allotment Management Plan one of the first (If MANAGEMENT AREA PRESCRIPTIONS not the firit) to be prepared This Is because ,t w11 have a direct bearing on riparian areas, water quality. and the protect7on 93. 95 The total acreage of management areas #13 and B14. 3% glven here, Is Of beneficial uses Also. It would seem that guidance for mineral 15.886 acres This does not coincide with the 19,000 acre flgure extractlon would be helpful to forest managers, perhaps in the form given throughout the rest Of the Plan and the DEIS for total of a Mineral Ertractlon Management Plan riparian area Why' Also. it IS stated that there prescriptions will apply to designated watersheds This iaplrer that some 13 The acreages cited here for wilderness areas do not coincide with watersheds would not be designated and would therefore lack specific those clted in the DEIS On page 94 Which Is correct? protection Under these prescrtptlons Would the remaining acres rlmply be covered by the other standards and guideliner' If not 5-13 Under Current SitUatlon/ReSOUrCes there 1s no discussion of soils mapped. these areas should at least be described as to Which This should be added drainages they occur In 21 HOW will research needs be priorltized' HOW will they be funded' For 94 HOW Would ORV use be "discouraged7" example, given that state water quality standards are not now met by certain streams on the ONF and CRNG. we believe the riparian area 94, 97 "Water Management" practicer should refer to the Mnltoring plan so research needs cited here to be of utmst importance What a$ to describe & goals would be attained assurances are there that they w111 be carried out in a timely manner' MONITORING PLAN 26 It is stated that livestock will have less Impact on rlparian areas 102-108 Thls is a nice summary of such a plan. however. further detail and wlll be better distributed, due In large Dart to water Should be provided. particularly on aspects Of the plan YhlCh developments However. in management prestriptlon #1 (pg 67) It Is pertaln to meeting federally or state mandated standards or stated that water develoDmentr would be constructed "where ..woiect regulatlans. such that reviewers can ascertain that correct level analysis shows the& developments to be cost efficient " If parameters will be monitored at the Correct time(r) -not found to be cost efficient. do we assume that impact to riparian areas Could cantlnue' This is confusing 102-1 03 The reporting period for habitat condition monitoring of wildlife and anadromous fish would need to be more frequent 21 Is there a cammltment to Improving a certain number of acres per than every 5 years if individual projects are to be revised year In rlparian areas> TO realize the goal Of 1,500 acres of before significant damage has occurred improvement by the year 2000 wlll requlre timely Implementation of enhancement projects and management strategies under prescriptions 105 A similar argument as the one above can be made for riparlan areas #I3 and #14 109 A portion of the tltle Of Table V-3 seems to be missing Standards and Guidelines A-4 Thlr table doer not address future maintenance or improvement of the 48 The Items llrted under a minerals management plan are gmd, but the following anadromous fish dralnager Badger, Cottonwood. Black Forest Servlce role In monitoring and enforcenrent of the operatlng Canyon. and Wind Creek Why not' plan requlrements should be described. particularly with regard to water quality A~PO.a general description of the process under H-1 Is It the case that there are 22 major watersheds on the Forest and vhlch operatlng plans Would be approved or disapproved in sensitlve that 20 of these are forested' Are the other two watersheds In areas would help to strengthen thls portion Of the Plan range' 52 The riparian dilCUlSiOn should refer the reader to appendlces A-1 and A-4 UHRICH %iercD5264E' United States Department of the Interior Bernie Carter. Ochoco National Forest. Prineville. Oregon 1. DP Robert Anthony. Oregon State University Cooperative Wildlife y: FISH AND WILDLIFE SERVICE Research Unit Portland Field Office Frank Isaacs. Oregon State University. Caoperative Wildlife Research it 727 NE 24th Street Harlan Scott. Oregon Department of Fish and Wildlife. Prlnevllle. Oregon Portland OR 97232 Mary Walters. Oregon Department of Fish and Wildlife Corvallis. Orewan Rlch Howard. US Fish and Wildlife Ser~ice.Boise Idaho Robert Parenti. US Fzsh and Wildlife Sernce. Boise. Iddho

An extension was requested by the Service an December 17 1986 and January 16. 1987 acknowledged by Ochooo National Forest on December 29 1986 A biological assessment on bald eagle and peregrine falcon was received on October 21. I986

BIOLOGICAL OPINION Ref 1-7-87-F-2 It 1s our Blolagical Opinion that Implementation of the Proposed Alternative Dave Rittersbaoher Forest Supervisor E-Departure of the Ochoco National Forest and Crooked River National United States Department of Agriculture Grasslands Farest Plan is not likely to jeopardize the Continusd existence of Forest Service the bald eagle end peregrine falcon Further informal consultation will he Ochoco National Forest needed and fUrtbeP formal consultation may be needed on project specific P 0 Box 490 actions as the Forest implements the Plan Prineville Oregon 97754

Dear Mr Rittersbacher DESCRIPTION OF bCTIVITY

This 15 in reply to your agency's letter of October 2, 1986 which NBS received The proposed Fomst Plan sets forth Forest-wide goals and Obiecfives land use on October 8 1986. requesting formal consultation with the Fish and Wildlife allocations. management area prescriptions Standards and guidelinee. and Service (the service) a8 described and rewired by Section ?(a1 of the monitOPmg and evalnation requirements to establish direction for management Endangered Species Act of 1973. 16 U S C IS31 et seq (the Act1 This of the Ochoco Natlonal Forest over the next 50 years The Forest Plan will be consultation addresses the possible effects of selecting Alternative E- revised on a 10-Year cycle The Fmest Plan is based on the preferred Departure of the Draft Environmental Impact Statement IDEISI. Proposed Land Alternative E-Departure and RBIOU~C~Management Plan (Forest Plan). and Appendices The subsequent impacts of thio proposal to the bald eagle (Haliaeetus leucoce~halusl. Alternative E-Departure emphasizes a combination of timber production. fedePally classified as threatened in Oregon and the peregrine faloon (p.IC0 roadless recreation. and big game habitat Tilnbei 1s Scheduled as a departure preerinus anatum). federally classified as endangered within the State of from nondeclining yield Timber harvests are Scheduled so that first decade Opegon. are discussed herein volumes remain close to CUrPent levels. and then declme over the next 10 to 50 years The departure is designed to maintain local jobs in the short term Candidate species are not subject to the provisions of Section 7 of the AI1 resources are managed or maintained at Some moderate level Endangered Species Act Therefore. the determination of jeopardy or "on- jeopardy to candidate species will not he addressed ID this Biological Bald eagle opinion However. candidate species will he discussed slnce they OCCUP or may occur on Ochoco National ForeSt and Crooked River National Grasslands and may Management guidelines for the protection of bald eagle nest and roost trees he affected by Foreet actions occupied during the breeding season are outlined in the Forest Plan (page 62) and Appendix D (page D-26) These have been adopted fr0m.the Bald and Golden On January 16. 1987, We completed our endangered species review of the Eagle Protection Act proposed project During the COUPS~00 out' revlew other individuals were contacted who had special knowledge or! expertise concerning the proposed project. project area. or threatened and endangered species in the area These include

OCHOBO DH ZE DDISK2 0111S/87 1 OCHOBO DH ZE DDISKZ 01/18/87 2

1-4-15 The Forest Plan (page 611 and the Biological Assessment indicate that the SPBCIES ACCOUNl preservation of actual and potential bald eagle winter roost sites is a goal In addition. it is the evreored intent of Ochooo Nntlonal Porest to utilize Bald Eaele the findings and recommendations of the 1986-1987 bald eagle winter roost OUPY~YConducted by the Oregon Cooperative Wildlife Research Unit There arp currently no known active bald eagle nesting territorie5 within the Preliminary recommendations include the development of site-specific Ochom National Parest and Crooked River National Grassland HiStorlCal management plans for each roost site with Input from the Servlce through records indicate that a bald eagle breeding territory was once associated with Seetion 7 Consultation IIsaacs et al. 19861 NO Written management plans have Big summitt prairie been prepared for any Pmst as of yet However, management plans are on schedule far development in 1988-1989 (Carter. pers corm I Where rOo8tS have The draft Pacific States Bald Eagle Recovery Plan indicates that Big Summitt been located. modifications to the timber harvest schedule have been made in Prairie and Lake Billy Chinook may have the potential for Supporting one and consultation with the Service two bald eagle breeding terntorieS respectively It is likely that potential bald eagle breeding tePritorieS In these areas would involve Ochoco Nationill Regarding recovery and Recovery Plans, a general statement has been included Forest and Crooked River National Grassland land$ in the ForeSt Plan (page 621 and Appendix D (page 0-251 that recovery plans take precedence over other management direction NO other details regarding A population of winterlng bald eagles occurs along the upper Crooked River pecovery plan Implementation are pmvided In the Forest Plan drainage in central Oregon As many as 115 bald eagles have been observed during Veak periods In addition to roosts on Private lands the bald eagles Pereerlne falcon most in forest lands adJscent to vslley foraging areas along the Crooked River Roost trees tend to be the largest. dominant or co-dominant conifer No management provisions have been included in the Forest Plan Specifically trees an roost stands Coniferous Pmst trees ape larger than the United for the peregrine falcon Some general guidelines have been prescribed for Stater Department of Ag?ioUltUre. Porest SerVlCe mlnimum old-growth the protection of raptor hawk and prairie falcon nesting habitat (Forest OpeCifiCBtzons for ponderosa pine forest type (Isaacs et al. 1986) Plan. page 62-63. Appendix D. Page D-28 and 0-271 THe primary food source available to bald eagles in this area EonSlOtS of dead candidate s~ecies Cattle. road kill deer. dead calves and afterbirths. and ground squirrel3 (Carter. P~PS c." . Isaac8 et al. 1986) Regarding federal candidate wildlife species. the Forest Plan (page 631 and Appendix D (page 0-251 indicate that consultatian wlth the SBPY~CBwill be InYentOPieS and surveys were conducted in 1983. 1984 and winter of 1965-1985 Initiated when COnfliCtS between project activities occur. when habitat needs to locate Winter roost a~eas The 1983 and 1984 inventory resulted in cannot be resolved. when uncertalnty exists. when species management Euldes locating two roosts (Pine Springs Canyon. Miller Canyon1 on the Snow Mountain ape developed OP when Other technical assistame is needed In addltion, Ranger district and one roost an Bureau of Land Management lands accessible inventories Of ersentlal habitats are to be malntalned through Porest Service mad8

Regarding federal candidate plant species. the Porest Plan (page 56. item 11 A 2-year survey which began in the Winter of 1985-1066 was contracted Out by and Appendix D (page 0-18 item 11 indicate that project actlvltles will be Ochoca National Porest to the Oregon Cooperative Wildlife Research Unlt to screened for known and suspected 10CatiOnS of Sensitive (which include federal investigate and locate suspected winter roosts in the Plne Creek drainage. candidate] species When suitable habltsts OP reported locatlons ape Shotgun Creek drainage, Wolf Creek drainage, Sugar Creek dralnnge around Big suwected to occur. a field ~'econna1ssmce 1s to he performed (item 31 Item Snmmltt Prairie and McKay Creek Winter roosts we erpected in these area* 4 indicates that Safeguards will be identified. and project personnel notified because they contain conlferouo trees with suitable characteristics for and held responsible for Implementation of safeguards Item 8 lndlcates that roosting by bald eagles andlor sightings of eagles flylng 2" the dlrection of if other high values or uses would be foregone if the proposed activity were these areas have been noted modified or deferred. additional Study and assessments my be needed before an appropriate course of sctlon is determined with Input from appropriate state Pereerino Falcon and Pederal agencies NO active nests have been observed on the Ochoca National Forest or Crooked River National Grassland NO records of nesting OP nest sites on OchoCO Natlonal Porest are known to exist Peregrine falcon sigbtings noted by OP reported to the PoPest Service and the Oregon Department of Fish and Wildlife 0CC"r at a frequency Of one or two eYerY winter

OCHOBO OH ZE DDISKZ 0111S187 3 Potential habltats for breeding and overwintering by peregPine falcons have EPFBCTS OF THE ACTION not been evaluated to any detail Cliffs. talus, and cave habitats are ea~le available 0" the ochoco National Forest Whlle such habitats may provide Bald sultablc habitat for peregrine falcons. these habitats are currently ocoupied by prairie falcons The plan (page 62) and Appendix (page D-25) itemizes prescriptions to protect bald and golden eagle nest. roost. and perch trees utilized during the The Recovery Plan for Peregrine Falcon (Paclfic Population) indicates a need breeding 888800 While these presqriptions may be ID conformance to the Bald for two breedlng palps in the management unit which Inoluder POPtlODS Of and Golden Eagle Protection Act. they do not Incorporate the best Scientific Ochoco National Forest data available on the protection and management of bald eagles. and thus may not adequately protect essential breeding habitat for bald eagles In OregDD candldate breeding eagles may begin to DCCYPY or establish a breeding territory as early as January 1 However.. since there are no breeding eagles presently on Ochoco FPderal candidate wlldllfe species which may Occur on OchoCo National Forest National Forest. no impaot to breeding bald eagles are anticipated at thle and Crooked RlVer National Grasslands inolude Swainson's hawk. FetTUglnOUE tine from the proposed action hawk western sage grouse. western snowy plover, tricolor blackbird. Spotted bat Townsend's big-eared bat. California wolverine. and California bighorn The biological assessment indicates that tlmber harvest aCtlYitleb and road constructlon could affect bald eagle Ylnter roosting without implenentatlan of available management constraints However. there appears to have been considerable Based upon information. the following federal candldate plant* may all occur on Ochoco National Porest and Crooked River National Grassland8 effort to Identify winter roost site8 whlle not roosts have been Identified to date. surveys are currently belng conducted to identify 0CC"IT.e"Ce status remaining exlstlng and potential winter roost areas in suspected areas an and D 3c adjacent to Ochoco National Forest and Crooked RiYeP National Grassland The s 38 biolaglcal assessment indicates that It Is the intent Of Ochoco National s 2 Forest to Utilize the flndings 06 the surveys and follow the management Astragalus diaphanus s 2 mcommendatlons for preserving the Integrity of actual and potentlal bald Astragalus pegetarioldes s 2 eagle winter roost sites The biological asSeSSment further indlcatee that Calocharus Iongebarbartus peck11 D 2 there management guides vlll be developed with input from Oregon CoOperatlYe Collonla macroc.1yx D 2 Wildlife Research Unit. u s Fieh and Wildlife Service. Oregon Department Of Lupinus blddlei s 2 Fish and Wildlife. and Oregon Natural Heritage Data Base Lupinus suolckil s 2 62) D 0-251 Silene SPuPOsa Yar scaposa s 2 Whlle the Forest Plan (page and Appendix (page indicate that recovery plans will take ppecedence over other management directions. no D - Documented S-Suspected specific Bctjms have been identified In these documents appropriate sections. Or other supporting documents regarding the Inventory and protection or 2 - Category 2 consists af taxa for which existing Information Indicates of potentla1 suitable bald eagle nesting habftat for llstlng may be warranted. but which substantial biological Pel.eKPl"e information to suppwt a proposed rule Is lacking falcon Based upon recorded oightlngs. the peregrine falcon appears to be a rare 38 - Category 38 consists of taxa which are not being conddered for lietlng on the hssis of CurPent taxonomic understanding These taxa mlgrant through ochoco National Forest lands at present the The Ilkellhood could be reevaluated In the futwe on the hasls of Subsequent research that a peregrine falcon would be affected by a forest action at present tllne appear* extremely remote 3C - CatrgoPy 3C consists of taxa which are not being consldered for llstlng on the basis of being more abundant or Wldespread than PPevIoualY Wildlife management guldellnes directed to protect breedlng pr-alrie falcons believed or lack of any identifiable threats These taxa could be and thelr nesting habltat should provide sore measure of protection far peregrine falcons in the event peregrines establish an eyrie aithln OChoCo reevaluated In the future should further research 011 Changes In land Use Indicate a significant decline Nations1 Forest As recovery efforts for the peregrine falcon gain momentum in the Pacific It should be noted that candidate species have no protection under the increase over Endangered Species Act. although additional protection for these species 0BY Northwest. the 1mpoPtanCe and msgnltude of monitoring should the be provided by internal policy next 10 years The level and rate of increase is Impossible to predict with avnllable Information

OCHOBO OH ZE DDISK2 01/15/87 5 OCHOBO DH ZE DDISKZ 01/15/87 e

1-4-17 candidate S~ecles .mioh mandate federal agencies to carry Out programs for the COnserYatIon of listed speoies. we recommend that the following Conservation measures pe Management guidelines hwe been outlined for various raptors which ShoUld implemented to further conserve and avoid adverse impacts to bald eagle9 provide some management for nesting habitat for candidate hawK species wregrine falcon$ and candidate species ow ever. similar guidelines are lacking for other candldate species and "on- breedlng habitat requirements of raptors In addition. inventOLIY and Genbral monitoring procedures are not clearly defined for any candidate wildlife species No implementation plan has been provided for various candidate 1 Management Ateas with known or Suspected essential. critical. or vlldlife species RefePenceE ta inventories are generally made With no potential habitat for listed species should be noted In Section V of the clearly deflned time OP monetary budgets to indicate what minimum led Of FoCeSt Plan lpages 63-98) An alternative would be to designate a separate effort is expected to occur duiing Implementation of the Forest Plan Management Area which provides for the management and Protection of known and suspected essential. Critical. and potential habitats of threatened and It 1s unclear whetWr Or not Items 4 and 6 (See DESCRIPTION OF ACTIVITY. endangered species land Belected sensitive spec~es) This alternative was Candidate species) apply to candidate or only listed plant species should used by the Deschutes National Forest items 4 and 6 apply only to federally listed threatened and endangered plant species and not candidates. then the actlon the forest "111 take on candidate 2 The Monitoring and Evaluation P~0gr.mPlan of the Forest Plan (Table plants or in determinlng the action to he taken on candidate Plants has not V-2. pages 102-109) should be expanded to provide greater detal by species been deflned in the Forest Plan If these Items extend to consideration Of and monitoring objective. i e , bald eagle productivify survey bald eagle candldate species then the ProCedureS would appear to be in place to avoid winter most inventory. bald eagle potential nestlng hahitat survey, p~regpine impacts wherever possible However. if a decision is made to PLIOeeed with an falcon inventory. candidate species and habitat Statu$ determoation habitat aCtlvlty vhlch may or wlll adversely affect a candidate species. the outlined enhancement actions procedures do not Indicate that monitoring of the Impact and/or a Post-PrOJeCt evaluation of affect to the pOpulatiOn will be documented Such information 3 Threatened. endangered, and candidate species should he added as an would provide a valuable basis far consideration of similar aCtiYitleS in the aotion and effect to be monitored under the following resourcelactivity f"t"Pe catecaries Recreation, Timber. Raoga (Forest Plan, page 102-109)

The Sensitive planf Species llst provided in the DEIS (page 13) does not 4 CoOPdinate with the O~egonPatural Heritage Program the oregoo reflect accurate information regarding federal candidate plant species If Department Of Fish and Wildlife. and the Service to exchange information on tnis list is used 8s a baSiS for management decisions and as long a8 a the Status and distribdtion Of threatened. endangered, and candldate (or procedure for the periodlc updating of a candidate species list 1s not sensitive) species This should be added as an item to the section on defined some avoidable forest action9 may have an adverse affect on candidate Threatened. Endangered. and sensitive Wildlife Species In the Forest plan plant species IPEe 62) and Appendix D (page 0-25) Bald ea~le CVXULATlVE EFFECTS 1 Develop sife EpeClfiC habitat management plans for each individual cunulatlve effects are those impacts of future State and private aCt10m which bald eagle "Inter most site and breeding terrltory ~n Informal consultatlon are PeaSonably certain to occur A Don-federal actlo" is 'reasonably cert.31"" with the Service An implementation plan for the development of these habitat to OCCUP iI the acrlon requires the approval of a State or local resouPce or management plans should also be documented in the Forest Plan or referenced in land-use control apeney. and such agencies have essentially approved the the Forest Plan If one already exists action In regard to the bald eagle and pereglline falcon. We know of n0 cmulatlve State or prlvate actlans that wlll occur in areas adjacent and 2 Conduct an inventow of potentlal breedlng habitat Tree stands within OchoCO National PQPeSt at thlh tune with Characterlstice sultable fop nesting bald eagles should be Identified and protected If neCe98aPY. develop management Pres~rlpIlOnEdesigned to preserve or enhance desirable nest tree charwterlstics in lnformal IPCIOENTAL TAKE consultation with the Service An lnrplementatlon plan for conducting this inventory should be developed We anticlpate the Jnc~dental take attributable to implementation of the Porest Plan preferred Alternative E-Departure to be zero IO) 3 Prebcriptlons to protect bald eagle nest tress should be developed in consultation with the SB~YIEB RegaPding the section on Bald and Golden Eagles in the Porest Plan (page 62) and Appendix 0 (page D-26) the Collovlng CONSERVATION RECOMMENDATIONS changes should be made

I" the furtherance of the purpose of Section 2Ic) and 1(aIl11 of the Act. either

OCIIOBO OH ZE DDISK2 01/15/87 1 OCHOBO DH ZE DDISKZ 01/1S/87 8 a Delete all references to bald eagle in this section. and This concludes formal consultation on this project If the pmposal is b Indlcate that Section 7 consUltatlm with Service will be significantly modified in a manner which would change the mpscts on bald initiated in the event bald eagles establish a breeding territory in eagles and/or peregrine falcons as discussed In this Opimon if new I)? adjacent to Ochoco National Porest andlor Crooked River National information is learned about theses specle~that could change the conclusione Grassland lands af this bpinion. if a new species occurring in the area is llsted or if there n. I. IS incidental take of bald esgle and/or Peregrine falcon which exceeds that a Change '%arch 1" to '"January 1". and specified in this Opinion. formal consultatmn should be reinitlated YOUP decision regarding the recommendations presented in this Opinion should he h Indicate that additional management considerations may he sent to this office necessa~yto pmtect bald eagle breeding and "on-breeding hahitats and that these will be determined in consultation with the service We appreciate the cooperation expressed hy your staff members during this CD"S"1 tation 4 Haintain winter Inventories of bald eagle8 which can be used to establish long-term winter population trends PereePine falcon

1 Maintaln records of sightlngs to esfahlish long-term trends

2 Conduct periodic inventories to determine status of the Species on forest lands

3 Identify and p~eservethe integrity of potential nesting and "on- breeding habitat cc OES Candidate Snecies RO-FWB (SEI BPO-SE 1 Adverse impacts to candidate species should be avoided WhePerer OFO-SE possible and technical asoistanoe Sought from appropriate state and federal agencies and academic organizations or institutions when adve?se impaoto appear to be unavoidable When adverse impacts to oandidate species are unavoidable. the effects should he monitored and documented

2 On page 56 of the Forest Plan. the Section onme is mlstltlsd and should read 'Plant" rather than "Wildlife"

3 In the Pored Plan, Peferences to "jeopardiye" on item 4. page 55 should he changed to '"may adversely affect" to avoid confusion with the legal definition of the tern "jeopardize

4 Coordination with the Oregon Natural Heritage Program should be added to the Forest Plan. page 56. item 7

5 An accurate candidate plant list should he provided In the DEIS. page 73 A statement Which clearly definea the procedure and time frame to he used for the periodic updating of plant status information should also be included in the DEIS (page 731. the Porest Plan (page 56). and/or Appendix D [Page D-181

OCHOBO DH ZE DDISKZ 01/15/57 9 OCHOBO DH ZE DDISK2 01/15/87 10

1-4-19 REFERENCES Department of Fish and W/ldl/fe

Carter B 1986 and 1981 Personal communication Ochaco National Forest 506 SW MILL STREET.P 0 BOX 59, PORTLAND. OREGON 97207 end Crooked River Natlonul Grassland Prineville Oregon

IS~ECS.F 1981 -November 10. 1986 Personal Conmunlcatlon Oregon State University, Caoperatlve Wildllfe Research Unlt Corvallls. Oregon

Isaacs. F , T Bryan R Goggans & R Anthony 1986 Habits of Bald Eagles Brown Winterlng along the Crooked River. Crook COUDtY. Oregon. 1986 OPegOn James E State University. Oregon Cooperative Wildlife Research Unlt Corvallis. state Forester Oregon Department of FOreStry 2600 State Street Salem, Oregon 97310 near sim The Oregon Department of Fish and Wildlife staff has reviewed the OChoeO Natronal Forest Plan documents and has attached Comments to this letter

The Ochoco National Forest 1s to be congratulated on therr COmpletLOn Of the Draft E15 and Draft Forest Plan We recognize that this IS a culmmatmn of many years of work by a very dedicated Staff Renew of this plan, years in preparation by many people. in the very short time frame provided, by a small staff 1s at best an arduous task Hopefully we have not misunderstood the LSSUeS Or mformatron PIOVlded Our EammentS and reconmendations are meant to >e COnStIUCtlVe and hopefully Wlll lead to POSItlVe results le frnd no alternative that we can $Upport ~n total The land allocations for :ammoditxes (MA11 and big game (MA2 and 3) are at extremes I" each ilternatrve We feel that there 18 a need far an alternatrve with a better balance of integrated resource eanagement There are xssue ~~SPO~S~S icattered through the alternatives that would meet demand, as we see It, for 'ish and wildlife resources during the llfe of the plan our comments are lased on what we feel are wrldhfe resource needs and we hope our ecomendatrans will be reflected m the selected alternative t should be pointed out at the Outset that we frnd any departuze altematrve blectionable because uzldlife resources would be diminished by overall eduction Of habitat for a short term economic gain Accelerated harvest will Isk recreatLOonal DPPOItUnltles a3Soclated with fish and vrldlife

hLS response to the POIeSt Plan 15 based on our understanding of NFMA and key rov151on5 of the pollcy of the State Of Oregon which, by,statute, in part ec1are ' wildlife shall be managed to provide the optimum recreational and aesthetrc benefits for present and future generatrons Of the citLzens of thzs state In furtherance of thLs PO~IC~,the goals of wldlrfe management are

OCHOBO DH ZE DDISK2 01/15/87 11 James E B~OY~ James E Brown November 10, 1986 NoveGbSer 10, 1986 Page 2 Page 3

3) Roading pose5 a problem for wlldlzfe The Plan 1s 11 TO maintain all species of fish and wildlife at OptLmun managers and prevent the depletion of mdqenous deficient m resolvmq the impacts of roadlng on habltat levels serious any effectrveness and hunting quality SpeCle* 4) Much blg game ulnter Tange on the Forest was not acknowledged as 21 To develop and manage the lands and waters of this state in such. important tzansition ranges omitted a manner that Wlll enhance the productron and publrc enloy- were also lent of wildlife . 5) snag management proposals "111 not meet future requirements for snag dependent species It IS to those ends we reiterate messages we have continued to send forest managers about habitat components that are at risk wlth or beneflt from commodity extractions The State of Oregon needs These flve 1sSUes Wrll be discussed m detarl as Ye address Our plannrng Criteria, but it 15 important that these issues be pointed Out at the Onset 1) Its basic so11 re50urce5 and PTOdUCtlVlty 21 Dependable supplies Of clean water 31 A diverse and dynamic range and forest ecos.ystem5, changing OYCT time and m arrangement with multiple TBSOUTCB management, but never 1051119 It5 Inherent capaclty to delzver ell klnds Of QUbllC benefits 4) Forage nanagement for grazing animals that 1s intolerant of resource deqradatran 5) Management of LIpar'Ian vegetation m a condrtmn meeting 1979 rri interagency Optimal gurdelines Attachments 61 Forestwide management of motorized vehicle use 14- 11 le feel We are eSpOU51ng a TeallStIc and reasonable p05Ltion on the amounts and conditmn Of needed habitats The forest has been Supplied the Depart- aent's forest Planning review criteria as an ard A wealth of research has been compiled that describes what 1s necessary to enhance wildlife and wildlife habitats Our response a150 addresses maintenance of "on-dimnrshing Wntlng OpportUnltles and enhancement Of all wlldllfe related TBSourCeS

In reviewing the plan we find that there are five issues that have not been Satisfactonly addressed

1) Riparian condltvms on the Forest are below standard The Plan dld not follow definitrons or lnventorv methods described ~n ?%"gLng Riparian Ecosystems for Fish'and Wildlife I; Eastcrn Oregon And Eastern Washington, 1979 ' The plan does not place acceptable einphasrs Or directmn for rlpallan Eone TeStoTation

2) Information OD livestock grazrnq 15 not suffreient for an EIS There AS not enough data on aanngcmcnt systems, conditmn and trend, actual use, or rmprovenent programs to evaluate effects of the grazmg QIOgmm

1-4-21 Oregon Department of Fish and Wildlife Comments on Issue TWO Social and Economic

Ochoco.~~~~~. National Forest~~~~ Draft Environmental Imact Statement and Proposed Plan No Comment November 7, 1986 Issue Three L1VestoCk GTaZlng

We do not SUPport an LnCreaSe m the Forest grazrng Program We flnd It This QOrtlOn of the comments deal with how the Proposed Plan addresses the 12 difficult to Iustify continuation of the current gmzmq PIO~ITS~ issues identified by the Ochoco National forest ulth respect to fi5h. wildllfe considering the Standards and Guidelines m the proposed plan The and habitats Plan states that 28 percent of the range re5ouzce 15 m poor condition and 42 percent 1s in fair Condition It a150 state5 'Utilrzatmn of Addltronal comments are added to express the Oregon Department of Fish and IlPaTlan forage by lrvestock range5 UP to an estimated 80 percent m wildlife IOOFW) concerns and recommendations for Forestwide Standards and places . Guidelines, Management Area Standards and Guidelines, and the prOpOSed Honrtoring Plan Additional comments aad 9ueStiOnS on sections of the plan The Forest has mentioned three ltems that would decrease grazing m sow are lrsted under General Comments areas

Is9ue One Tmber ProductmI 11 Farestwide Standards and Guldellnes for Ecosystem Management state ' Encourage recoverage or prevent deterramtion where The PIOposed plan states that the Forest has 495,006 acres of land activities may be leading to poor Condition. downward trend ' suitable for timber productron We recognize that most Of ths suitable tmhe.ber land 1s allocated to intensive timber management Iw1) while 21 MA2 (819 Game Winter Range1 allocates all fall green-up to big lesser amounts are Spread across NAZ, 3, 5, 6, 1, and lo game

The proposed plan allocates 541.0J2 acres to ml general forest whrch 15 3) The two riparian MA's place tlghter controls on grazlng use approximately 52,000 acres m~zethan the suitable timber base With thu m mind and the fact that V~IIOYS BmOnntS of the suitable timber base In order to counter tbis decrease the Forest proposes to increase acreage are m other land allocation there appears to be room to better Utilizatmn I" other a~eas we feel that before an increase in livestock integrate the general forest allocation with other T~SOUTC~allocations AUM's 15 implemented the Forest needs to demonstrate that the above items can be met with the current grazmg program The key to accoaplishmg seven of 11 alternatives allocated zero acres to eltner general forest or the above does not rest solely with range ImPrOVementS. the driving big gam (an all or nothing situation) In alternatives E, E-Departure. factor should be Stronger admmistration Of Forest Grazing Permits The and G the allocation of general forest 1s 7 to 8 times that of big game Forest has the direction and authorley to accOmplish all three 1te.s but wmter range Alternative .A. ellocatron to general forest IS has not elected to do 50 approxrmately 20 times that of big game winter range We have a concern for the utilization level (actual use) of other Salvage Program TO ensure that this program 15 not working in SpeCIfIC vegetatron types Of the Forest, (L e dry meadow, wet meadow, oppo91t1on to and at the expense Of Snag ~blectives, baselrne Snag levels scabland1 We can not address this concern Without allotment use data need to be determined for the defined management area The concern lie5 with malntainlng cover for nongame wildlife species and suitable habitat for state and federally listed plants ks mentioned in the cover letter we do not SUPPOTt a departure alternative due to long-term IL7PBCtS on wildlife, YIldlife habitat and The frrst priority for range raprovesent funds (either RBF or PMI should wildlife based recreation for short-term economic gains, be restoration Of degraded Sites We Urge the Forest to use the key area concept to detcrmne stocking rates and season of we In reference to demand the Proposed Plan (P 141 states 'The Forest does not have the capability to meet local demand for trmber While on Issue Four RlpBr'lan Page 13 the Plan states 'The average annual sale volume between 1975 and 1984 was 13! mmbf The average annual cut, 1975 to 1984 was The Affected Environment 3ectlon on Riparian and Fisheries Habitat 106 mmbf . The average annual cut 15 a reflection of demand and 8s identifies the Importance of riparian zones to wildlife and recreation drsplayed In the figure; above, the Forest was more than capable of use The write-up states "The three most important ~xpa~ianarea meeting local demand We SUPpOxt the harvest level identified in 'The factors .. are stream temperatures, streambank stability and large woody Forest Program for Oregon, 1980 ' debris ' While these are 1npOt'tant factors for fish resources, habitat drverslty and wildlif- values need to be emuhasized 8150 1 2

1-4-22 Region 6 MMR Direction for wildlife states B need for Forests to select a open roads >we OD big game m the Ponderosa Pine type allocated to management mdicatoi species for riparian habitats, if a SP~CI~S1s not General Forest The proposed plan calls fOT malntainlng 10 percent Cove1 selected for riparian habitats the re850115 nust be stated We recommend for big game zn all winter ranges allocated MA-1 Thermal cover 1s one the Forest designate the ruffed grouse a5 a management indicator species element 6f the habltat effeCtlYeneSI eqUBtlDn The PTOPoSed plan further for TIPBT~~"areas Th1s species 1s a good indicator of habitat States 'Evaluate road densities to determine their influence an habrtat conditions and Its poPUlatlOn on the Forest has decreased due to effectrveness for elk Inltlate road ClOSUTeS where approprrate ' What degradation of riparian habitat does the term *where BPprOpZlate' Bean? Roads are hed to habltat effectiveness and should be quantified ODFW belreves road closures are The Forest has selected steelhead, rainbow trout, and brook trout 85 BPPmPTlWe an all Forest land to keep road densities at or below management indicator SP~CL~SWe recommend resident trout be used as an 2 5 mles per section mdlCatOl SpeCleS The Department pollcy for vrld flsh 15 'The QrOteCtlOn and enhancement of wld stocks will be given first and highest We encourage more physical road closures on the Forest that are m consideration ' The Forest recognrtion of wild flsh a5 an indicator addition to the ween dot system These actions would benefit wildlife, BPeCleS Would pIOVlde SUPPOTt tO Department POllCY reduce the potential far resource damage, and maintenance Costs Roading vas found to be the single greatest concern of elk hunters in ODFW elk The QrOPOSed plan addresses the management Of 19,000 acre5 Of Llparlan WOrkShoPS zones on class I and I1 steams Table IV-2 on Page 30 lists streamside Management Unit5 for class I and I1 streams as having 36.016 acres What Issue SIX Habitat for 819 Game IS the basis for the dpparent discrepancy between these figures? The Borest goal for ~ipa~ianarea 1s to 'Maintain or restore the inherent The Affected Environment Section on Wlldllfe does not adequately address values of ~iparianecosystems ' This goal needs to apply to a11 areas the brg game Winter range requirements on the Forest It should include meetlng the defrnrtlon of rlparlan areas, mcludmq all or part Of an how many acres of "Inter range and transition range, as rdentified by big estimated 824 mile5 of Class I11 stream game use, are on the Forest, and why they are LmpOrtant It should also include a land type break-down by Percentage for the winter ranges' In 1978 the Regional Forester signed 'Managing Riparian Ecosystems (zones) For F1sh and Wildlife In Eastern Oregon and Eastern Washrngton What percent of the 72,881 acres allocated to 819 Game Winter Range 15 Th15 document established standards for Optlmum habltat conditions and Capable of neetlng Optimum habltat effectiveness IHEI)? established an rnventory procedure for evaluating rrpar~anhabitats We strongly urge the Forest to fallow the above document In managing the ODFW provlded the Forest Ylth map5 of summer, transltlon and "Inter riparian areas The FOIeSt has not displayed the t'lparlan area5 Or their ranges Attached 15 a map that dlsplays Alt 'E" Mh-2 allOCatlOnS, condrtrons trmsrtlon $,Inter range, and area5 that we feel need to be allocated to Ma-2 These area$ am essential for wintering deer and elk Maintenance Pame. 23 of the prooosed.. plan states that 'The follovm~acres are of the identified winter ranges at optimum HE1 1s necessary to assure enhanced with the COnStTUCtiOn Of the follClWng Structural Improvements, deer and elk PIOdUCtlYltY 3,000 acres of fencing. 300 acres mproved by woody debris additions, 300 acres of log weir COnStrUCtiOn, 50 acres of rock StmctureS, and 50 acres Forestwide Standards and Guideline for deer and elk address maintenance of habltat from shrub plantlngs ' The Rlparlan Improvement Schedule on of viable populations Explarn why the habitat standard has been Set for Page A-4 states 'Rehabrlrtation aCtIVitieS will include 1,175 improvement viable popuh.tlon when the pIOPDSed plan identifies much hrgher acre erruivalents of fencma. seedina ' Which Set of iaDToVenient population level? The standard muat be related to the herd 5128 and ;;sure; would be used Lf the PIOPO8;d plan were Implemented? The Forest distribution to be managed for The fact that blg game habitat IS a needs to pIogral and budget lmpTOYenent pTOleCtS for resldent trout publlc lSsUe would JUStlfY a higher standard than Vlable PDPUlatlOn habitat that 15 separate from anadromous flsh Elk were chosen as an indicator for the big game 155~because they have We feel that S~lverCreek should be allocated to a MA-14 PTeSCnPtlOn a greater sensitivity to man's activities than do deer The failure to sliver creek 1s a major water source with important fish values that use deer as an indicator has resulted m deficiencies in the analysis needs additional PmteCtlOn relating to seasonal deer habitat requrrements The DEIS needs to address the cumulative effects of the alternatives on the deer herds TO ISSW FJW Road Management correct this defickency ne recommend mule deer be used as a management indicator SPBCI~S wth elk We recommend a better distribution Of MA-2 The Plan states that 4 1 miles of road eX15t for each square mlle of allocations across the Forest that meets the needs Of both deer and elk developed area Since most of the road mrleage 15 ln the southern two-thirds of the Forest the road denslty there Could be We do not know how the Forest converted HE1 flgurcs to popu~atlan 5-7 mrlesjsection High road densrtles in the MA-1 area5 would reduce numbers The Forest needs to explain the Ploce55 uned to select the HE1 to a fractlon of OPtlmUm We have a COncezn for the adverse effects 4 3

1-4-23 winter range alloCatlon3 in the preferred alternatrve More dlBCUS6xm The Forest has selected the common flicker as an indicator for Old growth relating to the above may answer our concerns iuniper will the 40 acre old growth iuniper stands be mapped? what measures uill be taken to maintain the old growth juniper stands7 The 10 percent cover standard for the MA-1 areas will not provide enough thermal cover to maintain population levels The hldmg cover element Ne; data from westside pileated woodpecker study rndrcate that this dwrng hunting season would also be deflczent SP~CI~Sneeds more than 300 acres for a core area The area that was studied an the starkey Experimental Forest had a higher snag density than Issue Seven Roadless Recreation that on the Ochoeo With these two pomts in nind we reconmnd that the Ochoco allocate 460 acres to the prleated woodpecker core area for this We SUPPOTt the MA-3 roadless area allocations In Alternative F for planning period Lookout Mountam, Silver Creek, Green Mountain, Rock Creek, and Cottonwood. We recommend that the standard for Tlmber Harvest be changed HOW does the distribution of the old growth prescription (MA-41 fit wth to read 'No Harvest' The intent of MA-9 as stated 1" Pmphas1s. the Malheur National EoreSt? DeJCZlPtlOn, and DeSIred condition Statements 1s to maintain a nomotouzed roadless environment This intent would be lost If timber The PIopmed plan does not contain sufficrent rnformatron to evaluate the harvest 01 salvage were allowed old gmwth situation In order to do so the maps Should indicate which areas are suitable or capable, and the plant CommunrtleS they represent We support the allocatLOns for Deschutea Canyon-Steelhead Falls ~n AlternativeS E and G HOW w~llthe Forest delrneate and manage the 300 acre foraging area for the pileated woodpecker? We recommend that the minimum snag ~izem the Issue Eight scenic value$ faraglng area he 15 inches Research has found thls snag SlZe to be necessary for a prey base of carpenter ants Under the proposed Plan approximately 82 percent of the Forest would be subiect to vegetative manipulation The Forest will need a strong It is important that a number of replacement Stands be designated zn the monitoring program to ensure that so11 resources and plant community plan The numbers should be equal to the expected loss for the next diversity standards and goals are met 150 years

We Support the Scenic Travel Corrrdor allocations m Alternative C The AS 40 percent of the MA-4 areas are capable an equivalent amount of rationale for this Support IS tied to the old growth wldlife species suitable habitat should De retarned, on a drarnage by drarnage bssrs, SPecleJ vlth a StTOng preference for late sUCCeBs10nal habrtats need Until the capable areas reach a Suitable condrtmn Replacement stands trwd corridor to move from one area to the next The Forest Scenic should be managed for 100 percent potential population levels Of PrImBrY Travel Corridors and Rip~~"lanHanagement Areas will help meet that need CaVlty eXCBVatorS Will the travel corridors provide other old growth habitat characteristics beside large old trees? Is~ueTen Firewood Issue Nine Old Growth Our comments on firewood nlll be addressed under Forestwlde and MA Standards and Guldellnes for dead and down woody materlal Region 6 "3 Direction for wildlife lists old growth SPBCIBS for the Ochoco as pileated woodpecker, marten, and northern 3-toed modpscker ISSW Eleven snags The Forest has addressed the pileated woodpecker but not the marten or the northern 3-toed WmdPeCker The Department has data that show that Region 6 MMR DlreCtlOn for wildlife states 'Each Forest wlll determine the northern 3-toed woodpecker occurs on the Malheur National Forest not their management indicator species for this MMR', (Primary cavity far from the Ochoco There 1s no reason ro believe that this species Excavators) The Forest has not selected a MIS for SM~S ODrW does not occux on the Ochoco We do not have data that shows marten use recommends that the Forest use the hairy woodpecker as a MIS for the an the Forest we recommend that the Forest include the 3-toed as an Old ponderosa pine, arxed conifer, white fir. lodgepole, pine, and subalplne growth indicator species for mature lodgepole plna stands We further fir communities We also recommend the downy woodpecker a5 a MIS for the recommend that the Forest select a MIS to replace the marten The s~ze rlparian communities end dispersal drstance of marten UnltS WBS 2150 Intended to meet the needs of other old growth xelated species These Speclel strll need to With a designa$ed MIS fOI 50895 the Forest can establish speciflc be represented, whether or not marten actually earst on the FDIeSt cntena for meeting snag distribution on the Forest In-unit snags should be left as well as clumps to provrde for pllmary a5 well as secondary cavity users

5 6 Region 6 establrshed MMR's for wildlife to Yeet an NFMR requirement Besmnse to Standaids and Guidelines The Forest was directed to use MMR's as a COnStramt for benchmark runs and alternatives that are Commodity oriented The level at xhrch the For the puipose of the DE15 and the PIOpDSed Plan the Forest has defined Forest operates above these constraints 1s established by standards and 7uidelme and standard 85 gudelmes We want to eaphasrze that managing for 100 percent of potentla1 population of prlmary CaYIty excavators does not mean managrng Guideline - An mdication or outlrne of p0li~yOT conduct that 1s not a for 100 percent snag retentLon With thls understanding we "111 make mandatory requirement (as opposed to standard, which IS mandatory1 recommendatrons for snags 1x1 the Standards and Guidelines Review Standad - Performance criteria Indlcatmg acceptable norms or issue ~welve winter Recreation specrflcatlons that aCtlDnS must meet A prrncrple requrrlng a specrflc level of attamnent, a rule to measure aga1115t we recommend that the Forest control use of winter recreation in areas of wintering blg game and bald eagle wintering areas 1 Range: Under Forestwide S h G's no standards have been set except for use on crested wheatgrass Most of the statements appear to be goals We recommend that specific utilrzatian standards be applied to decrease= SpeCle5 A generrc CippTOaCh to Utlllratlon does Dot protect decreaser 5peCle9, and does not Protect Sltes vrth moist SOllS Under Forage Utilization 112 the word 'integrity' 1s SUbleCtive. the Forest needs a standard to measure against to determine protection needs for a riparian zone In t13 state a distance for salt location from water -- establish a standard Under Range Improvements we tecommend establishing standards for protectron of water sou~cesand overflow areas We recommend the following as additional standards and guidelines

4 'PTOteCt newly developed water SOY~CBSwith a fenced exclosure The exclosure will have no gates If B stock tank has an overflow pipe, the overflow should be piped away from the tank Protect the overflow Site as stated above far developed water sources' (Sanrtary water SOUTCBS are a defense agamst disease and parasite transmLss1on between wild and domestic animals and man )

5 'Each Ranger D15tIIct vlll establlsh a PrlOrlty 115t for PrOteCtLng existing water sourccs to the same standard established for new water developments The prlorlty llst Wlll allow for the Protectron Of all eX15tlng Water developments by September 30, 1989"

6 The use Of prescrrbed flTe 65 a method to lmPrDYe forage quality should be designed to PmteCt important browse stands such as mountain mahogany thickets Prescribe burns Should be coordinated mth wrldlrfe bwlogzsts

We support the MA-2 standard to reserve all fall green-up for blg game The fall green-up 1s LmpOItant on tTanSltlOn IangCS and WInCEI range5 not allocated to MA-2 Fall green-up should be marntarned on 811 areas that were dellneatsd as transltlon or vlnter range by ODPW 2 Residue Management In #Iestablish a Forest standard for what nUSt be left ODFW recommends two 1096 012. by 20'1 Per acre and/or two brush piles 010' dla 1 per aCTe except m lrparran areas In rlparlan areas allow for natural accumulatron of dead and down woody material Logs must bc uncharred

7 8

1-4-25 3 Rwarlan: Riparian and SMU and FLsh Habitat 112 include "wildlife hahltat MA-10 AS Stated In our Issue Response the Department does not support PToteCt1O". salvage harvest I" these areas

Please explain what 1s meant by '1s signrficant degradation of water 7 TraanSpOTtatlon System Traffic Management If2 recommend adding the quality'? There 15 a need to establish the standard for water following paragraph quality that addresses sediment In r1Pam.n areas the standard for ground cover should be 80t percent "Road closures for big game will be needed to maintain higher habitat effectiveness and assure hunting quality If habitat 4 50~15. MA-13 and 14 have a standard to 'Maintain 90 percent of the area effectrveness drops below HE1 = 35 roads will be closed' In an acceptable QrOdUCtlYe condrtlon' HOW Vlll the Forest determine 'acceptable productive condition'? Entry to new mads should be designed for easy and effective closure

We have a concern for soil compaction and displacement on the Forest 1 Wildlife. As stated in the Issue response we feel the Forest Should What 1s the background level of soil loss on the Forest? P 117 of DEIS establrsh the borthern 3-toed woodpecker, downy and hairy woodpecker as the Forest indicates 102,000 acres have compacted sorls and that figure MIS and should select 8 replacement species for the marten urll increase to 127,000 acre5 m the first decade What will Lhe long term effect be on productivity from these compacted acres? We also recommend the ruffed grouse and resident trmt as MIS for riparian areas 5 Fragale Areas: when cmsrdermg standards for fragile areas, (scablands. bogs, Springs, we meadows, dry meadows, etc.1 two elements must be Pnmary Cavlty EXEaVatoxS Recommend dropping 111 ThzS IS confusmg and addressed First, Standards to protect the 51te from adverse effects of the specific levels are Identified m the prescriptions management activities, second, standatd5 that protect the values of the edge habitat around the fragile area A standard that allows for Recommend a minimum snag size of 15' for pileated doodpecker forage over-story removal of a portion of the edge while maintaining a screen of areas understory veqetatzon would meet the intent of number 2 Protectmn of fragile areas from adverse grazing impacts may requre fencing 112 The sile of the clumps should reflect the needs of indicator specics

Dead and down woody material In the edges of fragile areas and natural A The area of evaluation should be on a subwatershed basrs openlngs should be marntarned for 100 percent potential popUlatlOn levels B Hard and soft snag5 must be left In harvest Units The Forest should address state and federally listed plants under this C Clumping alone will not meet cavity user needs category and the special management consideration for each SPBCLES or gT0"P of specres Rocky Mtn Elk and Mule Deer I1 end 113 should Set a level Commensurate wlth desired herd numbers not viable population numbers Narntainrnq 6 Txmber Ranagenent ODFW supports the Foreltvlde S L G described under 10 percent cover an one-half of the Forest will not maintain desired herd Sllncnlture we recommend the fullowmg be added to If9 (1st Para 1 *A levels %xem of UnderstoTy vegetatmn will be left along the edge of natwal openings and along roads to reduce the sight distance X2 HOW will Forest Protect SLteS?

Under MA-2 and MA-3 the standards for reforestation Should be driven by Threatened, Endanqered and Sensitive S~ec105 We recommend that a bald big game cover ob)ectrves not an annual or decade timber target Base a eagle most area be established at the Grasslands within 114 mile of Lake need to plant trees on a need to increase or replace cover for big gam Billy Chinook We recommend that the Forest use Criter16 In 'ManaoemCnt of WlnLerinq Bald Eagles. (1918, USFWS) to protect zoost 51tes NA-2 and MA-3 pre~~maercialthm-stockmq rate should be based on cover needs for blg game not Managed Yield Tables The MA-7 Harvest standards would all meet partla1 TetentlOn Of middleground except the TOtatlon age ACtlYltlCS under Partial retention must remain subordinate to the ChamcteriStlC landscape A rotation age of 90 to 100 years wrll over tlnc change the character Of the landscape by removing large mature and Old growth trees The rotation age should be the same as MA-6 10 9 3- 3- See Pesidue Management ac~esAliocuted Yith Ver'roim Plant Communztres., . The statement 'DIVerSitY 1s to be provlded through time' 1s a goal and a legal requirement HOV does the Forest propose to accomplish this task7 Old Growth - Under 'Methods' 5% per year 1s not a method, 1t.S a frequency At Snao Manasenrent As stated m the Issue response the Snag levels by Mh 5% per year It would take 20 years to verify that the MA4 areas are could be higher We recommend the following In place This time period 2s too long for a resource that 1s being managed at a low level We recommend 20% per year Is verified and utilize remote sensing a5 a method to inventory and monitor

*nags - 1 60 108-118a - 1-1 2 snags per acre Recourtend moving snag mformatron on Page 103 under Flsh and 2 100 !?0-3?? 100 Wlldlrfe, Range to Page 102 under Snags i --b 1 5 1OD Anadromous FLsh - 6 100 Reconmend monitorrng for resident fish be included 7 100 8 __ __ Elk Habrtat - la 188 Recormend estsblzshmg on HE1 Management ObpctLYe for Variability 12 100 Threshold 13 100 14 100 so115 - Place stzonger emphasis on prqect level momtoring for compaction a Varies by plant Community and displacement b Forest management would not affect level of snags wecamend that 5 year manitorrng reports be sent to roordlnatrng agencies Snags must be uncharred The recommended height end numbers by 0 8 H are rdentzfled m Thomas (19791 Wconmend that the nonltorrng plan address Dead and Down Wood Materrsl

-02 The plan should reference and support the guidelines for Clrff and rmrock habitats I" 'Wlldlrfe Management m Managed Forests'

12 11

1-4-27 She folloW1ng comments list ho" vel1 the pmDosed plan KCORR~~ICCSrhc FLsh and Wildlife Habitat PInteCtlOn Crlterla for FoIe5c Lands 1:larcn 1985, Affected Envrronment 1 DEIS Reformarred and Revlsed Seprenber 1986) ~ copy dtrachcd -

Veoetation Old Growth The Forest lists 12 plant species from "Rare. Thxeatened, and Endanqered Plants of Oregon', March 1985 HOW will these species 1 Forest will maintam only three Percent an old growth ODFW crlterra and their habitats be protected? is 5.15% 2. Does not mlude narthern 3-toed woodpecker as rndrcated m 2 ODFW sUppOrtS the RNA allocatrons in Alternative E R-6 MMRs 3 The Forest 1s dedicating old growth stands, plan does comply 3 ODFW encourages stricter enforcement of ORV regulations 4 No fuelwood cuttlng, may be raaded in some areas 4 Recommend that the Delmtment Lake rmprovement Prniect be added to the Snags. fish and wrldlife capital investment plan 1 fnventary by TRI compartment or watershed needs to be completed 5 ApBendlx A5 2 will be met, ODFW recommends core mea of 460 acres MA-2. MA-13 Tmber sales - Are the timber sale5 scheduled m MA-3, 3 Not met, Forest MA snag levels va~yfrom 40% to 100% and MA-14 desrgned to neet specrfrc Ylldllfe and IlPaIlan 4 InShG's~ ~ .. Obpctives? 5 Plan does comply

6 Chapter IV of Proposed Plan Dead and Down

P 25 Riparian 'Mameam or restore inherent ~alue5 " Only MA-14 1 In plan. recommend as standard Under residue would meet thu goal Does the Forest propose to lncrease the MA-14 2 save as P1 allocation ~n the next planning process to work toward thxs goal? 3 Plan does not comply Due to the poor CDndltlOn of 50m.e Tlparlan areas TeCOVeTY Wlll be a slow process Hardwoods and M4wr Conifer Species

P 28 Deslred future condltlon "Vegetatlan COmPOlltlOn VI11 change" 1 Would be met under diversity regulrement way to weedy, adventive. and We overtime giving annual species 2~ ....N/A recommend that the forest delete the above paragraph Thls 3 onlx portion of winter range considered, mast of transltton areas and condition IS not desirable and 15 not consistent mth Forestwlde wInteZ ranges not considered standards and Gurdellncs for ECoSygtems Managementffl2 " Encourage recovery or prevent deterloratlon ' R~parlan

P 96 of the Proposed Plan 1 NO map to show locatLon and condltlon What 1s the ratlonale for the difference Of 10' ~n the temgeratule 2 All addressed but no sediment standard standards for the DeSChUtes and John Day r1Ver51 3 Will be met on 19,000 acres of Class I and I1 streams 4 15 planned for Part of degraded area In an effort to have better data and speCleJ lnventorles for the next p1annl.W 5 Yes for a portlo" of area period we recommend that the Forest LdeDtlfY the needs m the statewide 6 yes Comprehensive Fish and Wildlife Plan The Department will cooperate when possible to help gather th15 mformation Meadows, Freshwater Wetlands, Nstllral openings

1 Not sure 2 NO, only 66t ensured - made recommendatton for renamder 3 NO, 2!3 of area will have trees but may not be m natural condltron 4 The Direction IS there 5 oms not comply

13 14 Cliffs, Rim rock, Caves, and Talus Road Management 1 Recommend that Fozest use standards rn (Thomas 19791 1 Only m part Aquatxc Habitats 2 NO 3 Forest wlll attempt to meet these 1 Yes on a limited basis 4 some are 2 NO 1 Yes Grazing 4 For anadromous fish only. recommend monitoring of resrdent tmwt 1 NO In-stream Habitat 1 NO 1 Yes, but not for all acres L4-11 Water Quality 1 Temperature ok (but not for all acres), sediment--no standard 2 Yes Water QYantltY I yes. but not for all acres 2 Yes

Elk and Dee1 Habitat

1 Yes. on 24\ of Forest, ODFW management obiectives w~llnot bc net on w-1 allocatl0"s 2 N/A 3 NO 4 NO drscussion of Current condition 5 Only on portion of Forest and not by geographic area 6 Not m total 7 a Not complete b Not complete

species of Concern 1 Bald eagle a Ye5 b Yes c Yes 2 Peregrine falcon -- N/A 3 Spotted owl -- NlA

I5 16

1-4-29 Departmenf ox Transportation PARKS AND RECREATION DIVISION 525 TRADE STREET SE, SALEM OREGON 97310 'October 30, 1986

Jim Brown State Forester Oregon Oepartment of Forestry 2600 State Street Salem. OR. 97310 Oear Jim: We have reviewed the draft of the Ochoco National Forest Plan with an emohasis on its imoact on the Oivrnan'r~ ~ .~~ ~..~oroovamc - nxkc crmir" waterways. trails. and to recreation in general. Ye have relied on the 1983 Statewde Comprehensive Outdoor Recreation Plan (SCORP) endorsed bv Governor Ativeh and the 1483-89 Oremn.~. State....- Prvkc- ._ System Pldn adopted by the Oregon Transportation Commission

Our reviw paid special attention to the plan's provision for recreational diversity (as shom by the Recreation Opportunity Spectrum). The Ochoco plays an important role in providing outdoor recreation Opportunities in Oregoll. It OrQVldPS hish oualitv huntino and river dependent opportunities as well as winte; nordic k.ivities. It also will become an important trail connector between the Pacific Crest and Desert Trail systems Our specific areas of concern are: 1. Predictions for future recreation use are based on state population growth. Much recreation grows faster than populatioll. Predictions of future use would be better grounded based on historic trends in the Ochoco 2. IJe endorse expansion of the trail system, especially the development of the East-West intertie which will join the Pacific Crest Trail with the Desert Trail 9 lie agree with management of the Deschutes Canyon-Steelhead Falls area to retain wilderness values until designated or released by Congress. 4. We also aqree with maintenance of scenic and recreational values on those described DOrtiOnS of the Croaked. Nnvth Fovk Crdolred and the Oeschuter River until Congresslonil dec~si&'is made. Oregon State Parks has recently completed a state scenic waterway study of the Deschutes from Lake Rllly Chinook wstream. STATE OF OREGON INTEROFFICE MEMO Jim Brown Parks and Recreation Division 378-6597 October 10, 1986 Page 1 TO Files DATE October 30, 1986

$ Major reductions are being made in those lands provldlng Don Eixenberger semi-primitive motorized and nan-motonzed recreational Research Analyst oppcrtunitles. to the extent that demand has or soon wlll outstrip 5upply. The reduction of these OppOrtUnitles pose a SUBJECT Review of Ochoco National Forest Plan. 1986 loss of recreational diversity as delineated by the recreational Opmrtumty Spectrum. We suggest that this issue be reevaluated in the Ochoco. The U.S Forest Service (U3.F S) plays a major role in the provi~ion of recreation In the State of Oregon It is an indispensible element 6. Methods employed to estimate the economic values Of recreation in maintaining a diverse quality of recreational opportumty which will are flawed and result in a serious undervaluation of gain even greater importance as the state's population grows and as recreation. This tundervaluat?on becomes particularly of out-of-state tourism olav5 an even more crucial role in the state's concern ~n those areas of the forest where irreplaceable economy. For example; fiderally administered lands provide over 30% of recreational Opportunities may be traded for low value timber the state's campsites and picnic tables. 50% Of its hiking and bridle resources. trails and 60% Of Its ORV areas. Thus. while the plan States that the U.S.F.S. provides 7 5% of Outdoor recreation natiinally, in Oregon, it We are pleased to offer these comnents. Ifyou have any question5, is likely 3 to 4 times that amount Ifnot more. please contact Don Elxenberger at 378-6597. The U.S.F.$ is a150 the near sole provider of certain types of recreation in the state Much river recreation, snow actlwtles and primitive and semi-primitive recreatlanal opportunity are greatly dependent on public lands managed hy the U.S.F.S. Forests such as the Ochoco form a mosaic of recreational richness and divernty that are irrepl aceahl e.

Recreation MC:jn 1W2D Overall, the plan adequately desc-rbes the general recreational issues in the Ochoco National Forest We have concerns. however. in using state population pmjections In estimating future recreational demand

Forests have varying degrees of recreational attractiveness; actiuties within a forest can have differing rates of demand Some of these may follow population growth; others may greatly exceed it Easing demand on population risks inappropriate planning for future use. Projections based on historical growth rates for speclflc actlvltles would likely be more accurate Disoersed Recreation

The Ochoco has no primitive recreation oppartunitres. excluding wilderness, Its semi-primitive matonred and non-motorized opportunitips are limited Currently, there are some 5q,OOO acres of land erovidinq such experiences. The preferred a1 ternative IE departiirei.wo;ld.reduce this to ahout 12.000 acres or 3 8% of some 843,000 acres of forested land Yet demand for rem-primitive opportunities accardrng to 0.S F.S. data is increasing in the forest

1-4-31 Files October 30, 1986 Page 3

Economic Concerns Ample supplies of developed and roaded natural opportunities exist through all years of the planning horizon. Yet demand for Methodolow semi-onmi tive rotonzed orcsentlv exceeds suoolv bv over 100%: demand ... ~ for &mi-primitive non-motorized in11 exceed supply by the yea; 2005. Each of the 11 management alternatives has a calculated Public Net The pmhlem would not he so crucial if this were an isolated case. But Value (PNV) expressed in millions of dollars. This is the difference the diminishment of both primitive and semi-primitive opportunities is between the discounted value (benefits) of all outputs to which the also projected in other Forests. The reduction of these opportunities monetary values or established market prices are assigned and the total Dose a loss of recreational diversitv as delineated bv the Recreational discounted costs of managing the planning area As such. PNV is a bpportunity Spectrum. estimate of the total monetary benefits gained through the various mixes of tradeoffs across the alternatives The U.S.F.S. is nearly the sole provider of these omortunities. We resource suggest that this issue be reevaiuated in the Ochoib' Perhaps a In formulating these values. a 1 ercent per year real price trend for regional analysis should be made to examine the status of the supply Stumpage was used for harvest Sch!dUIing analyses lhese were applied and demand for primitive and semi-primitive opportunities and the for the first fifty yea% and a 0 Percent price trend was used for the cumulative effects the current round of planning will have on them. remaining 100 yea& bf the planning nonzon. A 0 ercent real rice trend for all other resources vas ,sed dunng the !Jcvelop:ent o? the -Trails EZmarks and the alternatives In other words. tncir futire nominal values will change at rates equal to inflation Accordirg to the plan We endorse the expansion of the trail system, especially the then, recreational resources w~llnot increase In real value: their development of the East-West intertie which will join the Pacific Crest contribution to PNV in real dollars remain statlc throughout the 50 Trail with the Desert Trail year planning period. Wilderness In addition. the contribution of recreational values to PNV were reduced 37.A for use in comparing resource allocation choices. This We agree with management of the Deschutes Canyon-Steelhead Falls area was based in part on dissatisfaction with travel cost methods of to retain wilderness values until designated or released by Congress. determining recreational activity values. To arrive at this 37.5% reduction. the following method war used. Scenic Rivers First it was estimated that nationally, a 5 percent increase in price We aqree with maintenance of scenic and recreational values on those would result in a 1 percent decrease in quantlty of outdoor recreatlon described portions of the Crooked, North Fork Crooked and the Deschutes demanded for a price elasticity of .2 River until Congressional decision is made. Oregon State Parks has recently completed a state scenic waterway study of the Deschutes from p E. = quantity demand Lake Billy Chinook upstream. A copy of this study is available upon price demanded request. It was also estimated that in 1982, the Forest Serwce provided 7 5% of Developed Recreation all outdoor recreatlon and that as a consequence, there wlll be a 5 percent dewease In price for each percent of the 7.5 percent Forest The elan proposer four new developed sites in the Ochoco. According to Market Share or a total decrease of 37.5 percent for Clearing the the State Comprehensive Recreation Plan. the counties influenced by the market In other words, the increase ln supply created by the Forest Ochoco have large surpluses of campsites through the forseeable Service creates a 37.5% decrease In the price of outdoor recreation future. However, as described. several Campsites in the forest are at For example, the initial value of 524 for a day of resident trout peak use and development of new sites is needed and justified. fishing was reduced to $15. Fil es Octoher 30, 1986 Files Page 4 October 30. 1986 Page 5

~lscuss?on Their net effect 1s to seriously confound and underestimate the value The methodology used to estimate the Current and future value of recreational resources and their Contribution to Present Net Value recreational resources merits careful consideration if responsible Conslderatlon of resource allocations in the Ochoco Forest will be planning of OUP shrinking resource base IS to occur. distorted unless appropriate recreation value estimates are refigured throughout the alternatives. 1. Assigmng a 0 percent real price trend for all non-timber resources. including recreation flies in the face of eCOnomlc *Corroharat?on of these points are provided in the accampanyrng reality. The demand for much, if not most. outdoor recreation 1s Comnents by Rebecca L. Johnson. Assistant Professor. Resource gmWlng at an accelerated pace. Economist, Department of Resource Recreation Management, Oregon State Umveriity, Corvallis WhTle these comments were made pertinent Skiing and river-dependent recreation are two prime examples of to the Deschutes NF; the same methodoloqy was used rn the Ochoco and this gmwth. The supply wallable far many of these activ7ties Is 1s relevant to It. sluggish or even static. It is a well established fact that as demand gmws faster than supply. real price increases.

The assumption Of a 0 percent real price trerid gravely undervalues the contribution of outdoor recreation to the PNV of all the a1 ternatives.

2. Adjusting recreational activity values 37 5 percent downward 1s clearly erroneous. The values for many of these activities were generated using Forest Service sites and when Forest Service contributions to the overall supply were present. It is erroneous to assume that the Forest Service land IS an addition to quantity which lowers these values when that land was mapart of the total quantlty when the values were estmated. 3 A nationwide demand elastlclty is likely misrepresentative of the demand elasticity for specific recreation activities and may not be relevant to Oregon and the Ochoco Natlonal Forest 4 It is faulty to assume that because nationally the Forest Service provides 7.5% Of all OJtdoOr recreation, the same holds true for the Ochoco Forest. Also many Of the opportunities offered by the forest have no reasonaolc SLbstltuteS. Uointdin climhinq. wilderness travel, skiing are examples of th7s

5. There IS no reason to believe that Travel Cost methodology consistently Over estimates trip length, and therefore no reason to adjust those values downward as a result of th1s contention * T'lese methods. the 0 perccnr real grodth rate assumption and the further 37.5 percent devaluation of rccreation actlvlry values, are erroneous.

1-4-33 Enclosure If the planners for the Deschutes National Forest are not satisfied Comnents on the Recreation Values for the with the activity Values estimated by the Resource Evaluation Gmup, Oeschutes National Forest P1 an they should make an attempt to find recreation valuation studies which have been done in the Pacific Northwest region for rpecific activities which are pmvided on their forest. It appears that planners want recreation values to be comparable to other forest resource values, and therefore the same effort should be made to find values whlch reflect In sumnarizing the rationale for adjusting the initial values of the as accurately as possible the conditions that exist on the Deschutes Resource Evaluation Gmup. the plan states that TCM values need to be National Forest. adjusted to he comparable with marginal values of other forest outputs lp 1471 The nationwide demand elasticity of .2 is used to show that if the Forest Service quantity of outdoor recreation in the nation by 7 5% (thetr current share of quantity). price should decrease by DE: jn 37 5%. There are several pmblems with this logic: 16filD The prices which are being adjusted downward w~eestimated when the Forest Service land was a part of the total quantity. In fact, man" of the studies which were used to oenerate the mcreation valk were done for Forest Service sit& Studies that were done on non-Forest Service sites would frequently have had Forest Service sites as substitutes, and regional models would have included these Forest Service substitutes directly in the estmation It is erroneous to assume that the Fbrest Service land IS an addition to quantity which will lower these values which were est"- tine when Forest Service land was already~. a Dart of the total quantity

A nationwide demand elasticity for outdoor recreation may be a Daor representation of the elasticity for specific recreation activities. Similarly. the percentage of the total quantity of outdoor recreation In the U S that the Fovest Service land represents may be a pwr representation of the percentage that is relevant in the Oeschutes Uat>onal Fomst If adjusVnnents are to be done. an attempt should be made to use regional or Forest-related factors for adjustment whenever possible Other reasons stated for adjusting the values downward were related to problems wth the TM. lnclud~ngan assertion that TCM studies trplcally ape done for higher quality sites, substitutes are not accounted for. and trip length 1s not accurately measured While any of these may be true for a particular study, several points should be made' -- Values for some activities were based on CY14 studies instead of TCM studies Adjusting these values downward for problems with the TCM is clearly erroneous -- Not all of the studies used single-site TCM models, and therefore an adjustment for substitutes may or may not be necessary There is clearly no single factor to adjust all of the values by to account for exclusion of substitutes - It would vary by site -- Aside from the argument of whether or not TCM studies accurately measure trip length, there is no reason to beheve that trip length IS consistently over-estimated, and therefore no reason to adjust these values downward as a result of this contention Wster Resources Department

3850 PORTLAND ROAD NE SALEM OREGON 97310

A-1 Wak rights wdl be "3, for the water development prqects identifled y1 the rem. NDvwber 12, 1986 I-U potentml developers should be aware of state pol~cles affecting hydXcele&rlc pqeds. mclosei LS, the basm p"~for the area. Thank you for the oppomuuty to revim the report.

- ~~~~ WHYlt ~esourc&&pa6ent h&no preference for any plan finally 0109J select-. Hodever. we recomend that the goal of prowmg water origwW M forest lands be inclcded in anv "em P" hl- AS idenhfied 111 Table Iv-6, The Plan, water yieIds could diminish by a few p""t per decade for the next three decades Data 1s not available to detenqlne if this is the result of proiected preciprtatmn pattenis or management prqmns. me would "wage unplemsntatlon of a mntoritq progam to meanye the effdof various forest lMMgement techniques on runoff. A comprehensive monitarlng program may provide the necessary data for additional evaluation on the effects of Vaxl~management tEchnlques w runoff specific .xumnts - DEIS The DEIS should ahmleage state water resource policies atd the relationshzp to the varmus altezmtzves pzesekd M pages 74 and 175. Pmmsed Plan Page 13 me last sentence in the water section should be clarified as to speciflc meanig. b the sentence mean needs will mtpce water resources or water wlii still be sufficient to meet demaMs?

1-4-35 BEFORE M UAm RESaRCES Co*IlSSlLxI 5. Flows at or near the zero level also ncur under exsting COndltionS on many streams havlng little water under appwdation. OF THE 6. Aqwntation of the rater supply in periods of need Can cmthrwgh mre STATE OF CREGDN efficient use of presently appropriated water. 7. There are many pbsically feaslble storage sites. In the matter of formulating an ) inteorated. CWrdiMted omram ) ahn Day River Basin 8. Available data indicate that the grwnd rater resource is limited. for the Use and control bf the ) water resources of the Job nay Decer 2. 1985. 9. Rand rater represents an wrtant source of rater, prlmarlly In meeting River Basin ) existing dcmestic, livestock, and wnlcipal needs.

10. mere are substantial quantities of unappropriated rater. WHERERS the State Water Resources bard uMer the authority of ORs 536.3CU has Mdertaken a Study of the John Day River Basin as delineated on State Water 11. Over 1,4W,mO acrePeet of the raters of the bom Day River ana its Resources bard Hap, F~le6.70146; trlitutarles We ritMram in 1915 by the State Engineer for Out-Of-basin diversion for irrigation, power and dcmestic plwses. This WitMraral wlfRo\s results of this study have been plblished in the State Water Rewurces anants to mre than the average awldischarge of the Joh Day River at &ax! Report. bM Day River Basin and the Water Rewrces Departrent has HcDaMld Ferry. "Acted further Studies pertaining to the developrent of water resome5 of the basin; 12. No water has been applied to beneficial use mder the aforenentioned WltMraxal. WMREAS in these studies consideration vas given to meam and methods of augnenting, cmservmg and classifying stxh water resources, existing and 13. Utillratim of this withdrawal and its priority will preclude maxi" contemplated needs and uses of rater for dcmestic, mcipal, irrigation, beneficial use of the raters of khn Day River wlthln the basin. power development, industrial, nunlng, recreation, rlldllfe and fish life uses, and for pollution abatement as well as other related subjects ircludlng 14. Mare than 25 Fercent of the land halding water rights is m longer drainage, reclamation, and flood control; and Irrigated. Hare than 75 percent of the rater appwriated for mining and Parer uses is m longer Utilized for these purposes. WH- the water R~SOU~C~SCodSSlon under the autharity Of CRS 536.300 through 07s 536.340 may cla551Py Or establlSh mni" PereWUal St1"flWS '5. me= is need to mvestlgate mdxficatxm or rescission of the on the water resources of the John Day Basin; afooranentioned WItMrarals and -sed rights. mERERS as a result of sale studies the following flndings and c~ncluslons 6. There is need to insure water for mstic, livestxk, mmlcipal, and have been reached by this Codssion: wildllfe uses mlch, mile small. are of great kortance. The total basln yield is adeQ.!dte on an average-year basis to Supply all 7. There is need to aevelop stock rater facilities for better range existing and presently contemplated needs and uses of rater. Utlllzatlon. There are areas where the yield is nat adequate to supply existing needs 8. Irrigatim is and will cmtinue to be the major comuwtive use of rater. during a critical year. 9. Irrigation develc0wnt is restrxted by the limited acreage of bottom land Flows are mt suffxient durrng lO*-flw mnths to meet existing Or future am the unfavorable laation of other arable land. instream or out-of-stream demands. 3. HOSt irrigated lands do mt receive an adewate supply Of water throughwt sirmltaneous use of a major portim of the existing cms-tive water the irrigation season in an average water year and experience severe rights results in Plows at or near the zero level in many StTeamS durlw shortage5 in a critically lor water year. the s-r and early fall rronths. Storage would be wcessary to provide an adequate rater supply for irrigated and irrigable lands. * Hadifies John Day River Bash programs dated April 3, 1964, and April 0, 1981,

-2- Z. The hydmelectric pmer potential of the basin is limited. 23. Existing Stream regimn and rater use iedLfe the desirability or 39. Existing Ildustrlal use 1s more important than fish life use in the river hydrwlectric paler developrrnt In the basin. reach fm sage 14038530 to the North Fork. 24. Present industrial use of water is mall and is mt expected to increase 110. Exemption of md~StIialappllcatians flled before December 2, 19% would materially. allow development or alternatlve sources for eX15ting and future industrial demands 25. mere is potential for ilrreased mining activity. 41. biteria for the determination Of desirable base flows COmenSuTate with 26. Present mining use or water is v~lland is rwt expected to irrrease all beneficial uses of water have not been developed. materially. 42. ADnculture IS a more zmportant use than increasing the exlsting mmlrmm 27. Uateraased recreation is limited by lor seasonal streamflows and the flows on the North Fork Jahn Day. -11 nhrof lakes and reservoirs. 43. Pollution of surface and oround water 1s local, intermittent 1" 28. me natural lakes have sipificant recreational value. OCcurreM'e, and Is not a serious baslnwlde problem 29. the main stem of the Jshn Day River rmn Service mpek Bridge (river mile 44 Utilization of flows to minlmlre pollution should only be permitted If it 157) to Tuaater Falls (river mile 101 is designated as a State Scenic does not limit or conflict with the multiple-purpose objectives for water uatemay. use in the basin.

30. Aquatic life, including fish life, is and will continue to be the maJor 45. Flooding and streambank erosmn are serious local Problems in Some areas mxonswtive use of water. 46 Erosion of Cropland and rangeland 1s a major problem and often results I" 31. a major conflict exists betreen irrigation and fish life u5e of rater. siltation of streams.

32. there is potential for emnc-t of fish life and recreation. 47. Major drainage problems occur on irrigated lands.

33. Storage or other watershed Mnagement measures would be rewired to attain 48. Because of physical and economic factors, ClaSSlflCatlOn Of Certain waters. flows for-enhancenent of fish life and recreation. for llm?ced-purpose use would be in the public interest. 34. Flows recmmed by fisheries agencies are ~ubstantiallyhigher at many NOW THEREFORE BE IT RESOLVED that this Convnission hereby adoDts the follovmg locations than the flow levels that exist during an average water year. program in accordance with the pro~~s~onsof OR5 536 3Ou(2) bertaining to the water resources of the JOhn Day River Basin 35. Maintenance of "tun perennial streamflms wuld benefit fish life, xrldlrfe and recreation. A. The maximum economic development of this state, the attainment of the hiqhest and best use of the waters of the John Dav Rlver Basin. and 36. mirteen minim perennial streamflmis included in the Senate Bill 225 thi attainment of an integrated and coordinated program fo; the (1983) application are located in the Jshn Day River Basin. benefit of the state as a whole will be furthered through utilization of the aforementioned waters for domestic. 11vestmk. mminnal. onlv . ~~ ~~~~~ , ------, 37. me p-sed minim streamflows rould protect rlors during parts of the irrigation, power development, industr~al. minin~, recreatmn, year for inpartant powlations of wild amdroxlus and resident fish in the pollutron abatement, wildlife and fish life uses The Waters of the mainstem J3hn Day River and it5 North, Mddle. arm South Forks; Beech, JOhn Day River Basin are hereby so Classlfled with the following Canyon. COttmwm-3, Rock and Bridge CT&s tributary to the mainstem bhn exceptions. Day River, Clear Creek trihtary to Wale Fork JOhn Dav River. and Gmnite meek tributary to the North Fork John Day River. 1. Ihe maximum eConOmlC development Of this state, the attam"t Of the highest and best use Of the Waters of the natural lakes 38. mnicipal use for Mitchell. Dayville, and Ht. veer- is of greater of the bhn Uay Rlver Basin, and the attainment Of an integrated irrportawe than swwrt of fish lire and shauld be exewted fm mimm and Coormnated program for the benefat of the state as a whole perennial streamflaws will be furthered through utlllzatlon of the aforementloned waters only for domc~tlc, I~vestock, lrrlgatlon or lawn OT

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1-4-37 noncomrrnial garden mt to exceed onehalf acre in area, power developTent rot to exceed 7-112 theoretical horsepower, C. To suwort awatic Ilfe and nfnimlze collutlon. in accorddance with 796. Lars, m rereation, wildlife and fish life uses, and the waters of the sect& 3, Chapter 0" 1983. a&wrlatlan of rater -11 moe or granted by any state agency or pallc covration of natural lakes of the JoM Day River easln are hereby so M classified. thc state for waters of the streams ard tributaries in Table 1 rhen the flows are below the levels specified. TNs limitation shall not apply to: 2. me mxim ecommic developnt of this state, the attairment of the highest and best use of the waters of the ann Day River Imn Service Creek Bridge (river mile 157) Tunwater Falls a. Water legally stored or released lmn storage. to oanestic and livestcck uses. (river lo). and the attalrmnt of integrated ard b. mile an C. Fork ;bh cmrdinated prcgram for the benefit of the state as a *hole will Hnicipal uses on Bridge Creek, Wth Day River, and be furthered thmugh utilizatlm of the aforemntiwred waters th? &inDay River fmUSGS gage 14038530 to the North Fork. only for dcnestic, livestock, dclpal, irrigation, industrial, d. Inastrial use rights and In&strial use under pnnits with mining. recreation, wildlife and fish life uses; priority dates before k" 2, 198.5 on the John Day River fmn UYjS gage 140385x1 to the North Fori(. 8. For the purpose of mintaining a minim peremial streamflow sufficient to s-rt aquatic life, no apprcpriations of rater except Attahtmt of the specified flow levels during yme portion of the far dmstic or livestock uses shall be made or granted by any state yeas rill -re use of stored rater or other wasures to augrent amyor pblic corwration of the state lor the waters listed below flows. and as stom in Table 1: D. Rpplicatims for the use of the waters of the Job Day River Basin 1. The HiWle Fork John Day River above its muth or of its shall mt be accepted by any state ageocy for any other use and the tributaries for rlaws of the Middle Fork John Day River at USGS orantim of awlications for 5u3h other uses is declared to k Gage 14-0440 at Ritter '(511 114 NU 1/4 Section 8, Township 8 irejudlclal to'ihe wlic interest and the granting of awllcatlons south, Range 30 East) blow 10 cdox feet per second masured for suh otmr LSCS rould be mntrary to the integratea and at said gage except that this limitation shall not awly to coordinated program for the use and mtrol of the uater cewrces of waters legally Stored or legally released fmm storage. the state. E. 2. me North Fork John Day River above lomr WS Gage 144415 Rights to use of rater for Mstrial or mining purposes granted by near Dale (Y 1/4 SE 114 Section 35, Tmship 6 South, any state agerry shall be iswed only on condition tMt any efflwnts or ret- flws fm wrh uses shall mt interfere with other Barge 31 East) or of its tributaries above said gage for flws benefitial uses of water. of the North Fork 33h- Day River below 35 cublc feet per SeCOCK measured at said gage except that this lhtatian shall not apply to waters legally Stored or legally released from storage. F. Stmtms or Wrks for the utllizatim of the waters in ammarre wLth the aforementioned classlficatlons are also declared to be mless 3. North Fork John Day River above its muth Or Of Its prejudicial to the Wbllc interest plamd, constmted and me the of trlbutarleS for flows Of the North Fork John Day R1VBr at US operated in conformity with applicable provisions CRS 536.310 Gage lLCUM1 at Honment (SE 114 Section 2, Tmshlp 9 Wth, and any slrh Stmtures or lori(s are further declared to be Range 27 East) below 55 cubic feet per second marmd at sald prejudicial to the palic interest .Imich do mt give mgnirance to gage except that thls llmltatim shall mt apply to waters the rmltip1e-pnpose carept. legally stared or legally released from storage. ited December 2, 1985 me Day River above LEGS 14-0545 at Service Creek (N 112 4. om WAE? CaMIsS?.CN Settion 18. Townshill 9 South. Ram 23 East) or of its AESLXRCES tributaries. above sald gage for flois of the John Day River below 30 cubic feet per seCond measured at said gage except that this limitation shall mt apply to waters legally stored or legally released fmm stora9e. 5. me Job Day River above its mth or of its tributaries for flows of the John Day River at USGS Gage 14-0480 at Hmnald 184 Ferry (NW 114 Sectlon 11, Township 1 North. Range 19 East) below 20 cubic feet per second measured at Said gage except that tns limitation shall not apply to waters legallv stored or legally released from storage

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1-4-36 BEFDRE M WAiER RESJYSCES CCmISSICN

OF THE

STATE OF WEON

In the matter of fomulating an ) integrated, Coordinated pmgram ) JOM Day River Basin for the use and cmtrol of the ) water reswrces or the bhh Day ) Decdr 2. 1985. River Basin 1

M(EREAS the State wqter Res~ur~esBOard under the aumrity of [Rs 536.300 has undertaken a study of the John Day River Basin as delineated on State Water Resmes bard Hap, File 6.70146;

lMREIls results or this study have been plbliskd in the State Water R-es Board Report, John Day River Basin and the Water Resources Departnent has Cmckted lmther studies pertaining to the developeat of water mmesof the basin;

mEREAS in these studies CmSideratiW was given to mans and methods of augnenting, cmserving and classifying such water reswrces, existmg and contemplated needs and uses of water for danestic, mnrcipal, irrigation, wuer develwnt, industrial, nunhg, reereation, wildlife and fish llfe uses, ad for pollution abatement as well a5 other related subjects lrrluding drainage, reclamation, and flwd control; and

WH- the Water ReSmes Comnissim under the authrity of [Rs 536.300 thrmgh acS 536.3Ia may classify or estabhsh mni" perervual Streamflows m the water resources of the &hh Day Basin;

WEQEXS as a result Of Said studies the follaing findings and cmlusions have been reached by this Cadssim: 1. The total basin yield is adewate on an average-year basis to supply ail existing and prese+ly contemplated needs and uses of rater. 2. here are areas where the yield is mt adequate to supply existlng needs dming a critical year.

3. Flows are cot suffxient &ring lox-flw mnths to meet existing or future instream or Wt-of-stream dmnds.

4. Sirmltaneaus use of a major portim of the existing consmtive water rights results in flas at or near the zero level in many stmams dullng the smmr and early fall mth5.

1-4-39 22. The hydroelectric power potential the basin limited. 5. Flow at or near the zero level also occur under exlstlng conditions on of is many streams having little rater under appmpriation. 23. Existing stream reglnen and watPr use redwe the desirability of 6. Picpentation or the rater supply in periods of need can cmthrwgh rare hydrDelectrie power developrrnt in the basin. efficient use of presently appropriated water. 24. Present industrial use of water is mall and is not exwcted to increase 7. mere are many physically feasible storage sites. materially. 8. Available data indicate that the ground water resource is limited. 25. There is potentid for irrreased mining activity. Qand rater represents an inpartant source rater, primarily in meeting 26. Present mining use of rater is mll and is not expected to irrrease 9. or materially. existing danestic, livestock, and nunicipl reeds. 27. Water-based recreation is limited by lor seam1 streamfloxs and the 10. There are substantial quantities of unappmpriated water. mll nmber of lakes and reservoirs. ll. Over 1,4W,mO acre-feet of the waters of the JoM Day River and its 28. me natural lakes have siglificant recsatimal value. tributaries meWitMram in 1915 by the State Engireer for out-of-basin diversion for irrigation, and daoestic power pu~poses. This rith3raual 29. The main stem of the &n Day River rmService Creek Bridge (river mile amunts to mre than the average amual discMrge or the Job Day River at 157) to TUnvater Falls (river nile 10) is designated as a State Yenic Hd)oMld Ferry. Waterway. 12. has been use the No rater applied to tenefxial mder afarmntioned 30. PqUatiC lncludlng fish life, and Wlll CmtlW to be the major withdrawal. life, IS norrmsUnptive use of water. 13. Utilization Of this withdrawal and its prlorlty Will PreClUde MXi" 31. A major conflict exists between irrigation and fish life use of water. beneficial use of the waters of &n Day River within the basin. 32. There is potential for enhancenent of fish lafe and recreation. 14. Hore than 25 percent of the land holding rater rights is no longer irrigated. &re than 75 percent of the water appmpriated for mining and 33. Storage or Other Watershed maria-t measures wwld be required to attain power uses IS m lmger utilized for these purposes. flows for.e.Wancment of fish life and recreation. 15. There is--need to investigate mdlfication or resclsslon of the 34. Flws recamended by fisheries aggcies are substantially higher at many aformtioned withdrawals and Mused nghts. locations t,kn the flow levels that exist during an average water year.

16. There is xed to insure water for darrstic, livestack, micipal, and 35. Maintenance of minimm wrmlal streamflows rould benefit fish life, wildlife uses rhich, vhle mall. are of great importance. vildlrfe and recreation.

17. There is need to develop stock rater facilities for better range 16. mirteen minlrma perennial kluded in the Senate Bill 225 Utilization. streamflors (1983) application are located in the john Day River Basin. 18. Irrigation is and will continue to be the major cmswtive use of water. 17. me proposed ninimm streamflows rarld protect flow during parts of the year for inpartant populations of wild anadrumus and resident fish in the 19. Irrigation dewlcwent is restricted by the limited acreage of bttm land maln2tem John Day River and its Narth, Mddle, and Swth Forks; Beech, and the unfavorable locatim of other arable land. Canyon, CattmrOOd, Rock and Bridge CTeeks tributary to the mainstem John Oay River; Clear Creek tributary to Middle Fork John Day River: and 20. Host irrigated lands do not receive an adequate supply of water throughout Qmlte Creek tributary to the North Fork John Day River. the irrigation season in an average water year and experience severe shortages in a critically low water year. 8. lnicipal use for Hitchell, Oayville. and ut. Ver- is or greater iwortance than Swwrt of fish lire and should be exewted fm mi"m 21. Storage !mula be necessary to pmvide an adewate rater supply for perennial streamflors. irrigated and irrigable lands.

-3- -2- nmcmrcial gaxden mt to exceed me-half acre in area, p0.m developnent mt to exceed 7-112 theoretical Mrsewwer, 39. Existing industrial use IS more important than fish life use in the river recreation, wildlife and fish life uses, and the waters of the reach from oage 16038530 to the North Fork. naturalclassified. lakes of the John Day River Basin are hereby so

40. Exemption Of industrial app11cations filed before December 2, 1986 would allow development of alternative sources for existing and future 2. me maxim ecomic developrrnt of this state, the attaiwnt industrial demands. of the highest and best use Of the waters Of the John Day River fmServlce Creek Bridge (river mile 1571 tO Tmater Falls 41 Criteria for the determmatmn of desirable base flows comnensurate with (river mile 10). am the attalrment of an integrated arc all beneficial uses of water have not been developed. cmrdinated omram for the benefit of the State as a *le will be furthered t&h utlliiatiM of the aforementimd waters 42. Agricdture 1s a more important use than increasing the existing minmum only for dmstic, livestcck, mnicipal. irrigation, imstrial, flows on the North Fork jOhn Day mining, recreation, wildlife and lish life uses: 43 Fbllution of surface and OrOUnd water is local, intermittent ~n 0. For the w-se of mintaining a mini" premia1 streamflor occurrence, and is mt a seriaus basrnvrde problem. sufPicient to support awatic life. na apprcpriations of rater except for dcmestic or livestcck uses shall be made or granted by any state 44. Utllizatl~nOf flows to mmimze pollution should only be permitted if It amyor pbUc corparation of the state for the vaters listed below does not limit or Conflict with the ~lltiPle-Purpose objectives for water and as shavn in Table 1: use in the basin. 1. The Middle Fork JDhn Day River atom its muth or of Lts 45. Flooding end streambank erosion are serious local problems in some areas. tributaries for flows Of the Middle Fork John Day River at USGS Gage 14-0440 at Ritter (SH 1/4 MI 1/4 Section 8. Tomshlp 8 46 Erosion Of cropland and rangeland 1s a major problem and often results I" Swth, Range 30 East) below 10 CUblC feet per SeCMd EaSured siltation of streams. at said gage except that this limitation shall not apply to waters legally stored or legally released fmm storage. 47. trajor drainage pmblems occur an irrigated lands 2. The mrth Fork ~ohnDay River atove fomr LEGS Gage 14-041.5 48. Because of physical and economic factors. classlflcatlon Of certaln waters near Dale (9114 9 114 Sectlm 35, TOmshlp 6 South. for Im?:ed-purpose use would be in the public interest Range 31 East) or of its trihltaries abme said gage for flas of the North Fork JDhn Day River below 35 CUblC feet pr 5WOm NOW THEREFORE BE IT RESOLVED that this COmnlSSlOn hereby adopts the followmg measured at said gage except that this limitation shall mt program in accordance with the provisions of ORs 536.300(2) Pertaining to the 'apply to waters legally Stored or legally released from storage. water resources of the John Day River Basm 3. The North Fork John Day River above its mjuth or of its A. The mxiwm economic development of this state, the attainment of the tributaries for flows of the North Fork John Oay River at USGS highest and best use of the waters Of the John Day River Basin, and Gage 14-0460 at HOmt (SE 1/4 Section 2, Tomship 9 Scuth, the attaiment Of an integrated and coordinated progam for the Range 27 East) below 55 cubic feet per second measured at said benefit of the State as a whole will be furthered through Utilization gage except that this lmitatim shall not apply to waters of the aforementioned wetms only for domestic, livestock, rmmclpal, legally stored or legally released from storage. irrigation, power development, industrial, mnina, recreation, pollution abatement, wildlife and fish life uses. The Waters of the 4, The Day River abve uy;s 1u-0465 at ServIce Creek (W 112 John Day Rlver Basin are hereby SO classifled wlth the followln0 Section 18, Tomshw 9 Swth, Range 23 East) or Of its exceptions tributaries abve said gage for flas of the John Day River below 30 cubic feet per second measured at said gage except that 1. The maximm economic development of thls state. the attamment this limitation shall mt apply to waters legally stored or Of the highest and best use of the Waters of the natural lakes legally released fmm storage. Of the jOhn Day River Basm, and the attalment of an integrated and coordinated prooram for the benefit of the state as a whole 5. The John Day River above its muth or of its tributaries for will be furthered through Utili2atlon of the aforementmned flows of the John Day River at u9X Gage 14-0480 at Md)onald waters only for domestic, I~vestock, irrioation of lawn or Ferry (NH 114 Section 11. Township 1 North. Range 19 East) below 20 cubic feet per second measured at 5814 qage except that ths limitation shall cot apply to waters legally stored or legrily released from storage.

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-4- 1-4-41 C. To support awatic life and nlnimize pollution. in accordawe with SRtia, 3, Cbapter 796, 0- Las, 1983, m awrwriatlw of rater shall be made or granted by any state apzmy or phlic corporation of the state for waters of the Streams and tritutaries in Table 1 *hen the flows are below the levels Specified. ihis limitation shall not apply to: a. Water legally stored or released fmn storage. b. Danestic and livestcck uses. C. Hnicipal uses on Bri* beck, south Fork Job Day River, and the bin Day River fm UES wge 14038530 to the North Fork. d. Industrial use rishts and indstrial use uvler PermLts with prlority dates k6re L!emTber 2, 1986 on the JDhn Day River fmUSGS gaw 14m85x) to the North Fork. Rttaht of the wecified flw levels during sae portion of the year will mire use of stored water or other measures to amt flows. D. Pwlicatims for the use of the waters of the &tm Day River Basin shall not be accepted by any state agency for any other use and tk grantins of applications for mh other uses is declared to be prejudicial to the phllc interest and the granting 07 awllcaticns for such Other uses ddbe mtraly to the integrated and cmrdhted prqram for the use and Nmtrol of the rater reyIurces of the state. E. Rights to use of water for Mstrial or nldw purposes granted by any state agerry shall be issued mly on cmdltlon that any ePflUents ox ret- flms fm wrh uses shall not lnterfere wlth other benefikial uses or water. F. Stnrtms or mrks lor the utilization of the waters in amrdance wlth the aformtiowd classifications are also declared to be prejudicial tn the plbllc interest tnless plamd. constnrted and operated in confodty with the applicable PrDvisions Of ORs 536.310 and any such stmtu~esm *m*s are further declared to be prejudicial to the pallc intereSt rNch do mt give coglizance to the rmltip1eprrpose mncept. Dated Decen&r 2, 1985 WATER RE9xRz25 Co+ussI(N

-6- BEFORE THE WATER POLICY REYIEW BOARD 4. Augmentatmn of the water resources can be achleved through storage OF THE of surplus winter and Spring runoff; reduction of storage, rhannel, and transmission losses; and more efficient use of presently STATE OF OREGON appropriated water. 5. There are physlcally feasible Storage Site5 In the basm. 6. Unappropriated waters of the Deschutes River and its trlbutarles above Bend, Tumalo Creek above Colmbla-Southern Canal, Crooked I" the matter of formulating an ) OeschUteS River Basin River, OChoCo Creek and Whrte River and Its trlbutarles have been integrated, coordinated Program ) withdrawn for special uses. for the. ~ use~~~ and~ control Of the ) November 29, 1984* water resources of the Deschutes 7. The establlshed llrmted purposes of existing Storage developments River ~asm ) restrict multiple beneflcial use of the water resources. 8. The existence of ground water has been eStabLShed in certarn WHEREAS the State Water Resources Board under the authority of ORS 536.300 sections of the basin, but quantities have not been determined. completed a study of the Deschutes River Basin, 9. omestlc, livestock, and municlpal uses of water, while important, WEREAS results Of that study were published in State Water Resources Board represent mnor quantities in existing and Contemplated future water Report, Oeschutes River Basin, dated January 1961; Use.

WHEREAS the Water Policy Review Board under the authority of OR5 536.340 may 10. Irrigation 1s and w~11contlnue to be the major consunptlve rater use reclassify the water resources of the Deschutes River Basin; in the basm.

WHEREAS the Water Pol~cyReview Board under the authority of ORs 536.300 and 11. Adequately rrrqated agricultural lands represent only a small 536.3UO has undertaken a restudy of the water re5ources Of the oeschutes Rlver portion of the total irrzgated area. Ba*1", 12. The exlstmg Irrigated acreage could be more than doubled pIOVidlng WHEREAS in this study consideratlo" was. glven to means and methods of an adequate supply of water were available. augmenting, conserving, and classifying Such water resources, existing and contemplated needs and uses of water for domestic, municipal, rrrqation, 13. The basin has substantla1 potentla1 for power development. power development, mdustrlal, mlmng, recreatlon, Wlldllfe and fish llfe uses, and for pollutaon abatement as Well as other related subJects including 14. The basln has potential for mdustrml development. drainage, reclamatLon, and flood Control; and 15. Sufficient water rill not be available in many locations for major WHEREAS as a result of said study the followmg findings have been reached by water-using lMUStrleS without PrDVlsion for seasonal storage, this Board acqusition of existing rights, or development of ground water resources. 1. lre total q.mti:y of hater 15 SLffitlent on an average year basis to Satisfy all existing ann conrer?plareo needs and uses Of hater *it" 16. The use of water for mnmg purposes is Sllght and 1s not expected to tte exception of ~r~lizationof wter to min~mlzepollLtlon. increase materlally An the foreseeable future.

2 Flows are not sufficient on many streams during the Sumer months Of 17. Recreation 1s a major use of water and an important factoI ~n the average water years to supply exlstlng and future demands. economy of the basin. 3. Simultaneous use of a major portion of existlng Consmptive rights 18. There 1s an abundance of resewxrs, lakes and streams available for resuits I" flows at or near the zero level on some streams during the rater-based recreation in the western Portion of the basln. smer months. 19. There 1s potentul for more extensive use of exlstmg waters for recreation @urpcses. Modifies DeSChutes Basin Programs dated February 20, 1962; May 24, 1962, April 3, 1964, May 26, 1967, July 7, 1978, January 10, 1980, flprll 1, 1980 and Aprll 4, 1981

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1-4-43 20. In the area of intermittent streams, reserv~irs provide water-based 35. criteria far determination of desirable base flows comnensurate with recrea.ion. all beneficial uses have not been developed. Flow levels for recreational use may be Substantially greater than flows recomnendeo 21. Water consumption by wildlife does not represent a significant for the support of aquatic life. quantity. 36. It is imperative that ungle-purpose development of available sites 22. A major conflict exist6 between m-Lgation and fish llfe use of water. does not preclude optmum utilization of the resource. 23. A major conflict exists between power and fish life use of water. 37. Certain major rivers, or river sections, and nmrous lakes, minor streams, and creeks are by nature of then physiography, locatlo", 24. Reduction of present reservoir and stream level fluctuations, land ownership, or econmc potentral available only for limted maintenance of minimum reservoir levels and unproved streamflows resource uses. would enhance fish life and recreation. 38. Physical features, degree of economx development, and water use 25. River related recreation 1s important to the economy of the upper requirements vary from subbasin to subbasin. DeSChUtes Basin. NOW THEREFORE BE IT RESOLE0 that for reason of variance m physical features, 26 The Support Of resldent and Stocked fish is essential to degree of economic development, and water use requirements from subbasin to river-related recreation. subbasin, the Board adopts the following findings and issues program statements for each of the subbasins of the DeschUteS River Basin. 27. Recomnended base flows Suggested by fisheries agencies are substantially higher in many locations than flow levels that can be obtained during average water years under current stream regimen and FER DESCHUTES RIVER existing water rights and priorities. WHEREAS the State Water Resources Board Under the authorrty of ORs 536.300 has 28. Storage and scheduled releases of excess winter and spring runoff, undertaken a study of the Upper DeSChUteS Rmer Basm as dellneated'on State reduction of channel and transmission losses, Or aCqUlSltLon Of Some Water Resources Board Map, File 5.7014; existing rights would be necessary to obtain the flows reconwended by f15heries agencies The economic feasibility of such measures has WHEREAS in thlS Study consideration Was grven to means and methods of not been determined. augmenting, conserving and classifying such water resources, existing and contemplated needs and uses of water for domestx, mumclpal, mrlgatlon, 29. Pollution Of surface and ground water 1s not a signlflcant problem at power development, UldUStrial, Mining, recreation, Wlldllfe and fish llfe present. uses, and for pollution abatement as well as other related subjects includmg drainage, reclamatlbn, and flood control, and 30. Floods, drainage and Streambank erosion ale not maJOr problems. MREAS as a result OF said Study the fallowing findings have been reached by 31. uajor foreseeable quantitative uses of Water in the DeSChUteS River this Board: Basin will be for Irrigation, power, recreation, and fish life uses. 1. The total quantity Of water 1s Suffxlent on an average-year basls to satisfv all exrstmo and COntemDlated needs and uses of water wlth 32. Utilization of flows to minimize pollution should not be permitted if such use limits or Conflicts with the multiple-purpose concept. the exception of utlilration of water to minu" pollutwn. on 2. There 1s not enough water legally available on a critical-year basas 33. Establlshwnt of restrictions further appropriations would prevent I an increase in depletion potential on some streams which would aid in to meet existing and contemplated consumptive needs within this basln. maintaining minimum flows. 3. Maldistribution exists with regard to physical location and with 34. Where Streams are seasonally Overappropriated, the establishment of respect to availability during time of need. restrictive actions would have no immediate physical effect until additional flows become available 4. Many streams do not provide enough flow for present nonconsmptive public uses in periods Of relatively low as well as critical flow.

-3- -4- 5. Augmentation of the water resources m permds of need Mould require 24. Utilization Of flows to minrmlze pollution Should not be pemtted if *torage Of surplus runoff. Such use interferes with the multiple-purpose concept.

6. There are physically feasible Storage sites in the basin 25 Certain lakes are, by nature of their physiography, location, land ownership, or econmic potential available only for limited resource 7. The existence Of ground water has been established in certain use. sections of the basin, but quantities have not been determined. 26. The maximum beneficial use of the waters of the Upper Deschutes Rlver 8. A11 unappropriated waters of the Deschutes River and its trlbutanes Basin will be for domestic, livestock, mumcipal, irrigatron, power above Bend have been withdrawn by the State Engineer for dmestx, development, mdustnal. mmlng, recreation, mldlrfe and fish life irrigation and power purposes. use*.

9. A major portion of the withdrawn waters has been appropriated. Id)W THEREFORE BE IT RESOLVED that thls Board hereby adopts the folloring program in accordance with the provlslons of ORs 536.300(2) pertalning to the 10. There 1s need to insure water for domestic, livestock, and municipal water resources of the Upper Ceschutes River Basin. uses which, while small, are of benefit to the state. a. The maximum ecomic developnent of this state, the attainment of the 11. Irrigatm use of water is small in this basx and is not expected to highest and best use of the waters of the Upper Deschutes River increase materially in the foreseeable future. Basin, and the attairment of an mtegratea and coordinated program for the benefit of the state as a whole will be furthered through 12. Substantial quantities of water have been appropriated for irrlgatlon utilization of the aforementioned Yaters only for domestrc, use m downstream basins. livestock, municipal, irrigation, power development, mdustrial, mining, recreation, wrldlife and flsh life uses and the Waters of

21. Pollution Of surface and ground water 1s not a significant problem. 1. Maan and livestock consumption. 2 Water legally released from storage. 22. raina age and reclamation of drained lands are not significant factors in present and contemplated water use attainment of the specified flow levels during some portions of the year will require development of water storage Or implementation of 23. Flood problems are minor. other measures to augment flows.

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1-4-45 c C. AppllcatlOnS for the use of the waters of the Upper Deschutes Rlver Basin shall not be accepted by any state agency for any other use and the granting of applications for such other uses is declared to be preJudLcla1 to the publlc mterest and the grantlng or applications for such other uses would be contrary to the integrated and coordinated program for the use and control of the water resources of the state. c 0. Rights to use of water for industrial or mining purposes granted by 0 any state agency shall be issued only on the condition that any effluents or return flows from such uses shall not Interfere With c other beneficial uses of water. 0 E. Structures or works for the UtilLZation of the waters m accordance with the aforerentinned classifications are also declared to be

0c premdicial to the public interest unless planned, constructed and operated in conformity with applicable provisions Of ORs 536.310 and any Such structures or works are further declared to be prejudicial c to the public interest which do not glve proper cognizance to the 0 multiple-purpose concept.

n MIDDLE DESCWTES RIVER 8 WKRERS the State Water Resources Board under the authority of was 536.300 has c undertaken a study ofthe Mlddle Oeschutes River Basin as delineated on State 0 Water Resources Board Map, Flle 5.7014. WKREAS in this Study conslderatlon was given to means and methods of c augmentmg, conserving, and class1fylng such water re5ouIce5, existing ana 8 contemplated needs and uses of water for domestic, munlmpal. Irrigation, power development, industrial, mining, recreation, wlldllfe and fish life uses c uses, and for pollution abatement as well as other relatea subpots including 8 drainage, reclamation, and flood control; and WKRERS as a result of sald study the following findlngs have been reached by this Board cz 1. The total rluantrty of water 1s sufficrent on an average-year basis to satrsry all existing and contemplated needs and uses Of water in this s basin with the exception Of Utilization of water to mmrmlze 0 pollution. 2 Maldlstnbutlon exist5 with regard to Physical location and uith g respect to availability during time Of need. 0 3. Simultaneous use of a mapr portion of existing consumptive rights results in flows at 01 near the zero level on many streams during the smer months.

m4u -8- 4. The existence Of ground water has been established Ln certain 21. Base flows recommended by fisheries agencies are substantially higher sections of the basin, but .wantities have not been determined. ~n many locations than flow levels that can be Obtained during average water years under current stream regimen and existing water 5. There are legislative restrictions on the use Of waters of Tumalo rights and pr10rltleS. Creek. 22. Pollution of Surface and ground water 1s not a significant problem. 6 There is need to insure water for domestic, livestock and municipal uses which, while small, are of beneflt to the state. 23. Major foreseeable quantitative uses Of water will be for irrigation,

.Ioower. recreation and fish Lfe. 7. Irrigation 1s and wrll contlnue to be the major EODSUmptlVe Use of water. 24. Utilization of flows to minimize pollution should not be permitted if such use limits or conflicts with the multiple-purpose concept 8 Natural flow and present degree of regulation are lnsufflclent to satisfy existing irrigation requirerents 25. Mamtenance of minimum perennial streamflows would generally benefit recreation, wildlife and fish life. 9 Water supply will be a limiting factor in developing potential irrigable land. 26. Criteria for determination of desirable base flows cmensurate with all beneficial uses of water have not been developed. 10. Augmentation of the water resources in periods of need can be achieved through storage of surplus winter and Spring runoff, 27. Certain river sectmns, mnor streams, creeks and lakes are by nature reduction of storage, channel, and transmission losses; and more of their physiography, location, land ownership, or econmic efficient use of presently appropriated water. potential available only for limited resource Use. 11. There are physically feasible storage sites. 28. The mG” beneficial use of the waters of the Middle Deschutes fiver Basin will be for domestic, livestock, munlclpal, irrigation, 12. There is substantial potential for power development. power development, industrial, minmg, recreation, wildlife and fLsh life uses. 13. The development Of the power potential could seriously Confllct wlth recreation and fish life values. MIW THEREFORE BE IT RESOLVED that this Board hereby adopts the following program in accordance with the provlslons of ORs 536.300(2) pertaining to the 14. There 2s considerable potentla1 for IndUStrlal Use Of Water water resources of the Mlddle Oeschutes River Basin.

15. Storage and Scheduled releases Of Surplus Winter and SpIUig runoff; A. The maximum econaic development of thls state, the attalment of the reduction of channel and transrmssion losses, or acquisition Of some hlghest and best use Of the waters Of the Middle DeSChUteS Rlver exlstmg rights would be necessary to obtain the Waters needed by 0asm and the attaiment of an integrated and coordinated program major water-using Industries. for (he benefit Of the state a5 a whole will be furthered through utilization of the aforementioned waters only for doneStiC, 16. use of water for mining purposes is slight and E. not expected to lLVestock, mumupal, irrigation, power development, industrial, increase materially in the foreseeable future. mmmg, recreation, wildlife and flsh life uses and the waters of the Mlddle OeschUteS River Basin are hereby so classified with the 17. Recreation is a major use of water. following exceptions. 18. The MetolluS RlYer is Superlor as a natural IecreatlOn Value. 1. The state Water Resources Board program, Lower Main Stem Oeschutes River, adopted April 3, 1964, as modlfled by the 19. Water consumption by wlldllfe does not represent a significant Water Policy Review Board. quantity. 2. The maximum economic development of this state, the attainment 20. There 1s inadequate streamflow for fishery requirements. of the highest and best use of the waters of the main stem. Metolius River, above river mile 13.0, and the attainment of an integrated and coordinated program for the benefit of the state

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1-4-47 as a whole will be furthered through Ytillzatlon of the operated in conformity with the applicable provlsrons of ORs 536.310 aforementioned waters only for dmstlc, livestock, irrigation and any such structures or Works are further declared to be of lawn or non-comnercial garden not to exceed one-half acre in prejudicial to the public interest which do not give prop, area. power development, recreatlon, wildlife and fish llfe uses cogruzance to the multiple-purpose mmept. and the vatel’s Of the main stem, Metollus River. above river mile 13.0, are hereby so classified. LOWER DESCHUTES RIVER 3. Further, no out-of-basin dlverslons of the waters of the mainstem Metollus River, above river mlle 13.0, shall be WHEREAS the State Water Resources Board under the authority of ORs 536.300 permtted for any use. studLed the Lower Deschutes River Basin as delineated on State Water Resources bard Map, File 5.7014; 4. NO further appropriations except for domestic or livestock uses Shall be pernutted for waters of the mainstem Oeschutes River, WEREAS the Water Policy Review Board under the authority of ORs 536.3w and from the head of Lake Billy Chmook near river mle 120 to the 536.340 has undertaken a restudy of the Lower Deschutes Basm; North canal Dam near river mile 165. IREREAS In this Study consideration Was given to means and methods Of 5. The maximum economic development of this state, the attainment augmentmg, conserving and classifying such water resources, eustmg and of the highest and test use Of the waters OP the natural lakes contemplated needs and uses of water for domestic, municipal, irrigation, of the Middle Deschutes River Basln, and the attainment of an power development, industrial, mining, recreation, Wildlife and fish life integrated and coordinated program for the beneflt of the state uses, and for pollution abatement as well as other related Subjects including as a whole will be furthered through utillratlon of the drainage, reclamation and flood control; and aforementioned waters only for domestic, livestock, irrigation of lawn or noncommercial garden not to exceed one-half acre m WKREAS as a result of said study the following findings have been reached Dy area, power development not to exceed 7-1/2 theoretical this Board for the tributaries of the Deschutes River within the Lower horsepower, recreation, wildlife and fish life uses. Oeschutes River Basin: 0. FO~the purpose of maintaining a mmimum perenma1 streamflow 1. The total quantity of water is sufficient on an average-year basis to sufficient to Support aquatic life, no appropriations of water except satisfy eX1Stmg needs and uses of rater with the exceptwn Of for domestic or livestock uses shall be made or granted by any State utilization of water to minimize pollution. agency Or pUbllc Corporation Of the State for the Waters of Lake Creek or its tributaries above the Confluence of Lake Creek with the 2. MaldlStrlbUtiOn eX15tS With regard tO physical location and with WtoliUS River for flows of Lake Creek below 20 CubLC feet per second respect to availability during time of need measured at the mouth of Lake Creek except that this lrmrtatlon shall mt apply to waters legally Stored or legally released from storage 3. Many streams do not provide enough flow for’ nonconSumptlve publlc (priority date - May 24, 1962). uses at present in perlods Of relatively low as well a5 crxtlcal flor. c. Applications for the use of the waters of the Middle DeSchuteS River 4. Simultaneous use of a major portion OF existing consumptive rights Basin shall not be accepted by any state agency for any other use and results in flows at or near the zero level on many streams durrng the the granting of appkcatmns for such other uses 1s declared to be sumner months. prejudlcla1 to the publlc interest and the granting of applicatmns for such other uses would be contrary to the integrated and 5. Flows, unless augnented by storage, would not be sufficient on most coordmated program for the use and control of the water resources of streams ddring the sumner months to supply future consmptive and the state. nonconsumptive demands.

0. RlghtS to Use Of Water for industrial Or mlning purposes granted by 6. The existence Of ground Water has been established I” certain any state agency shall be issued only on Condition that any effluents sections of the basm, but quantltles have not been determmed or return flows from such uses shall not Interfere with other beneficla1 u5e5 of Water. 7 All unappmprlated waters of White River and tributaries have been withdram by the State Engineer FOP specla1 USeS. E Stru~ture5or works For the Utilization Of the raters in accordance with the aforementioned classifications are also declared to be preJudLca1 to the DUbllC Interest Unless Planned, CMStrUCted, and

-11- -12- 8. There is need to insure .quantities of water for domestic, livestock, 26. Maintenance of minimun perennial streamflows would be in the public and municipal uses which, while small, are Of benefit to the state. interest. 9. Irrqation is Q,rd will continue to be the major Consmptive use of 27. Certain lakes are by nature of their physiography. location. land water. ownership, or economc potential available only for limited resource use. 10. Potential exists for the development of the agricultural economy through expanded irrigation 28. CriterLa for determination of desirable base flows Cmensurate with all beneficial uses of water have not been developed, although 11. The unavallabzlity Of dependable supplies Of adequate water in the information is available on flow requirements for aquatic life. future would be a restrrction on the development of the agricultural potential of the basm. 29. The maximum benefxal use Of the waters of the tributaries Of the Deschutes River within the Lower Deschutes Basin will be for 12. Power dewlopent appears to be economically and physically feasible. aomestic, livestock, municipal, Irrigation, power development, industraal, mining, recreation, wildlife and fish life uses. 13. TiIere IS linuted potential for imustrial use of water. NOW THEREFORE BE IT RESDCVEO that this Board hereby adopts the following 14. use Of water for mining purposes is slight and is not expected to program in accordance with the prov~smnsOf DRS 5X.W0(2) pertaining to the increase materially in the foreseeable future. water resources of the Lower DesChUtes River Basin: 15. Recreation is an important use of water in the basin. A. The maximum economic development of this state, the attaimnt of the highest and best use Of the waters Of the Lower Deschutes River 16. Water consumptmn by wildlife does not represent a significant Basin, and the attaiment of an integrated and coordinated program quantity. for the benefit of the qtate as a whole will be furthered through utilization of the aforementioned waters only for domestic, 17. Full development of the anadromous fishery potential cannot be livestock, municipal, irrigation, power development, industrial, achieved without the improvement of fish passage and low-flow mining, recreatmn, wildlife and fish life uses and the waters of the conditions. Lower Deschutes River Basin are hereby so classified with the following exceptions: 18 Material improvement of minfmum flows for fish life cannot be achieved without the development of surface water storage. 1. The state Water Resources Board program, Lower Main Stem Deschutes River, adopted Apnl 3, 1964, as modlfied by the 19. Pollution of surface and ground water 1s not a significant problem Water Policy Review Board.

20. Major foreseeable quantitative uses of water Of the Lower Deschutes 2. The waters of Boulder Lake in Hood River and Wasco Counties are asi in v~llbe for irrrgation, recreation, and fish life. classified only for domestic and livestock uses: power development not to exceed 7-1/2 theoretical tmrsepover; 21. Drainage and reclamation of drained lands are not Significant factors recreation, wildlife and fish life uses; and Irrigation not to in present and contemplated water use. exceed 100 acre-feet annually frm water stored in the lake.

22. Lmited flood problems exist, mainly on the eastern tributaries Of 3. The maxmqm economc developMnt Of this state, the attaimnt the Deschutes River. of the highest and best use Of the waters of the other natural lakes of the Lower Deschutes aver Basin, and the benefit of the 23. There are physically-feasible storage sites within the basin. state as a whole will be furthered through utilization of the aforementioned waters only for domestic, livestock, irrigation 24. small re5ervous on minor tributaries could reduce flash floods and of lawn or noncOlMlercia1 garden not to exceed one-half acre in streambank erosion and provide late-season irrigation water. area, power development not to exceed 7-112 theoretical horsepower, recreation, wildlife, and fish life uses and the 25. Utllizatmn of flows to minimize pollution should not be permitted if waters of the natural lakes of the Lower DeSchUteS River Basin such use limits or conflicts with the multiple-purpose concept. are hereby so classified.

-1L -13-

1-4-49 El \D B. For the purpose of maintaining a minimum perennial streamflow N sufficient to support aquatic life, no appropriations of water except nu) for domestic or 1IVeStock uses Shall be made or granted by any state a ency or public corporation of the state for the waters of the White Ryver or its tributaries above the confluence of Whlte River With the Oeschutes River for flows of the White River below the Specified flows in Table 2, except that this limtatlon shall not apply to waters legally stored or legally released from storage. C. Applications for the use of the waters of the Lower Oeschutes River Basin shall not be accepted by any State agency for any other use and the orantino of aoD1iCationS for such Other uses 1s declared to be preJ;diCialtO th$ 'public interest and the granting of application; for such uses would be contrary to the integrated and coordinated program for the use and control of the water resources of the state. 0. Rights to use of water for mndustrial or mining purposes granted by any state agency snall be issued only on condition that any effluents or return flows from such uses shall not interfere mth other beneficial uses of water. E. Structures or works for the Utilization of the waters in accordance with the aforementioned class~ficationsare also declared to be prejudicial to the public interest unless planned, Constructed, and operated m conformity with the applicable provrsrons of ORS 536.310 and any such Structures or works are further declared to be preJudicLa1 to the pubhc interest whlch do not give cognizance to the multiple-purpose concept.

OESCHUTES -UPPER CROWED RIVER WIEREAS the State water Resources Board under the authority of ORS 536.300 has undertaken a Study Of the Oeschutes - Upper Crooked River Basin as delineated on State Water Resources Board Map, File 5.7014,

dralhge, reclimatmn, and flood control, and

WHEREAS as a result of said Study the following findings have been reached by thlS 8OaPd.

1. The total quantity of water 1s sufficient on an average-year basis to satisfy all existing rights to water in this basm.

2. There 1s not enough Water on a critical-year ba%s to meet exlstmg consumptive needs.

-15- 3. Maldistribution exists with regard to physical location and Wlth 21. Small reservoirs on minor tributaries could reduce flash floods and respect to availabllity during time of need. streambank eros~onand provide late-season irrigation rater. Simultaneous use of a major portion of existing consumptive rlghts 4. 22. Utilization of flows to minirmze pollution should not be permitted If results in flows at or near the zero level On many streams during the such use lhts or confhcts with the multiple-purpose concept. smer months. 23. Criteria for determination of desirable base flow cmensurate with Most stream do provlde enough flow for nonconsumpt~vepublic 5. not all benefiaal uses. of water have not been developed. uses at present in Penods of relatively low as well as crltlcal flow.

24. The maxmm beneficial use of the waters of the Umer Crooked River~ .~ The existence of ground water has been established In certam 6. 8asm will be for domestic, livestock, municipal, ' irrigation, power sections of the basin, but quantltles have not been determlned. development, industrial, mmmg, recreation, wildlife and fish life uses. 7. There is need to insure quantztzes of water for dmstlc, hvestock, municipal and mining uses which, while small, are of benefit to the MJW THEREFORE BE IT RESOLED that this Board hereby adopts the fallowing State. program m accordance With the provisions Of ORS 536.300(2) pertaining to the water resou-$ of the Deschutes -upper Crded River Basin: 8. There are no munlclpal water systems in the basm. A. The maximum econc" development of this State, the attaimnt of the 9. Irrigatmn is and will continue to be the major consumptive use Of highest and best use of the Waters of the Oeschutes - Upper Crooked rater. River Basin, and the attamnt of an integrated and coordinated program for the benefit of the state as a whole will be furthered 10. Most irrigated lands in the basm do not recelve an adequate supply through utilization of the aforementioned waters Only for domeStlc, Of water. livestock, municipal, irrigation, power development, industrial, mining, recreation, wildlife and' fish life uses and the Waters of the 11. Substantially more than the average annual yield of the Upper Crooked Deschutes - Upper Crooked River Basin are hereby so Classified. River Basin has been withdrawn by the state Engineer for irrigation purposes. 8. npplications for the use of the waters of the Deschutes - Upper Crooked River Baam shall not be accepted by any state agency for any 12. Power development appears to be economxally and physlcally feaslble. other use and the granting Of applications for such other uses IS declared to be prejudicial to the public interest and the granting of 13. There 1s limited potentla1 for lndustrral use Of water. applications for such other uses would be contrary to the integrated and coordinated program for the use and control of the water 14, Water-based recreatlan w~llbecm a more srgnlflcant we of water in resources of, the state. this basm. C. Rlghts to Use Of Water for industrial DI mlnlng purposes granted by 15. Water consumptron by wlldlife does not represent a significant any state agency shall be issued Only on condition that any effluents quantrty. or return flows from $uch uses shall not mterfere with other beneficial uses of water. 16. Game fish populatrons are limited because Of extreme low flows, high water temperatures, and extensive Populations of rough hsh. 0. Structures or works for the utilization Of the waters in accordance with the aforementioned classifications are also declared to be 17. Pollutmn of surface and ground water is not a signlflcant problem. prejudicial to the public interest unless planned, constructed, and operated in conformity with the applicable provisions Of ORs 536.310 18 oramage and reclamatmn of drained lands are not signlflcant factors and Wy Such StTUCtUIeS Or works are further declared to be in present and contemplated water use prejudicial to the public interest Whlch do not give proper cognizance to the mltiplcpurpose concept. 19. Flood problems exist mainly on the malnstem of Crooked River. 20 There are physlcally feasible storage sites withm the basin.

-18- -17-

1-4-51 DESCHUTES - LOWER CROOKED RIVER 13. Reservoirs will provide a major portion of water-based recreation. WtEREIIS the State Water Resources Board under the authority of ORS 536.300 has 14. The waters of the Crooked River, including Opal Springs, from rive undertaken a study of the DeSchuteS - Lower Crooked River Basin as delineated rmle 6.5 to river mile 18.0, are a valuable source of mumcipal, m state Water Resources BoaId Map, File 5.7014; irrigation, and industrial water.

WHEREI\S ~n this study conslderatlon was glven to means and methods of 15. Little ,potential for enhancement of fish life exists and is dependent augmenting, conservmg, and classifying such water resources, existing and upon securing adequate streamflow. contemplated needs and uses of water for domestic, livestock, municipal, i;rlgatlon, co*er derc!o,”nt, indstrial, mining, recreation, dd!rfe and 16. Increases of population and the need to serve presently unsewered fish life .ses an0 for po11Ltion ooate.?nt as hell as otner relateo sL3jects areas will require municqal sewerage works to be expanded inc1;d:ng oralnage, reclamtion. an0 flood control, an0 17. Limited flood problems eX1st. WHEREAS as a result of said study the following findings have been reached by this Board: 18. A coordinated plan of operation Of OchoCO and Prlneville Reservoirs will materially alleviate flood damages In the Prmeville Valley. 1. The total quantity of water 1s sufficient on an average year basis to satisfy all eXiStmg and contemplated consumptive needs and uses of 19. There are physically feaslble storage Sates withm the basin. water. 20. Small reservoirs on mnor tributaries could reduce flash floods am 2. There are streams within the basin whose average annual yield is not streambank eroszon and provide late-season irrigatmn water. sufficient to satisfy existing rights. 21. Utilization of flows to m~nlmlZePOllUtiOn Should Mt be permitted if 3. Maldistributlon casts with regard to physical location and with such use limits or conflxcts with the multiple-purpose concept. respect to availability during time of need. 22. Certain river sections, minor streams and Creeks are by nature of 4. simultaneous use of a major portion of existing consumptive rights their physiography, locatlon, land ownership, or econmx potentmi results in flows at or war the zero level on many streams during the available only far limited resource use. smer months. 23. Criteria for determination Of desirable base flows comnensurate vlth 5 Most streams in the basin do not provide enough flow for all beneficial uses of water have not been developed. nonconsumptive public uses at present in periods of relatively low as well as critical flow 24. The maximum beneficial use of the waters of the Deschutes - over Crooked River Basin will he for domestic, livestock, munrc~pal, 6 The existence of ground water has been established in certain Irrigatmn, power development, industrial, mming, recreation, sections of the basin, but quantities have not been determined. wildlife and fish life uses. 7. There is need to insure water for domestic, livestock, municipal and MIW TMREFORE BE IT RESOLVED that thls Board hereby adopts the following mining uses Which, while small, are of benefit to the state. program in accordance wlth the prOV15lOnS Of DRS 536.300(2) pertalnlng to the water resources of the DeSchutes -Lower Crooked River ~as~n: 8. Irrigation 1s and will continue to be the major consumptive use of water. A. The maximum economic development of this Stare, the attam” of the highest and best use Of the Waters Of the DeSChUteS - Lower Crooked 9 There 15 additional potentla1 for lrrlgatlon Use Of water. bver ~asm,and the attairment of an integrated and coordinated program for the benefit Of the state a5 a whole Will be furthered lo. Power development appears to be economcally and physically feasible. through Utilization of tlle aforementioned waters only for domestx, livestock, munrcrpal, irrigatmn, Power development, industrial, 11. There 1s potential for industrlal use of water. mming, recreation, wildlife and fish life uses and the waters of the CkS-hUteS - Lwer Crwked Rlver BaSh are hereby SO Classifled with 12. Suffxient water will not be available m many locations for mam tl L following exceptions: water-using lndmtries without the provision of seasonal storage.

-20- -19- 1. The state Water Resources Board program, Lower Main Stem Oeschutes River, adopted Rpril 3, 1964, as modified by the Division of State Lands Water Policy Review Board. - 2 NO further appropriations of water except for domestzc or I wmsm"r*-6- I 1600 STATE STREET. SALEM, OREGON 97310 PHONE 378-3805 livestock uses shall be made or granted by any state agency for the waters of Ochoco Creek and its tributaries. B. use of of applicationsappllcatlons for the the Waters waters the Deschutes - ~owerLower OREGONSTATE 885111 aPrPntd November 17, 1986 Crooked River Basin 5hallshall not be accepted by any state agency for any LANO BOAR0 Other use and the granting of applicatlons5 for such uses 1s declared Y,C,Or(A""~* totO be prejudicial-prejudiclal to the public Interest and the grmtlng granting of om" applicationsaoolications for such other uses would behe contraryrnntrary to the integrated and coordinated mowam for the use and controlontrol Ofof the water 8ARBA11Awn~m Bob Brown resources of the state. s.-~~~~~~~l.Office Of State Forester B,LLRYwIIIIomD 2600 State Street C. Rights to use water for mdustrlal or mining purposes granted by any S'.*mT'**W'' Salem, OR 97310 state agency shall be issued only on condition that any effluents or ~e. Response return flows frm Such uses shall not Interfere wlth other benefrcial ochaco NatLOnal Forest ~gency uses Of water. Dear Bob 0. StmctmeS or works for the utlluatlan of the water in accordance our IS with the aforementioned classifications are also declared to be concern that the Forest Service has not addressed and the effect their management plan will have on slmzlar prejudicial to the public interest unless planned, constructed resources managed by the state 01 adlacent private lands. operated xn conformty with the appllcable provisions of ORs 536.310

and any such structures or works are further declared to~~ be~~ The federal government, as the malor landowner In a pre)udi&al to the public interest which do not give proper area, cognrrance to the multiple-purpose concept. geographical can, with it's management policies. enhance or stifle the economy or alter the development of that area, We feel this IS a very important aspect in the management plan. Dated NoveIP$er 29, 1984 whlch needs attention Thank you for your consideration I" thls matter I Wlll WATER POLICY REVIEW BOPRD look forward to seeing you at the meetlng on November 24.

Engineering Technicran PEL/^^¶ 0492E

WATER POLICY REVIEW BORRO

-21-

1-4-53 Oregon Department of Agriculture nt of Energ,

""RA"?S"_,_ I 635 CAPITOL STREET NE, SALEM, OREGON 97310-0110 625 MARION ST YE. SALEM,OREGON 97310 PHONE 3784040 TOLL FREE 1-800-221-8035

November 5. 1986 November 7, 1986

James E. Brown, State Forester Oregon Forestry Department Mr James E Brown. State Forester 2600 State St. SALEM OR 97310

Dear Jim: SUBJECT Ochoco National Forest and Crooked River National Grassland The proposed Land and Resource Msnagement Plan of the Ochoeo National Proposed Land and Resource Management Plan Poresf and Crooked River area is within the Jefferson, Wheeler, Grant, Crook, Deschutes. and Harney County Soil and Water Conservation Oear Mr Brown Districts. Each of these districts are governed by a Board Of local elected Directors who. under the Oregon Soil and Water Conservation The Oregon Department of Energy has reviewed the Forest and Grassland District Laws. ORs 568. have d responsibility to work with the Proposed Land and Resource Management Plan, DEIS and Appendices The Pore~tryDepartment as described in the Memorandum of Understanding Department has no problems with the Proposed Forest and Grassland Plan between the Department of Agriculture and the Sorescry Department. Areas of interest to the Department are siting of maJor enerqv facilities ORs 568.225 emp0we~'sthe districts LO provide for conservation of ana Policies concerning aeveloprent of energy~reraJr&s Ma;& energy renewable natural resources of the state, to eonserve and develop fat I I I t i el I nc 1 me fos s I I-fw Iea, geocnerma I , nyaroe I ectri c an0 b lciass natural resources, control and prevent soil erosion, eonrrol floods, plants o\er 25 M.. in size. biovass-flelea co-aencration alantr In e*ccIs conserve and develop water ~eso~~lcesand water quality. preserve of 50 MW capacity, high voltage transmission iines and large pipelines wildlife, conserve natural beauty. and promote recreational Our comments are below development. Fossil Fuels The DEIS suggests that 90 percent of Ochoco lands are Each chapter of the Ochoeo Natimal Forest awl Crooked River proposed prospectlvely valuable for oll or gas resources ODOE feels the lack of Land and Resource Management Plan identifies areas where the 8011 and conclusive data. other than speculative leases. may not support that yarer conservation districts would have concerns. Such ab, how the tonclusion However. ODOE agrees that any post leasing activitter vi11 implementation would affect the Boil and water runoff, and to what be evaluated through both NEPA and prescriptions developed in this plan extent ermion and sedimentation Would he kept to a level within In addition, there appears to be little potential of siting a acceptable standards. fossil-fueled power plant in the Forest and Grassland Thus, none of the alternatives' presented by the OEIS. including the Preferred Alternative. The stndy. as mitten, defines areas that show vllat is being proposed appear to have any effect on siting these facilities to mlnimize soil and w=ter problems. If them suggesLions are followed throughout the program, and if 88sistance from Soil Geothermal The low potential of finding exploltable geothermal Conservation Service and soil and water conservation districts is resources in the Forest and Grassland is indicated in the DEI5 ODOE utilized, there Would be greater chance of improved soil and Water agrees with this conclusion and the resulting lack of specific policies conservation practices being followed throughout the study area. addressing development of this energy resource In addition, other federal standards exist ,should development ever appear likely sin(rere1y. Hydroelectric There amears to be little tmtential to develoo additional hydroelectric.facilitier Which ai; iarger than 25 megawatts in the Forest and Grassland Thus. none. . of.. the.. . .Il?ornitlves-. .-. .. -. . . . presented in the DEIi~appearto~have~any effect on sitlng these fac1Ilities

Oil 6 water conservar1on oivision (503) 378-3810

The Oregon Department Of Energy IS an Equal Opporlunily Employer

1-4-54 MT ~amesE Brown November 1. 1986 Department of Geology and Mineral Industries Page 2 ADMINISTRATIVE OFFICE 910 STATEOFFICE BLDG, 1400SW5thAVEI PORTLAND, OR 97201-5528 PHONE(503)229-5580 Biomass There appears to be little potential of siting a biomass-fired Elantin the Forest and Grassland in the next ten to fifteen years Thus, none of the alternatives presented by the DEIS. including the Preferred Alternative. appear to have any effect on siting these November 12, 1986 facilities Transmission Lines and PI elines The DEIS ind7cates that transmission lines and pipelines crossPportions Of the Forest and Grassland. and that additional facilities are likely in the future The DEIS states that all Mr. James E. Brown alternatives alloH the transmission of power through the area Thus, the Department of Forestry Department has no objectlon to the Proposed Alternatlve However, the 2600 State Street DEIS contains no discussion of the effects of the alternatlves On sltiny Salem, Oregon 97310 +rancmi.cinn ~ liner and oioelinerr~ Given the likellhood that future transmission lines andlor pipelines will need to cross the Grassland, the Dear Jim, DEIS would benefit from including such a discussion We have prepared this response to the Draft Envlrowental Impact Statement to the Proposed Land and Resource Management Plan for the OChoCO National Forest & Crooked River-National Grassland. Apparently the planning team has a minimal background In geology and mineral TBSOUTC~S. A different set of standards were Used for minerals than for other T~SOU~CPE. For example, a dollar value was placed on campers using the forest but the thousands of dollars worth of mineral exploration that has occurred In recent years was not counted. Thousands of dollars worth of gemstone production TEMlLF ja from commercial and recreational 51teS was not counted. 3922o(dl ,fl) The $999,000 ($3.00 per ton for 333,000 tons) of road metal (aggregate) was not counted; however, a cost figure of $866,080 was used for mineral operations and maintenance Program management.

Appendix B - Description Of Analysis Process contains no inventories for minerals, no maps'showlng rock quarries. mining claims, gemstone mines or metal mines. The data bare does not reflect the gold and other geochemrcal anomalies. found m the DeBartment'S ODen-flle reDOrtS 0-83-4 and 0-86- 6, which suggest mineral poientlal. It IS surprxsing that the land was rated as moderate or high mineral potential without an adequate mineral resource data base. The follD&g detailed comments may be helpful in revising these documents.:

1-4-55 amendices - Draft Environmental IInDact Statement alternative that is used until formal mineral inventory is completed. 49 The statement is made that alternatives have comments little effect on mineral activities 1s not true. Withdrawing acres from mineral location has an A-5 The issue of "Provide a mining and effect of mineral activity. mineral xnventory" and "Geothermal energy Under Economic Benefits the production of opportunities should be studied and develooed" locatable minerals 1s not considered. were deferred for resolution Outside of Foiest 79 The Forest Service has not performed a Plan. However, iudmnents were made in these mineral resource inventory but under "Cultural documents that could onlv be made based on Resources" mines and mining camps have been inventory data. inventoried. 63 The Statement is made that "Mineral and B-4,5 6 6 If inventories could be performed on Energy Resources on Forest and Grasslands" have recreation, cultural resources, ecoclass, and soil been classifred in terms of potential value and and water, why not minerals including energy? existing access restrictions. now can this be so when there has not been a mineral inventory? 8-44 On this page minerals had a cost of The statement IS made that the forest and $866,080. Under Benefits DaUeS B-45 to B-50 grassland have no known geothermal resources. The minerals are not listed except as something that Department's geothermal maps show a warm water would hurt the protecting of historic and cultural spring on the Forest. resources. Under Priced Beneflts should Include 146 The bias against mineral production 1s shown the value of road metal, gemstone productyon. and in the statement that several old mines may meet mineral exploration. Oll~andgas ind georhermal the National Reulster and that Dotentlal could be energy lease revcnues should also be rncluded used against r;-establishing any of these mines. under Pricc Benefits. 162 The iasperoid being mined may be an indicator of a hot Spring gold systems and rockhound sites C-5 &C-8 For the Lookout Mountain roadless area should not be withdrawn from bemu located under on page C-5 only 2 mines are wlthin the roadless the mining law boundaries, on page C-8 there are 200 mininu 163 A mineral inventory should be completed clams wLthm the-boundaries. before areas are picked for Research Natural Area. 180-186 NO geologist or mineral ..People Were listed as C-40 How was the grading of Moderate preparer; . Potential for the Greer Mountain roadless area 217-226 No mineral or geology reports were listed in derived? The potential given for those roadless the references. areas with mining, claims, mmes, and mining districts are listed as unknown. E-3 The Department and ELM have identified a Potential gold mineralized area lust to the South of Haystack Butte. This area should not be John D. B&ulreu withdrawn from mineral location or leasing. Deputy State Geologist Draft Enviromental JDB:ab Impact Statement ATl/word/brown Coments 12 Under Net Public Benefits, only redera1 minerals are listed as having a market value. The market value of the exploration, development, and mining of locatable mmerals should be added. 17 It 1s shown that Alternative H would emphasize market apportunlties. This IS the li Department of Environmental Quality

=me factors such as sediment and tenprature mmrol frao fmest nanagenant activities. Kmever, equally important infocnatlon on other Eactms in a multiple ueforest, SUEh as sedlment mmrol fra 'pazing and 7. 1986 November ~otoriledrecreation, is lackng. In addition, findlngg need to be ma& cesrding the relationship hetween baselme water quality con&tiom and Ihe effecfi of the planned forest activities. James E. Bm,State Foreester Forestry ueparment *Inink You for allarmg YS the opprtlnity to rem- the Draft EIS. The Office of State Forester kpartment look8 fowazd to revienng the ~endnentsto the Draft EIS 2600 State Street kfore a final re"men&tian 1% made reoardln- t.hl "preferred alternatiye" salem, oregon 97310

SubJest. Draft EnYieanmental Impsst Statement and Plan for the OchocO National Forest and Crcoked River National Grassland

De= Mg2L. The Department has reviewed the Draft Environmental Impact Statement (DEIS) and Plan for the Ochoco National Foreet and Cmked River Nationel Grassland and provzdes the follming comments for the Forest Service to we in preparing the State's coordinated xespome. These cments are related to air quality and water qnality impacts of the pmpsed Plan. The Deparanent does not rec-end a "preferred alternative" at this time. The deficienciee outlined bel& reflect a need far haakgromd infomation that is necessary for the Deparhoent of Enviromnental Quality to eValUate and select M alternative After this infomation 1s included in the ETS, the Department wovld be more capable of reccmrnending a preferred alternative.

~egardingair quality. the Deprtment's main area Of mncern is that of air quahty impacts related to forest presaribed bvrning The EIS indxotes that ripificant increases in emissions from prescribed bvrning are likely under most alternatives over the next 20-30 years If edBsioBs are expected to increase above 1977-78 baseline levels. M analysis needs to he included in the plan regarding the impact of the proposal with regpat to the Clean Air Act and Oregon Clean Air Implementation Plan requirwents, the impact Of planned burns on nearby Class I and I1 areas, the impact of proposed prescribed hrning activities on the viaiblity Protection Plan, and consistency of the proposed Plan With Federal and state environmental polidea.

Regardxng water quality. the Department's mncems are that the Plan he consistent with Oregon's adopted Statewde Water Quality Management Plan for forest practices as required by the Clean Water Act. It is important to ensure that the proposed activities of timber harvest, road mnStrUCtlon. chemical handling and Ysag. sewage dlspsal, livestook grawng and other foIeSt land activities caoply wlth OregOD'S water WailitY standards and glndelines. Adequate infomation exists in the draft EIS for

1-4-57 Cments on the Draft Environmental ..~..state "f.. "ram".-.~-.. Impact Statwent and Plan for the Department of Environmental Quality Ochom National Forest and Cments on the Draft EnYIrOmental Impact Statement Crmked River National Grassland and Plan far the Ochom Natlonal Forest and CXoOked River National Grassland 78 emiBI%Dn levels is reQUired to relata projected emlsdons and impacts to the PSD baseline period,

In the DEIS section on air quality effeots of each alternative (pages 103- I. AIR QUALITY 104). it ie projected that all of the alternatives (with the exceptmn of "D") will result in a reduction in emissions 20 to 30 years in the future. In the interim, increases in dsdons of as much 85 39% ahve Ths checklist smariies Department of Environmental puality. Air Quallty NTrMt levels are eqested to occur The prqected zncrease I" emissions Diviuon mncerns that should be included in the Environmental Impact (as much as 4.000 tons tsp per year) is significantly abve the ermsdon Statement (EISI for the Ochom Natlonal Forest and Crooked River National baseline and will reFlre completion of a detaled analysis of dsslon Grassland that was suhitted for Department review. This llst 19 not impacts on PSD incrwents, Class I area visibility. attarnment/mdntenanCe intended to be a11 inclusive. ht should rather be viewed as a framwork of air quality Standard3 and mnsistency with environmental policies. Outlirvng the major areas which should be addressed in the EIS. Statements which far1 to address the concerns listed will be considered inadequate 1 Attaiwent and Maintenance of Air Quality Standards. to meet Department approval. A basic requirement Of the EIS IS to emluate tile impdct Of the The OhecLlist is organized into 4 napr Sections, each Of vhch should propmal with respect to the Clean Air Act and she OIegDn Clean Air address the adequacy and mns1stencY of the propffied plan with respect ImplementatLon Plan requirements. The first ~s4- that must be to the follming elements. addressed is that of impacts on air quality stadark attarment and malntenane. Specifically, ,the EIS must show that the proposed action 1 Attainment and Maintenance of Air Quality Standards does nct cause or significantly mntribute to air quality standard 2 Pl'eYentlO" of Significant Deterioration Requirenents violations. Air' quality impctr within an attainment area. Such as 3. visibility Protection Of class I areas where the Ochoco Natlonal Forest is located. mwt not exceed 4. Consistency with respect to Federal and State of Oregon Prevention Of Siglificant Deterroration (~~01rbcrements (see attached environmental polide? Table 2) nor may the mpacts cause nolatlons 06 alr quallty Standard3 (See DEQ Rnnral Air Quality Report) estimated by swing Current _I Current infomation descrrbmg air quality monrtofing actiyltm.s and Wlity mndrtions and the estimated xncrwent for the appropriate smariling air quality mndrtions across the State may be fowd in the everaging times. Air Qvality Division's Annual Report Copies of this report and other information can be obtain by writing to the Division or callmg (5031 2. Prevention of Siglifisaint Deterioratron 229-5380. Technical assistance and qudence in the preparation of EISS in available froa the Department on request Part C of the Clean Air Act. requires the Departloent to Insure that pollutant incrementa ~n class I areas do not exoeed speufic lrnrits In reviewing forest Plan EISSr the Principal issue of mncern to the asopted by Conqpeas irrespective of the orisinadnq source (see Department related to air quality is that of air quality impacts related attached Table 2) TO asewe that these Incremgntr are not exceeded to forest prescribed hlrning A basic requirement related to air quality due ro plqnned increases in Prescribed burmng msuons, a technical of an EIS is presentation of an analysls of planned burning in relation analyeis of the impact of planned hlms on nearlw Class I areas (see to past hrning actindes Generally, If rt can be Shown that pzqected DEQ Annual ALP Quallty Report) and Class I1 land3 1s required. If annual and daily air pollutant emissions do not exceed, or are expected the analysis indicates siglxficant impacts. speufic ymantifiable to be less than that which Occurred during the besaline pariod, then issws measures desigled to mitigate the impacts must De described in the discussed in Sections 3 and 4 are satisfied and no addrtlonal technical EIS . analysis of these issues is required. Since the baseline used in the analyses reflects current wissions, an evaluation of EUVCent versus (977- 3. Vislbrlity Protection For Class I Areas

The Oregon Yidbllity Protection Plan, adopted DY the Enviromental pvality C-issian on October 24, 1986, require9 the protection of visibility vlthn Class I areas durrng the perkod of the July 4th weekend to Labr Day. inclusive. The EIS should desceibe the Forest's

mu11728 -1- MR1728 -2- C-ents on the Draft Enviromeneal C-enta on the Draft Environmental Impact Statwent and Plan for the Impact Statenent and Plan for' the Ochom National Forest and OchOm National Forest and Crmked River National Grassland Crmked River National Grassland

Smk Management Plan as it applies to Class I area visibility protection and evalnate the impact of pra'opased prescribed burning actfvit.es with respect to (a) assuring the mntinued protection of visibility mthn Class I areas iron further deterioration and lbl the affect of propsed hvning activities on short and long-term visibility mnrrol strateaes as ovtlined in the Visibility For Nonattairm State Implenentation Plan (SIP) Copies of the adopted visibility lmrcromams per CVMCmeter1 protection plan are available frdi the Department. Pollutant Annual 24-Hour 8ilour 3-mur 1-Hour 4. CmiStenSy With Federal and State Envlromental Polides. so2 1.0 50 25 0 Department policy ImR 340-20-0011 resvires that Rishest and Best TSP 10 50 PIactirable Treatment and Control be applred to pllution sources NM 1.0 within Ore-" G3BR 340-13-005, Envirollnental Standards for Wilderness m* 05 2.0 Areas, sets forth policy on envlromental impacts within wilderness land5 while lFDA Forest Servioe Heasion VI policy ( Service Manual MilligamS per oubrc meter No 2400, supplenent 347. March 19851 requires that. in remwitron of the value of forest reddues utilization, pzesodbed burning only be aommplished for tbse mirs where all ath9r alternatim treatments axe macceptahie. The EIS should include a statenent addressing the ,- mmistmcy of the propsed plan with respect to these @ides, Mahum AllDwable Increases stating the degree to which alternatives to prescribed fire have been IPSO 1"crWentSI amleered.

Fm fmther information remrding air ymallty, mntact john core Class I Areas (229-53801. Pollutant Annual 24dOur 8-HDur 3-Hour s 02 2.0 5.0 25.0 BP 5.0 10 0

Claes I1 Areas Pollutant AMUal 24-Hour 8-Hour 3-How

s 02 20 0 91.0 512 0 TSP 19.0 37 0

Class I11 Areas Pollutant AnnlYl 2440- 8-Hour 3-Hour

s 02 40.0 182 0 700.0 BP 37 0 75 0

881728 -3 - a1728 -4-

1-4-59 CmMts on the Draft Tnvlronmental C"ent4 m" the Draft snmroMl=nta1 impact Statement and Plan for the Imwact Statwent and Plan for the Ochom National Sorest and Odlom National Forest and Crooked River NiUonal Grassland Crooked River National Grassland

I1 WATER QURLITY concert "ith the grazing aceiviues. =ha Proposed plan shows an idcrease m animal umt month9 (Am91 by ran9 allamment. with The Mana~mentPlan and DEIS were remeed witbin the concept that land many a11oMents showlng an increase in geazlng pressure Ha, dies managenem actrv~ueshave the potential to benefiually or adversely the Forest Service propme to handle the increased granng pressure impact the quallty of the watermforest land downstream of the and yet improve rrprlan zone condit~ohs? What spc&fL.cfoxst forest The Management Plan has the opportunity to ~mpro~existing gravng procedurffi will i!e used? We believe the respoNe to these degeaded resowces and to maintain or protect ewating desired resource questio~should be &splayed ~n the plan and be included in an mndiUonr. The level of enphasis placed on water quality mn&t(om and expanded dircvssion on pa9 111 of the tEI.5 the processes ujed to protect that quality play an imgrtant role in provldlng *dance to the managers in the future on a prqect-bpprqect The P~BLdiscusses standard5 and widelines for water wallty The be51s dlscusuon translates thee Standards rnto levels of acUvlty for forest manasment TNs is appropriate in the Plan If the process Tha Water Quallty Dlvl~ioncomments are detalea in the follming flve of translating watershed sensitimty into forest managenent sections requrrements is described ~n the DEI5 or the Plan We commend this effort and strongly s"ppo* the concept of "51"4 an equivalent Clear 1 Consistency Wlth PFoVISiOM of the Clean Water Act cut area (Ea) standard. From OUT prspctive, two iews need to te addressed in the discisuon of Eras a-d their UtlliZY I11 What The Plan provrda a pel statement to mantarn 01.improve water criteria were used eo delrve the E[?i values frcm the sfre- qua1xty It also has a -a1 Of mantaming or restoring >"herent sensitiv~eyvalues? (2) Har wlll the Eavalue be detemned and ,$Pr Nologlcal. pnysical, and aesthetic values of ~ipiaanBcoIyStws We imp1enente.q 2" a spuflc watershed? believe these are mmprable pals, toth of wbich, will marntaln or improve water quality I" the forest. TWO aments need to be mad9 The Plan ale0 dieousses standards for Baa- disposal We request YOU re~rdlngthese gals I11 we request that speufic reference to uxlude the follming lanaage "Sexage treatment and dlspeal Oregon's Water Quality Standards (OAR Chapter 340. Divluon 411 and facilities Shall be approved by the nepartment of EnvlIOmental Oregon's Forest Practice Rules (OAR chapter 629. Division 241 be added QYallty Or ~tscontract apnts and Shall be in compllaJse Wlth rules to the warer quality pal statenent (page 25, Proposed Plan1 (21 of the Envlromental Qvallty Canmlssxon There are 9_0 exirting 8tate water quality Standards for riparian -ea5 a5 stated in DEE =able s-3, 'arpanan condiuons " we agree We would like to remmise the Farest Service Staff's effort to make that the condruon Of the riprian mone can have an impact on the predrctiors of sedrment yleld for each alternative and to predrct water guality That is the mncept used ln the current forest changes over time. The Ydrloy~tables where these predictions are practice rules and I" the proposed ziparian rules currently before Shwn generate sane quesr" the Board of Forestry We believe the statenents made in Table S-3 are necessary blt Would suggest the fallwlng clarlfylnng word chanq (11 Is the Unit of measure COI-rect for sediment in DEIS Table "Any degeaded ripanan areas found to be adversely affecung water II-3A part 2 and Table S-2 part 27 Should It be quality will te ITproved to assure that the water quality meets State rons/acre/yaan If the unrt of measurement IS mrrect a5 Water Quality Standards I' We agree wrth the Streme 1zSted for Stated. then we would disagree m%h the predicted 1 8 nprlan Improwment in the Plan's Appendrx R4 ton//p4r value for the preferred alternatLve admuld like to see the analysis supporung the predrcuon =ha propmed plan appars to be consistent with the state's Water Qmlrty nana~mentPlan for the Job Day and Deschutes Riwr Basim. (2) Are the valves for sediment yield displayed ~n fhc same Th4 "Desired Condibon" statement for r>Va tenperatures 1s accurate. tables M average for the forest? If 50, are there watersheds with larger amounts of sedrment pfoductlon and It IS obr~ousthat the Forest Servlae staff is ware of the problen are these the swle watersheds listed In Plan Rppendrx A4? ares and those SO~YUONnecessary to correct the water quality woblws Thls IS apparent by the drsoussion in the DETS begrnning (31 Do these values Lnmrporate erosion from grarrng? on mq 107 ,Whit is not clear xn the drS~Ussion13 wheLher the propsea improwments and nIltiFti0" efforts for forest mana*ment are solely drrcctcd at nvugatrng forest harvest impacts or are I"

MR1728 -5 - MR1728 -6- Cments On the Draft EnYll'OmMtal C-ents on the Draft Znvirowental Impact Statenent and Plan far the impact Statwent and plan for the Ochom National Forest and Odlom National Fmest and Crooked River Na~onalGrs~slanP Cro>ked aver Natlonal Grassland

Discussion of eustinq water quality and trends is inadequate If ,the proposed Plan alternative can maintan or imp'ove Water quality masidering the pblic valm placed on the forest for visual quality. (as suggested on pa- 21 of the Plan), then the IEQ muld SYPPak remeatLon and water quality. We suggest the Plan and DEB pronds th9 preferred alternative XmBve~,we are not mnnnced frm What the existing water quality in a sectlon of the appendices to the CEB. we have been presented fm renew that thls pal can be fvlly IS the material in the Plan Appenmx A4 also tWse strews With the achieved Thrs assessment is hesed On a lack Of informatron On POOreSt water quality? With the mawtude of the potential mpacta 'padng techniques and +he effemtimess of Ems as Propsed. thet thls Plan can haw 0" water quality. it is vitally important to Inclvded in thls concern 1s our mdsrstandlng that the Fmst Sernce &splay the baseline water qualrty mnditions I" sane detail pnor to 1s proposing to -murage harvest of tree spaes that are laoiited rmplenentation of the plan &mer to streams. Such harvesting practice wlll potentially Place great- presswe on the water resource 2 Red- of Water pualillty XonitaTlng Plans 4 Reviw of Manawment of Speaul Use Watersheds Statfmants of gals and the acmmpmylng plan to achiee the was and obeotives. in our estimation, are ouly a portion of what is necessary We mnow mth the managenent prescr~ptiorrsdesi9Ied for wfid-ess in a plan The Plan m-t also 1ncl-e a process to assess ita and "swi-pr>mitlve nomctorized" areas The mana-ment FMmiptlOns effeotiveness m protecting the wat- quality during the llfe of the for "semi-prirmtive motorized" areas lac& a presscnptlon for Plan protectinqwater quality. It IS our opl~lonthat a malor sollzoe of eediment production can cmae fran thwe areas if they are not The morutming Plan that was reviwed is mntained in Tables V-2 and mntrolled for er05100 Inmeased sedlmenr p'oductron to the strews v-3 in the plan We find the prowed monitonng in the soil resource will oocw mthont mi'dqahon and should be so stated A EbesCfiPtiOn section adeqaate for water quality. we did not find the same actinty for erosion mntrol should k inclvded. propmed fm range. wrldlife, or wrlderness areas we balieve that Water 18 a resource that needs management and monitoring fm plality The Plan &e4 not discuss management mndderations for Sodl PnVate and quantity A snggested modification to =able v-2 to mver our water sFtans that mx@t "le the national forest a5 part of their mnceT-M Would be to add '"water" to the "Resamce/ActiYltY mlmn watersheds. Protection Should be Provided to my SYch watersheds in and add "quality in the "Actio? and Effect Monitored" cOlvnn In the OdlOm National Forest Tk Plan shnuld a180 desmlhe how the the "UIYta of Measwe" mluan. add "pstidck, heebiade as Proteotion prosan will be monitmea. appropnate." 5. Renw of Plan for Gmmd Water Qvality Protection 3 RBnW Of Llanaqament StxatezLeS and Alternatives The Plan virtually ignores the grovld water canpnent of the The CEQ made no attempt to determine a preferred alternative for water hydrologro cycle. Althoud> gromd water probbly wlll k mlIL"1y quality We remgnplrze that this is a land manasment plan, so we affected by forest management activities. the plan should rem@= are mns-ed wth the MriOYs levels of potential water quality the importace of somd water quallty prctectlon and hscyss the implots frm those land activities we also remgnile that followrng points difference* in management intemity of an activity among alternatives will meate ~arpngpotential impacts on water wlity a) Activities that affect s0md water Wallty wlll evcntvally affect svrface water quality convenaly. change in surfaoe We revin*ed all alternatives and management stratezLes and water quality mi&t be reflected in gromd rater quality inesmiptions with interest tarards tbe dsspee of stentral fm water quallty lmpaots and the 0ppOrt.Ynities available to emme water b) Lakes with vnrqlr pr~stineWater quallty may need sPZual qamd quality protection we asslmed thet the hisher the le~lof sol1 water protection requrements to prevent nutnent enT-ldl"L. disturban- by activlties, the seater the potential for eros~on particularly mth regard to sewage mspsal practices assodated IxOblemS, also, the greater the enmmagement fm remestion and wlth intenslye remeational -e livestock ~padnq,tk greateE tb potential fm ad&tional water quality Problems.

MR1728 -1- "128 %-

1-4-61 C-ents on the Draft Envlromental Impact Statment and Plan for the OdlOm National Fmest and Crooked River National Grassland Department of Land Conservation and Development

1-1 ATWE" 1175 COURT STREET N E, SALEM, OREGON 973100590 PHONE 15031 3184926 CI All s~qagrdLepsal PTactims need to te in mmpliance wlth state resuirwents. Please State thcse requirments by reference in the Plan.

dl Gromd water protection plwn~ngslnuld te included in all November 10. 1086 chemcal handling ~ractlcesin the forest. This would mclude, ht not te limited to, hrtaad2s. pestlddes, fertllllers, and degeasing IO1"ents at maIDtManCe Sbps

el Activities and ~roced~nesthat ininidre ercsion, and Surface water runoff also will incr.ease infrltratron, allovmg for mme SameS E. BCOWII, State Forester stable FK romd stzeam flws Department of Forestry 2600 State Street For further informatron regarmng water quality, "act John Jackson at Salem, OR 07310 2296035. Dear Jim: The purpose Of thlS letter is to provide DLCD comments for the state response to the proposed resources plan and draft environmental impact statement for the Ochoco National Forest. As you know, the statewlde goals and acknowledged comprehensive plans outside Oregonls coastal zone do not have any binding effect over federal resource planning activities, like the Forest SB~YICB'Smanagement plans Nevertheless, DLCD 15 quite concerned that the Forest Service demonstrates that such plans (and their Y~TIOUS alternatives) are developed to be as compatible as posslble with the affected Communities' acknowledged comprehensive plans. Our preliminary review reveals that Lhe Ochoco's plannrng Staff has endeavored to produce the Drooosed resources ~lan and DEIS with extensive interest groip Hnd local Involvement. We are pleased that the DEIS on page 172 discusses the senerel connatibilitv cf thc vart~us management alt&natives with the acknowledged county comprehensive plans in the area Such information I" the DCIS noL only serves to Strenqthen federal-local cowdinallon-but hopefully can aid in easier identification of a preterred elLcrnative from the statc's pcrspecLive

In order to assure that Information In the selected alternative and final EIS 16 as up to date and complete as possible. we %.west that the DChoCO Staff rec~uesl that the Hffected countie; check to make sure thal Lhc'ciLed land use

MR1728 -9 - n General File #7-2-3-300 James E Brown November 10. 1986 Page 2 Forestry Department OFFICE OF STATE FORESTER references are correct and accurate This would Seem to be 2600 STATE STREET, SALEM, OREGON 97310 PHONE 378-2560 2" order particularly far Grant county whose plan was recently acknowledged by LCDC. Second, the counties should be consulted by the Ochoco about whlch Clty land Use plans MEMORANDUM in their areas, ~f any, should be reviewed, especially from an economic standpoint I hope these comments are helpful ~n preparing Oregon's SUBJECT OCHOCO NATIONAL FOREST DRAFT ENVIRONMENTAL IMPACT STATEMEN1 response to the Forest Servlce-s plan for the Ochoco AN0 PROPOSED LAN0 AND RESOURCE MA GEMENT PLAN National Forest. Please feel free to contact Jim Knight of our office if you have any further questtons about our TO James .E. Brown, State Forester letter FROM Dave Stere. Director, Forest R ources Planmng DATE November 6. 1986 8

The Oepartment of Forestry Resources Planning Section and field Staff have reviewed the Ochoco National Forest Omft Environmental Impact Statement tOEIS1 and Proposed Land and Resource Management Plan (LRMP) JFR JBK k, Our review toncludes that the Department cannot support Implementation cc. Crook County Court Of the Forest's Preferred Alternative, E-departure". Instead, adoption Deschutes County Board Of C0mmlssI0ner.5 of Alternative "H" 1s recommended far the following reasons Grant County Court mrney county COUrt 1. The Forestry Program for Oregon timber harvest targets for the Ochoco Jefferson Count" Court are met for 40 years without a depapture from nondeclining evenflow Brent Lake, DkD 2 Riparian conditions are Significantly improved whlle maintaining Jim Knlght, DCCD granng potential Bob Brown, ODOF 3 Economic efficiency is maximir-d

4. Job numbers, personal income, and payments to counties are maintained at Satisfactory levels throughout the planning horizon 5 Intensive forest management levels exceed the Forestry Program objective 6 Department of Fish and Wildlife management objectives for elk are exceeded for at least the next 20 years 7 Most of the remaining unroaded areas are allocated to presmptlons which allow timber management

8 The Deschutee Canyon-Steelhead Falls area and portions of Lookout Mountain are managed to provide needed semi-primtlve, nonmotonzed recreation opportunities.

1-4-63 STATE OF OREGON INTEROFFICE MEMO

TO James Brown. State Forester DATE November 10. 1986 State Forestry Department Therefore, the Ochoco National Forest should modify Its Final EIS and LRMP by selecting Alternative "H" as the preferred alternative in order ''OM Ann Nolan Hanus. State Economist .dJIM-d to maximize net public benefits Office of Economic Analysis rff"

The Oepartment of Forestry's review also compares the Ochoco OE1S and SUBJECT Sumnary of Findings and Recomnendations for the Ochoco National Forest LRMP to the objectives and policies expressed in the Forestry Program Plan for Oregon and Identlfled factual errors and omissions in the documents.

A detailed analysis of the Ochoco Natlonal Forest~ ~~~ Plan IC.. attarhod. These Comments are an integral Part of the Department's review and Should be considered substantive by the Forest Service I have reviewed the Draft Environmental Impact Statement (DEIS) for the By considering these comments and recommendatlons, the Forest could further Dchoco National Forest. The Department of Economic Development and the improve the Performance of A1 ternatlve "H" Particular attention should Employment Division have provided their analyses (attached) which have be given to the Ochoco's economic assumptions and analysis, timber yleld been critical for my response I have discussed the plan with Forest tables and salvage program. and b>g game management strategies. Service planners, industry representatives, members of the Council of Economic Advisors. and local officials DHSlOM jp Attachment The counties most directly affected by the Dchmo National Forest Plan are Crook, Harney. Jefferson. Wheeler. and Grant These counties, espe- cqally Crook. rely heavily on the Forest for their mainstay For example. over 1.600 Crook County workers are directly employed in lumber and wood products. mainly in Prineville The forest products industry In Prineville consists essentially of four lumber mills (Pine Products. Con- solidated Pine. ochoco Lumber. and Prinenlle Sawnil1 Company) Which employ about 500 people. Two millwork plants (Clear Pine Houldings and American Forest Products) employ another 920 Workers Including several other small operations and logging firm brings the total to 1.620 workers Overall, Crook County is more dependent on timber than the statc dverage.

Crook Caunti

Percentage of workers engaged in

Hanufacturing 19 9% 39 1%

Lumber and Wood 31 9% 98 0%

The 1.640 lumber and wood products employes comprise 36 percent of the total 4.450 employment covered by unemployment insurance. If Forest Ser- vice employes were included. the percentage would be raised from 36 to 42 percent Considering the indirect effects from lumber and wood employment, industry and Forest Service payrolls in 1985 amounted to 54 percent of total covered payroll

Local governments ais0 depend upon the Forest for revenues Twenty-five percent of timber receipts are given to counties for schools and roads Crook and Wheeler counties derive thirty to forty percent of their reve- -2- nues from the Dchoco National Forest timber sale revenues James Brown -3- November 10. 1986 James Brown -2- November 10. 1986

The direct employment Impacts in the tmber ?ndustry may be incorrect Lifestyles are tied closely to the Ochoco not only do most people earn ifthey are based upon historical relationships between mill employ- their living from It. but they also derive much enjoyment from various ment and timber harvest. Gains in labor productivity in recent years forms of recreation. Furthermore. water quality and availability are have been significant. especially in areas like Harney County where closely linked to the forest new. more efficient mills began operating in 1982

The Forest Service's preferred Alternative E-departure emphasizes a com- The Forest Service should re-examine its assumptions about employment b?nation of timber production. roadless recreation. and big game shifts between Harney and Crook Counties The assumption that the habitat. Timber harvests are scheduled so that first decade volumes shift in timber harvest emphasis to the Snow Mountain District will remain close to current levels. and then decline over the next 10 to 50 boost Harney County at the expense of Crook County 1s questionable years According to the Forest Service, the departure harvest schedule The Prineville mills already compete SUCFeSSfullY far sales on Snow was designed to maintain local jobs In the short term. Mountain and will probably continue to do so

Conmentz The Forest service excluded the impact on Wheeler County entirely. This cannot be justified when the OChoCO comprises 10 percent of 1 The Forest Service selected Alternative E-departure on the grounds Wheeler Countv's total land area Also. Wheeler IS the gateway for that ~twould boost the economy in the first decade of the plan touristi. caGerr and hunters entering the Ochoco Although Thereafter. the harvest would fall substantially. and the economy Wheeler's population IS relatively small. It is heavily dependent on would be harmed significantly The long-term cost of the departure the Ochoco far its economic welfare Loqqinq still accounts far 10 cannot be justified by a short-term gain, particularly when It would percent of its private sector wage and siiari employment be so damaging to the region's long-term economic stability The changing species mix and ava~labihtyof old growth Ponderosa The departure schedule provides for 123 HHBF per year for the first Pine will have a major impact an the industries Ponderosa Pine pro- decade. 118 HHBF per year in the second, and 89 HHBF in the subse- vides, by far, more jobs per million board feet than any other quent decades The current harvest level is 160 NHBF while the 1975 species in the forest The Forest Service should explore harvesting to 1984 annual average 1s 134 HHBF The current harvest level is and silvicultural techniques that would increase the harvest of unusually high because loggers are taking advantage of renegotiated Ponderosa Pine. prior year contracts The departure schedule would result in a significant number of job and local government revenue losses in decades The Fopst Service proposes the reduction of timber full yield acre- following the first This would undermine the region's long term age Currently, 423,000 acres are managed for full yield under economic stability Furthermore. the reduction may came at a time E-departure. 262.500 acres would be managed at full yield and 232.000 when the demand for Northwest timber is rising if projections are at partial yield (50 te 90 percent) The Forest Service should correct that show declines in Canadian and Southern states' timber exolain its reasons for this shift and the mmlications for timber harvests hiwestmg The land base for timber harvesting has been eroding over the last ten years with consequential negative impacts On timber The proposed schedule could have an adverse effect on the industry's harvests. incentive to make large capital investments necessary to process smaller dimension logs In the future. smaller dimension logs will The projections for local government revenues from timber sales may comprise a much larger share of the timber harvest Industries will be high Currently. the Forest Service assumes that all tmber need to retool and perhaps modify products The preferred alterna- offered for sale will be sold for a projected price This yields a tive may not provide sufficient economic incentive for industry to projectxm of the maximum revenue a county might receive Actual make these capital investments since the future timber harvest would receipts could be lower if all the timber offered for sale 1s not decline drastically harvested in the same year A range of probable County receipts should be shown. 2 The Forest service should correct its estimates of employment effects and clarify the methodology and terminology behind its multipliers The Forest Service should address the implications of its shift from The figures for direct and indirect employment imply very low multi- uneven aged management to even aged management Ifuneven aged pliers -- less than two for direct timber jabs This multiplier management was successfully used in the past. why IS it no longer should be around two to three In addition. the figures used far employment gains due to recreation, wildlife and resource effects appear to be too hfgh For example. in the first decade the plan estimates a loss of 27 "timber. direct" jobs. a loss of only four 'timber. indirect' jobs and a qain of 94 "recreation. wildlife and range resource" jobs.

1-4-65 Aopendix James Brown -4- November IO, 1986 U.S. Forest Service Methodological-

1. Population Projection advantageour? While even aged management may result In an Increased harvest volume, would the larger trees produced under Uneven aged The population projection used has llttle to do wth reality. The management result in hTgher valued timber' What IS the Impact on staff of the national forests are using a population proJection of vlrual, w?ldllfe. and recreational values? 2.WL annual growth rate for Oregon Oregon's population has been increasing dt an average annual rate of 0.7%. Additionally, the use 8 The economic impact of the alternatlves for the management of the of population to predict recreational land use is questionable. Ochoco National Forest cannot be fully determined without considering how changer in other Forest plans -- particularly the Malheur - Will The Qepartment agrees with the Qivision of State Parks that a better affect the region For example. Harney County receiver twice as much procedure for proJecting recreational land use should proJect what timber from the Malheur National Forest than from the Ochoco If types of recreational use will be needed and the number of people harvests are reduced on the Malheur, competition for timber on other that will be involved in each type of recreation. This is a more forests would increase Also, recreational opportunities should be difficult task; however, the results vi11 be much more meamngful. considered I" the context of opportunities available from not only the Forest being studied but also from adJacent National Forests 2. Cost Accounting and u~ldernesrand other reserved areas Each forest develops fts own method for allocating costs. This Reconmendation results in widely varving accounting systems and in turn cause two problems: Alternative E-departure should be rejected because it would significantly damage the region's economy in the long term Alternatlve H should be - Different forests' costs are not comparable. It would help in selected because it maintains a sustained yield timber harvest close to reviewing these plans to cotupare various projected costs. This the 1915-1984 harvest level A sustained. predictable harvest level 1s cannot now be done in a meaningful way. more 1,Xely to benefit the area's economy without the severe disruption that would be cawed by Alternative E-departure - Different cost accounting methods are reflected in the answers the conputer provides for alternatrves. Therefore. part of the Alternative H's present net value IS higher than any of the other alter- difference between proposed forest plans is due to different natives except Alternative H-departure Alternative H prowdes for Jobs accounting methods and not to differences in cond>tionr. slightly hlghe? and returns to counties considerably higher than the current level Livestock grazing would be significantly higher (+I9 per- 3. No public input until the plan ha; been fully developed. cent) than the present Elk habitat would support 90 percent more than the current population in the first decade, and ripanan zone managemeni Currently. the forest staff develom about a dozen alternative would be excellent In all areas llth hlgh recreational use Or potentially actions Hna rms tnese alternative; tnro.gn an InpJt-outpJt m3del on high use The tradeoff would be less old growth and raadlesr recres- a conp~rerin Colorcdo. Tnese carpr:er runs arc quite ekpenrtvc. tion Wilderness acreage. however. under Alternative H would not change Tnercfore. after tlie Draft Enviror.rdn:al !n,act Statement (0~1~11s from the current amount of 36,000 acres circulated for review, the forest staff is bite hesitant to-nake additional computer runs. It Should be noted that Economic Oevelopment Oepartment has recommended Alternative B because of its higher timber sales (131 KMBF per year) On the Ilallowa-Whitman DEE, in particular. the state has requested a They believe that Alternative 8 would have "the least amount of negative new alternative to be devised. The forest staff is very hesitant to impact on local communities comply, not only because of the cost of the computer run, but also if the new run falls outside the range of previous alternatives, ANH rlf addltional public hearings would be needed. 73213 To avoid this, each forest staff should circulate thelr alternatives cc 30" YUrlXW for comment prior to making the computer runs. This will allow for a Thomas F Kennedy cost-effective method of examining a wider range of alternatives. Don 5ieward L.37l.3 CUIlY 40136 Jeff Hdnniim 10-29-86 Attdthmcnls 10/31/86 GENERAL FILE 2. TO identify and implement economically feaslble levels of intensive 7-2-3-300 forest management required to achieve Cost effective growth and harvest.

OREGON STATE OEPARTllENT OF FORESTRY 3 TO maintain comnunity stab?lity, by remaining flexible for increases in future harvest levels that would offset projected shortages. REVIEW OF THE OCHOCO NATlOllAL FOREST'S ORAFT ENVIRONMENTAL IMPACT STATEMENT AND The May 13, 1986 Regional direction provided specific compatibility standards by which the DEIS alternatives can be compared with these objectives. An PROPOSED LAN0 AN0 RESOURCE MANAGEMENT PLAN example which makes this comparison for the Ochoco alternatives is attached. This'infomation must appear in the f7ml EIS.

The Oregon State Department of Forestry's Resource Planning Section, in FACTUAL ERROR AND OMISSIONS Ill THE OOCUIIENTS cooperation with other Department staff, has reviewed the Ochoco National Forest's Draft Environmental Impact Statement (OEIS) and Proposed Land and Wilderness Acres - (OEIS, page 42) Figure 11-3 incorrectly portrays the,, ,, Resource Management Plan ILRIMP). Our Comments focus on four areas of number of acres that Mould be managed for Wilderness under Alternatives E concern. (11 Compatrbrlity of the Ochoco DEIS and LRMP with the basic and "8-deo". The acreaoes shown are onlv one-tenth of the actual amount objectives of the Forestry Program for Oregon (FPFO), (2) Factual errors and allocated under these two a1 ternatives. omissions in the document, (3) Comparison of the DEIS and LRMP view of the future with the Forestry Program for Oregon, and 14) Preferred alternative Old Grwth Acres - (OEIS, page 42, 139) The OEIS in Figure 11-3 and recomnendations Table 11-3A misrepresents the amount of old growth timber that will be preserved by the different alternatives. For example, Alternative "F" 1% SUMMARY shown to preserve 17,743 acres old growth Figure IV-6 illustrates that thrr alternative wrll actually provide around 57,000 acres of old growth when lands The Ochoco DEIS and LRMP documents are well written, comprehensive and allocated to other management areas that will provide old growth conditions informative. The Forest has set a Standard that the Department hopes other are considered. This same discrepancy occurs ~n the other alternatives as Oregon National Forests will attempt to match. However, our review has well. indicated that several important technical problems remain. In addition, the Department does not support the selection of Alternative "E-departure" as the This example illustrates a lamer oroblem in National Forest DlanmnQ The preferred alternative. Instead, adoption of Alternatrve "H" is recommended. public ha; not been fully 7nfoi"ed'about the wildlife, recreaiion an; scenic The following comments are the Oepartment of Forestry's recommendations for values that are currently being produced through land allocations such as improving the Ochoco plan when it 1s issued in final form Each of these Wilderness. RNA's and other manawmt areas which limit OP wohibit timber comments should be considered as substantive and all should be addressed 1n management Timber valuer that have been lost to these and bther management the final EIS designations are not clearly presented in the plan analysis. Therefore, the public cannot easily determine the actual level of values provided by the CO!~IPATIBILIIV OF ThE OCnCCO National Forest. They also cannot examine tradeoffs that have been made by OLIS AIIOTI:2 2ITH WE IVES CF previous land allocation processes nor trace the continued erosion of the YRL FORLSTRI YROGHAM FOR ORiGOI. commercial forest land base.

To leave out a OISCUSS~O~of tnc val~3blec~n-.rio~tions to recreition, Treatment of the Forestry Program for Oregon - IOEIS, page 172) The wllollfe habitat, uatersnco PPOteciion and other "on-marret ~31.2~ that accr.e Department of Forestrv aooreciates the text devoted to addressins the soals io the o.blic fro? lenirlative and ddministrdtivc oesmdtwn dro from and obxctives of stdte,'iocal and other federal agencies In pirticuiar. the management strategies-that are not decided through the-current planmng OChoCo-has provided a good overview of the FPFO. Unfortunateli, the Forest process is doing the public a great disservice and, in addition, may violate has failed to meet the requ7rements of the May 13, 1986, Regional direction to NEPA and NFMA requirements the Forest on CO~OWI~Q the DEIS alternatives with the basic ObJectiveS of the FPFO The DEIS his 1n;orrectly compared the alternatives to the Forestry Change in Jobs and Personal Income - IDEIS, page 46) According to planners on Program's timber harvest targets alone and has failed to consider~ual the Ochoco, employment and personal income levels for 1984 were used as the mswhich include: basis for comparinq the chanqes proposed in the alternatrves for these parameters. instead of using a single year for this analys~s,the OepaPtment 1. To maintain the maximum potential commercial forest land base recommends usiog the 1976 to-1905 average levels This ten year average consistent with other resource use while assuring environmental results in 2,013 lbmber and wood products Jobs compared to the 1984 level of quality. 1.950.- lobs. Us~noan awra~erecoanizes that the 1Umbw and wood DrOdirt< industry in cyclical and that new iechnology also changes employment &erns.

-1 - -2-

1-4-67 LUMBER AND UOOD PRODUCTS EMPLOYMENT IN CROOK d HARNEY COUNTIES 2. Table 111-4 is misleading in that it does not provide total U.S. (1976-1985) economic data for comparison. Oregon's per capita income is only 90 percent of the U S average. Therefore, even if the county data 1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 shown is near the Oregon average it is still below the national average. 2420 2540 2640 2590 1580 1390 1310 1670 1950 2040 3. What units were used to develop the graphs in Figure 111-31 The Ten Year Average. 2013 Department disagrees with the statement that combining government and manufacturing sectors overestimates the importance of timber to the Recreation Demand Growth - (DEIS, pagf 51, App., page 8-143, LRIIP, page 161 economy. The importance may actually be understated since the The DEIS text on page 5T states that .. recreatiomsts on this Forest are greater direct. indirect. and induced personal income created by predominately local". It also states that the populatlon within the two mrlling and remanufacturing is not shown. Both Iiere, in DEI5 Table countv Primary Zone of Influence is~ exoected~ I~~~~ to~~ increase~ ~~~~~ at~~ least 15.~ owcent VI-2, and in Appendix Table 8-V3, comparisons of personal income during the n&t 20 years This infers an annual growth rate of 0.75 percent derived from timber versus other resources should be displayed per year which matches the most recent statewide projection by the State IMPLAN just totals job numbers and fails to differentiate if they are Economist In contrast. the Appendix on page 8-143 states that "Current part-time or full-time. Concentrating on employment numbers rather estimates show the state's populatlon to be increasing at an annual rate of than personal income levels downDlavs timber's contribution to the roughly 2 percent" Which population growth estimate was used in calculating economy, particularly with respect to family-supporting Incomes. A the recreation demands shown in Table 11-13 of the LRMP? If the Ochoco has more accurate portrayal would show both job numbers and total used a 2 percent growth trend, the analysls of recreation demand may provide personal incomes. ,unrealistically high results. The State Economist's most recent population growth projections for this portion of the state or another accented Prescribed Fire and Air Quality - (DEIS, page 671 The text makes several methodology should be used in this analyns to estimate recreation demand. references to the contribution of Prescribed fire to airshed degradation. The Regardless of the method used, both the Ochoco's estimate of the growth rn DEIS fails to note that prescribed burning reducer the risk of catastrophic recreation demand and the Fovest's selected alternative should be consistent natural and man-caused wildfires which could qenerate severe and unplanned with the recreation and population projections of existing local land use reductions in visibility. Forest smoke will inginate on the Ochoio whether plans. or not prescribed burning occurs. Through the use of smoke management techniques and by employing today's controlled burning methods, the effect of Potential Timber Yield - (DEIS, page 591 The text incorrectly defines prescribed fires on visibility can be minimized. The Department supports full potential yiew.. the total harvest level that could be sustained use of this and other management tools in order to prevent the significantly assuming intensive forest practices on all available acres". A more accurate greater air quality problems and other costs which would result from wildfrres definition IS that ootentlal ueld is " .. the OOtlmum DerDetual in areas of untreated fuel accumulations. sustained-yield havesting level attainable with intenslbe iorestry on regulated areas considering the productivity of the land, conventional logglng Elk Management Objectives - IDEIS, page 77) The text provides the current and technology, standard cultural treatments, and interrelationship wth other proposed Department of Fish and Wildlife management objectives IMOI for elk resouce uses and the environment" (from Ochoco 1979 Timber Management Plan). and states that these objectives 'I.. have been used as Indicators of demand Tms latter definition makes "potential yield" equal to "allowable sale during the planning process". The DEIS then states on page 175 that '"If the quantity" (ASQ). However. the text states that potential yield is equlvalent FOPest selects a habitat management level that varies Significantly from to a maximum timber FORPLAN run and IS not comparable to the DEIS alternatlve ODFW's NO, it IS anticipated that ODFW 11111 assess the consequences and ASQ levels. The Department disagrees with this canclusian and urges the readjust the MO If necessary" The latter statement appears to depict the Ochoco National Forest to provide additional discussion on the relationrhlo management objective as a measure Of supply rather than demand Given this between existing potent?al'yield and the alternatlve allowable sale quantltles discrepancy, the Department of Fish and Wlldl~fe'smanagement objective seems in the final EIS to be of little value in comparing the merits of the different alternatives The final EIS should clarify the relationsh~Dbetween the Forest plan and the ComPJriron Of Past, Present, and Preoicted Tllnber OJtpitr - IDElS, page 601 ODFW elk management objective. Table 11-8 I.~~lode no~eusefil II tne pl3nneu vo1Lme UY alternatluc ,#as given fur ~acnof the five deceucr rather than lust tne nlon and la.. dscnoec.... Cmtr Assumptions Concerning Leisure Lifestyles - IDEIS, page 991 This discussion foot COmparisons should also be given Centers on the oint that greater recreation OPPOPtUnltleS will bnng more money into the Yocal economy. However, the DElS has noted elsewhere that !most Social and Economic Setting - IDEIS, page 54-66) Several points in thls of the recreation use on the Forest comes from local residents Ifhigher discusslOn must be revised paying timber industry jobs are lost to provide more leisure time opportunities, recreation use could actually decrease as families move to 1. Deschutes County populat10n In 1985 should be 65.300 not 15,300 other areas reeklng employment. The remaining population would not make up this lost income and local businesses would suffer rather than benefit. Wallowa County provides an example of this scenerio The Ochoco should reevaluate its assumptions on the economic effects of changing recreation SUPP~Y

-3- -4- Effects of Timber Harvesting on Soils - IDEIS, page 115) While it 1s true the employment effects of hunting. Does line 9 double Count hunting that the Intenslty of site disturbance is greater with the clearcut harvest employment effects by asrumng that all semi-primitive "on-motonred system than in selection harvests, the text should also emphasize that the recreation is hunting? frequency of entry into stands is higher when the selection system is used. Overall, soil damaQe may be more slunificant in oartlal cuts Soil Our research shows that the Job nultiplrer coefficient should be characteristics at-the tme of entrj. the number'of entnes, and the type and closer to 2 than 0.5 Why does the OChoCO use such a small multiplier degree of disturbance all detemne potentla1 far so11 damage The Department to estimate indirect and induced employment? Supports the mltlgatlon measures Outlined on pages 121 and 122 to minimize forest soil damage. If a multiplier of 0.5 has been used, why are the Tndlrect employment effects for Alternative '"8" in decade 1 in Crook County almost equal Semi-Prrmltive Recreation - IDEIS, page 157) A sigmflcant amount of the to the direct effects? reweation use on the Ochoco Natlonal Forest occurs in the form of huntlng. Regulated road closures ~rovideODDOrtunltleS for semi-Dnmltive non-motonzed Table B-V-3 shows no indirect effects in Jefferson County from timber recreation during the hunting season while providing roeded recreation harvesting. but does for recreation, wildlife and range resources. opportunties throughout the rest of the year. Has thls source of The text also indicates that no income from any of the resources is semi-Primitive, non-motonred recreation been considered ~n the estimates of spent in Deschutes County, the primary shopping hub of Central supply provided by the different alternatives? Ore9on. These conclusions amear to be incorrect and should be revised to more accurately pb;tray the economic importance of the Oevelopment Of Tinbcr Yield - IApp., page 8-35) It appears that tne Ochoca llational Forest. sibstantial drop in potential yiclo fron tnat previoJsly estaollshed by the 1979 Ocnoco Timber Managcnent Plan IS rostly calseo oy cnanglng nanaged yleld Is the "current situation'' IiaPvest level of 127 IDiBF the correct taoler. This IS similar to the drm in potential levels we and others nave basis for determining the employment effects of changing the amount experienced in our ProJeCtiOns The magbitude of the drop an the Ochoco, of timber sold? Has the contribution of ralvaoe volume been fullv however, is greater than expected. considered? If the purpose 15 to describe pot;nt?al Job losses, . would not the use of the existing potential timber yield of 137 MMBF While we agree that the approach taken in buildina these tables is techmcallv be more appropriate? Does the species composition of the "current correct, we suggest that you review them to determine where intenslve Situation' reflect historic average? management could further increase timber outputs. For example, settlng the PROGNOSIS keyword BAMY for the PIP0 habitat tYDetype to 121 may be inamrooriate.inappropriate. Harvest Dispersion Constraints - IApp.. page 8-60, LRllP page H-1) Page B-60 While current, natural stands have not grown toto be denser thanthan 121121'kqubre square feet states that the watershed harvest dispersion Constraints will be between 17 per acre, there may be opportunitiesOpportunltles inIn managed stands to decrease clumprness percent and 23 percent. On page H-1 the range of dispersion constraints 1s and to exceed this selected maximummammum through pre-cammerclalpre-commercial thinning and brush Qlven as 25 Dement to 35 oercent. Which Set of fioures IS Correct? What control Fational SLPports tnere vcky reitrIctive Ocnoco n2r;es: aispcrsion constraints hnen the Deschutes !lationel Forest satisfied this minimi? management It appears that opportunities for cost-effectively ~ncreasingtimber growth requirement IIliaI wtn a 58 percent constraint? through intensive forest management have been lost in these yield tables. Is this because the Ochoco has averaged slte-Speclflc stocking levels and UllOllfe IWR Conrtralnts - IApp , page 6-61) The flndl EIS Sno~loinclLoe d Dlantdtlon Performance into one Forest-wide averaae? Averaotna on fwests. .... tdblc 51n1laT to tnc Adg.st 8. 1984 LllOllfC EUX I11tI11X proadceo Oy the with relatively low productivity such as the OchoGo would s;em-to take away Region. Tnis table provioes needed infomation on the n.mbcr on OdDltats opportunities to intensively manage high site lands while addlng few oeing pwioea oy tne Forest for eacn inaimtor species, tile acres of sh!taole OPPOrtUnitieS to obtain increased arowth from low site lands If this 1s the lano Involveo, the effect of these allocations on timber proaLct1on dnd Other case. yielor shoild be ~ncredseot6 reflect actJal management and gro,,tn useful details. Sdch adta is critical in deteninlna if tnu Ccnoco HMR opportlnvtles. The So.th Central Oregon/lortnetn Call fornla Yarldnt PROSNOSIS constraints are consistent witn Regional gbidelines and tnat the constraints

moas1 ind~oe dmroDPiate to ~~QSSCSSthe ~CCUP~CVOf tne~ ~ Ochoco ~~ ~~~ ~an.medv~eld ~ are indeed tvJCly reqdirements tables fir rtiids ;im,lar to those on the Deschuies National Forest Elk Numbers - IApp., page 0-1451 Table 8-YIII-IO prcsents only tnc projected Employment Effects - IApp., page 8-52] It appears that errors may exist in elk hauitdt Capability in DeCdOC 5. The docmnt fails to point oLt that most the documentation of employment effects that could distort the socio-economc of tne alternatives w111 support eln nmbers mone the proposed PDFH -3 analysis of the alternatives. Such distortion could also affect the nanagement objective for at least 30 yedrs. tiell oeyond the life of tnia theoretical performance of the DElS alternatlves. The final EIS must address plan. As dn examole. Alternative I1 nap an el). naoitat caoabilitv I" the following problems and document how any reviSlOnS will modlfy the Decade 2 which 15'2 6 times greater than the current management obktive and a1 tematives 1 2 times greater than the proposed ObJective. The Forest plan should emDhaLlre the irretrievable commitment of resources such as elk habitat rather 1. The text states that the ninth line of Table E-V-1 informs the reader than citing long-term projections that future planning decisions may alter. that 1000 hunting recreation visitor days spent in Harney County will create one hunting Job. Line 6 in the Same table already tabulates

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1-4-69 Big Game Thermal Cover - (LRMP, page 11 The plan proposes malntaining at Insects and Disease - (DEIS, page 67, 1041 The final EIS should provide more least 40 to 50 percent of the land base in biq qame ranws in thermal cover detail on how the different alternatives will affect the potential far future In contrast, research recommends 40 percent oi the range in themal and hiding insect and disease problems. Specifically, the Forest should address how cover as being optimum. Of that 40 percent, 20-30 percent should bemding future mountain pine beetle outbreaks and possible western spruce budworm cover. and 10-20 wrcent in thermal cover in order to achieve ootimum problems will be prevented or promoted by the alternatives. Conditions Why is the Ochoco recommending less than optimal lblsof hiding cover and forage areas on big game ranger? Without adequate forage areas, the The Dep'aartment believes the ability to prevent future insect outbreaks is target population cannot be maintained. de,woenc ~ponthe timber nanagenent strateg, pirsJe0 Alternarlves whlch increase the nrwer of acres tnat are nor managed to increase tne nealth and COPPARISOh OF ThE OElS All0 .RVP VlEU OF TnE vloor of the limoer reso~rceare nore lllelv to reSJlt in future insect F.1.RE dlTH THE FORESIRY PROGRAM FOR OREGON epidemics. The Department of Forestry supiorts utilization of an integrated pest management system and intensive forest management practices in all Demand for Ochoco Timber - (DEIS,,,page 5, App , 8-41] The text on page 5 of a1 ternatives. the DEIS states that a lack of a . suitable timber SUDD~Vfrom the Ochoco has been protrayed (sic1 as causing higher stumpage prices :..I' and that Suitable Forest Land Base - (DEIS, page 891 There appear to be two problems higher volumes of timber sold from the Ochoco could be processed locally, with the suitabil.ity anaiysis shown in Table 111-25. Under item IV, POSSIblY leadinq to lower stumeaue ences". These statements combined with inaccurate numbers have been used in the calculation of tentatively suitable the fact that mich of the ponderosa pine processed in Crook County is land More maortantlv. there are several undocumented chanues from the tPansported from outside the area, conflict with discussion in the Appendix analysis eresinted on 'bise 278 of the Ochoco AMS document. is a result, the which assumes a horizontal demand curve for Ochoco timber. DEISsho$ a forested iaid base which 1s 9,485 acres less than the AtlS and a suitable land base which is 12,093 acres less than the AMS indicated. What is The DEIS also has failed to fully address the changing timber supply situation the justification for these changes? in Oregon Inventories on private industry lands are falling and ponderosa pine availability on all ownerships is decreasing In light of these trends. 819 Game Management - (DEIS, page 140) Questions on big game management it is unrealistic to assume that the Ochoco National Forest faces a horizontal ?unanswered by DEIS include: demand curve for timber and that the number of jobs, personal income, and payments to counties will not be affected by economic influences outside the 1. Since some winter range areas receive heavier use than others, would National Forest boundaries. The economic analysls for the DEIS should take not more intensive management of these preferred ranges and less on into account the dynamic social and economic environment in which the Forest the remainder be more desireable and promote both big game and timber operates with lower overall management costs and higher overall benefits?

The Department disagrees with the assumption that the Forest's actlv?tjer have 2. More challenging hunting Opportunties can also be achieved thmugh no measurable effect outside the '"zone of influence". For example, Oregon's road closures. limiting the numbers of hunters, and reStnCt3ng the inetrOpOl1tan economy, through such Indurtner as bankins, insurance. and heavv harvest to certain types of game (example - Bulls with three or more machinery, 1s indirectly dependent on timber and other iesaurces from all the- antler points). To what degree would increased use of these other Region's Hatianal Forests This large-scale econmlc Influence of the Dchoca methods of regulation reduce or eliminate the need to limt timber should be addressed. PPoduction?

Ponderosa Pine Volume (DEIS, page 591 The text states that the current 3. Elk numbers in central Oregon could increase to the point where the - availabilitv of winter ranue would be the limitins factor Conflicts timber inventory shows 67 percent of tile total volume on the Forest 1s ponderosa pine and that the ponderosa pine harvest in all alternatives will be with other ises on the priiately owned, natural winter range would within 62 to 72 percent of the total harvest volume This clalm IS increase. By continuing to optimize the available summer and winter contradicted by information recerved from the Ochoco planmng team. The elk range on the Forest, the Ochoco may be managing its land for elk latter shows the proportion of ponderosa pine varying froin a high of 80 numbers that cannot be supported by the total habitat In light of percent in decade one of Alternative "A" to a low of 55 percent ~n decade the other Pesowce uses an the Forest, at what point will the three of A1 ternative '"E". lMa?ntalmng a reasonably constant supply of marginal benefits of additional elk be exceeded by the marginal Cost ponderosa pine to milling and remanufacturing plants IS critical to the of providing the Iiabitat? central Oregon economy. Harvest plans of the alternatlver should not propose large changes in species mixes, especially reductions in the percentages of 4. What costs and property damage may be incurred by adJacent landowners ponderosa pine offered. through elk migration and hunting recreation? HOW will the Forest's actions affect this problem? How are these costs factored into the Plan's an&lys,s?

-7- -8- - (DEIS, page 1661 The Department supports the efforts of the Regeneration Harvests - IApp 0-30) The t7mber resource practice standards e the costs of road construction and to close unneeded roads and guidelines tor the General Forest Management area and other prercnptians either reasanallv or oermanentlv to increase effective wildlife habitat. include the statement that regeneration harvests will occur at culmination of Cooperat7ve roadclo&e progrdms during elk season have proven to be very mean annual increment ICMII. Is It necessary to extend regeneration harvests successful. Benefits of regulated road closures include past 95 percent of CMI? Whenever shorter rotation lengths wll not confllct with the goals of the management area prescnpt~onor lower the present net 1. Reduced animal harassment through impwved hiding Cover. value, 95 percent of CI,IRI should be used At a mlnlmum, It should be included in the criteria for the General Forest Management area. 2. More opportunities for high-quality, rem-pnmative. non-motorized hunting experiences. harvest Cbtting I.lethoor (App., F) - The Ocpartxnt of Forest?, s.pports the flexible, site Specific approach to the selection of hdTwst c.ttinq inetnoos 3 Reduced conflicts between timber and wildlife management as reqJireo oy tne Regional G~loc. Tne Ocnoco 1s encowagec to raintaln this flexlbilit~10 the Forest olan. hhen determinino the hawest CLttlnC rethoo. 4. Reduced road maintenance costs by elrmmnat7ng hunter traffic during economic binefits to the Fbrest and the timber pirchaser should be considered wet fall months. as well as logging feasibility. stand Characteristics, s>lvicultural response, and the effect on ather resources and their user. In addition. uneven-aaed The final EIS should emphasize that it 18 the use of roads not the roads management should'be considered to maintain timber yield in those areas ;here themselves which affects wildlife habitat. The Ochoco is moving in the right clearcutting is limited or prohibited to accomodate other resource uses The direction by regulating the use of roads while still allowing access for Forest should work to im~roveknowledoe of uneven-aoed manaoement aoolicatianr periodic. cost-effective, timber management activities. in eastern Oregon forest; through silGicultura1 reseatxh, &fined yibld tables, and economic analysis Unroaded Areas - (App C) It is inappropriate that the Forest's preferred alternative retains 28,441 acres or 48 percent of the remaining unroaded areas Research - I-RKP. page 21) Tnc Forestry Program fop Crcg~cnco.raqes in an undeveloped state. The Oregon lhlderners Act of 1984 states that rerearEn to ~rproveforest prod~ctIvIt~,tnc ecnnnnics of intensive ranagcment unroaded areas not designated as wilderness should be managed for multi le use practices, and to ioentify the naoitat neeas of 010-protrtn preferring and that management for future wilderness consideration is not nec& wildlrfe. Therefore, tne Deparment supports tile resedrcn PPoqran ortllneO Dy keeping with the intent of this law, the Department of Forestry recommends the Forest. In addition to the researchneeds identif7ed bi the Ochoco, we that unroaded lands which support productive forests be returned to the believe more researrh IS needed to suitable land base and that tile timber volume be included in the regulated timber harvest schedule. 1 Develop new technology to Peturn some of the 2,560 acres removed from the suitable land base for regeneration difficulty to timber Fire Protection - (APP., Page D-9) The Department of Forestry supports the management status. Forest's polic, of applying-dgrCss1ve suppression action to uildfires that tnrcdtcn life, private propew, piolic safety, rnpravencntr, or investments. 2 Improve knowledge of elkkattle competition HO~CV~P.tnc DEI5 an0 LRM? SnoJld more clearly exolain Wmt CritCrI.3 will determine when a "threat" exists and the ''appkpAate" suppression response 3. Gain better silvicultural knowledge on understory management and that will follow Unplanned ignitions should be used as prescribed fires only uneven-aged management. if compliance with the Oregon Smoke tlanagement Plan can be assured Coordination of protection planning and suppression efforts With other Timber Salvage Prograin - (LRMP, page 59) The Ochoco National Forest has an protection agencies, including this Department, should be included as a part . opportunity to improve its timber salvage program by nore aggressively of these guidelines. harvesting scattered, overmature ponderosa pine These large, valuable trees are often lost to insects and disease before they can be included within a Minimum Stocking Levels (App., page 0-20) The Ochoco National Forest is planned harvest Unit Forest industry estmater that 20 llMBF of high quality, proposing minimum stocking levels of betdeen 50 to 75 trees per acre, high value timber could be recovered per year. Eighty percent of tliis salvage Ueoendino on site This level of Stockina is below the minimum stockina level work could be conducted on areas Suited to tractor logging As a result of peiimitteh under the Oregon Forest Practic& Act. Since the Forest Service has increased salvage, forest industry would obtain the larger ponderosa pine agreed to meet or exceed the Fovest Practices Act requirements, the proposed desired to supply its mills and remanufacturing plants, communities would minimum stocking levels are unacceptable These standards nust be revised to enjoy increased employment and personal income, and the Forest Service would satisfy the requirements of the Act which include establishing at least 100 receive higher stumpage mvenues. The Forest would also enjoy a higher net seedlings or saplings per acre, well distributed over the operation area? timber growth rate through reduced future mortality Meamrhlle, acceptable within six-years. Refer to OAR 629-24-401 and 402 for details on this levels of old-growth and snags would be retained through management area requirement. The final EIS should document what effect this higher minimum allocations and 14Nqs. The final EIS should address this recommendation. level would have on future timber yields, biq game cover, and other resource outputs

-9- -1 0-

1-4-71 llamtorin - (LRIIP, page 99) The Ochaco has provided a very goad framework Alternative "h" coulo be fdrher improved tnrougn adoption Of In@ Oepartment of +or its monitoring and evaluation program The following changes would Forest~] 5 ofner rccommendatlons in tnlr revle!i. Tne Ocnaco I.at!ondl Forest improve this very important part of the management plan. is encowagco to carefilly consider thls CL~SB of dctlon 1. Change the reporting penad for land suitability from 10 to 5 years. The objective for this category should be revised to include the OM cn potential for returning lands incorrectly classified as unsuitable to Attachments the suitable land base. 7353E

2 As new information becomes available, minimum management requirements should be revised to Insure that neither under-protection or over-protection occurs.

3. The variability threshold for payments to counties should be more specific than "an unexpected trend up or down". A variability threshold Of 2 10 percent IS recommended 4. Personal income should be added as an activity to be monitored. Monitoring frequency should be annual with a 2 10 percent variability threshold.

PREFERRED ALTERNATIVE RECOMMENDATION

The Department of Fovestry requests that the Ochoco National Forest select Alternative "H" rather than Alternative "E-departure" when the Forest plan is issued in final form. Alternative "H" provides a more nearly optimum mix of resource outputs which addresses the issues identified by the public, achieves a higher level of long-term net public benefits, and more closely meets the ObJectives of the Forestry Program for Oregon.

Specifically, the Department supports Alternative "H" for the following reasons 1 The Forestry Program far Oregon timber harvest targets for the Ochoco are met for 40 years without a departure from non-declimng even flow

2 Ripanan conditions ape significantly improved while maintaining grazing potential.

3 Economc efficiency is maximized

4. Job numbers, personal income, and payments to counties are maintained at satisfactory levels throughout the planning horizon.

5 Intensive forest management levels exceed the Forestry Program obJectives. 6 Department of Fish and Wildlife management Objectives for elk are exceeded for at least the next 20 years 7 Most of the remaining unroaded areas are allocated to prescriptions which allow timber management. 8. The Derchutes Canyon - Steelhead Falls area and portions of Lookout Mountain are managed to provide needed semi-primitive. non-motorized recreation opportum ti eS

-11- -1 2- ... -El- @ STATE OF OREGON 11V TEROFF ICE MEMO N . '=w

TO ~nnHaws, state Economist 7 Dh,,. October 79, 1986

FROM Thomas F. Kennedy, Economic Development Depa

SUBJECT OC~OCONational Forest Plan Review I This memo is composed of the followlng Sections I. Background 11. Mills identified as primary and secondary users of timber from Ochoco National Forest Ill. Components of the U.S. Forest Servlce Plan IV. Economic Development Department's Analysis of U.S. Forest Service Plan

V. Economic Development Department Recomendations

0 0 VI. Appendix General Questions Regarding Forest Service ilethodology D D " " I. Background n Iy ID" The land administered by the Ochoco National Forest and Crooked m n River Grassland occupies 955,100 acres Within Crook. Harney, Grant. Jefferson and Wheeler Counties of Oregon. The area's economy is r m < highly dependent on forest-related industry, agriculture and cm tourism. 0 " In Crook and Harney Counties, over 80 percent of the forest land 1s 3 in public ownership, most Of it 1s administered by the U.S. Forest m Service. n Y Maximum mill capacity In Crook and Harney Counties is approximately n5 D 385 m1llian board feet annually. 1933-34 estimates indicate that n approxmately 160 m~llionboard feet (42 percent of maxlmulii Iy capacity1 is being milled annually in these two counties. y1" Undoubtedly, timber availability from the Ochoco National Forest -nD affects stumpage prices as well as local economic well-being D < All five cointies the affected area of the Ochoca Kational -D Forest and Crooked River Crassland are hcavil) depcnuenr on ~anientsfrom the Forest Service for tleir oDerdtino oudwts.

D ihbty to forty percent of Crook and Wheeler' County-revenues are m derived from this source. Grant, Harney and Jefferson Countws receive payments representing 15 percent of their revenue. The 0 timber industry and related government agencies account for approximately half of the area.'s economic base.

1-4-73 I Ann Hanus Ann Hanus October 29, 1986 October 29. 1986 Page 2 Page 3

I1 Mills Dependent on Ochoco Timber IV. Analysis of the U 5 Forest Serv~~ePlan Primary Purchasers of Timber from the Ochoco National Forest 1. The Economic Development Department does not expect the employment increases projected by the Forest Servlce to actually happen. A Consolidated Pine, Inc. Prineville reduction in the allovable cut of 9 IWBF per year will 11kely Ochoco Lumber Co. Prineville further reduce employment. Prineville Sainnill Prinevil le Pine Products Cor0 Prineville The implicit multiplier used in the above table IS extremelv low. Snow tiountain Pine CO. Hines In timber-dependent comiunities, a direct timber job usualljl DAW Forest Products Co. Bend results in two to three secondary jobs. The above job implies that Only a fraction of a .lob results for each direct timber lab. A Secondary Users of Raw Matenal from Ochoca National Forest more reasonable [and ionservative) multiplier would assume at least c1ea.r two Indirect jobs for each direct job. this means that for the 50 Ckdm Pine Corporation Pnnev7lle jabs to be lost in dwect tmber production ID Crook County, there American Forest Products Co. Pnneville IS a potential loss of at least 100 indirect jobs. D & E Uoad Products, Inc Prineville PlOneer CUt Stack CO. Pnnevllle Also, there is no reasonable explanatlon In the plan for haw 59 &dm~~kW Corporation times recreation jobs will be created in Crook County or how 22 jobs will Frenchglen ihlhrork Co. Hines be created in Harney County. 111. Components of Alternative E-Departure are' 2. The potential reductions in the harvest are a real concern. The U.S. Forest Service is predicting a reduction in demand for timber 1. Reduces the allowable cut for the first ten years of the plan by 9 after the first decade of the plan. This reduction in demand will million board feet [MIIBF). The 1975-84 sales volume Was 134 MMBF result from a decline in new housing demand in the U.S. after per year. Alternative E-Departure xould provide for 123 MllBF per 1995 By 1995, the baby boom generation rnll have, as a group, year for the first ten years Of the plan. completed the purchase of new houses.

2 After the first decade the allowable Cut would be reduced to 118 The Economic Development Department disagrees with thlr analysis. IYlSF per year for the second decade. For the third decade the for the following reasons. allowable cut would be 89 IIWBF per year. While U.S. demand will decline. so will the supply of tmber from 3 After the first decade the species mix will change. Ponderosa pine the South and from British Columbia as !ell as areas of the harvest m11 decline as a percentage of total harvest and the Northwest. dlrlmeter of the ponderosa pine harvested will be significantly smaller The rpec7es mix will increasingly consist of mare Douglas Additionally, the demand for lumber ffom Pacific Rim nations is fir, Liestern larch and white fir just now beginning. As incomes in these nations increase, the demand for lumber for building IS expected to increase. 4. Alternative E-Oeparture forecasts increased employment in the Ochoco region as i) direct result of the departure timber scliedule: The Econormc Developrilent Department. State Forestry Department, and the forest products industry are trorking to develop these markets. Table 1. Projected Employment Changes This increased demand, coupled with declining supplies elsewhere, Resulting from Alternative E-Departure nay well take up the potential slack in the U.S. domestic demand. So, it is to Oregon's advantage to make sure that the Forest Employment Crook County Harney County Service maintains the highest reasonable allowable cut. Timber, Direct -50 t23 3. AS the species mix changes and the dianeter of the tinber Tinber, Indirect -19 t15 decreases. the mills in the area will face Increasing costs. They Recreation t59 t22 will have to retool to be able to Process small trees. fmd a Total Employment -10 +SO timber supply from outside the aria, OP close

Source Ochoco Oraft Environmental lnpact Statement. p. 97. Ann Hanus Ann Hanus October 29, 1986 October 29, 1986 Page 5 Page 4

Alternarivs 8 matnrainr old gronth f3rest 81 32,COO acres com;lared Th?s will require capital investment for retooling and the impact to 50,000 in E-Deprc~re. rnis 1s toe price ior mainraining a on Jobs 1s undefined, 1.e.. increased productivity may result in srrong local economic job base. job loss. Uhrle Alternative B trould maintain Lookout llauntain as "General 4. County Revenue Projections Forest" (GF) category, ire would recommend that Lookout Mountain and Silver Creek be maintained as semi-onnitive non-motorized (SPNI41 The ~ro~ectm~sfor countv revenues from timber sales are not category, as proposed in Alternativb E-Departure real'astic. Lurrently, th; projections assme Enat all the timber offered for sale ~111be sold for a projwted price. Tnir yields a TFK.rfh uro.iecLiou of tne nldximm revenJs a counti mwht receive. Actual 40136 ;nu& receipts will be less. Based on pist :rends in timber sales, a range of possible county receipts should be provided. V. Economic Development Recommendations 1. The Economic Development Department rejects Alternative E-Departure because it predicts a decline in Jobs due to timber harvest reductions from the current 160 MllBF per year of actual sales in 1986, to 123 IIllBF per year for the first decade and an even worse decline to 118 MMBF per year and 89 IUiBF per year for the decades that follow.

2. Table IV-30 of the EIS indicate that tne Plan proposes the reduction of acreage in full yield from the current (1979 Timber ilanagement Plan) figure of 423,000 acres to 262,500 acres. this means that less than a third of the land in the Ochoco forest is proposed for full yield (91-99%) management. Approximately half the forest is currently being managed for full yield.

We do not support reducing the acreage proposed for full yield managerilent.

3. The Economic Development Department reconmends the adoption of Alternative B with some modifications.

Alternative 8 has an Allowable Sale Quantity (ASQ) of 137 IlMBF per year, which is the current potential yield for the next tu0 decades. (This campareso a reduction of 123 MIKIF per year, 118 MliBF per year and 89 lIl,IBF per year for the three decades in the Preferred Alternative.)

Alternative 8 is the alternative With the least amount of negative iiilpact on the local conmunities. It also has more elk population in the first decade than the preferred alternative. The loss of some elk population in the third decade could be avoided ifthe U.S. Forest Service was to have mope road closures (inth gates, e.g ) to mitigate elk habitat disruption Additionally, increased t,atershed management would improve elk habitat.

1-4-75 3. AsIessment of the economic analvris and data used in State of Oregon '1 l?iX the Ochoco OEIS. iMPLOYMENT OIVIVON overall. the Plan appears to be a reasonable comprom~se nepariment ot liman I:csoIII'Les ---.- L.ZI I.,? ?IYl.z3L,,l responding to the Often competing demands placed upon the I resources of the Ochocn NF. ranging from recreation and wildlife to timber supplies and gbanng The economic analysis appears reasonable in its basic aSsUmptlOn5 and TO Jeff Hannum, State Date, Orlollel 71. 1906 inmt data. However. the COmPUter uenerated COnClUSiOns Addrerr Labor ECOflOmlSt regarding impacts .of the ' selected alternative (E Departure) on employment are questionable First. the FROM M c. Mahap No. 0090A assumption that the shift in timber harvest emphasis to Address Labor LConOm~St the Snow Mountain District during the first decade of implementation will boost industry employment in Harney Subject Comment on Propose :hoc NF and and Resource Management Plan Lbunty at the expense of that in Crook Lounty is highly dubious. The Prineville mills already compete successfully for sales an Snow Mountain and will almost 1 Lconomic dependency of the local area on the Ochoco NF. certainly continue to do so Thus, analysis of Plan since over 80% of commercial timber lands lie within impacts on employment should be limited to the overall National Forest boundaries in Crook County, mills located portion of Table 8-v-3 (attached) The arrumptionr ~n prinevilie are largely dependent on publlcly owned regarding direct effects appear reasonable assuming static tlmber The forest products industry 7n Prinev3lle conditions are maintained during the decade in the local consists essentially of four lumber mills (Pine Products. wood products industry (No new plants, but machinery ConSolidated Pine, Ochmo Lumber, Prineville Sawn111 Co ) improvements in existing mills wh?ch tend to reduce currently employing about 500 employes. and two millwork manpower needs) plantr (Llear Pine Mouldings and Amencan Forest Products) currently employing some 920 employes. Several small However. over the past decade in Central Oregon losses in onontlonr and lominq firms bring total current basic lumber production have than been offset by -r- -- - ~ ~ _. more employment to 1620 gains in remanufacturing Although the Pnneville mill5 are presently basicaliy large old growth Ponderosa The lb20 lumber and wood products employes comprlse 36% of processors. given the inevitable change in future timber the total 4450 employment covered by unemployment harvest characteristics implicit in the Plan. it is highly insurance Adding 280 Forest Service employes brlngs this likely that adaptations to more efficiently process figure to 42%. or 1900 Assuming a multlpller of 2 0. small& logs and new plant(s) for chip or fiber based the countyls covered employment not attrlbutable to the nmducts will occur, If so. thlr could offset employment lumber and wood products industry would be only 650 vet'. the A~SO, industry and Forest service payrolls in 1985 Plan proposes to sustain the old growth timber harvest comprised 54% of the total Covered payroll Essentially. dunna the firit decade of Plan Imolementation at the without the presence of the Ochaco NF Crook County would &en& of harvest levels in subsequent decades in terms more closely resemble Gilliam county. economlcally of both mbf and mmcf (See attached Table 11-8) Without dependent on agriculture and the Les Schwab Tire Co. the Departure. while mmbf would decline as tree dimensions shrank. mncf would be unchanged (Table IV-4 attached) 2 Comparison of the crook County economy to that of the This falloff in mmcf might lessen the prospects for chip state as a whole or frber based manufactunng Sacrificing long term The economy of crook County is narrowly concentrated In harvest levels far short term gains should be carefully three sectors lhe manufacture of lumber and wood conndered in the light of local preferences products. government; wholesale trade Statewide. the percentage of covered employment engaged in manufactunng AssUming a multiplier of about 2 0, the indirect ~n 1985 was 19 9% compared to 39 1% 1n Lrook. In Crook, employment effects seem very conservative. unless they are 98% of manufacturing employment war in lumber and wood the net Of combined d,rect and recreation effects Gains products compared to 31.9% statewide. Employment in stemming from recreation enhancement appear Somehhat wholesale trade was 8 3% of the total in Crook. 6 6% Optomistic since this activity 1s highly summer onented statewide solely due to the presence of the Le5 Schwab on the Ochoco Also. recreation IS heavlly oriented Tire Lo , whose headquarters, warehousing and recapping towards camping. With local expenditures largely limited operation are located in Pnnev3Ile. Government to the ourchase of fuels and suool~es Even if correct. employment was 19 5% in Crook compared to 18.1% statewde jobs cieated Would be of a 'hlghly scaronal nature. due to the presence of the Ochoco NF headquarters and averaging perhaps $6-8.000 pep year. less than half that regional officer Of 8LM and Oregon State forestry In of jobs in lumber and wood products This impact is

2 1 Ponderosa pine reflected in the low overall net Income gain Given the sustained yield of old growth (t$z70,000) nrovided over the next decade under the Preferred given in the overall effects table, despite a net creatian It Of 63 lobs Over the first decade ilternative. C Departure. IS highly llkely that all Prineville mills Mill be able remain in operation. In sum. assuming the almost Certain adjustment of the although continuing to experience the slow erasion of Prineville mills to the shift in lharvest emphasis to Ihe employment resulting from technologlcal improvements In Snow Mountain District. mill employment in Crook County the Subsequent decade it appears inevitable that reduced will remain relatively stable, except for the gradual harvest levels will force the closure of at least one ongoing decline resulting from technological change. over mill. with the loss of rouohlv 100 mill and lOualnu the first decade of Alternative E Departure employes. while remaining mi implementation Subsequent employment changes will depend allow for the processing of smaller dimension 109s on whether or not plants capable of utilinng changing However. paPt or a11 of thls decline could be Offset If harvest characteristics are built. with the near term the growing volume of material unsuitable for lumber boost in timber harvest at the expense of long term encourages the construction of a plant for chip or fiber harvest volume possibly hindering this development if the based products The impact of the long term reduction in Ponderosa pine lumber production locally on millwork Departure varient of Alternative E IS adopted. operations is unclear slnce at present they abtaln well 4 Econamc impact of the preferred alternative on the over 50% of their lumber requirements from nonlocal local area and State sources In evaluating both the Dexhutes and OchoCo NF DElS there is a growing awareness that the most basic question The changing character of the timber harvest in coming regarding the management of Ponderosa pine dominated decades. with its growing volume of small logs ill suited forests has been inadequately addressed Past harvest7ng to lumber Product10n. could well have an impact beyond policy appears to have stressed uneven aged management those cOmmunit>er dependent on the forest products The new Plans Stress even aged management. with limited industry. It seems likely that in many C~SES. for reasons analysis of the comparative advantages of the two of Insufflc?ent volume or lack of capital 7" a aiven systems. This omis~ion leaves unanswered a number of locality, new plants capable of Ut11121ng this material uuestlons Among them If uneven aued manaaement war will tend to be bullt in centrallred locations rhus. successfully use: in the part. why-is it -no longer some communities may well beneflt from these changer I" advantageous' While even aged management may result in an employment terms, while others will experience significant increased harvest volume. would not the lamer trees declines Th7s development is already underway. Wlth some produced under uneven iged management be 0; greater areas experiencing dec1,nes as a result of the decllne ~n value' What about the capital costs incurred by area sawmill employment of the past few years. whlle others mills as they are forced to adapt to the processing of have expanded remanufacturing operations to replace these smaller. lower value logs? Would not the complexity of losses The message is clear at both the state and local the, proposed Plans and their Implied h?gh management costs level If present employment totals ~n the forest be greatly reduced under uneven aged management as almost products industry are to be maintained. the capital the entire Forest could be managed for timber production investment needed for new or expanded remanufacturing since harvesting of any given tract would only occur on a plants must be attracted 30 or 40 Year rotational basis and natural reueneratm would occur to a much larger extent' Would not adoption of even aged management greatly alter the appearance of much of the Forest in a detrimental manner?. ..The retention of Uneven aged management on those areas most subject to the public view would certainly seem to be a tacit admission on the part of planners of this concern Would not species variation be reduced by even aged management with its emphasis on the generation of a single plant species. Ponderosa pine7 Why, under natural conditions. do pine stands usually assume an uneven growth pattern? Have public and timber industry views and concerns regardtog such a drastic revision OF Forest management policy been solicited7 Without due consideration of this most basic forest management concern, the validity of any Plan issued in the Ponderosa pine region must be seriously questioned.

4 3

1-4-77 'A5 ,: EFFECTS OFTHE ALTERNATIVES ON EY UENT AND INCOME (FIRST DECADE) -1s v Z.DW .,I, .-&Y cc.,-3

r29 .2l .I

.59

-66 -16 .n

4 .16 a9 ASSUMPTIORS AND INTERACTIONS CONCERNING OCCUPATlOtlS

Tabla IV 4 ALLOWABLE TlhlBER SALE OUI\NTln

1-4-79 On Conments The Proposed summer and fai;, when recreational and hunting use of the Ochoco 1s at Its Ochoco National rarest peak. Thus a full 402 of the county's private sector wage and salary Eianagenient Plan employment IS either directly Ochoco related OP potentially BO. Perhaps of even greater importance is the County government's dependence on payments from the Ochoco. 1984, payments from the Ochoco accounted for 44.3% of the Prepared by In Richard E Kuczek countYss revenues. Obviously. any significant decrease in these payments Labor Market Economist would Create an immediate and severe financial crisis for the liheeler County government. In particular, any layoffs of local or county errployees would severely impact Wheeler, and would severely affect the small retail sector in As I am the LME for Wheeler and Grant Counties, I am, of course, primarily the county. on of concerned with the impact that the Plan would have these counties. Most I think that it 1s safe to conclude that Wheeler stands to experience maJor my comments will directly relate to this concern. Some comments will be more As these impacts will general in nature, as certain overall characteristics of the plan will impacts from the National Forest Plan for the Ochoco. certainly have Significant effects on all the Counties which have a dependency almost certainly be negative, Wheeler could be severely affected. the Ochoco. on Wheeler can hardly afford this. Wheeler is totally dependent on agriculture, timber, and recreation as rts economic base. AS both agriculture and tivber First, I would like to brieflv address Grant Countv. While 59.000 acres of have been troubled industries. with decl>ning emplowent, Wheeler has suffered the Ochoco ere in Grant ann &ant is rery rLCn a limber dcpenoint county. the 56% represemr greatly. Wheeler's population has decreased by over the last 25 years. Ochoco a relatively rrall Portion Of Grmr's forest base, thcre Potential for growth in agriculture or timber employment is nil, and acreme tne Edlneur Forest I" Grant. I ~O~PPwlth beins far wore of hetlanal - -<.-- on recreation related employment is unlikely to significantly incpease under even the Forest Service's-assessment that the Plan Hill not.have~a-maJorimpact the most recreation/big game emphasized alternative for the Ochoco. Grant, though I do believe that some of the undenrable aspects of the plan on will have a small but negative impact Grant. Most comments made about The first flaw with the Ochoco plan is that It attempts to be all things for Wheeler County, and about the Plan in general will also apply to Grant, but all people and uses. A national forest is a limited resources. Competing with less impact and less affect. The real danger to Grant rlould come about YS. VS. etcl mean same demands (timber harvest big game vs wilderness riparian. if the llalheur Plan (still in product~onlwere to include the undesirable that not all demands can be maximally satisfied. This will, of course, result features as the Ochoco. This 'double hit' could have severely detrimental in making some people unhappy. The Ochoco planners seemingly wanted to avoid impacts for Grant. making anyone unhappy, so they attempted to provide everyone (every demand or competing use) with everything. They essentially have achieved this by Wheeler County 1s sumnarily dismissed by the Forest Service as a county which decreasing general forest acreage (tmber hzrvest emphasis) and increasing does not have a major dependency an the Ochoca. I drsagree with this. acreage for virtually every other usage. Big game management acreage was a Indeed, Wheeler may very well prove to be the single most impacted county of particular gainer (the Plan, in all alternat?ves offered, has, as a primary all those which contain portions of the Ochoco. While Wheeler only contains driver, a Forest Service perceived mandate from the state to double the elk 127,495 acres Of the Ochoca, compared to 223,237 for Harney. and 433,820 for population. This mandates increased big game management at virtually any Cost Crook, Wheeler IS a relat7vely small county, and the Ochoco acreage 1s fully to other uses, and distorts and limits all alternatives.1 (This driving of the IO!! of the total county land area. Elore importantly, it represents a much plan by elk population needs resulted from the acceptance of a state issued larger proportion of the county's total forested area. In addition, Wheeler goal of doubling the Ochoco's elk population in a game management plan as a is a gateway for tourists, campers, and hunters to enter the Ochoco. While minimum requrrement for all acceptable alternatives. The Ochoco already this tourist trade through Wheeler may be small compared to hat through other meets, and could continue to meet. all other big gaiie management ObJectives. count?es, and while logging actlvlties In Wheeler are minute compared to those with reduced big game management areas. Elk require large areas per animal, of Crook, Harney, and Oeschutes, Wheeler is a tiny county with a tlny and the major elk population increase requires significant additional land population and miniscule wage & salary erployment Ochoco related employment devoted to big game management to achieve this populatlon expanslon goal. No is a vital part of the County's pnvate sector economy and a slgmficant purpose other than increasing elk 1s aCcompl>Shed by th>s, and $>"re the model contributor to wage employment. accepts this elk increase as mandated, it will devise no alternatrve whlch docsn't achieve it at least for a period of time. It 1s also a pnncipal While the timber industry in Wheeler County crashed a few years ago, and the 1. county currently has no mills and slight opportunity for regaining one, basis (apparently) for downgrading some of the alternatlves considered While this keeps everyone but the tlmber industries happy, it reduces the logging still accounts far 10% of all private Sector wage and salary timber harvest (the E-Alternative). TO make the timber lndustry accept thls employment. As these logging Jobs are among the highest paying Jobs in the county, they represent a significant Contribution to the county's earned reduction rn logging potential, the preferred plan (E-Departure Alternative) provides for ten years of significant over-cutting to keep the timber harvest income and provide cntical support to the county8s small retail trade as sector. Retail trade accounts for about 30% of the county's total private up. TO put it bluntly. it appears if, to avold making the hard, controversial decisions as In rector wage and salary employment. Retail trade also demonstrates a clear to usage priorities, which could result seasonal pattern, where employment will increase 5oX to 100% during late political pressures. the planners decldcd to 'burn' the forest for ten years. This proposed massive over-utlllzation of the Ochoco's resources wlll If other Uses are to predominate over the timber haruest, local timber Inevitably result in a future 'crash' where utilization must be drastically industries would be far better off to see a steady-yield plan (such as decreased to allow the forest to recover. Thls crash effect 1s totally E-Alternative, without the departure schedule) implcmented directly. A allocated to timber harvest under the prefwred alternative. The impact on reduction in timber harvest now will be less detnmental thdn a such larger the surrounding and affected counties will be severe. limber related reduction, for several decades, beginning ten years dohn the road. Also, employment will decrease sharply. payments to counties will be slgnlflcantly while even-age management will help keep Cubic-feet (harvest) up. this is of reduced, and Secondary economic sectors will be impacted by the spin off. The no great benefit to the timber Industry, which would have to invest millions Forest Service contends that some of this future adverse impact rnll be to use the resulting logs. Retention of an uneven-age growth management alleviated by increases in recreatmnlhunting retail and service employment. scheme rould do much mort to keep the value of the harvest up, without large This is not true. The Forest Service equates recreation related jobs with facility investments, which is at least as mportant as board feet or cubic logging and milling Jobs. Recreation related erplowent 15 much more seasonal feet harvested. Uneven-age management wuld also have supenor visual. (and a much shorter season) than timber related employment, and such Jobs pay riparian, big game. and recreatxmal values. as well as h3gher timber valuer. much less per hour than logging or mill work. The adverse financial impact in terms of lost WaSeS would be sevepe even if we here talking of a one for One The other direction the planners could go vould be to make those hard (and .?ob trade. It is olan from the Plan, that even the Forest Service's possibly UnPOPUlar) decisions they seem to be trying to avoid, by establishing apt?mistic (and uniupported) clam for jab increases from increased clear prlorities as to forest usage. If non-timber Uses are to be given the recreationallhunting use does not come close to one for One replacement of higher priorities, this should be done Out front and with a steady-yield plan, lost timber jobs. which keeps harvest value, not just cubic feet, as high as pornble. Such an

aooroach would facilitate olanmna for~ the~ ~ necesrarv adwstmentr.~"~~ and~~~~ would~ be~~ A second flaw IS that the Plan does not fully credit the impact of the shift far easier for the timber industri to deal with. The least adverse aeoroach, from uneven-age management to even-age managerrent. This will rean a drastic of course, in terms of local (adstate-widel economic impact, would be to set decrease in the harvest of valuable older Ponderosa Pine (which the local timber harvest as a high priority (both yleld and value) and to reduce the mills are designed to handle) and a shift to younger, small trees (which the emphasis on other, Comeetina uses barticularlv the ill-conndered mandate to local mills can't utilize). AS in ten years the timber harvest nil1 begun to double the elk popula

lhcrc 15 litrlc UOA[ in m) nind tnat the preicrrco E-DepdrtLre Alternative $.ill uc niqI~I, Letrln,Cntal to tne co~ntiss(Iscludlng llneeler) hnlch have a nmificeni dcnencence on lnc Ochoco. The tlnotr industry 1.111 be hwt, in ~~ the long run, bnd county revenues from forest payments wiil greatly decrease. Wheeler County will experience a major decline in county government revenues which it will have no chance to recover from other sources. As timber related employment drops, the secondary econonlic Sectors will likewise suffer, and the few new jobs created in recreatianlhunting related Sectors will in no nay make up for the lost timber earmngs. I see little positive about the long range impacts of the preferred alternative, the visual qualities of the forest will even suffer under it.

1-4-81 /55& 'j. "-3% Department of Human Resources Camille Hall August 14, 1986 I 8%3 EMPLOYMENT DIVISION Page 2 I & "22'" I 875 UNION STREET N E SALEM OREGON 97311

IN REPLY REFER TO 1. Direct impaLt - em, pent change within the ier and wood products industry August 14, 1986 RES:JH R&S 2 2. Indirect impact - employment change in other industrial Sectors resulting from purchases by the lumber and wood products industry. 3. Induced impact - employment change resulting from purchases by households that receive incove through either the direct Camille Hall. Planner or indirect effects. The Oregon Consortium 260 SW Ferrv. $102 Albany, OR si321 To help You better understand the concept of economic multipliers and avoid their possible misuse. I've enclosed several recent papers on this topic. This letter IS in response to your request for an estmate of the employment multiplier for the lurber and wood products To derive an emploment multiplier for lulrber and wood products industry both statewide and for the non-metropolitan countler for Oregon and for^ local area; within TOC, we enlisted the help corpnsing the Oregon Consortwm. of two economists (Stan Detenng of BPA and Hans Radtke) wiio have had considerable exDerience in this area. The emoloment First of all. let's define the concept of an economic multi- multipliers that follow bere generated wing the IlIPLAN &stem plier Since local businesses, households, and government developed and maintained by the U 5. Forest-Service. Thi; 1s a agencies purchase goods and services frcm one another, any new xomputer-bared System which uses input-output analysis proce- development in a community generates both direct and indlrect dures and PPOvideS forest planners with the caeabil~tvto econonlc impacts. The mu1t;plIer is a slngle number that develop non-survey based interindustry models and apgy them estimates the total economic Impact of a given change in the to the evaluation of alternative management programs. The local economy. There are many different tvms of multiolierr. specific IIIPLAN computer runs were prepared by the Bureau of including multipliers for business output ibr sales), personai Land Management, US Department Of Interior. Detering and Income (or earnings), and employment. Ibst multipliers are Radtke believe that the IMPLAN system estimates of employment estimated as follows. multipliers tend to be a l~ttlehigher than employment Impacts generated using valid survey-based models. I have enclosed a brief paper describing the IliPLAN system. If you want mope total chanqe detailed information, let me know. multiplier =initial cnange,

in whatever units are being considered- business sales dollars, number of jobs, etc. For our purpose, we will focus only on the employment multiplier (9 of jobs, not FTE'sl for a particular industry, lumber and Wood products. Also. this will be considered a Type I1 multiplier which aggregates the following impacts

AN EOUAL OPPORTUNIN EMPLOYER Camille Hall Camille Hall August 14. 1986 August 14, 1986 Page 3 Page 4

Employment multipliers for SIC 242 and 243 are shown below for Note that, in general, the emplopent multipliers get larger as the State and a number of local areas. the area covered gets larger. Thls 1s because the economies of large areas are more dlverse. and a laraer mormrtion of income~isspent locally on good; and servlies.' Tii7s explains SIC SIC AVER- why the lumber and wood products multiplier for the state is

AGE one ~ . ~~ ~~ ~ Oreoon (an 18 242 243 2.9, while the for Easternlcentral ~I~~.~ countv area) is about 2.5. Since you WIII be doing planning at tie Oregon (statewide) 2.9 2.9 2.9 sub-district level within TOC, we suggest YOU use an employment mUltip1ier of 2.2 for lumber and wood-prodicts, which is an Grant B Harney 2.2 2.3 2.25 average of nine individual areas (not the cambmed areal within Crook. Deschutes, & Jefferson 2.3 2.4 2.35 TOG for which separate data was ava~lable. Thls averaae COOS 2.2 2.2 2.2 assumes that SIC'242 and 243 are given equal weight, aid that Curry 2.1 2.1 2.1 they fairly represent the lumber and wood products industry Lincoln 2.1 2.2 2.15 (SIC 241. Clatsop 2.1 2.3 22 Ti llamook 1.7 2.1 1.9 Usually, these multipliers are used in the context of analyzing Lake 2.5 I NA 2.5 the impacts of new jabs or new industry to an area Yhether Wheeler, Gilliam, Sherman, B Jefferson 1.9 INA 1.9 these mult~~liei?m~actrwon be of eoual maamtude ~n the opposite direction if an area lort the'same nimber of jobs IS TOC Average (based on above areas onlyl 2.1 12.2 2.2 an interesting question. To the extent that these workers remained in the area and received income from transfer Dawents etc. the downside multipliers would probably be lower, iteleast Additional multipliers for other areas in the short run. .=- I hope that this information will be helpful to you. If you NW coast (clatsop. Lincoln, B Tillanookl 2.1 2.2 have any questions, please don't hesitate to call me OP Jeff Portland lletro (Clackamas, Multnomah, 8 Hannum. Washington 3.5 3.3 SW Oregon (Coos, Curry, Douglas, Sincerely, Jackson, & Josephine1 2.3 2.5 Lane 2.5 2.8 E. Oreson (includes 18 Counties in E. &-C. Oregon1 2.4 2.5 Crook, Deschutes, & Jefferson 2.3 2.4 SE Oreoon [Lake. Harney, B Malheurl 2.4 2.4 w;11amette vall;" ( Lane, Linn, Marion, MDS'JIM Polk, Yamhill,-Multnomah, Washington, R Columbia1 2.9 3.0 Enclosures Jail 2.5 2.6 cc Area Labor Economists Radtke 52060/10-13

1-4-83 IEIPLAlh AN INPUT-OUTPVr ,IBALYSIS SYSTEM 2--ilward adPalmer FOR FOREST FERI'TCE PLANXIXG Richardson, 1972) and applied, Significantly reducing the CO~Lof obtaining a useable model. The debare about the veracity of secondary Gregory S Alwacdl' data models compared to primary data models continues (Schalfer and Charles J Palmer?/ Ch~,~f969,Miarnyt, 1979). Given the maqitude of Lhc planning taslc confronting the Forest Service, however, the cost of PreParmq the required number of madele using primary data procedures INPLAN, a computer-based sysreo for developmy: non-surveY 6- -- Was clearly prohibitive. Consequently, a data base of e nomic Input-owput models, is discussed The contents and procedures used tuformation relying upon secondary so~rceswas dweloped-€9 as well develop the nation-wide data base identkfied and Lhe to extensive are as Bo effielent software system to perfow rhe required computations. analytical capabxlities of the system described in the context of The resulting INPLAN System has the capability of producing a Forest Service planning efforts. Finally, posszble extensmns of the om-survey based mpnt-ontput model for any re&" of the united system are noted States, with the greatesc degree of geographic reso1utioD being a slng1e county. INTRODUCTION DATA BASE The USDA Forest Service has developed a computer-based system referred to as to aSszSt it9 land and T~SOYTCCmanagement INPLAN, The base of mapr parts planning efforts involving economic impact The IEIPLAN IMPIXY data consists two (1) a assessment natlona-1-level technology matrix and (2) estimates of sectoral system utilizes input-outpmt analysis procedures and provides ferest activity for final demand, final paymenrs, OYCPUL and employment planners with the capability to develop "on-survey based inrerindustry gross for each county. ?ata represent 1077 colmry level e~onomc and apply them to the of alternatlve management The models evaluation actlvity fa,: fur hundred and sixty-SIX sectors programs This paper provides a general overvie& of the data model building procedures and analysis capabilitzes thac comprzse the IMPLAN The national technology matrix denares secraral produetian funcrims system and is utxlired to estimate local purchases and sales. This 466-seetor, gross donesrlc based nodcl vas derlved from the Commerce lnpuf-~ut~~rmodels have frequently been to describe the role of used Department's 1972 nz,t~ondinpUC-onfDut oodel (US. Deoarrnenr of forestry acrivi~iesm regional economies (Elrod, et al. 1911. Commerce, 1979(a)). The 'use" and make' cables LWTC reetlf,ed ro sn Trautmvn and Porrcrfleld, 1974) InpYL-OYtpYt models have also been industty by industry basls and updated CD 1977 wing rela~lveprice used to evaluate forest policies and progrems (Sehallau, et al. 1969. and (Stone and Connaughton =nd ~c~~llop,1979) The usefulness and applicability of chmges rhe RAS procedure Brow, 1062) With the 1977 National and Piadvcts ACCOYII~S S Department of Camoerce, input-~ufp~tarralysis eo Foresc ServIcc plannlng has been demonstrated Ineo~c (u 1977(b)) informatux 8s eonrrol kgrcgacion of saw (Palmer and 1978 Alvard and Stewart 1978) Indeed several used rota15 Eearon, agriculture, eOnstNCtim and manufacturing sectors, and Act of the planning requirements of the National ForesL Management of disaggregation of the coming sectors resulted in ihe reduction in the 1976 L 94-588) and its implementing regulations (36 C F 219 (P R number of seecors from 496 m the Department of Commerce teblcr to 466 Subparr A, September, 1979) require economic analyses of p'oposed in IEIPLAN. The Wtnx IS a hzghly disaggregated roPPesen~atim of plans such as those that can be performed using input-outpur national average Sectoral input and OYLPIIL techn~lopyand IF is an the techniques. basis of these ProdUetiOn flinctmns that regzonal purchase pairems are estimated. Nvny >ppl~cnrlonsof ~npc-oufpu~models have utilized primary data obcaincd through dlrccL suxvcy5 Conseqvently the Cost ln Ceros Of moncy and manpower for these studies has been subscantis1 (Bouraue and Haasen, 1967) VB~IOYS techniques for constcyctlng models mslng secondary data have been proposed (Czmanski and Nalizla. 1969, Approximately 12h forest plans, 9 regional plans and a national program

_- i' This was developed by Engineering-sconomies Associates of Berkeley, California. This use of thc company ilamc IS for the oencfit ? ~~~~~~~h?orester ROC~~Momtain Forest and Rang~Experinenc of the render. such use does nac ConSritUte an official oodorsei*en~or Station, USDA Service, Colllns, Colorado. S-A. Forest Fort U approval of any service or product by the U S. Uepa.;mcnf of co exclvsion of others that may be suitable. 1' Economist. Land Management Planning Staff, USDA Forest Service. Agriculture the Parr Collins. Colorado U S A b--Alunrd and Palmci J--Alvard nnd Palmer Gross OUtPUr and employment estimates utilized several sources, EStimaCrS of eCDnOml~activity and production cmploymcnt for each OK principally censuses For example agrlCUlture sector activity wed the the a66 S~C~OTSfor all states and every county wzthln caeh state were Census of ligrieultvre (U.S Department of Commerce, 1977(b)) and made for the compmenr~of an input-output abl le listed in Tahlc I the Asriculrvral Sfatistics (u s Depairmenr5qf Agriculture 1979) The estimates of economic activity for staces and eo"ntiC5 "err made Gross Output measwes for most other sectors- vrzlued proxy through a downward movement approach beginning wiLh total national mEaSY*eS derived from employment and payroll dace principally rhc activity and disaggregating to States and vliinately to Counties with national summaries of the county B~EI~LBSB~atrerns (D s ~eparrmenrof canrrol totals employed at each level. As previously noted, the COmmerCc, 1977(a)) and employment data from Lhc Dun and Bradstreet updnfcd 1977 national fable was benchmarked bith the 1977 National COTPOration (1977). Some sectors could be related to specialized data Income and Product ACCOU~LS. Since comparable accounts are not sources svch as the Census of Housmg (U S Deparrmeni of Commerce. available for States or counties, the most snitable regional measures 1970) for owner-occupied dwellings and the Census of GovermenLs (U 5. of economic activity were used to disaggregate the national production Department Of Commerce, 1977(e)) for government-related sectors All and demand BCCIVII~,first among States and then among counrles within data was adjusted to the 1977 base yea< and unreparied data has each state estimaied utilizing the RAS procedure

Final demands were estimated consistent with control totals from the Narional Income and Product ACCOYO~S,by updaflnz the 1963 Table 1 -- Conrents of the IMPLAN Data Base for each 11.5. County Multi-Regional Input-Output data (Polenske. 1970) usmg the US procedure a8 suggested by EIeClenam~nand llarrmg (1974) The three components of value added were allocated on the basis of gross _- outputs. Both final demand and final payment estmates were disaggregated using rhe 'downward movement approach

A Final Demand In its entirety, the IMPLAN data base provides a EOmprehenSIve, nation-vide set Of input-output information which can be used fO 1 Personal Consumption Expenditures construct non-survey based regional fables The natmnal technology 2 Capital Formation matrix 1s mainrained at the highly disaggregated 466-5eetar level of 3. Inventory Change detail which greatly reduces aggregation errors caused by urmg 1- or 4 state and Local Government Sxpendirures 2-dzgit SIC (Standard Industrial Classification) industry groupings. 5 Federal Govermenf Expenditures Consequently, the industry-commodity relationship IS mvch more 6 Foreign E~ports Consistent than in highly aggregated models. The hierarchical nature Of the tiara base, achieved by the use of published control totals at each level of disaggregation, results I" a data base chat pcra~tsthe B Final Payments constzuction of models rhar are consiscent both in terms of definition and activity These principal aspects result in significant 1. Employee compensation improvements over the data used in many previous non-survey 2 fndireec Bvsiness Taxes input-output studies. 3 Properiy-Type 1°C."

DATA REDUCTION c Total Gross Output

D Production Employment The IElPLAN software system was desqned to serve thrcc functmns (1) data retrieval, (2) data reduction and model development and (3) impact analysis The fxrst two functmns are dlrcusred in thls section and the third In the following section

5' Bureau of E~onomicAnalysis inpuc-ouLpuL sectors 3 00 through 77 05. excluding sectors 11 00. 12 00, 65 01 and 71 01 (U S Deparrmenr of Commerce, 1979(b)).

1-4-85 5--Alwri d and Palmer 6--iilvard an& Palmer

The data retrieval System was designed so Lhar the use? could have In addition to this typical fable of ~CCDWLS, detailed cepL:tS of access co inpur-output data for any U T state county 01 combmation sectoral eomoetitive and n~n-cmpecitive "mi purchases are given. thereof The study area data 1s referenced vua srandnrd $el of ?lased upon the re.ion.31 acco~ncs,the predicti\e ~PYL-YYLPYC uodcl State and county codes with the extracted dara LIealed as conlrol can be derived by computing the srandard LemLxef-type mverse and totals for the region being analyzed ModzficaLion of data, if ealculahng various Income and employment ilulcipliers If desired by the user. is permlrred appropriate, the number of sectors m the model can be redvced through aggregation pnb~to inverting the matriy Utilizing the national technology matrix and the regional control totals, a data reduction method is employed to develop a regional Several limitations to nan-survey data rednction techniques have been input-outpmt table The method used exploits the property of noted (Xichardson, 1972, Fisch and Gordon, 1978) and the supplrdemand 'openness" displayed by regional economies compared with the natmnal pool procedure likewise has limitations. Cne principal limitation of economy (Richardson, 1972) Regional econooles exhibit much greater the suoply-demand pool technique is that crass-haul candltions are PmpeiSltieS to import and export than is observed at the national ignored while evidence suggests that this nay be a common occurence In level Based an the assumpfion that trade balances are the principal regional economies. This arises from the technique's method of difference between national and regional purchase parrerns (chat is, allocating local production to meet local requirements before inports industry productLon functions are identical but regional imports and or evporrr are estimated Through the YS~of a highly disagpregated eYPoTts make local interindustry fransacfions different), the technology matrix and a COIISIS~BV,L data base, the IYPLAN SYSLCO has supply-demand pool Eechniqne (Sehaffer and Chu. 1968) for data mitigated though not elmmafed many limitations noced by othcrs For reduction was adopted. example, Richardson (1972) commenced chat ihe use of the national technology matrix may overestlmnte tho lnferdependence of a reglonal This method for coni~~uctinga rcgional cable begins with the nac~onal eeanomy. Similarly, Miernyk (1976) criticues the supply-denmd pool technology matrix and regional data fop gross OUipYtS, final demands technique 8ssumpt10n of proportionare xmports by all purchaslop and final payments Regional data for all 166 seccoc.5 IS Sorced wlrh industries. Contxnued lmprovemencs are being SOY~OLto enhance the respeci to gms5 outputs. If the Sectoral gross OUtput is greater SYJtPIO. than zero (firms producing the commodity exist within the region), the corresponding column of direct coefficients IS extracted from the national matr~x. Using regional gross OU~PYLSand the abbreviated 'u:IIsYsls matrzx of nat~onatdlrecr coeffiexenrs regionel purchase trmsacC1ons are computed This transactions matrix is then scanned row by row. If the industry represented by any row has zero regional gross Output The analytical capabilities of the I>PIPL:Ze system can be classiflcd (the industry does not occur within the region) the estimated into two broad categories (1) rhe esLimaCio7 of impacts orieinaring purchases of char commodity are assumed to be "on-competitive domestic from changes in final demands, and (2) Lhc evaluation of constraints imports and are shifted from the regional transaCrionI necrix to final upon sceroral gross DY~~YLSLsrrmaiing the regional economic impacts paymcnts If t& grasz aurpvt is poslrive and the commodify balance of disturbances m the finrl dcmnd vecror caused by resonrce shows a surplus- , the domestic import pvrchases are assumed LO be management ~CL~O~SIS the most frequently used foro of ~~YL-OYL~U~ zero, the regronal transactions estzmated with national direct analysis employed in Forest Service planning studies. These deranc coeffxlents left to are unchangod, and the ~urplusassumed be disturbances arise from such acCIYiCies as fxmber harvesting. grarlng domestic exports If the commodity balance indicates a deficit, the and recreation, as well as direct budgetary mpcnditwes for goods and regional final demands and transactions esrimaced with the national serv~ccs. Economio impaers sre expressed by the changes in rcgional coefficients proportionately reduced the row to obraln a are across income and eammgs. employment, gross OUFPU~and various other balance, and the differences assumed to be eonpefitivc domestic parmeters imports The result of this ~L'OCCISis a matrix of local transnctions beiwocn regional industries plus estxmates of both comperlrive and Inpu~-output models are typically used m Forest Service planning "On-COmpLtltlYe "arts a5 we11 1s export5 studies eo estzmate the reganal economic effects of Irplementlng cwnagcmcnc plans These plans describe the infcnded The dora reduction procedure used a in IMPUN produces complete cable manaremmt activities 00 a National Forest along with the expected of rcgmnnl input-output including transactions table, the ~ccounrc a Outputs, resource uses and budgetary enoendltures econonic impect~ fiedl dcmnod and final payments quadrants, and the fourth quadrant are characterized a5 changes (increases or decreases) frm eurrcni condirlona. Plannin~rems frequently employ Input-outpor models in orher ways The models provldc e~ccllencdescrlpcions of regional economic StrneCUre, glvlng piannlng teams valuable information for fonulatinp Agency policies regarding eccnomc growth or 6' Regional gross ourpur 1s greater than regional final demand stabilization Opparrlmiries for dcvclapinG marlets for forest plus infermediato demand estimated with national dircct caefficienre. products can often be idenrifled through the we of Input-OUtpUL

-1 - 5--Aluard and Palmer 7-Alward and Palmcr The economic effects estimsced WIL~INPLAN are dcscribed by parameters typical Of Input-OUtpuL studies. They are structural in nature permitting multiplier effects to be traced throughout the YaTious regional Sectors Direct. indirect and induced changes in gross introduction of new industries Inp~c-o~~tputmadela have become OYCPULS and fmal demands, employaen~and import requirements. lneome mtegral components of the formal pldnnlng models employed by the and earnings are the most representative parameters used to describe Forest Service impacts The availability of a complete fable also permits calculation of grogs regional product Induced effects are computed The linlages between Forest Service manageoenr acrxons and using a modified '"Type 111" multiplier procedure (Hiernyk, 1965), corresponding estimate9 of net changes in regional final demands are iteratively solving the open model TO capture the effeCFS of induced critical components in the use of Input-ontpur analysls for impact CDnSUmptive spending. Detailed employaenr analysis is possible by esclmaci~n These disturbances in final demand =rXse from LVO tracking employment requirements among various occnpatmni and PIlncipal sources publie expenditure effects and prrvare sector accounting for the effects Of either 1-mlgrarion of Workers or Output effects (Cartwight, 1979) Public expenditure effects arise re-employment of unemployed local labor In comhinaLion, this from demand disturbances caused by government purchases of goods and infomatiom provides a comprehensive, detailed acceunc of potential E~~VIC~SFor example, timber stand improvement projects or the regional economic impact* COnStruCtion of recreational facilities involve pvrchases for labor, materials and ID forth which can dleectly be transformed into a demand disturbsnce vector Private sector outpuc effects are somewhat more IELPLICATIONS ASD EXTENSIONS complex These effects stem from che YS~of forest resources and indirectly (from the viewpoint of the Forest Service) result in demand disturbances For example, the Forest Service's provismn of varmus The IEIPLAN system provides the user ready access TO detailed factors of production such as stumpage for wood producrs (racer for non-survey based input-ourpur models of regional economies. The municipal and domestic uses, and forage for red mear praducrioo must availahiliry of an exrensive data base permits constructaon of be traced to LTS final reglonal economic use. eithe~directly LO decniled models that portray the S~T-YCLY~Oof the regional economy ehporrs or ma forward hnkagcs and -5tenning-from effeecs (see, under study The data reduction technique rakes explicit account of for example, Racsler. et al, 1966) The effects of the use of forest the open" nature of there econoaies, tracing boih intra-regzonal ~~SOYTC~Sfor recreation can be direeclg transformed into demand flows as well as mports and exports The models also permit analysis disturbances by derlvlng a typlcal 'bill of goods purchased locally of Forest Service activities. either mdividually or in combination3 by the recrea~ianiscduring the pursur of Such activities In all such a5 a managemenr program The COn~truCLlonand use Of these cases the demand dzstvrbances represent regional market transactions models are relatively rapid and inexpensive, and the sysrem is expressed in purchaser's priecs with apprOpriaLe rransportarian and available throughour the Agency via distributed CD~PYLCInetwork A trade norgins mepc advantage of the sysrem is LO permit resources to be devoied to the vtilirafioi Of input-ourpur models in planning rather than to Traditional applicatlons of inpu~-outpu~models utilizing demand model construetion. disturbances as the source of interindustry effects, Contain an Impllclt aSs"mpil0" of Svffieienr resource 5YPPlY to permit atta1nmene Possible extensions in the use of IMPLAN data and models involve more of an equilibrium economy. As is often the case with forest extensive YE~Sof impact models in Forest Service planning TO date. ~eso~rces,some of the primary resource supplies may be restrieLed most impact analyaer have focused upon local area studies In the within a reg~onaleconomy (for example. the amount of water may be context of a multi-level planning system (see the arricle by Hof xn rcsrncrcd) If the change ~n forest Output is used. under these this volume), the usefulness of InpnL-output modcls will certainly circumstances, LO dcrlve a disturbance in demand and the model used co hecome apparent State and regional models will likely become closely estioafe the rcsultanf multlpl~ereffccrs, the backward linkages would linked to the planning model to estimate the ~eonom%e ~mpl~car~ansof usually indicate a total demand for the resource exceeding the various Forest Service policies Similarly. structural anelyscs of original change The IMPLAN system has been designed to perform timber policies invcscigated by the Timber Asse~smentMarket Model analyscs under these condxrions by permitting the user to link the (Halncs and Adam 1980) may also be possible IC appears that the chan:r ~n ~~SOY~CCOutput directly to a change in SCetOTal gross availability of input-output models on a reg~onalbasis vi11 permit a output rather than a change in €mal de?" The input-output model vide breadth of Innovative uses in natural iesonree managenem is then used to estimate the maximum level of delivery to regional find demands nCtamoblL gxven che constrained level of gross output. This kind of analysis is often app1sah.e to economics that are highly dependent upon pr~~rywsources

1-4-87 10--Alvnrd and Paliner 9-Alwnrd and Palmer Palmer C.1 and G D. Kealon. 1978 Lcononie input-outpur analysis an approach to identifying economic and social Impacts of land use LITERATURE CITED Plsnnlng Proceedings Land Use Planning Iworkshap, University or Kentucky. Lexington Kentucky, pp 96-105 %dams. 0 >I end R D Haynes 1980 The 1980 softwa-d timber Polenskr, K 1970 A multiregional IDPYL-OYLPUL model for the s assessment mzr'ict model structure, proiecrions and policy u Report a21, Economic Development Admmlrcration, u s D~~~~~.~~L smulacions forest Science Nonograph 22 of Commerce, Washington D.C. Alvard G S and w L Stewart 1979 Economic impact asSCsSment for Richardson 11 W 1972 Input-output and regxonal economies John land management planning Proceedings Land Use Planning Wiley and Sons, New York. Workshop University of Kentucky Lexington XenturkY, PP. 123-128 Roesler, T W , F.C. Lamphear, and M D. Beveridge 1968. The economic impact of irrigated agrzculture on the economy of Nebraska Bourque, P.l and G. Hansen. 1967 An inventory of regional Nebraska Edonomio Business Bureau of University of and Reports hmber Four, Input-Output studies sn the Unites States Business Research University of Nebraska Lincoln Nebrash Washington, Seattle, Graduate School of Business Adminzsrration, Occasional Paper No 17 Schaffer, 12 A and K. ChU 1969 Nonsurvey technique8 for COnStrncting regional interindustry models. Papers of the CaCCvrrghC 1 1979 Estimating the regional ecOnOmlC impact Of Regional Science Association 23 83-101 Forest Service programs. Regional Analys~SDIYiSiOn, Bureau Of Economic ~nalys~~u s ~epartmenrof Commerce (nimrograph). Schallau. C., W Maki and 1. Beurer. 1963. ECODO?LCimpacr projections of alternative levels of Ember producrmn ln the Connaushton K P and h' ElcKillap 1979 EstlmaClOn of "small are*'' Douglas-fir region Annals of Rea~onalScience 3 96-106 multipliers far the wood processin% 6ecCor - an eeDnOmetriC approach Forest Science 25(€) 7-20 Stone K and G. Brown 1962 Behavioral and rechnlcal change 1" economic models Papers of the Second Congress of the Czmanskx, 5 and E E Mal~zia 1969 Applicabllicy and limicationS in InEernarmnal Eeonomic Asso~~atmnVienna ihe use of national ~np~r-ourp~ctables for regional studies. Papers and Proceedings of the Reglone1 Science Assoclarlnn Troutman, F.H and R L Porterfield 1974 The role of Aciwnsas 23 65-77 fozests in the Stare's economy. Ind Res. and EXT Center, University of Arkansas Publieatran 0-16 Little Rock. Arkansas Dun and Bradstreet Corporation, 1977 Emplapent daca (compurer rapes ) U.S DepartmenSof Agriculrvre 1979 Agirculrurr SlacI~Lics Washington, D C Elrod R H K n Sheshai and W A Schaffer 1972 Interindustry study of forestry S~CLOI-E for the Georgia economy Georgia Forest U.S. Department of Commerce, Bureau of the Census. 1970. Census of RCSOU~CBcouncil ~eporc31, laco on Georgia Housmg. 1970. Washington D.C

rlsch 0 and 5 Gordon 1978. An eval~a~imof rhrce approaches to US Department of Commerce. Bvreau of the Census Councy BYEI~CLS The economic submodels of Fruk, lamc6on and NorChrup input-aurput Patterns, payroll and employ men^ data, 1977(a) (computer rapes) in NSF-RAN8 Funded Regional Environmental Systems Projects Report to the Xarlonal Science FoundatLon. 0 S Department of Commerce, Bureau of the Census 1977(b) Censvs of Agriculture, 1977 Iiaasbington D c ?Icllenamin, D.G and 1.E liarring. 1974 An appraisal of non-survey Journal techniques for estimating regional input-ourput oodels U S Dcpartmenr of Commerce, Bureau of the Census 1977(c) Ccnrue of of Rcglonal Scxence 14(2). Covcmmenrs. 1977 Washmgton. D.C

:liernyk, w it. 1965. The elements of inpuz-output analysis. Random US. Deparrmcnr of Commerce, Bureau of Economic Analysis 1979(a). House New York The detailed inpuc-outpuL structure of the U S economy volume^ I and 11. !Liernyk, w H 1976 Comments on recent developments In regional input-output analysis International Reglonal Sclence Review U S. Department of commcree, Bureau of Economic Analysis. 1979(b). l(2) 47-55. National Income and ProdUcc Accounts 59(7) lO--Alunrd and Palmer 9--Alvnrd and Palmer Palmer C J and G.D. Keaton 1978. Ccononie ~npu~-oufp~tanalysis an LITERATURE C;TED approach to identifying economic end social impacts of land use planning. Proceedings Land Use Planning Workshop, Un~versityof Kentucky, Lexington Kentucky. pp 96-105 *dams, D H and R D Haynes 1980 The 1980 softwood timber assessment market model structure, pro~ections and policy Polenske. K 1970 A multrbegional input-ourpar model for the U.S simulations Forest Science Monograph 22 Report 521, Economic Development Adminlscrallon, U S Department Of Commerce, Washington D C. Alvard G.S and Y L Stwart 1979. Economic impact assessment for land management planning. Proceedings Land Use Planning Richardson I1 W 1972 Tnpu~-oufpuf and regional economies John Workshop University of Kentucky Lexington Kentucky, PP. Wiley and Sons, New York. 123-128. Roesler, T.W , F.C. lamphear, and M.D. Bevecidge. 1968 The economic Bourque, P J. and G Hansen 1967. An inventory of regional impacL of irrigated agricultvre on the economy Of Nebraska input-OnLput studies m the Unites States University of Nebraska EConOmiC and Business Repocts Number Four, Bureau of Washington, Seattle, Gradvare School of Business Administration. Bnsiness Research Unrverrity of Nebraska Lincoln Nebraska. Occasional Paper No 17. Schaffer, W.A. and K. Chu 1969. Nonsvrvey techniques for Cartmight. J 1979 Estimating the regional economic impact Of constructing regional inrerindmarry models. Papers of the Forest Service programs. Regional Analysis Dxvision. B~reauof Regional Science Association 23 83-101 Economic Analysis U S Department of Commerce (mimeograph) Schallau, C , W Maki and 1 Beuter. 1969 Economic impact Connaughtan K P and P EIcKillop 1979 Esrimaiion of "small area' projections of alrerndrive levels of riober production in the mulripliere far the wood processing SCCLOT - an econometric Douglas-fir region Annals of Regional Sclence 3 96-106 approach Foresf Science 28(1) 7-20 Stone X and G Brown. 1962. Behanol'al and technical change in Crmanski, S and E E. Mallria 1969 Applicability and limitations in economic models Papers of the Second Congress of the the use Of nacional I~~YL-OU~~YTtables for regional studies. Inreenational Economic A~so~iafionVienna Papers and Proceedings of the Regional Science ASSOCiILioI1 23 65-77. Trpufman, F H and R L Porterfield 1974. The role of Arkansas forests in the State's economy. Ind. Res and Ext. Center, Dun and Bradsrreer Corporation, 1977 Employment dara (campurer University of Arkansas Publication 0-16 Little Rock, Arkansas tapes ) U S Departmenfof Agricvlfure 1979 Agriculture StaZiStiCS. Elrod R H K.M. Sheshai and W A Sehaffer 1972 Interindustry Washington, D C. study of forestry SBCLOIS for the Georgia economy. Georgia Forest ResOYrCe COurCil Report 31, EIacD" Georgia U S Department of Commerce, Bureau of the C~~SYS.1970. Census of Housing, 1970. Washington D C Fiseh 0 and S Gordon 1978 An evaluation of three approaches to input-OUtpUL The economic submodels of Fruk, Jameson and Northrup U.S Department of Commerce, Bureau of the Census Councy Business in NSF-RAhV Funded Regional Environmental Systems Prwects Parterns, payroll and employment data, 1977Ca) (computer rapes). Report LO the h'aiarional Science Foundation. U.S. Department of Commerce, B~reauof the Census 1977(b) Census of MeMenamin. D G and 3.E Harrmg. 1974. An appraisal of non-survey Agriculture, 1977. Washington D.C rechniques for estimating regional inpuc-output aodels Journal of Regional Science 14(2). U S Department Of Cpmmerce, Bureau of the Census 1977Cc) CBDSYS of Governmen~s, 1977. Washington. D.C. :liernyk, W I! 1965. The elements of input-output analysis. Random House New York U S. Department of commerce, Bureau of Economic Analysis. 1979(a). The detailed input-output BL~YC~U~.?of the U.S economy Volumes Miernyk, W H 1976 Comments on recent developments in regional I and TI. i"p"t-OYfp"t analysis. 1nrernariona1 Regional science Revie" l(2) 47-88. U6. Department of Commerce, Bureau of Economic Analysis. 1979(b). National Income and Product Accounts. 59(7)

1-4-89 expondemand Ic(~Iumobl - 60C leakage

SI w 40 .I6 .06 03 -01 $1 66

How local respendingmulhpher -.._..__- the diedof export sales

..I .. .I

A n EC 11661 February 1984 REGON STATE UNIVERSITY EXTENSION S€F?VICE lmpad analysis

Output, income, and employment mullIpIlers

Forccaslrng

1-4-91 Table4 -Summaryilanmci ~rrioralmuPiplicn lor rural Oregon (OYIIIICI Accuracv of the mullinliers Rank Standard Mean olmeani Medoan Range deuiaaon Lumberandwood pioduclr 1877 IO 1990 1383 2 367 329 AWCUIIYW 2203 3 2 295 14232 698 435 Fiihinganddrhproceiring 2069 6 1972 1653 2573 359 other manvfarlvr~ng 1960 7 1786 1455 2765 436 Klamath 1968 1713724000 78 CC"l*l,"C,,O" 1929 8 2027 12792330 316 Dovglri 1968 2 709 304 000 82 LodBmg 2244 1 2273 1265 2947 455 Tillamaok 1973 593 379 000 SI' Calerand tavern6 2 219 2 2229 1521 2793 369 U"l0" 1974 930 894 000 59 Communtcafion and 1734 11 1761 1325 2099 244 man, 1977 380550000 86 tranlponallo" c1atrop 1977 1844 158000 63 Aul~m~iw I647 12 1530 I3832 653 379 Baker 1979 513 793 000 57 Profelrlonal 2203 4 2 502 12202 753 573 MOSrOW 1919 309 122 000 74 Financial 1886 9 1784 13092 853 503 ' 1980dollaii Wholedeprodum 1555 I3 1491 12352191 265 Retad iervxes 2110 5 2l5I 157i2539 378

COW," Ltncoln' Grant Claim hlamlh Douglas T~llamoak Union Grant Cbtsop Baker M~~~~~ sccwr lYS3 1904 1968 1968 1970 1973 1974 1977 1977 1979 1979 Lumherand\Lood I576 1990 1601 2312 2007 1813 2367 2004 1487 2077 1383 produrlr AgilC"l,"re 1 Si0 19-11 2 295 2 627 2 572 2 610 2 698 2012 2341 2 I69 1423 FirhindOsh I878 1651 2173 2267 1972 . - nmrrnmil - - - ~~~~~ - Olhermrnvirclvrinr 2 226 I787 2765 1706 2 1'19 1697 1591 1702 1988 1455 Conrlrurllo" 2 278 1695 1723 2 181 2057 2027 1654 1901 2 330 2096 1279 Lodgl"g 2947 2MO 2011 2111 2123 2418 - 2038 2129 2533 1265 Crlciandlr\emi 2141 le52 2031 2793 2301 2657 - 2190 2269 2421 1521 Comrnuniralionrlid 2017 2 UYP 1537 1717 1765 l9W 1641 1408 1909 1761 I325 fnnlpOllallon A"l0mallle I383 1 -42 I 581 I 606 I424 2653 - 16% 1479 1832 1427 P,oicino"d 2502 2032 I220 238'3 2565 2751 2753 1267 2517 2586 I650 F,"a"C,.l I752 1309 I499 1815 1341 2833 I923 I769 2 759 I784 1941 WIIDIPI.IIPP~O~UCII I485 1291 I491 1747 1608 1691 2 191 1356 1419 1594 I235 Rrlril wrwes 2 461 1969 1961 2 180 I748 2 I53 I575 2420 2 386 2539 I855 ."aq","l Ba" "S'O" 6 5 Fadorr affecting multiplier size

Grant 1964 193 7 434 6514 c1atrop 1968 95 28 2% 8 635 Klamath 1968 172 49 512 8 176 Using existing DO"gla5 1970 7, 71 713 7 934 sectoral multmlrerr lillamook 1973 74 18.902 8 944 U"l0" 1974 176 21 200 9 189 Grant 1977 193 7 830 IO 863 Cl.fl0P 1977 95 31 269 9 565 8rho 1979 133 16 WG 7821

7 8

1-4-93 1981 Diiiancelo 1981 Percapda pciional C0"W 5\1SA' VOpYIBID. #"come 1 Baker 133 1 6 300 8,315 2 Benton 35 70.050 8.776 3 Ck!WmS - 245,loo 10,811 * c1rtrop 95 32.600 9.559 5 Columbia 29 36110 9,355 6 COO5 134 63 300 8.561 7 Crook 144 13 200 8.763 8 CW," 194 17 300 8.798 9 Derchufei 128 63,650 8,471 IO Douglas 71 92.3W 8 644 11 Cllllam lSl 2 02s 10219 12 cram 193 8,150 8.447 13 Hai"e" 191 8 ow 8.560 14 Hood River 62 IS 725 10.851 15 lackion 166 133.70 8.676 16 IdferSO" 118 11.950 8,473 17 Josephine 138 blZ0 7,441 18 Klamath I72 58.621 8.704 ICorvalLr. 19831 19 Lake 261 7.600 8.713 20 Lane - 275 WO 9.026 21 Lincoln 83 38.530 9.462 22 Ll"" 24 90.10 8 744 23 Malhevr 61 27 225 7774 24 Marlon - 209 230 9,277 21 Morrow 191 7.375 10.917 1 Oregon rurvey-bncdcounly Input- 26 Mvlfnomah - 561.90 12.148 Ovtpvt madclrrnd rrrormlcd rncarrh 27 Polk - 46.610 7.826 28 Sherman 120 2.22s 8,282 29 Tdamook 74 21.100 9 193 30 Umalllla 208 59.90 8.707 31 Union 176 24.410 8,353 32 Wallowa 239 7,300 8 972 33 warm 83 22.400 10,168 34 Warh#ng!an - 255 000 10.970 35 Wheeler 171 1.425 9,982 36 Yamhill 26 56,300 8,956 Portand Irlm U8me mdm-clldahoIlMSAI IreFoomolcd inlnbleb

9 t'

1-4-95 GRANT COUNTY COURT COII.T*D"SE

24 November 1986 8. COSLS of Various alternatives was laid out, hut the practical question of whether the funding was available was not addressed It seems there is a good passibilicy char an alrernarive could be chosen and then not followed If funding were cut off Me Earl Layrer Ochoco Natlunal Forest 9 We have s real cmcern far timber harvest. Are we over cuccing Box 490 on the Sh0r.L term and will find a sustained yield impassible? Prlnevrlle, Oregon Have the cumulative effects on the regions timber supply of this plan and other foreSt plans been eonsidered? Cerrainly we Dear Mr Layser, need co be aware of the capaciry of the local mills, but we also need to think 20, 50 and 100 years into the future Here Thank you for your appearance before the Grant County on the Malheur we are getting the effect af a reduced cut on Resource Council last month At our meeting the orher the Wallowa-WhiLmn--milIs in NE Oregon are coming m here for nlahr we agreed an comnents in :espmse Lo :he proposed sales The ragronal crnber mpply should oe rustained wirh forest plan We grouped fhe6e a licfle differenrly from the entire region in mind, considering haul trme, reforestation your reponse sheet, so please bear With us patencial. and all the other facrorr that go into meshing a timber harvest with a sustained yield I The proposed plan and ~upp~rfmgdocumenrs are me big and much LOO complicated We realize you are trying to cover all your bases, bui rhe product we have now discourages people from Thank you for the opportunity to eamenr trying to wade through it. Perhaps alternatives could be worked out in general terms rather than fine decarl, pending Sincerely, a decrsron on direction LO Work

2 We proposed char anyone who has the opportunity to participate 2n chis planning process. and does not, should not then have the option TO come ~n an appeal and hold YP the implemencarion of Larene Allen the plan To allow this IS LO essentially say that =he planning County Judge process 1s not sufficient, and negates the purpose of having a plan in the flrsi place

3 Are the numbers accurate? One coment concerned an error m a grazing fee (sorry. I can't find page number now)

4 Related to IW-we believe ihe value of wilderness use 1s greatly exageraced

5 Related LO li3--variaf~on in big game use dayye'. ref E-72, B-64,65

6 In rhe rnferest of good timber management, with the interest of the sustained forest the primary goal, we think thinning and other management praCtICes are not Sufficiently emphasized We would uqe a fatal resource manage men^ objective, including sail, water. and air as well as products such as grass and Limber

7 The effects of VB~~DYSalfernatrves on school and COU~L~budgets needs LO be followed OlUF CROOK COUNTY

BBBNmlhMiin Slreel @ Prinevrlle Oregon 97754 December 17, 1986 HARNEY COUNTY COURTHOUSE &W N BUENA VISTA - BURNS OREGON SmO

Forest Supervisor December $7, 1986 91e Ochoco National Forest Forest SupeTYIsor BOX 440 OChoCo NatlOnal FOceSt Prmevllle, OR 97754 P.O. BOX 490 Prmeville, OR 97754 SUpeIVLSOr:

The Crook County Soil and Water Conservation District would Dear Forest Supervisor: like to cment on the proposed Forest Plan. The Haeney County Juvenile Department Wishes to 1. Protect the land econmy. convey our concerns to you regarding the forthcoming de- cis~onfor the Ochoco National Forest Management Plan. 2. Protect natural resources but E them m a wise manner. Grass ad timber are both renewable resources and are in better condition when they are man active growing state than m a dormant stagnant We are concerned about possible cutbacks in the one. lumber industry and the effects this would have on families and youth in Harney County. Our recent past experience 3. Cut down on permanent road bulldmg. Use temporary roads and See has proven that high unemployment rates cause family dis- them over. Paved hard surface roads contribute a lot to run off intergcation and increased Juvenile delinquency Only during storm. This can contribute to an undue amount of erosion. recently has Harney County begun to climb Out of the economic depression we have endured since early 1980. 4. Provide for 32,000 acres of old growth, and preserve the core of We believe the forest IS big enough for all users Without laokout Mountain and Silver Creek as roadless areas negatively impacting any of them if it 1s managed pro- pec1y. 5. Providc more trec thmmr.z in stads tllat will rssporfd. we urge you to carefully conslder the Impact 6. Use the present level of firewood avaLability. a decrease in lumber production would have on Ha" Caunty families. We further recommend that present 7 Use a combination of B Plus and E Departure Round off the edges firewood availability remain at the present level and make It work. We emphasize the need for proper soil and water stewardship. Thank you for your consideration in this matter. We also emphasize the need for man to utilize these and not just slt on then. Thank you for your consideration, and Goal hckl Crook County SWCD Mary Hanneman, Court Director k2~7,~~-,Secretary cc: Jim McClain Richard Breese Dona1d.G. Witte

1-4-97 Studies now appear to indicate riparian area5 Should be Stocked with 11ve6tock or game to maintain thekr natural condition as has gone on for eons. Nature Should be allowed to take its course along streams although upstream Box 1193 impoundments do appear to be highly beneficial from all Burns. Oregon 97720 aspects. December 10, 1906 Firewood 15 a desirable side product of the fprest and ttlere Dear Forr~tSuper ,150r 15 no reason all local need cannot continue to be met. We would estimate ten tlmes a5 much wood rots or burns ~n the Please consider these comments to the Ochoco Forest Plan: forest every year than 1s ever used domestically

Flrst and primarily It must be recognized you are a National To summar12e. Forest As wCh YOU ar- not designated a5 a park. Your respanslblllty should not be preservation a5 In wilderness, 1. &UMS should be Increased to utlllze all forage to a but rather prt.seruatlan ai ~n production. Production takes degree that perpetuates It5 production and be under constant many forms ~ncludlng,but not limited to, recreatlan review to avoid erosion. ’ opportunities Of all kinds, wildlife habitat, firewood, Christmas trees, grazing AUMS and commercial timber sales. 2. Timber harvest can be more easlly determined 0; long Of these the Inst two probably have the most ~mpacton the range projectlOnS and should not be Increased even economi of the area temporarily un1e11 such increase can be su5talned over a long period of time. Jobs are the bey to iudglng the successful management of the Ochoco Other benefits will continue regardles-. if the 3. Upstream impoundments should be constructed to lmprove highest poss*ble productlan is obtained BY all means. water quality. improve game habitat, improve rlparlan areas er0510n and other man caused actlv~tlesmust be managed. and xmprove recreation with llttle If any effect On Only through such careful measurer. can production be production Of timber or game perpetuated Allowed harvest must not exceed the capaclty Of the land to reDrOduCe 4 Domestic uses should receive highest prlorlty fol- accommodating the needs of surrounding residents However, 110 creatuo can look far enough Into the future to determine what limits of timber rutting or grazing will be 5 No management plan should adversely affect the economy or desired to maintain Y perpetuating production There are lifestyle of Communities nearby absolutely too many variables that cannot be accurately predictvd Weather, fire, disease and ~nshctsall will have Sincerely, their effect.

Therefole. ~t makes no sense to establzsh a timber cuttlng program that is riot flerible, that 15 not now in productJon ~al-neyCounty Farm Bureau Board of D1reCtOi-S and at or near the prime harvest stage Due to economi~~. tlmber that 15 “pe for harvest may not alYaY5 be saleable; a5 w,tncss the zery rr.cent past.

It makes no sense to o~ergrazeforage and It makes no sense not to graze available feed. Under-harvest does nothlng to improve the grass or the economy. also true Of rotting trees. True. an attempt to average Should be made. but in the case of grazing, an annual evaluation 15 Critical; which IS Somewhat dlffereht Lhan d timber crop that takes many yeai-5 to P’oduce. Crook County Courl

PH" l.UI.

December 18, 1986

December 19, 1986 Forest superv~sor Ochoco National Forest BOX 490 Prmevllle, Oregon 97754 To. Forest Supervisor Ochoca National Forest Statement of the Crook county Court ln response to tl pose From Crook-Wheeler County Farm Bureau Ochoco National Forest Plan - preferred alternative.

Subject Proposed Plan Ochoco National Forest Dear mr. Rittersbacher,

The Board of Directors of the Crook-Wheeler County It would occur to the members of the Crook County Court that to Farm Bureau on behalf of its 336 members ~n Crook.and reply in depth and speclflc detal to a study of the Ochoca Wheeler Countles wishes to respond to the proposed National Forest which has been undertaken for the past several Forest Plan for the Ochoco National Forest. years, would be qulte mpossible In this short renew period. Farm Bureau at the county, State and natronal level However, we consider the Potential consequences of the fmal solidly supports the multiple use Concept of federal adoption and lmplementatron of the plan, to be so highly land management We do not support the addition of any Sxgnificant to the local long range economy and quality of life lands for wilderness designation Furthermore, we do not in this area that we must address those areas of most support the set-a-side of any lands for mldlife habitat. questronable affect. We believe that a plan can, and should, be selected that Since you will be recelvlng documents from more technical would maximize the utilization of the Ienewable resources sources on specif~cs,we would Submit a more ph~losophical without endangering any one phase of the multiple use approach. concept. We feel at this time, none of the proposed alternatives meet this criteria. The final plan should The Court questions the WLSdom of implementatlon Of any of the blend certain elements of the several proposals to plans. Rather it would appear to us chat the multlple use. achlevc the multlplc use concept Sustained yield concept under which the forest has been managed for the past several years IS still the most viable plan. This Signed Greg Merritt, PreSidCnT 1s not to say It has been perfect, nor that the term multiple CRDOK-WHLCLCR COUNTY FARM BUREAU use may be mrsconstrued. but why burn the barn down to rid the mrce, when the management system has been quite effective over the past several years. We would remind all mvolved that it is interpretation and quality of personnel which makes a process effective, rather than the plan itself. The Court would encourage the Forest Service to maintain and If possible, increase the amount of intensively managed land for timber pmductzon.We feel also that the area of land should be

1-4-99 Ochoco National Forest Plan 2 Ochoco National Forest Plan Page Page 3 left whole, for all useable purposes, rather than havlng set We would encourage a s-Iective cut harvest of the Forest, aside areas for specfic purposes. Proper management of the rather than even or clear cut. whole~ will-~ Drovide for all uses. rather than inferior management by property lockup. In spite of periods of controversy over the years, it 1s our opinion that the ochoco National Forest has been competently We feel that there should be greater emphasls on reforestation, managed. we feel that drastic changes as proposed by the E- on bug control and on salvage, none of which appeared to be departure plan are wrong, unnecessary, detrimental to the well addressed, if addressed at all in any of the plans. economy and would not serve the best long range interests of The two areas whrcb would be most manageable would be to plant any of the VBTIOUS factions. more trees and develope a creditable system for salvage of It is our belief that those involved in the forest products timber from bug kill, blow down. lightning strike, fire and industry, the cattle rancher, envrronmentalist, hunter, game other types of dlsease. biologist and those for recreatmn can CO-exist, UtllLZing the entire forest. We believe that the U.S. Forest service has In the past thirty years I have failed to hear the charge that both a policy and a moral obligation to continually seek from "30 to 50 mLllLon board feet of lumber 1s lost annually In procedures which will protect the long term economic stability our forest", disputed by members of industry or Forest Service of our Community. personnel. Respectfully submitted, Appropriate provlsIons for a Conslstant salvage program could have a profound effect on maintenance of sustained yield and at the same time reduce that element of our wastefulness and lack of stewardship We do feel that a few reasonable corrrdors Should be protected, such as, Hlghway 26, the road to Walton Lake and possrbly two DHfcm or three more. where travel 1s or probably will became significant Finally, we would submit that we have three wilderness areas in the Ochocos, none of which met the federal CrLteria for wilderness designation, however, they are set aside and we believe the future will pzove the wisdom of the des1gnatLons m Spite of the polltical motlvatlons.

In this context, however, it IS the unanimous opinion of the County Court that we can ill afford any further raadless areas, or large areas set aside for single purpose SLtUatiOnS. There does not appear to be any unchallengeable, factual evidence that the existence of the pileated woodpecker or continued existence of other forms of wildllfe or the management Of game animals cannot be dealt With m harmony and Compatibility wzth the harvest Of timber throughout the entLre OChoCO range.

We would encourage the re-opening of the road to the top Of Lookout Mountain even if on a controlled basis for the enioyment of the view for the elderly and handrcapped. City or Przirzeuille m EA37 1"IRO ITilEEI Jefferson County PRlNEVlLLE OREGON 97754 ,.? Yn Courthouse 657CStreet Madras, Oregon 97741 Telephone (503)475-2317 The following endorsement was adopted by the City Council on December 17, 1986. December 19, 1986

'The City Council of the City of Prineville hereby endorses any modifications to the Ochoco Management Plan WhLCh would maintain or increase timber related employment through:

Dand Ilrttershacher. Forest Supe~sor A. Intensively managing a balanced Lmljar base suAraule 11. s. nppnrtmenr of ~~~~~~dt.~~ for all uses of the forest. Ochaco Narional Forest P. 0. Box 490 E. Increasmg salvage programs to maxmize timber production. P"lle, 0,egon 97754 C. Stewardship of land be included zn grazing application. Dear MI. Rmershacher We feel that a ma3or factor to be considered in managing the After rrudymg the Economic Impact Analysrr, submirred by Brian Long. and forest 1s economic stability of the local community and our attending the December 12, I986 C.0J.C. meerrng and hearrng testimony regarding quality of 1Ife." this analysis we. the Jefferson Comfy Court, would like to go on record that we oppose the Ckhoco National Forerr, E - Departure, plan.

It IS our opinion that If S0,oOO acres must be set aside, then this should k for the we of selectwe logging and not for any other purposes.

In CO~C~IL.BO~,the economic impacts that this plan would have would advenely affect Central Oregon 1ndwt.y.

Clty AdminLStrator HERSCHEL READ JeffersonCounty Judge

1-4-101 @Q 01792

COLUMBIA IUVER INTER-TRIBAL FISH COMMISSION PRINEVILLECROOK COUNTY CHAMBER OF COMMERCE 975 5 E Sandybulward Suite 101 Ponlmd Oregon 97114 Tolephone (503) 238-0667 LEGISLATIVE COMMITTEE

699 Ochoco Ave , Pnnevdle. Ore 97754 LC iI I J ED

,IM HOWARD Chrmn CHUCKBOYDEN V Chmn

~ecember18, 1986

Mr. James Torrence Regional Forester Pacific Northwest Realan 319 S.W. Pine P.O. BOX 3623 rk. Uave Ut'cersbacher Portland, OR 97208 'IChOcO Forest Superv15or rcderal Building Dear Mr. Terrence, Pnnevrlle, Oregon 97754 The COlUmbla River Inter-Trlbal F1Sh Coom1ss1on appreclates ci-. Iuttersbacher: Dear this opportunlty to comment on the Draft EnvlrOnmental Impact Statement (DEISI and the proposed Ochoco NBtlOnal Forest Plan. It was u?animously to convey to you the followug voter! resol- The Comm~s~lon1s composed of the Fish and Wildlife COmmitteeS Of ution passei by a recent meeting Of the legislatwe Cmlttee of the Confederated Tribes of the Umatllla Indian Reservatlon, the Pnnevllle--Croolc County Chamber of Commerce: Confederated Tribes and Bands of the Yakima Indian Nation, the 'ae It hereby resolbed by the PnnevLlle-Crook County Chamber Confederated Tribes of the Warn Sprlngs Reservation Of OregOnr of C~wemelegislative Comiitee that we sapport any modlfxatmn and the NBP Perce Tribe. These four tribes have rights reserved to the xhocv mtional Wzest plan Which would mantau or mcrese by treaty to take fish that pass their usual and accustomed tmber-related enp1o)~cntthrough fishing places. Amgng these fzSh are the anadromous specles that originate ~n the Ochoco National Forest. (a1 intensively managing the land base suitable for cmorc1al producCmn and The Nature Of the Treaty RIght tb) Increasmg the salvage program to maxmze tmber productmn. '"le Feel that the most maortant factor to be used in managing the fnrest 1s the economic s:abilLty of the local omunity and The tribes' right to take frsh that pass their usual and O"r qvallty oi lrfe'. accustomed places 1s a r1ght conflemed by DumerOuB Court declslons. See Soha Y. SmlTh, 302 F.Supp. 899 (D. Or. There were 35 members Of the comrttee present and voting. 1969), aff'd7Unlted dvTOr-, 529 F.2d. 570 (9th Cie. 1976): WaShln ton 5 Washin ton State commercial Passen ee Fishin vesse? ASS'", 443 u.:. 658-79 Passen er Fish:, d.-mdiFto bindlng State goveh!ents, S2e Passengez Fgvessel 443 U.S. at 682 and n.25, the treat= are also binding on pe~vateclt~zens, See e.g., Unlted States V. Wlnans, 198 u.S. 371 (1905). and, ofzurse, the federal government. Passen er vessel, 443 US. at 682; See also Confederated the Umat~neservatlony- Rlexander, 440 F. Supp. 553 -.T977.d xnespecrfic authorization by Congress, Indian treaty rights &annot be abrogated. Id., c~tlngnenomlnee a ___-V. United States, 391 U.S. 404, 413 (-68)). In Passenger Fishinq the Court painstakingly This result Was reaffirmed by the Supreme Court 1" Passen eP eranlned the ClrCUmStanCes suCKOUndin9 the nrqotlatlon of the riahin Vessel. There the Court declaced that "[nIon-treztY treaties in an attempt to define fhe pareies' long-term ishermen-__ may not rely on property law concepts, devices Such as intentrons. The Supreme COuLIt emphasized that Stevens + Governor the fish wheel, license fees, or general regulations to deprive invited the Tribes to rely on the United States' good faith the Indians of a fair share of the relevant Of anadromous efforts to protect their right to a fisheries li~elihood. run8 fish rn the case area: Podaenger F~shlngv-, 443 U.S. dL Stevens SpeCificallY told the tribes: "Thls~~~~ moer Ithe treatvl . . _.... ~~~~.1_ 684. The Court'e intent la clear: aosent ~peciflctreaty secures fish." Id. at 667 n.11. During the treaty +our dbrOqatiDn leqIslation from Conqcera, (Xenoornee Trlbe 'I. Unlted ne90tiatZOnst "the GOveF~OCrspromises that the treaties would protect that commerce -, 391 U.S. 404, 413 (196811. no one may use= mTtm eosr~~e -food were cruciaTTii deDChve treaty fishermen Of thrlr fair share of Lne anddcopIoUS Obtaining the Indians' assent." E. at 676 (emphasis added). AS fish. the Supreme Court stressed:

It 14 ~osolutelyClear, as Governor Stevens himself Federal to Protect SUbieCt Matter Of Treaties Said, that neither he nor the Indims Intended that the - latter "Should be excluded from thelr anclent fishari-s," . . . and it la accordimgly ~nconceiuable In addition to their obligatmn to not destroy Indian treaty that either party deliberately agreed to authorize Cqhts without Specific Congressional action, federal agencies futuce 4rCLlrTS tn crowd the Indlans out Of any muat use their authoritv to safeauard that which le the sub7ect meaningful theLC Use Of dceustomed places to fish. matter Of federal treaties. In RlttlCaS Reclamation District V. funnyside Val12 Irrigation DiDtrICt, 7-32 19th Ciz Id. - The Supreme Court a140 Inentioned that the treaty guaranty of 985 , tne Nlnth CLCCUI~affirmed D district court Order to "the right Of 9 flsh" was meaningful on1 if fish were operate a Yskima water pro]ect in a manner that would preserve available foe the ta Ing. d. at 678 (erophasidda. spring chinook salmon redds. Federal pro]ect operators had originally mugilt to reduce water releasea rn ocder to store The 130 years ."e the treaties were signed have witnessed Water for the next irrigation season. The proposed flow a truly startling number of methods by which the quantity Of fish reductions would have left the redds hlgh and dry. Testimony at aVailable for the taking Could be reduced -- if not decimated. the district Court hearing indicated that the proposed water The Courts have respondedto these threats tothe treaty right by storage would be poselble If twelve redds were transplanted or if declaring a policy that the treaty right Cannot be defeated by berms were c~nst~~~ted.Id. at 1035. However, the district technology or other methods not anticipated by the treaty Court 3udge Was "unsure ofThe effect of these measures. 80 he slgnatorles. For example, in United States v. Winans, 198 U.S. Continued the watermaster's authority to release water as 371 (1905)r the defendant construccedSiiw~(adevice neceasary." Id. Expressly declining to decide the 8cope of the capable of desteoyzng an entire run of fish1 and excluded the Yakma rnaiannatzon's treaty fishing rights, Id. at n.5, the Indians from one of their usual and accustomed fiehlng places. Nlnth Circhit found that the district Court IudqeTad fashioned a Commenting On the effect8 Of improved fiehrng devices, the Court reasonabIe remedy. g. noted that: The message in Kittitas 18 clear. Federal agencies are Wheel flshing IS One Of the CiVI11zed man's methods, as obligated to exercise their authorities in a manner that will legitimate as the BUbstituZlOn of the modern harvester protect -- not degrade -- the habitat needed to support for the ancient sickle and flail . . . It needs no anadromous fish. In addition, when addressing anadromous fish argument to show that the Superioclty of a combined habitat needs, varroua measures may be utilized, but the final harvester over the ancient sickle neither increased nor Choice turns not on tr'adltional notlOnS Of agency expertise, but decreased rights to the use Of land held in common. In On the biological needs Of the fish. the actual taking of fishwhite men may not be confined to a spear or crude net, but it does not follow that they may constr1Ict and use a device which gives them Magnitude Fisheries Reserved by Treaty exclusive possession of the fishing places, as it is of admitted a fish wheel does. The Forest Service's duty to protect and enhance anadromous -Id. at 382. Thus. although improved technology may be brought to fish habitat does not cease once a fish run becomes viable. The bear on the frshery, that technology cannot be allowed to imperil tribe8 did not reserve a right to take a few fish from-a meager the rights secured to the parties to the treaty. run struggling for survival. Some might argue that the Columbia River treaty tribes reserved the right to COntinue harvesting that number of ffeh that they had traditionally harvested.

1-4-103 Obvionsly, that harvest level is not yet possible given the contemporary depleted fisheries. The Supreme Couct has held that both Indian and "on-Indian fishermen possess a right, "secured by "moderate living standard" may only be achieved by allowing the treaty, to take d farr share of the available fish." Passenger tribe to engoy the "same level of exclus~veuse and exploitation" Fishin Vessel, 443 U.S. at 684-85. The Court determined that It had at the time the treaty was concluded. Id. The purport of d Faxst allocation should not exceed 50% of the this holding 1s clear. Federal agencies owe-a duty to refrain harvestable fish. z.at 685-86. The Court then declared: from abtlvities that will interfere with the fulfillment of treety rights. Moreover, this duty cannot b~~~~~r~by It bears repeating, however, that the 508 figure engaging in an "accommodation" or "balancing" process between xmpo.ies a maximum but not a minimum allocation . . . Indian treaty rights and a competinq economic interest such as [Tlhe central prlnclple here must be that Indian treaty timber harvest. Any such "accommodation" reached by the Forest rlghtsto a natural resource, that once was thoroughly Servioe would amount to a de facto abrogation Of Indian treaty exclus~~elyexplo~te3by tile Irldldns, secures 80 much rights. In the Context of forest management, unless the Forest as, but no mOCe than, is necessary to provide the Servlce Can demonatrate that the trlbes' treaty Kights are Indians with a livelihood -- that IS to say, a moderate presently being fulfilled, it cannot lustify approving activities lrvlm~. 4ccordrngly, while the maximurn possible in the forests that will cause further degradation of anadromous allocation to the Indians 18 fixed at 50%. the minimum fish habitat. IS not. the latter will, upon proper Subm1ssions to the district court, be modified in r88po088 to changing Circumstances. Id. at 686-87. -The National FOlesf Management E Mandates Coordination Perhaps the reason why thi8 "moderate living standard" unearthed by the Supreme COUCt has not proven to be a tCUly The Forest Service IS only one of the many entltles Involved thorny problem in Pacific Northweat fisheries management is in the complex rnteractions that have caused the diminution of because no one can reasonably contend that the Indians' harvest anadromous fish =Una to their present State. Colnmbla RlYeK presently ylelda a moderate living. This fact was implicitly hydrOeleCtriC development and Other downstream problems have done acknowledged by the Supreme Court in Passenger Fishlnq Vessel geievous harm to the basin's fish runs. Whlle the Forest Service when it stated that the 50% ceiling on the Indians' harvest can rightfully blame downstream problems for much Of the harm allocation was necessary "to prevent their needs from exhausting inflicted on anadromous fish, such blame does not Obviate the the entire I-~JOUT-C~and thereby frustrating the treaty right of Forest Serviceasresponslbxlity to protect anadromous fish and 'all [other] Citizens of the territory.'" E. at 686. the need for all perties with management authority that affects these fish to work together to improve the fishery resource. Regardless Of what the term "moderate living standard" means, it will eventually be defined by the 2UdiCiacy -- not a In dealing with anadeOmOuS fish, the Foreat Service must federal agency See Id. at 687. AS discussed edcliee, the Ninth look beyond the boundaries Of a given national foreat. ClCCuit has alreaFdeT*cinLned that federal agencies must refrain Columbia River stocks of anadromous fish migrate as far inland 88 from taI(Loj *.;.ions that will rnduc? the nulnbec of flsh ~n a the Bitterroot National Forest and as far north as Alaska. As depleted run. See Kittitas, 763 F.2d at 1y135. Nor does this the PaCIfiC Northwest has Come to realize, Che anadromous f16h duty cease when= anadromous flsh run manages to increase its runs can only be restored rf State, federal, and tribal land, numbera beyond the dangerous level of minimum viability. In water, end wildlife managers adopt a coordinated "gravel-to- United States Y. Adair, 723 F.2d 1394 (9th ClK. 19841, the Ninth gravel" management approach to this valuable and mobile renewable ?FFztTEZ4 tnat: resource.

Implicit in this "modecate living" standard 15 th- This approach 1s reflected by the Northwest Power Planning conclusion that Indian tribes are not generally Council's Columbia River Basin Fish and Wildlife Program. The entitled to the samne level of exclueive use and F1sh and Wildlife Program, mandated by the Pacific Northwest exploitation of a natural resource that they enloyrd at Electrrc Power Planning and COnseTYat10n Act, 16 U.S.C. Section the time tndt Li~eyentered into the treaty reserving 839b (1982), encompa88e9 the Columbia River and its trlbutarleB and will be financed by Pacific Northwest ratepayers. This comprehensive protection, mitigation, and enhancement effort does not appear to be integrated into the DEIS or proposed plan. Nor were the increased fish returns made possible by the recently Here the Ninth Circuit has lndlcated that the Klamaths muat concluded United states/Canada Salmon Interception Treaty, 16 be allowed to achieve their "mo4erate living." NO one knows what U.S.C. Section 8396 (1985 supp.), mentioned in either document. that is. The COUCt explicitly stated the possibility that the

5 These efforts, along with the Salmon and Steelhead fish areas which have the potential to adversely Enhancement Act, have changed the complexion Of fisheries affect downstream use will be identified management ~n the Columbia Basin. The SUCC~~SOf both the Salmon quantitatively. Interception Treaty and the fish and Wildlife Program turn upon lnaximleing utilization of the anadromous fish habitat in Columbia -See Northweat Power Planning Council, Proposed Work Plan Pacific River tributaries. A large percentage Of these tributaries run Northweat Hydro Assessment Study (August 1, 1984) at 3. The through national forests. The Forest Service muat acknowledge results of this Study will provide the most current and its reQponSibilitieS to act in concert with these policies. The comprehensive examination of Columbia Basin anadrc"u8 fish Forest Service cannot make B reasoned deciaion With respect to production capability available. This study will be used to anadromous fish habitat if it does not factor these activities identify areas and stream reaches that, due to their value to into its decismn-maklng proceas. The Pacific Northwest cannot fish, should be protected from hydroelectric development. It afford to spend money enhancing fisheries that are simultaneously would be wasteful and expensive indeed to invest money in habitat belng degraded by timber harvest, road-bullding, and grazing. enhancement and protectLon only to have those efforts smothered by sedlment generated by logglng and roadbulldrng. The Forest Forest Servlce coordination wlth Pacific Narthwest fisheries Service and anadromous €ish managees from federal, stace, and enhancement activities is not only sound policy: It is also tribal governments should coordinate to make sure that the required by law. Forest Service regulations declare that a information generated by this Study wlll foster the most review of state, federal, and tribal planning and land use' >udicious re~ourceotilization possible. activities shall De lncluded in the forest plan EIS. See 36 C.F.R. Section 219.7 (a)-(.=) (1984). In addition7th.z regulations provlde that this r'eYleW shall consider the CUmUletive Impacts Obgectives of federal, state, local, and tribal governments, inter-related impacts of these Plans, and a decision by the Forest Service on how each forest Plan shall address these inter- There are 17 national forests in the Columbla basin that related impacts. Id. at (e)(l)-(4). Among the ob2ectives of produce anadromous fish. These are: the Clearwater, Nezpeecer federal, state, andFribal governments are the fish production Bitterroot, Boise, Challis, Payette, Balmon, Sawtooth, Umatllla, plans currently being formu~latedunder the auspices-of United Wallowa-Whitman, Mount Aood, Nalheur, OEhOCO, Glffoed Pinchot, --States Y. Oregon, the F~shand wildlife Program, and the Okanogan, Willamette, and Wenatchee. All of them are going InterCePtlon Treaty. The OChDCO National Forest DEIS and through the forest planning process. Approximately 50 to 70% of PCopoSed plan do not reflect the consideration of thee= pro~esse8 all remaining anadromous fish habitat IS contained in these requzred by the NFMA. forests. Events on these forests will have a profound impact on 'he anadrgmaus fish ~esourcethat IS Vital to the welfare and ,riatence Of the four treaty trrbes. Anadromous Assessment Unfortunately, the Forest Service does not seem to realize that each forest is an Important cog in the machrne that will either reYlve the fish or slowly road, As a consequence of its federal mandate to protect, runs log, graze, or sine mitigate, and enhance fish and wlldlife while assuring the then into oblivion. To adequately assess the envrronmentel Pacific Northwest an adequate and economical power supply, the impacts of Sts actions as required by NEPA, the Forest Service Northwest Power Planning Council is currently estimating the must study and disclose the cumulative Impacts of all 17 forest plans listed above On the Columbia River anadromous flsh runs and location and extent Of anadromous fish ~n the Columbia Basin. This assessment the four Columbia River treaty trrbes. It 1s simply not adequate will: for each forest to merely look at the impacts of its activities within the borders Of the forest the surrounding estimate the resource value by characterizing the or 1" productivity of each stream reach. Productivity is COmmUnitles and Counties. Nor IS it adequate for the Forest defined fo be comprised of three factors: 8mo1t Service to baldly assert that it has assessed cumulative impacts production, migration use and upstream geography while Offering absolutely no evidence that it haa made any Such which may. through sedimentation, affect downstream consideration. Flsh production precluded by activities within anadromous fish areas. This Study will quantify each forest and in conjunction with Other forests affects not the smolt prOdUCtivity of each etream reach. only surrounding communities, but also downstream Indian tribes Mlgratron wxll De accounted for by including in any and other fishers both inriver and in the ocean. estimate of smolt production for an individual stream reach upstream pcoductivity as well, i.e, Adequate assessment of CumulatiVe lmpacts requires a Certain the PrOdUCtiYity will accumulate as one moves down management worldview. It requires that managera of land, water, a Stream. Stream reaches upstream of anadromous or fish realize that even though they nay only have management

6 7

1-4-105 authority over a relatively small aspect of the anadromous fish Moreover, in the absence of a system lifecycle, thelr management decisions may have a declslve impact perspective, monitoring and evaluation of actions on other fishery management decisions or the fishery resource may be uncoordinaced, lacking, short-term, itself. ThlS 15 by no means a CIYOlUtionaey concept. In fact, sporadic, or narrow focus. the Forest Service avatls irself Of this management approach every time it asserts that the reason that basin fish productlon Id. at 8. IS not any higher is because o€ downstream passage mortality and _- harvest management. The Forest Ser'YiCB is Correct when It States There are many who consider the need to provide €or that harvest and passage ons side rations are ~mportantto the increased natural frah ProduCtzOn to be a maJor constraint OD overall health of the Columbia oos~n anadromous fishery. anadromous flsh harvest regimes. The tribes have foregone However, fish production, both natural and hatchery, 1s also harvest Of flsh, to which they are legally entitled, fOT the equally important. The Forest SeCviCe 1s directly responsible purpose of providing increased escapement of natural1y spawning for natural fish production OCCULring on national forest lands. adults. Despite these efforts, and despite the incresslng Pointing accusatory fingers at other entities does not relieve numbers of returning adults (many of whlch are hatchery flshl, the Forest Service Of its duty to ensure that it8 ,management wlll the tribes are under pressure to further forego harvest not adversely affect already depleted naturally producing stocks. opportunitrea. FO~~SCmanagement that will cause reduction in natural flsh produCtlOn wlll further exacerbate this sItUatlW8. The Lded that proper flaheey management requires Reductions in natural fish pmductwn directly conflict wlth the coordination of harvest, passage, and production needs has been tribes' treaty rights. around for a number of years. It 18 embodied in the Paclfic Northwest Electric Power Plannlng and Conservation Act enacted in The Forest Service has often informed CRITFC and tribal 1980. See 16 U.S.C. SBCtlOn 839b(hl (1982). It 1s also an staff that the Foreat Service is only responsible for supplying integralxpect of the NOrthwest Power Planning Councrl's efforts BmPlt habltat capability and that there 1s far "tore capable to coordinate restoration of Columbia basin fisheries to the habitat than there are smolts. The Forest Service's extent affected by hydroelectric power production. See Q. responslbllltles include more than merely furnishing a given Northwest Power Planning council, Salmon And Steelhead PTaiinlng, amount of habitat. The Forest Service must identify that which staff ISSW raper (June 3, 1986): is being utllzzed by flsh and, to the extent 1t can, that vhlch will be utilized through either United States v. or Fish A gamut Of potentla1 problems may result from and Wildlife Program enhancemenIarmthTconcern behlnd uncoordinated actions. Fish production investments protection of naturally spawning stocks 1s the desire to protect may be in conflict. Power system operatzons may Unique gene pools that will be needed to restore the basin's diminish production or offset increases in fisheries. For a recent d1sCUSsion of the role Of genetics zn production. Harvest ~ractlcescould prevent Columbia basln flsherles management, see Northwest Power Planning escapement in adequate numbers to ensure sustained Coun~ll, Salmon And Steelhead Research, Staff Issue Paper (June increases in yield. The mixed-stock harvest could 3, 1986). undermine passage actions designed to protect or enhance certain stocks of fish. Harvest and pover needs may not be enfficiently defined tO guide Mitigatlo" DrodUCtIOn efforts. Production decisions may be made without full regard to harvest needs ani to power system constraints with respect to passage. The Forest Service has Often relled upon mitigation In the Land and water management actions may undermlne hope that mitigation will compensate for the damage inflicted on fish production investments. fish habitat by timber harvest- However:

When actions are taken in the absence of a Mitigation of fish habltat losses IS often system perspective, there also may be too little presented as a panacea and substit~tefor recognition of the Spectrum oE choices among maintenance of habitat quallty. The concept Of production, passage and harvest actions. ACtiOns "fisherLee mitigation" is more myth than substance. may be taken without consideration of the full It seldom materializes end when it does, It only range of alternative means to acnieve objectivea. partially compensates for substantial 10sae.s. Actions may be taken With inadequate analyaia of Tnere le no history Of fisheries budgets SUffzClent thelr llkely effectlvenesa. AS a result, there IS to mltlgate subetantlal losses Of quality habltat. no assurance that a given action achieves sound Recent and pro3ected budget trends lndlcate a biological ob3ectivee at the minimum economic cost. -Stat"= E Slt"&tiO".

8 9 -See Espinoaa, Background Paper Fxsheries Resources Analysis Of In Northern Cheyenne -, the court declared that "a the Management Situation Clearwater National Forest (undated) at federal agency's trust Obligation to a trrbe extends to actions reservation 56-57 (emphasis 11) text). The Commission is unfortunately it takes off that unzquely impact tribal members or acutely aware of the vagaries and inadequacies of fisheries property on a reeervation.' Id. at 27. In an attempt to save ita 8nitigatron. Thus, Ye are extremely skeptical Of vague promises Coal leaaing EIS from LnvalzTatlon, the Secretary of the Interior of best management practices, implementatzon Of standards and alleged that there was no apecific statute or treaty that guidelines, and reliance on enhancement to mitigate management required the Department to consider the impacts o€ coal leasing impacts on fish habitat. on the tribe as an entity. Id. The Secretary also alleged that his decision to lease the coaTwaa in the "national Interest" and Given the tmportance of the anadromou- elah resource, very "vital to the nation's energy future." ". at 29. TLle Court little reliance Should be placed on mitigation measures that do declared that: not have a proven recozd of effectiveness. The Forest Service must be careful to not askmore of a mitigation technique than it The Secretary's Conflicting responsibilities and Can give. New Or untested mitigatlon techniques should be federal actions taken in the "national Interest," thoroughly evaluated before being widely u8ed and relied on. however. do not relieve htm of his trust rlonitoring should be vigilant, stringent, and should include all obligations. TO the contrary, identifying and entities that ace Involved in the manqrment o€ anadromous fish. fulfilling the trust responsibility 15 even more Finally. mltlgatlon methods Should be Chosen on the basis Of the important in situations SUC~as the present case protection they Will pCOYide the fishery reBOYrEBt not how much where an agency's conflict~nggoals and they will affect the cust/oenefit analysrs of commodity resources responsibilities combined with political pressure such as timber, range, and mineral extractLon. See Pacific asserted by non-Indian8 can lead federal agencies to compromise Indian rights. -Power b Llght C0.r Opinion NO. 381-A1 30 P.P.C. 4T(1963)m or ignore art, rev'd rn e on other rounds, 333 F. 26 689 (9thCif; %6%--- cert. denied, 379 U.S. 96-51 (where it IS declared -Id. at 29-30 (citations omttted). Similarly, the Forest Service that it is the policy of other federal agencies to require must not allow its Obligation8 to the Columbia River treaty complete recompense for fisheries damage.) The DEIS should be tribes to become lost in Its concern for the local Citizenry. It revised to include analyses Of known mitigation techniques. must accord the treaty right special consideration and scrupulous These analyses Should include evaluations Of effectiveness. safeguards. Unfortunately, the DEIS did not devote this standards f& application, and any other information that might consideration to the tribes' interests. be of aid in decldlng whether a given mitigation technique is appropriate. IS reliance On habltat enhancement as mitigation The Forest Service owes a duty to not only discuss the appropriate In the face of the current federal budget crunch? effects Of forest manasement BCtLVitles on the tribes, but a180 a The Commission will be happy to Contribute its expertise towards duty to safeguard resiurces Of crucial importance to the tribes. This duty not fulfilled by actions which 8onct1on degradation evaluating the use Of various mitigation methods on a case-by- de case basis. Of flsh habitat needed tn re-build the COlUinbra RLVer runs.

-Trust Responslbllity ---Sales Below Cost

the years, fish and wildlife have often been The tCUSt cesponslbllity that special relationship Over concerns is subordinated to the needs of allegedly more econonrcally between the United States and Indian tribes that originated in valuable. but environmentally damaglng commodities Such as timber Cherokee Nation Y. Geor21a, 30 U.S. (5 Pet.) 1 (1831) where the Supreme Court describe Indian tribe8 as "domestic dependent harvest, irrigated agriculture, grazing, and hydrolectric power nations" and declared that "their relation to the United States production. Thus, it is not without some lronlc amusement that resembles that of a ward to hls guardian." Id. at 17. This the Commission Observes the current controversy over unprofitable relationshrp is part of the very fabric of feder'r Indian law and timber sales. Those who have advocated resource declelon-making it imposes stringent fiduciary standards of conduct on federal primarily On the basis of short-term eCOnOmiC gain suddenly find agencies I" tnelc deallngs wit" Indian tribes. See United States themselves "hoisted on their own petard." Perhaps this role V. Creek NaLlon, 295 U.S. 103 (19351. See al-o Et-h- revecsal will convince thOBe involved natural -Trine - v. -_HO(le1, CIV. NO. 82-116-BLG w?rKnay 281 l* all in resource 23. decision-making that cost/benefit analysis 1s et best an "unfaithful lover" and that resource decisions are best grounded on Other bases.

10 11

1-4-107 The Commission is not automatically opposed to "sales below cost" 5- What concecne is that the DEIS contalna ~er us no The OChoCO NatLonal Forest 1s a national forest and Should assurance-_ an timber that of the sales proposed for the next 50 not be managed private woodlot for handful local mllls. years vlll actuady Its real Costs. The NFMA regulations as a a Of recover If the trends sustainable flow from surrounding lands on that the Focest Secvlce "shall com~arethe dicect Costs for are require declining trend the local aces, the intentions Of the Forest Of growiny and harvestmg trees, ~ncludmgcapital expenditures a I" to mathh past levels of harvest may in the long fail to required for timber production, to the anticrpated receipts to run support local mrlls. The Forest Service not charged wlth the the government...". C.F.R. Section 219.14(b) (1984). le 36 Obligation to insure community stability. Its true mission ia to "Direct costs" are defined to "~ncludethe anticipated that the resoucces lt controls will oe pronuctive into ~nvestments,malntenance, operating, management, and planning ensure perpetuity. It fails that standard If it allows timber harvest costs attributable to timber production activities, including that reduces the productive capacity Of forest fish habitat. miti ation measures necessitated b the Im acts of timber prod&tlon. E. at Section 219.14(bd) 7Gphhdda.- Budget The Commls9ion IS COnCeCnPd that the Forest Service will respond to the ''sale8 below cost" contcovecsy by artificially "~mproving" ~tstimb2C halance sheet by shortchanging aale Given the present domestic spending trends, It IS extremely mitigation needs. The DEIS Should dlsclose the manner 1" whlch unlikely that the Forest Servlce wlll be able to Count OD mitigation measures and levels of mit1gatmn funding are chosen receiving budgets Of equal or greater amount than what it and applr-d. This information may demonstrate that the timber currently gets. The DEIS should include a complete explanation pCOdUCtiJrl envrsloned by the proposed alternative fails tO Of how the Ochoco National Forest will respnd to budget cuts, include all mitigation costs and is therefore even more cost which programswill be cut and the amount of the Cuts. Region IV Ineffective than It presently appears. Bland aseur'ances that the national focests in Idaho have a 25% c~nstrainedbudget Forest rmnplement mitigation which It alone Service will measures alternative in their DEISS. The OChoCO would be wise to initiate detecmlnes are necessary fruetrates the policies behind bath NEPA planning that would anticipate substantial bddget CUtbaCk8. and NFMA. Both of these statutes demand disclosure, public scrut~ny~and public input. water In attempttog to 3ustify "sales below cost," the Forest -auality Service Should explaln where It tntemd4 to flnd the funds to pay for mitxgrt~ny the effrr~taof timber management on fish and The NFMA and 1t8 implementing regulations explicitly require wildlife It IS our understanding that Knutsen-Vandenberg funds the Forest Service to ensure protection of stceams and fish for fish and wildlife are not generated by "eale9 below Cost" habitat. Plains must "insure that timber will be harvested from whereas a sale that covers ~tsCosts also yields mltlgation National Forest System lands only where -- ... protection IS money. In other worrlsr EIJ~ and vildllfe are much more adversely provided for streams, streambeds, shorelines, wetlanda, and other affected by a below Cost sale than by a sale that 1.9 financially bodies of water fromu detrimental changes ~n water temperatures, sound. blockages of water coueses, and deposits of sediment, where harvests are likely to seriously and adversely affect water conditions or fish habitat...." NFMA at Sectron Community Stablllty 6(9)(2)(E)(iir). The NFMA regulations parrot this language. % 36 C.P.R. Section 219.27(=1.

Desp~tet1w ,dtt*c dearth Of statutory authority, the Forest The Porest Service is also obligated to abide by State water Ser~iceappear9 to orlieve that the "maintenance of community quality standards adopted pursuant to the Clean Water Act. 9tablltty" 1s the primary constcaint on forest management. In Unfortunately, the Ochoco National Forest appears to have adopted addition, "maintenance of cominunity stability" also appears to a rather lackadaisical attitude towards these prOvISlOn8. For mean perpetuation or increase in commodity Outputs to the example, the Forest spends one and a half pages (DEIS at 172-174) detriment Of non-commodity outputs and an attempt to artificially diecussing Oregon State Forestry Program Pro3ections for the maintain lifestyle^ which would not otherwise be economically Forest. In stark contrast, the Forest spends one and a half feasible. In es~ence, the Forest Service seems to perceive its inches (DEIS at 175) di~cus~inghow well the Plan meets Oregon's mission as be1n.j ttir guarantor of the local timber and range water quality standards. One would never know that Oregon's industries. water quality standards, not Oregon State Forestry Program ProJections, are binding on the Forest Service. In addition, the Forest does not appear to be able to comply with state standards for temperature and turbidity. E. Does the Forest anticipate

12 13 continuing management activities on those drainages where conditions 80 that the tribes' treaty rights are protected. The standards are being violated? And rf 80, on what legal basis tribes possess considerable expertise I" this area and would does the Forest Justify activities that will either increase or welcome further EOnsUltatiOn with the Forest Service to ensure perpetuate violations of the law? adequate protection.

The purpose of the Clean Water Act is to protect and The Northwest Power Planning Council is rn the process Of maintain the beoeficlal u~esof water. Fisheries are one of develooino a list Of DOtential hvdrO 81teS with the least these beneficlal uses. The Forest states that It 18 u81ng a potentiel *or adverse miacts on other resources. Forest Service habitat capabllity Index ranging from 1-100 to measure fish activities related to hydroelectric power should be coordinated habitat. The Forest states that habitat capability ranging from with these efforts. 15-60 1s "fair to good." (DEIS at 69). In every other national forest plan that we have examined (2 in Washington, 5 in Idaho, and 1 In Oregon), habltat capability ranging from 15-60 18 Forest-Wide Standards g Guidelines considered to be poor. For example, the South Fork of the Salmon River has an existing habxtat capability of approximately 55%. This c1ver 1s often cited as a prime example of a drarnage that Mining ha8 been severely impacted by paat logging. The DEIS does not Contain enough Informatron to determine Whether these habitat Managelent plans for mineral developments include standards are in compliance with state water quality standards. reclamation requirements but there 18 no indication of monitoCing However, from what we see, it appears that zn no way can requirements by the mlning company (Plan p.49). Is monltorlng Of beneficial uses be fully protected even by the FOreSt'B mining the 8018 responsibility Of the ONF3 What IS the forest- "excellent" standard (which claims that achieving a rating of 41 wide goal for reclamation: does It imply restoration to natural out of a posslaie 100 is "excellent"). appeara"Ce?

Range

Transitory range management will be coordinated Uith timber management (Plan, p.50). What factors are considered in the The Secretary Of Agriculture has an important role to play tradeoff between range and timber management? It often seeins 1" the licensing of hydroelectric prO]ects that will be located that the DNF will go to extreme efforts to extend grazrng systems in national foresrs. Sectam 4(e) of the Federal Power Act, 16 even to the detriment of timber production. The most PrOdYCtlVe U.S.C. Section 797(eI (1982) declares that the Federal Energy bottom lands bordering streams are generally already Clearcut and Regulatory Commission 1s authocized: after becoming incorporated into grazing allotments, these lands are never ,returned to productive forest management. Why are the most pqoductive lands allocated soley to range, a commodity outpnt which costs the ONF far more to administer than It generatea in receipts? thi United State; ...Provided, that licenses shall be xasued Within any reservation only after a When other management strategies will not protect the frnding by the Commission that the license will not integrity Of ripria" C0"""itieS in BCtiYB allotments, fencing interfere or be inconsistent with the purpose for will be used to control utilization (Plan, 9.501. It seems that which Such reservation was created or acquired, and the predomlnant lesson from grazing studies near riparian areas shall be SUQIBC~ to and Contain such conditions as is that salt blocks and waterlng structures are inadequate in the Secretary of the department under who8e luring cattle away from riparian areas. What iB the record of ~wisd~ctionSuch reservation falls shall deem compliance Of Cattlemen With requests to frequently move their' necessary for the adequate pcotectian and herds out of ripariar) zor1es? In which instances will fencing be Utilization Of such reservations.... required and how many miles of fencing would be needed per year? would anadromous fish streams be fenced when found in allotments? It is the Forest Service's duty to impose terms and conditions what IS the condition Of particular anadromous fish streams? that will assure adequate protection for national forest lands from the harms cesul ting from hydTOeleCtriC development. See Riparian Management EsCOndido Mutual Water Com an Y. La Jolla and Rincon Bandsof niseion Inalms, 184 s.++0r; ~~a~~8fi~t~~For prolectd Which could inpact water quality, obiectives part Of the Forest Service's trust responsibility to the tribes for management of riparian areas will be developed under the NEPA to ensure that it exercises its dnty to impoae teems and process through the project's environmental analysis (EA). will

14 15

1-4-109 rlparran zone treatments Only be considered after EA9 are done Potential tree COveCS asdigned to all riparian zones 90 that the for timber management pro~ects?That 1s. will any riparian public can determine whether the standards (80% of potential) are evaluations and treatments be done independently of timber being met? proJects? rlnat part does range evaluation play m inventory and improvement of dsoclated riparian areas? If 20% Of a stream length can be unstable, 20% can have no tree cover, and 40 to 60% could have no ground cover, how can HOW "19 tt established that 40 to 60% gromd foyer is this be considered to be adequate to provide excellent riparian sufficient to prevent significant Water quallty degradation? sane conditions? What level OE ?,i,jraddtzon 1s considered slgnlf~cant? On which streams flovrng through allotments does ground cover exceed 60%.

--water zua1,ty Road crossings will not alter stream characterlstlcs (plan, p.53). HOW frequently will roads cross streams--every 100 ft., Management activities "may involve soroe temperature every 1000 ft? increases, pcoviled the standards for class I and I1 streams continue to be met" (Plan, p.52). What are the standards for the Soils different classes? HOW much temperature increase 1s allowed? Considering the extreme temperature problems downstream of the NO more than 20% of an activity area can be compacted to a ONF, how cdi any ii)c* temperature increase be considered not to degree which degrades vegetative prodUCtIvzty (Plan, p.55). have adverqe 111 iiIl,t',- -iiict3? Cable lagging is estimated to Increaae sol1 bulk denslty on 10% of aCtLYlty areas and tractor lOYglng on 30% (DEIS, p.177). Stace water quality standards will be met by limiting timber Sloe the forest plan calls Lor predominantly tractor logging, harvest to "no more than 25 to 35 percent Of suitable land base how can a maximum of 20% compaction be assured? HOW much at any point In time". What factors were considered in Sediment reduction in vegetative productIvIty from soil compaction IS modeling? Did sediment modeling include timber harveqt, road requrred before it is considered a significant? Are the miles of Construction, granlng, end mining (Including all the methods for Permanent road network included rn calculatmns ol compaction? Conducting each activity)" Relative watershed sensitivities IS this surface area subtracted from the productive forest land COrCespond to 25, 30 and 35% limltations (Plan, p.52). There base when calculating future production? Is the reduction in seems to be very little difference in limitation between stable productivity from a11 sour'ces factored into future timber and Unotdii' m. .,?trcihede. In calculat~nyequivalent harvest what Praduction caloulationa and the estimated LTSY? What length of age stand is considered to be a Closed stand and what is the time is Cequlred for various degrees of compactlon to be revereed minimum size watershed to which tne standards apply? naturally7 What percentage of 8011s will be ripped to reduce COmpaCtlOn? HOW much wlll this increase soil erosion? Are Sank stability 1s generally provided by tree Coots for a sediment Output rates calculated On the basis of vatereheda (if distance of 5 to 10 times the diameter of the trunk (Plan, p.52). 90, which size watersheds) or on a forest-wide basis? Much more MerChantible trees may be removed If sufficient trees remain t0 drainage specific informatron Should be provided on sediment provide COO^ >.crangth. If bank stability end Sufficient shade OUtpUt and erosion as well as on other characteriet~csof the fan be provided by the treesvithrn 5 to 10 trunk diameters, will watershed eystems. riparian zones be essentially clearcut Outside this near-stream \rea7 Timber Management

Enough trees "should be" lett to ~s?etShade requirements and Clearcut units should be prepared for planting within 2 Bupply Sufficient amounts of large woody debris (Plan, p.52). Is yeers after harvest. Planting occurs within 1 year of 4itP this etatrmenr made by DBsUmptiOn or calculation? What 1s preparation and the atand is hopefully certified 3 years aLter considered a .~uEf~cientam0u.i of large woody debrls? Fuzzy planting (Plant p.57). Thle prOCeS8 appears to take 6 yeaCs language such as "should be" and "if poaslble" needs to be although sites are suppoeed to be certified Within 5 years. What reworded to E. happens if a site cannot be Certified as revegetated? Will it be replanted and are funds available for the usual frequency of --Wetlands Becond efforts at revegetation? What 1s the success rate Of teYegetatlon on different site types On the ONF? Riparian areas "should be" managed to maintain upper streambanks ~n stable condition along at least 80% Of the --Reforestation Str~wi'slength (Plan, p.53). In addition, in riparian areas normally dwtnated by trees, ~0%of potential tree crown cover Stocking standards are bB8ed on trees 4.5 ft tall (5 to 10 "Should be" eatarned. Will the ONF provide a map Of the years old). If 30% of a watershed can be in a harvested

16 17 Condition at a time, then It appears that 60% could be less than --Pcimary Cavity Excavators 4.5 ft tall JY tsIe second decade. Would th18 rate oE harvest ~n a watershed b> allowed and would it automatically be assumed to Snag habitat will be provided by cl"mplng acres of timber meet !dater aualitv standards if the watershed SensitiYitv ratin9 managed for snag retention within managed stands (Plan, p.61). indicated th'e watirshed ahould be stable? could wildlifhdemend~ Will this uneven distclbutlon of snags really comtet-act losses for thermal atid illding cover be provided under these of snag density in managed stands? Have the spatial requicwaents Circumstances? What average stocking density ha8 been achieved of snag dependent species been considered relative to all the in the past on the ~arioussite types on the ONF? If only the speclea WhlCh use the snags? True, Some apecles may benefit from minimum SLockLng level is achieved, this apparently will be clumping (Thomae 1979) but this does not Imply tnat all would. Eonaidered sufficient. If lnlnimum levels become Common how would HOW does the species territory size requirements match the future allowable haCVe9ts be ad,usted? Wnat percentage Of diQtribUtiOn Of preferred snag trees. Given the large number Of recommended StoCkiOg levels are assumed when prolecting forest wildllfe species Whlch depend on large diameter standlng or down productivity' dead trees, how can the requirement of 2 snags/acre and 10 inch DBH satisfy their needs? Thomas (1979)(Appendix 20) lists many --PrecOmmecci~l thlnnlng birds and mammels that depend on tree cavities ~n trees larger than 15 inch DBH. In additlo", wlldlife use Of downed 109s IS Precommerclal thinnlng will only be peefocmed when expected given in h19 Appendix 24. Numerous species, including many rare return exceeds the Cost of the action (Plan, p.58). HOW much does 8pecie8 and big game, have various life history requirements the pro3ected timber yield depend on precommeecial thinning. centered on use Of downed logs. It 1s doUDtfUl that 10 lnch DBH material would satisfy the needs of many of these species. --Haevest Schedule It is Stated that "large snags, greater than 20 inches dbh Total timber sold (ASQ plus salvage) for the decade Will not is no longer a requirement because only tnr pileated woodpecker exceed the planned level by more than 5% although it 1s also requlres the large SDagS and their MMR'S wlll be met with the Stated that in caseofe catd~t~oph~~eventthzsmaybe increased benchmark old growth allocations" (Plan, Appendix Ml). What 19 to I-?%, dhat IS the distinction betveen normal operations and the MMR for the pileated woodpecker? Will its populations remain catastrophic Conditions? It 19 commendable to require redUCtlons viable with the dispersed nature of the proposed old growth in the ASQ Boove this level but what keeps the planned ASQ plus areas? For reasons discussed more fully below; CalCUlatibnS of salvage level from Deing exceeded by 10% each decade. Are forest-wide habitat potential for this woodpecker are erroneous. adJustments anticipated from decade to decade to compensate for As noted previously, Thomas lists many species which depend on over harvest any decade' large snags. Among these are the Darred ow1 which is listed 1" the "Oregon Non-Game Wildlife Management Plan" (ODFW, 1986) as --Low Prodwtivlty Lands being in danger of extinCtron Ln Oregon. The ODFW Plan also lists Lewis's Woodpecker as being vulnerable and It requires Why is tlmbeC ndcYe4t writenplated on sites With less than snag8 greater than 12 inches DBH. The flsher requires Law+ 20 cu.ft./acre/year production? Other forests forbid haevest of Snags and 1s also listed by ODFW a8 YUlneTable. The Status of treee On low productivity sit-4. the Canada lynx is questionable and the wolverine ia Vulnerable; both species require large downed logs for cover. The tendency illllilif- to minimize the quality Of fish and wildlife might be expedient for logging companies but shortchanges the entire forest -- Pileated Woodpecker eC09y8teB.

HOW many palr.3 Of pileated woodpeckers can be supported on Have pOpulation trends been estimated for any Of the species the r~malnlngold growth outside of wilderness areas? What listed ~n Thomas (1979) taking into conrideration the size of i>eccentage of maximum densitlee can be BUBtained with 2 snags per dovned logs? Large enags become large downed logs. If large acre? The

18 19

1-4-111 --Rocky Mountain Elk and Mule Deer cover is shrubs. What proportion is dense forest cover? The ONF will maintain at least 108 of all winter range in The Gredn Dot System will be used to regulate temporary road thermal cover (Plan, p.611. What standards ace there for hiding closuce. It has been our experience in reviewing SUCC~SR of cnad cover? What ~lansare there for increaaina thermal Cover on closure policies that a system of Signs does not work. We winter range where IC 1s deficient? Suggest that the ONF 1s not a publlc Toad4 agency and doe8 not need to keep a large number of roads open after logging has --Dead and Downed Logs ceased. Wildlife would benefit from lower road densities and less sedimentation Of streams from road travel would occur. The "Wherever possible", 2 uncharred logs/acre should be left Nezperce Poreat has been succeseful in instituting permanent for vlldlife habltat. Where is 1t not possible to leave 2 closures with Concrete barrrcadea in ~oop~rdt~onwith timber logs/acre after logging? The minimum size log identified 1s 12 companies and the Idaho Department of Fish and Game. inches and 213 ft long. What IS the value Of even 2 ponderosa pine logs of good quality of these dimensions compared to the Forage Utllrzation Standards on winter range are the Same as "alae of the wildlife species which depend on this material? for General Forest. Since winter range ha8 largely been What percentage Of maximum densities of all dependent species incorporated by private Cattle ranch operatrons. Wouldn't It be could be supported by such levels of dead and dawned logs if wiser to give big game a break on habitat Critical to their theae guidelines were employed forest-wide? What are the SUIYIY~~. If there IS such resentment by cattlemen to wildlife densitlea of thls kind of material in VBT-IOU~ old-growtn forest use of their hay. maybe the ONF should consider much greatec types on the ONF" Have *nag rnventorles ever been done? reductions in the heavily subsidized us@ Of forage on nationdl forest land. Vlrtually the only place where grazing is not permitted 1s on adinmlstrative sites. Management Pre8crlptIon8 819 Game Summer Range

General Forest Optimum enmmec ranqe will be created bY timber harvest to reach i 40/60 ratlo of thermal cover to open-range. What is the On 58% of the ONF the largest trees will be 16 to 18 inches present ratio on summer range? What is the average distance from DBH. Ths only sn*gs present wlll be those needed to meet the forage areas to thermal cover? cavity nesters requirements [Plan, p.65). Does this mean that any snags beyond Che minimum requ~rementsw111 be eliminated? Old Growth The ~eneralForest prescription commits a very large percentage of the focest to small maximum size. 9s the old overstory ia Only 3% of the ONF will be retained as old growth [Plan, removed and the understory Is thinned, the forested range lands p.74). Whi is ic that when the ONF LS already one of the most will be found more frequently ~n falr and good foeage condition heavily managed forests and ha8 lost more old growth then most class [Plan, p.65). Thl~1s a rather sad commentary On range other forests that it cannot plan to leave the remaining old management if it 14 necessary to convert the remaining old timber growth? Tt seems that present degraded conditions always set d stands to thinned tree farins to pcovlde new transitory range that framework for the furure and the future will be the present minus does not suffer from over a century of overgrazing so that the 508 regardless Of What the starting point was. It IS difficult forest-wide average range COnditlon can be shown tO be improving. to see how the ONF can meet requirements for dzspersron of seral vegetative Stages and ecosystem diversity by limiting old growth ~angeotilization standards will not exceed an average of to 3%. 508 on meadow8 and on slope. less than 308. la this a new standard or has it been used before? If this standard has been Why is the minimum snag 8128 given as 10 Inches DBH when used for solne tiroe why are the ranges predominantly in poor to much larger sizee are required? If the old growth area 1s fair co,idit~nnstill" What 1s new about management or capable of producing trees of 21 inches DBH or more, why is it enforcement that vrll assure a departure from the declrning range to0 much to require larger 8lze snags? Are 2 snags per acre conditions that the ONF has experienced until now? what grazing expected to provide 1008 of potential population sires foe seasons are allowe3 for meadow? pi 1ea ted woodpecker?

Big Game Winter Range Retention Foreground

50% of Dig game winter range will be managed in thermal Is it legitimate to aasume that cavity nesting species can cover [Plan, p 6R). Is the ONF distinguishing thermal and hiding be found at 100%of potential in the linear patches created by cover. It appears that much of the vegetation termed thermal retention foregrounda when these are found near roads, traila,

213 21 and campgrounds, It Seems that the Viability of many species is resting on Shaky bI010gical assumptions Which are based more on multiplying total areas by assumed wlldlife densities than by Timber' management in the riparian zone features a 200 year considering the spatial relations among management units. rotation. The Wenatchee Natlonal Forest Uses a more COnSerVatiVe value of 260 years. Hacrrs (1984) recommended 320 years rotation Wilderness in riparian zones for Region 6 forests. EY~"ln western Oregon it requires 260 years to produce tree8 Of 30 inch DBH. HOW would Only 4% of the ONF 1s planned to be retained as wilderness. old-growth dependent species fare in riparian stands Of 200 years Forage utilization standards in wilderness are the same as those old? Maintenance of older age riparian cover would reduce found on General Forest areas emphasizing grazing. Why 1s drsturbance to Streams and also pmvlde mace effective habitat grazing intensity ~ustas high in wilderness as in intensive for old growth dependent species and Integration Of the entire allotments? What seasonal restrictions apply to wilderness forest. areas? Do these TeStriCtxOns prevent the klnd of sol1 COmpaCtiOn found on allotments? It IS ObYIOUe that in the ONFa greater p~oportlonOf timber productmn occucs in riparian zones compared to other management Riparian ~n acceptable Condition areas than one finds west of the Cascades. This fact ~lnplles I that ~COPRCriparian zone management for multiple-use would be On streams where the desired condition is not met the Stream 8nOCa Ceatcictlve to the tlmber Industry in the ONF. This, will be improved to an acceptable condition (Plan, p.931. What however, should not dictate what 1s environmentally acceptable. 1s the time frame for improvement from poor to acceptable CO"tT-OI of water temperatures by conservatlo" of riparian EOVel: condition0 Which classes of streams are placed into the in eastern Oregon is even more critical than I" western Oregon. management category for attainment Of acceptable Condition- What 2s the planned width of riparian zones? If a riparian The minimum requirement for shade is 75%. What le the zone is nothing nore than a picket fence It Cannot assume a role average percentage Shade on thrs Class of stream [riparian in as a reel fwnctional ""It. acceptable condition1 presently and on specific Streams of this class? If 75% shade IS unattainable, the standard will be 100%. Riparian in Excellent Condition What does th1s standard mean? If 75% is truly Unattainable, then 100% would be also. NO activities that degrade water quality in perennial and fish-bearing streams will be allowed [Plan. p.95). will streams On the John Day Rzver, temperatures at or below 66 F may be WhlCh were formerly fish-bearlng be rehabilitated to fish-bearing raised a maximum of 2 F [Plan, p.93). Since high etream status? In which anadromous fish streama have act~vit~ea I1 occurred which have degraded water quality? The statement that temperatures are Such a severe problem in the John Day system, how any fmiCtheC increase in temperature be allowed? If no activities Whlch cause degradation Will be allowed is good but can what kind of commitment will the ONF make to realize this temperatures are raised on one tributary, will they be reduced on another by an equal Or greater amount. Overall temperature standard? If grazing is causing degradation in atreains and reductions should be the rule if the ONF 1s trying to improve riparian zones will it be discontinued or will Out-of-riparian shade. Why is 68 F chosen as the maximum allowable? Is this zone watering devices simply be Installed? considered to be an Optimum for fish? Why is 58 F the maximum in HOW much Of the riparian zone assrgned to excellent the DeSchutes R1YeC if both the John Day and Deschutes are steelhead streams? HOW would the potential temperature increase management condition is presently in excellent condrtzon and how be determined before harvest? For how long after harvest will much wLll be elevated to this candltion? Drainage-specifrc stream temperatures be monitored to determine whether information would be needed for public understanding of the goals temperatures are within acceptable limits, and which flow for specific streams. Otherwise, no one will ever know whether Conditions do the standards apply to? What are maximum he is following or meeting guidelines. HOW many Of these streams temperatures currently on the streams in this class? meet the 80% Shade guideline presently? If this guideline is not now met how can 5% be cut per drcdde? If trees reach 4.5 ft in a If the goal for riparian shade in this management unit is decade it would seem that little shade would be provided a decade 758, why are cavity nesters to be managed at40%Of potential? after haeveqt. IC 2 decades are required before BUffrclent shade is provided by riparian regrowth, the peesent riparian shade in Only one pasture per allotment will be scheduled for these streams should be about sa% presently for 5% to be cut pee improvement during a flve-year period (plan, p.941. How many decade, thereby reducing shade to a austalnable 80%. Wow much pastures are there per average allotment? Why is the rate Of timber harvest has occurred in the past on anadromous streams? improvement so slow? After one pasture irr improved, will it be Has this timber regenerated? returned to Its previous level of grazing?

22 23

1-4-113 be done on all allotments? The variability threshold for range condition is any change which would affect AUMB. What change Wauld really require a reduction in AUMS? HOW Often have RUMS Wildlife been reduced from the planned allowable levels due to severe climatic conditions? Will rainfall or forage productivity If pr'lorlty stands are lost then land designations would be measurements De made throughout the grazing 8ea8On tO determine modified. what are priority stands? Does land designation When Cattle should be removed? modification mean that other mature forest land would be allowed to grow into old growth Condition? The oblective rn planning range improvements is to gain a desired cattle distribution and use pattern. If this 16 the If snag habitat is not BUffiClent to meet ObIectrves, Output OD3eCtLVet IC would seem that cattle dlstrlbutlon would be schedules would be revised and the management practice would be measured. ~f specific levels of forage production were the modified. What help would be provlded by revlsrng output oblective, then production analysia would De appropriate. achedul-s, If the ob]ectlve la to provide various percentages of potential habitat, why IS the monrtorlng unit slmply acres (or Timber even snag numbers)? The ONF Should be Inventocylng WlldlXfe populations to determine Whether snag numbers meet the obiectives Have any measurements been made on the ONF of tree growth for the populations and not ]"st whether an index such as Snag rates in second growth areas vs. prev~ouslyuncut areas of the numbers is met. same Site type? It would be Interesemg to know the likelihood of future growth Variations Caused by harvest. For fish and wildlife improvements what does It mean to have methods of evaluation commensurate with permittee? In fish Riparian aceas will be evaluated every 5 years. will improvement prolects *hat would the oD]ectives De? It appears permanent stations be established to determine a trend? What that counting of fish 1s not considered a8 part of evaluation. would these sites be? Can more precise data be given at thia TO determine whether variability thresholds ace exceeded, one time for riparian condition--1.e. by drainage? If the threshold must know what the Ob]ectlves of pro]ects are. HabiEat of variability is 20% from predicted, how 1s the prediction made? improvements may be valuable assuming they are engineered Does this statement mean 20% degradation from the previous correctly out ~ithoutevaluation of pro~ectaand general measurement? What percentage of total riparian area would be evaluation of fish numbers in streams throughout the forest, the sampled every 5 years? only thlng that may result 1s "pro~ectcoopletlon" [i.e. installation of structures) as listed in the mon~coling plan. Physical and biological sampling I" riparian zones is noted tor riparlan aceas. These data will enter STORET but no action The only monitoring dealing With anadromous fish appears to 18 indicated if changes are noted. What is the value of

De macroinvertebrate sampllng. WI11 the ONF prOYlde any funds monitocino~ ~~~~ when norhino~ ~ ~~~~ will be done In case of a deviation? for this sampling? HOW extensive a program would this be: how Will ahaAge'i in atream bed Sediment or fish habitat be will the data be used: why are there no thresholds of periodically evaluated? Why Isn't aerial photo surveying done On variability: why ace fish not actually counted? all ripar~anarea instantaneously to determine every 3 years what MaCroinVertebrate sampllng is worthwhile as an Index of health Of the trend xn percentage Shading is rather than felying on the aquatic Syatems but it seems unlzkely that enough sampling would solar pathfinder method? be done to be ef€ective. so11 Any management prO]eCtB inYo1"l"g potentla1 effects on anadromous fish streams (especially prolects in thelr scoping and It was previously stated that a forest-wide average of 200 EA stages) Should involve the Umatllla and Warm Springs Tribes as soil compaction would be allowed for activity areas. Does this c0-managers. These tribe8 plus the other CRITFC tribes have degree Of compaction conetitute the predicted compaction level. treaty-secured rights to a portion of the fish originating on the If so, With a 20% threshold of variabllity from the predicted ONF. Any management activities enhancing or degrading tnia level, compaction would have to affect 24% of the activity area resource directly affect the success of the US government in before action is taken. If an area is primarily tractor logged, meeting its responslbillty to the tribes under the treaty. the predicted compaction cbuld involve 30% of the activity area (predicted value). With e 20% Variance the critical COmpaCLiOn Range would be 36%. It would seem this areal extent of Compaction is erttrerne. For a given area compacted, what degree of increase In Which allotments are in poor or fair condition and what bulk density nas been shown to reduce tcre growth? What degree would be done on each to correct the situation? As part Of the of increase I" bulk density would be allowed? IS campaction monitoring of trend ~n range Condition. will utilization Burveys considered to be an irretrievable loss in production? what

24 25 degree of compact100 would be necessary before the loss xs improvement were OCCUC~L~~.It seems to be taken for granted essentially permanent? that thLngs are better now than they ever vlll be In the future. Regardless how much habitat loss has occurred on the ONF from In water quality sampling will there be long-term stations past management, we must be willing to accept more. While we are establlshed for determinatlon of baseline data for cumulative being conditioned to accept the liquidation of the remaining old effect analysis? HOW many streams will have thermographs? What growthpondeeosa pine, we apparently should be content to have are the state standards for water quality which will be followed? parklike retention stands nea~campsites. What procedure would be followed for determination of a deviation in water temperature or suspended aedzment? If there are Timber currently no Dasellne data forest-vzde or for Individual Streams, what standard values would be used in the znterlm? Will wafer The preferred dlternatzve (E-departure) call9 for an AS9 Of quality evaluations be made only In association with specific 123 MMBF In decade 1 declining to 118 MMBF in decade 2 and 89 logging pzo~ects? w~llevaluations also be made of grazing, MMBF Dy decade 5 (Plan, p.22). 69% of the harvest volume In the mining, and road DUIldlng compared with Control areas? flrst 2 decades would be ponderosa plne [Plan, pl). The volume of ponderosa pzne harvested in decade 1 wlll he 57 NMBF/yr and Cultural Resource8 could decline to 47 MMBF/yr by decade 3. The tlmber Industry has apparently convinced the ONF that it can survxve Only if it Monitoring to determine whether cultural resou~ce8are being releases the ma3orlty Of the remalnlng old growth ponderosa pine. protected and znventoried shows no plan for consultation with the After thls material 1s gone the Industry will be faced wlth lower Umatilla or Warm Springs Tribes. This should be corrected. A Volume harvest, small& diameter tlmD&, lower quality timber. point is definitely made ahout consulting ranchers regarding and lower value 8pecles. Satisfying the Short-term goals of whether forage utllizatlon Standards are being met. nil18 whlch may close a decade from nov when the prime timber 19 gone might lookgood on paper to those concerned with aeeting RPR goals or those who want to sidestep ~r~ti~xsmoftheindustrybut General Comments the forest's other resources inust absorb the brunt of thls kind of management. It seems unfair that under MUSY management that timber can he harvested at hlgh levels Or departurea but that Land AllOEatlOn non-valued outputs are assigned to MMR levels.

The DEIS (p.YlI) Statea the "alternative E-departure The ONF has sold an average Of 136.1 MMBF/YT for the last 20 emphasize4 a ~:~mOinatlonof timber productionr COadleSS year*. NOW that sone calculatlons have been made Of the LTSY Of recreation, and blg game habitat." Thls statement seems to be tlmber (19.3 mmcf or approx. 115 MMBF), It vas decxded that quite misleading. Only 48 Of the SdF 18 to remain in wilderness haCVe8t in excess of LTSY should continue for two more decades. at the end of the planning period and a total of less than 48 There is presently 280.5 MMBF of tlmber which was Sold hut 19 will remain in semi-primitive condition. Although 8% of the ONF uncut. There will be 5 MMBF of salvage LOgglng I" decade 1 and 1s classiftt4 64 oig game winter' range and 16%as summer range, if a catastrophic event occurs an additional 12 MMBF [Plan, p.59) these are*5 could lust as easily be called cattle grazltlg could be harvested aB salvage. Th18 bClngS the total potential allotments. The 2~st1fzCa.ion for removing Old-growth from harvest to 140 MMBF/yT I" decade 1 (green volume plus salvage). winter range 18 to ProduCS an optimal ratio of timbered to forage IC appears that in additlon to thlst total timber harveet Can be areas. Howeverr elk are managed at far below their potential SO wlthin + or -5% of the planned value (Plan, p.104). Why is the additional forage produced IS evidently destined for the harvest Of salvage tlmoec not counted toward satisfying the LTBY Cattle. volume? The amount of timber produced in a period Is irrespective of whether IC IS alive ox dead at the end Of the The Plan identifies the ma3or management decisions proposed period. (p.1). Alternative E-departure la the preferred alternative. The baS1C tOOC Of the plan 1s set by two ma~ordecisions. The Based on timber inventorie5 con.3ucted 1" 1973 and 1982 the first 18 to nnr.IPlt 123 MMBF of geeen timber during the next ONF timber base has declined 14% in thLS Short tine period (Plan, decade and the Second ie tO gradually increase grazing from p.32). If this trend continues how can future planned harvest 75,000 to 83,100 RUMS. other management derisiona seen voluaes be realrzed? What is the expected standing volume after incidental by compaclsan With these because the area9 involved Ilr~dcl~5? It also appears that ponderosa volumes have decliiliid are so small. 41111 hrC9U94 the time Erarnes for change to occur by 18% in tiiis same time period? Why have subalpine flc are 80 Indefinite, one might guess that the Statue quo would be Inventories declined by up to 338. It seems that the kind of acceptable. When guidelines call foe maintaming Peesent forestry practiced on the ONF may not qualify as site ConversiOn conditions "or" improving trends and there is no clearly but Could De termed total forest canverslon. Radlcal changes in tdentified baseline CDndltlon, one would never know if foreat species composition should not be tolerated any more than

26 27

1-4-115 site convecsion. fish production over the years, it might reconsider whether maintaining Or increasing the grazing program made sense. The R point is always made about how the decadent stands need to ONF plans to spend only $80,000 of KV funds in 1988 on "fish and be removed because OL their low growth rates. Why, then, does wildlife" pro]ecte. HOW much does it expect BPA to spend? What the mature ponderosa pine have a net growth rate Of 23.6 CF/acre fraction of these funds are destined for fish enhancement? Are end the two-StOCy and Immature stands have lower net growth rates wildlife enhancement funds basically range enhancement funds? (Plan. p.31)7 Over-obligation of range reso~rces,over-allocation of water Old growth forest will be represented by 26.377 acres of old Lcom streams and groundwater supplies, and aver-harvesting of growth management and 23,500 acres in wildecness. The total old-gronth and favorite tree species has been a way of life for available old growth on the ONF 1s 80,000 acres (Plan, p.24). the John Day and DeechuteB Rlver Baszns for a Century. Lumber This should mean that 38,123 acres will be placed Into the timber mllla in the vicinity Of the ONF have never operated to capaoity base. Compare With the Plan On p.28 where only 22,300 acres was but supposedly it 1s the responsibility Of the ONF to meet their available to the timber base. If old growth ~n the timber base demands. Maybe they overbuilt for the available resources. had bee0 Cut on a 300 year rOtatIOn previously, why has this been OverconBumption and waste Of water out-of-stream anger8 iunlor reduced to 203 yeacs? Considering the minute amount of old Water users and affects senior u8ers in drought years. Provision growth remaining and the importance to the eCOSyStemS in the ONF of adequate water of high qualrty (low temperature, nutrients, of safeguarding genetic and species diversity, why should the 22 and sediment) 18 essential in maintaining healthy fisheries. The to 30 M acre8 Of old growth be harvested on such a Short rotation ONF must do it8 lab to enSUCe the rebulldlng Of this reaourCe. echedule. Very little time is allowed for old growth Supposedlyr allotments have been fully occupied for years and the chataCterist1Cs to become established before harvest. survival of ranchrng operations depends on using forage on the ONF (DEIS-84). If allotments are already filled to capacity, the Grazing demand is increasing for more, and range conditions ace poor to fair On 70% Of the ONF. then perhaps a reduction and not an Grazing Wlll be increased by 11% in the fzrst decade (Plan, increase would be appropriate If the Forest really hopes to meet p.22). Of the 19,000 acres Of Clparian area On the ONF, 12,300 the needs of Other resources. The "demands" of the timber and acres are Slated foC tmpcovenent. on almost all allotments there grazing interests are described as ever-increasing. The Plan appears to ne little room for increase in RUMS. Most allotments does not address the Forest's obligatzon to the tribes for are stocked to capacity. Why are there so inany allotinents having restoration of fish and wildlife T~SOUCE~Sand aufficient water obligated AUMS exceeding carrylng capacity? For example, Wind of high quality to sustain these resources. If the "demand' IS Creek, Wolf Creek, Allen Creek, Silver Creek, Buck Mountain, not apparent, the oblrgatlon of the Forest Service to do much Lower Nlc011. Wl11 grazing be reduced on these allotments? HOW more than lust maintain a presently degraded fish and wildlife is carrying capacity calculated7 Ia this capacity the maximum resource should be. Treaty obligations must be treated as hard capacity assuming the range is restored to healthy condition? conetraintk and not discretionary items. Are the Obligated RUMS the sum of RUMS for Cattle and wildlife or Only cattle' IS the use Of forage by wildlife Other than deer Fish and Wildlife and elk considered? Increasing the total obligated AUMa so that it equals the estimate7 tot.+l cdrcyfi3y capacity would be a 3.8% The budget for fish and wildlife 1s planned to go from increase (Plan, Rppendlx F-5). HOW is an 11 % increase $102,000 in 1985 to $288,000 in 1988. If the need is identified calculated3 for this amount Of money to protect the fish and wildlife resource and funds are cut eventually, will all expendrtures DO Tho total ?*age budget for 1985, including range protection cut equally or will fish and wildlife nimpl: be funded at and manalJ,nent and range Improvement was $309,000. The range historic leyele7 Is the ONF Committed to make funding for the receipts for th1s year were $50,400. The amount spent to nece88ary fish and wildlife programs as 90116 as roading and administer the range gcogcam was 6 times the receipts at a range administration has always been? minimum. The co9t8 tr) Lib -~~v~ronm%t10 lost production of fish and wildlife, soil erosion and compaction, vegetation loss, and SO118 reduction in tree production are tradeoLL4 which are not a~co~nteilfoc when ~val~atingthe wisdom of Such extensive Under the Plan, 156,600 acres Will be logged between 1986 programs, let alone increasing the RUMS. The minimization of the and 1995, 80% of this by tractoc harvest and 20% by skyline. importance of the ONF fishery resource in the Plan is covered Tractor Skidding and machine piling will result in 25,000 acres below. The Forest Service is lucky that the BPR has invested 111 Of compacted soil (Plan, p.26). This would reeult in 16% of the stream enhancement but if the Forest Service itmlf 11.39 tu pro]ect acres being compacted. The maximum compaction allowable mitigate the losses in fish habitat Caused by It9 grazing, is 20% (plan, p.55). ow ever, if compaction by tractor yarding roading, and forestry programs and repay the cumulative losses in With haul road8 is 33% and cable yarding with haul eoade is 18%

28 29 total (DEIS, p.1151, the weighted average or 808 tractor/20% skyline Is 308 compaction. If cornpactron of haul road* is numerous 2" long steelhead may not indicate good habitat eliminated, assuming that naul roads will become permanent 1o~ses conditions. Condition$ leading co successful smoltlng and to the forest base, then weighted average compaction of future outmigration are essential if the oNF IS to meet its production forest base 90115 would be 238. This means that 3fi,000 acres goals. HOW well is this index correlated With smolt Output, not just spawning and emergence SUEE~SS~ will 0- L *Wp~~~t-drather that 25,000 forest wide and the effect on slopes less than 30 degrees will be much greater than average. HOW can COmpaCtlOn De liinlted to 20% In an actlvity area when A present habitat capability index for rainbow trout tractor yarding with haul roads can cauee 33% soil compaction? (rneluding steelhead) is 148. ~lternatlveE-departure is reported to be able to raise thls to 58% (DEIS, p.108). TotaL existing soil compaction amounts to 102,000 acres. Elsewhere, it is reported that E-departure VI11 increase the Sased On 495,395 acres of land suitable for timber production, index to 438 (DEIS, p.137). Why IS there thls discrepancy? this amounts to 218 of the forest base already being compacted. Minimum Viable populations arc listed as being supportable by a What 18 the rate of reversal of this effect7 Hoe are the 9% habitat CapabLlity. If one can De comforted by calculations cumulatzve effects of compaction being dealt with7 If a minimum Such as this, we Shonld be grateful for 1.6 times minimum viable Of 25,000 acres are belng Compacted each decade, the total acres levels presently. compacted after decade 1 wlll Oe 127,000 (DEIS, p117). Table TV- determine how the ONF Plan coordinated 11 Shows a conatant level of total existing compaction from In an attempt to 1s decade to decade m alternative E-departura. The implication is with Other public planning efforts under 36 CFR 219.7, the Warm that only IC) years are required to revere= Lhe effects of each Spcings Indian Reservation Conprehenslue Plan was studied LDEIS, decade's compaction, but that the present level Of compaction p.172). It waa found to contain "no references to the Forest or lasts thTOUghOUt the next 5 decades. the Grassland." "Concerns expressed included availabrlrty of access to the Forest and Grasslands, being able LO gather CalCUldtIOn Of ton8 of Sediment produced among alternatives vegetative materials, support Of prescribed burning, protection seems tn 0,. 3nly logging related (DEIS, p.117). What are the of archaeolological sites, end the general availability of forest effects of different amounts of road building, cattle grazing, and Grassland resources." The ONF appears to be taking a and mining? Tract"< yardlng with haul roads can result 1" 47% management plan developed for use on the Reservatxon, which is bare soil. This !effect seems to be accounted for in sediment Outside the boundaries Of the Forest, as an indication Of the calculations: however, the 108s in vegetation FOYeC and root full range of constraints the Tribe might place on management Of the Forest. Although there Were meetings between the ONF staff stcength ~4~l.ird"y grazing le not included. Why7 The methodology for calculations of sediment production and delivery and representatlvea Of the Tribe, we wonder whether most Of theae to stream channels should be made very clear, including the meetings were confined to the CnltUre and Aerltage Committee as formulas and references. most Of the acknowledged tlllbal concerns focuaed On these features. It Should not be Construed that a lack of reference to Fisheries anddromous fish 00 the ONF in the Reservation Comprehensive Plan lneans a lack oE ooncern for this resource or indicates no need to A fish haJitat capability index was developnil by sampling Consult the Trlbe on fisheries issue8 On the ONF. Although the various streams 0'1 the 3U7 ranging in condition from poor to ONF is Outside Reservation boundaries, it is clearly Yithin the tclbal ceded If the ONF to meet wlth the Tribe t0 excellent. It would spell" that II~~~RSa complete inventory 1s area. were accomplished that it would 0.3 drffrcirlt to know the mean state Of discuss flsh and wildlxfe issues, there 1s no doubt that the Stceams with any CectiLt1Lf. iWat CharaCteriStiCS were measured issues addressed within these forest plan Comments would also be in samples of stream condiLion7 Was the blolOgiCa1 potential of amona the areas of concern discussed at that meetins. As the stCe.mS evaluated with respect to physical potentials? It expliined earlier, the Warm Sprlnga Trlber along with the other has been COininOli for many Forests to determine a habitat index Columbia River treaty tribes, have taken a Columbia basin-wlde based on a deqraded channel Or rlpaclan structure aS a standard. approach towards managing fisherLea. This kind of anilysrs would possibly calculate the fish potential gzven a Chann"1 tfge with broken down banks and a low percentage The DeachuteS and John Day Rivers have 42 miles of spawning pools. Iithout a means Of determining what the stream used to be area and a total of 87 miles Of perennial tTibUtarieS on the ONF (Plan, Appendzx M3). Although plans presented for rlparian there is 110 way to determine how far the peeeent condition 18 are from it8 potential (see our Appendix on monitoring plans). zones on anadromous fish streams, it is unclear how the intermittent and ephemeral streams that are tributary to these A habitat index of 41 to 68 is supposed to represent good anadromous fish drainages wlll be treated. These types Of stream EonditLonS. This index shoul,l coe aSsOCLdted wlth 1000 to 3000 2" coursee are important sources of high quality water for to 9"t fish per nlle (DEIS, p.108). SlnCe Steelhead Juvenlle8 downstream reaches and also serve as sites of temporary sediment spend two years in freshwater habitats, the mere presence of and organic matter storage. During high flov periods this accumulated material is transported downstream to spawning and

30 31

1-4-117 rearing areas and can be deposited. The Plan should reveal what maintaining in a viable condition, is not being wantonly the treatment of the Stream source areas is. Can unrestricted destroyed e 1sewhere? loyging and aCCYmYlation Of logging debris Occur in these source areas? what Irvel of grazing control 1s applied to these areas Snag Management in comparison to the perennial waterways designated as spawning areas? Pileated wOOdpeCkers are reported to presently en]oy 55% Of their habitat potential forest-wide (Plan, p.15). Oespite the OUT TeV1-d ~7fPl.%l &ape"3lX 142 (InVentOry of Anadromous liquidation of the maiority of the remaining Old-growth, they are Flsherles HablLltI yrves us cdUBe for concern about both the expected to have a habltat capabllity Index Of 51 by year 2030 quality cof sldta used to generate potentxal ,n.tnatg~nc=t,t o.,t~ons (DEIS, p.137). b.lthough ONF planners can rasrly multiply 0.5 and the resulting options themselves. iiillle the appendix appears or 1.0 snags/acee by a standard woodpecker density for excellent to accuratrly 1 L~Estream systems supporting anadromous species, hableat, the formula does not necessarlly obey ecologrcal data delineating extent of frsh-use within those systems are principles. snags in the middle of young regenerating stands or frequently suspect. conversations wlth ODFW staff lead "4 to clearcuts do not necessarlly have the sane value to vildlZfa as qUestlon how 3ChOCO XF derived mileages Of steelhead spawning the same density of Snag5 in peietine habrtat. FlgureB such a4 habitat and adult Steelhead escapement numbeP8 clted rn the 55% habitat capability probably are very deceptive when epplled appendix. Spawning habitdt mileages appear understated (or are, forest-wide. Although it is admitted that 10 inch Snags are at best, mlnimumsl as are the nUnOers of spawners indicated as Inadequate for the pileated woodpecker, these would be the rule typically using the areas. On some Of the listed creeks, ODFW'S foe management area 1 (General Forest) Where trees Wlll be spawner roder are38 atop short of the Ochoco NF oorder. On at harvested at 80 to 90 years age. Althou,Jh recommaended Snag least one stream (Rock Creek) ODFW ConduCtS "0 annual spawner levels here are reported a3 40%r they are effectively 0% for surveys. What, then, was the source Of OChOCO's data' HOW were plleated woodpecker. The 40% level is a level at which the the adult escapement figures estimated? ability of a ~peclesto maintain self-sustaining pop~lations beCOmea tenuous (Thomas 1979, p.72). Rednclng snag levels does If appearances are correct and minimum steelhead value8 ace not necessarily produce linear decllnes ~n wlldliie levels and It being Used, CD-11 the end result 18 Chat tne forest's importance is dOUDtf"1 thee these kind8 Of ecological effects ace reflected as a steelhead producer 18 downplayed. The management by the seemingly precise percentages of potential haaltdt mplic*tions of th1s action am that, relative to steelhead, capability reported. other resource values are made to appear greater than they actually +re, thU9 it oecomes easier to lustify management SlnCe 58% of the ONF ulll be In the General Forest category choices favocimg those inflated values. 5uch deliberately having essentially no value for pileated woodpeckers, the forest- introduced biaSY5 thwart any meaningful asaesssent of total Wide capablllty for the pileated woodpecker 1s Certainly not 558 forest resource values and serve only to denigrate both forest now or in the future. Use Of the plleated woodpecker as a MIS planners and the plannlng process 10 general. OEhoCO National and then monitoring the Dumber of snags of 10 znch QBH IS a Forest 13 chac9-d with producing a forest plan that adequately ridiculous RXOLIC~SB in meeting goal8 on paper. Reporting and fairly presents management options available to it given erroneous habitat capabllltles 1s merely an attempt to make the its actual resource base. SO long as that CRSOU~EB base is publrc believe that we can keep all our flsh and wildlife while inaccurately p,>?V?eyed, and particularly so If the misportrayal still increasing timuer and grazlng programs. is knowingly made, the planning documents will be fatally flawed and beggrncj for appeal. A more realistie assessment of the It seems dOUbt.fU1 that wlth the complete COadLng of the ONF, forest's enaaCoinmis fish re~ources(as well as other t14h and the practice Of SUminarIly dispatching all snags durlng logging, WildlLfe spaciea) LS needed 1" the Plan. and the demand for firemod, that the ONF's policy of green dot systems to limit access to parts of the forest will prevent snags Further, to DP Useful any habitat Inventory must recognize and dowh wood from being pulled from wildlife habitat, riparian the species' hdbltat needs at each of Its life stages. Steelhead Corridors, and stream channels. Although all standards for snags require more than 3USt spawning habitat. Where LS the inventory relate to hard snags, maintenance of soft snags 18 not sprclfred. of 3uvenlle rearing habitat? Where are the references to Will recruitment and preservation Of soft snags be assured Juvenlle and adult mlgratlon corCldor'B? What 1s being done to Outside of wilderness? Permanent closure of many areas must De assure that these Important areas ace maintained? P~OYIALII~JEo? aCCOmpllshed to provide BeCUCltY areas for Wildlife and safeguard less then d species' total habitat needs is a futile gesture. impoverished streams. A good inventory la needed of the distrlbutiqn, species COmpOSitiOn, size frequency, and Condition Fin.lly, xf it should be found that mapr rearing areas or =lase of snags existing on all managemenc units to establish B migration routes foc ochoco-produced Steelhead do 1~eautside the baseline for accurate estlmdte OE present potential. ThlS should forest's boundaries, what efforts 1s the Forest making tO help be related to actual estimates Of pop~llatlon denelties Of insure that th19 T*~OII'-CF, which it is legally charged with dependent wildlife. Such LnventOTIes ace needed for all

32 33 resources, not Iust green timber volumes. of compacted soils is used?

CumUlative Effects On Solla Timber

The F3cest was divided into 24 map= watersheds and each was Stumpage prices received for Old growth ponderosa pine r1541gOef rlbter quallty" (DEIS, p.133). The Plan should clearly list all the c~efficlentsof mitigation efforts which Of the 544,303 acres of forested land on the ON? Outside of would be used. The idea that threshold values are set up and wilderness and RNAs, only 0.47% is classlfled as unsuitable due that they can then De exceeded if something p08itive is done to regeneration dlfflculty. Is it reasonable in an arid somewhere else In the basin 1s unacceptable. Mitlgation factore environment that 80 little area 1s classified a8 having ace Some of tn* ,nOJt tenuous management tools the ONF is dealing regeneration difficulty? what olasses of sol1 and slope gradient with. These coefficients work well in FORPLAN runs when a are considered as unsuitable because of regeneration problems? Coefficient IS called for to complete the analysis or to balance What are the stocking SUCEBSS records which accompany these site high sedlinrnt so~tputsOn activity areas. The validity of Classes? mitigation factors l* "cry Slte--SpeEIfIC. Unless e*te"siYe monitoring accompanies a large share of the mitigation efEorts, If you would like further information eegardlny our mitigation ra apt to be pcimarily an office excercise with no Interpretations Of OChoCO National Forest plans, please feel free CDnneCtiOn to reality. The ONF does admit that "after the fact' to Contact any Of 0°C staff, Jlm Weber (pollcy asslstent), Dale mitigation is often not as effectxve as preventing degradation 0" McCulloUgh (biologist)r or Alex Helndl (biologist), at (5031-238- a aite in the EicSt pl%ce (DEIS, p.134). Despite this admission 0667. there appeare to be little hesitation to apply mitigation while exceeding thresholda. If thresholds Of slope =~tabilrty ace exceeded, leading to exc~ssiv~loss of topsoil, the sediment might be deposited in settling basins but ~t 18 not cleat how this can Count+raCt the loss in soil productivity on the slope.

HOW many factors are really considered when calculating ECA S. Timothy Wapato values. Doe3 It LnClUde all management related effort8 such as Executive Dlr'eotor lagging, road burlding, grazing, and mining?

SOL1 compaction from harvesting may mean "that a future stand to bp r+ganerated rn 100 years may need more tlme to achieve the outputs normally prolected for 100 years" (DEIS, p.120). Soil ~ompactl~nis "readily measurable 16 years after cuttlng" (DEIS, p.120). It was Shown that reductions 05 tree growth cdi- 'y 12% over a 16 year period are possible from soil co8opaction. Establishment of new tree seedlings could be even in~ceeoverely affected. Since it appears to be well accepted that 8011 coinpaction is a reality and that reduction in growth rate ia to be expected, what average percentage reduction in growth is used ~n FORPLAA runs and what natural rate of recovery

34 35

1-4-119 APPEUOIX

A good monitoring plan requires a good system of classif~cat~onof land. Such a classification should be hlera

36 37 Defmitlon of terms used to thls point: though they have the same dralnage area and flsh species. POT example, they may have different rock types, Climates, hydrologic Capacity: ThrOeetical term for a potential of any system; this characteristics, etc. represents all performances of which the system is capable. Definitions to emphasize: Performance: Any State of a system -- this 1s an observed event Such a8 a current ~elocityat a point in time, a certain species System: A land system Of any 8iPe which Can be defined by its COmpsition I" a rrpar1an *one, etc. unique capaciw.

Systems should be defined by capacity because if Environment: The hlgher level system Which subsumes the performances are used the basis for applylng a glven management collection of lover level systems within ita geographic bounds. Stcdteigy 1.1 t.,O aystems may be superficial similarity. Any tW0 The environment is a single gk?OrJ?aphlc unlt and not a Collection systems may look alike at some point in time but this does not of disCOntinoUS spatial Units. Environment IS the framework in mean that thelc capac~tzes(long-term potentials) are equal. FOT WhlCh any System evolves biologically and 90010a1~allv. It is example, two stredm6 (nay have fish Communities dominated at not 3ust clmate but the entire-set of- capacity d;termliant< ~n peesent by steelhead. For one of these streams, steelhead may be environment for a given system IS 2ust a system in Its own right the species best adapted to all statee Of the watershed system In but at the next higher level. which the stream is embedded. Foc the other stream, Steelhead may be found Under 3 limitsd set Of Watershed states. LikewLse, What are the components Of CapaClty which must be the mere lack Of flsh in any stream at present does not Indicate represented oy sets of variables? These call be Categorized as l3ck of Capacity to support fish. In fact, the strealm may IhPVe Climate, substrate, biotal water, and culture. Substrate may had great frsh production potentla1 which was altered by POOC also be decomposed into geology, soils, an4 topography. Some logging p~actices. poor management on top of thia may assure varlables Such a8 Climate may be easlly understood in broad that fish never retorn if the stream is clasaif~edas a "on-flsh geographic terms but data for Specific locations are rarely stream. A good 518?5iflcation system should recognize long-term available. Cultire represents land use decisions; Such decialons potentia1s and not TUS~present state. The diffecence between are Often dependent on Cllmatlcr Vegetational, geological, and two Systems may be Shown diagrammatically below. The zone of other zonations, especially in pFimltiYe cultures. ovecl.rg C~~CLI~~Q~Spoints in tlme for which the systems had similar perfocmances. x and Y axes represent two performances of Examples of variables representing each of these components a stream such as mean annual width and depth. Of Capaclty are glven In Table 1. MOSt of the variables can represent mystems at any level In the hierarchy; the degree Of generality becomes greater at higher levels.

Robert Bailey (USFS, Ft. Collins) has classified the entire United States into eco-reglons. This systems emphasizes potential natural vegetation, Koeppen's climatlc classification, and phyrriographlc regionalization. fhl8 SyStsm does nor utilize the fU1i set Of varlables illustrated above. For example, culture or detailed descriptions of topogeaphy are not employed. At the scale at whjch eco-regions are drawn, the simplicity Of deleting some vaclables may be COnven'lent Considering the fact that the remaining deteCminantS Of ClaSSificatron are broad mnkfvll depth capacity-type concepts. HL~C.+?C>LC.+I lrnd Systems could be given labels such aa region, 'One, sub-zone, watershed system, watershed, stream Robert Hughes, James Omernik, and MOstafa Shicari at USEPA netvr)c<, stream segment, reach, and habitat type. Each land in Cocvallia, Oregon have developed a system of land system sUbsllmne-i tila cipacitres and performances of all systems ClassifiCatlon Which Starts from Barley's ec0-regions. The within it. he class of any system (1.e. at any level in the heterogeneity Of eco-regions is then described in a hierarchy) ls defined by the Capdclty uf the system itself and regionalization which identlfles frequency distributions of the environlrnt it 14 found in. The environment of a system is facets of land units using features such as potential vegetation the next higher hierarchical level. That is, a strear network and soil txpee. systzn in,, 1 4,C-rshed aa its environment. A watershed ha8 a sy4tern of ~atershedsas its environment. TWO watersheds The type of classification emphasized in this document was classified by hlerarhrcal ~laS8iflcati0tlwould be said tO be initzated by Charles War<-" in Oregon State University Department fundamentally different ~f found In two different zone8 even of Fisheries and Wildlife. Warren's claes1fiCation contains all

38 39

1-4-121 components Of a complete classification by capacity. Fcissell et full set of capacity determinants oan be referred to if a more al. (1986) present ideas on stream classification at the lower complete zonal classification IS indrcated. Classification of levels in the hierarchy Sasccibed above based On Warren's watersheds within these zones could Utllile all variables concepts. specified above. ElcCul lo4gh (Columbia River Inter-Tribal Fish Commission) By using the previously mentioned systems to regionalize the used Wacceo's theoretical concepts of system classlflcation but forest and to find stream reaches of a given class, sampling started wlth Balley'8 em-regions. Identification Of watershed sites are obtained. Within a ceach (i.e. a stretch of atream types (prr-c:lasslfied by drainage area and downstteam Slope1 Was wlthin a stream segment having a hoinogeneous overall bed slope done within eco-regions by utilizing mil series, slope, aspect, and geology which contains Series of habitat complexes) samples altitude, and solar eadration (calculated for winter solstice and for monitoring will be taken to represent a portion of the equinox). These variables were determined for a11 facets Of capacity Of the reach, the watershed. zone, and region in 0.014 in12 31ze from a regular grid laid over each watershed. A11 relation to present State and history of management in this VariaDles except Boil Series "ern determined based On altitudea hierarchical framework. Flsh sampl ~ng,foe example, can take read from the 4cid system into computer programs which calculated place by logical habitat clusters. These are repeating units characteristiis oi land faceti. Miltivariate atatistical containing riffle*, pools, backwatere, side channels, etc. prograins determined similarities between watersheds using the Riffles and pools act 88 unit8 fQr sprclea which can move detailed descriDtions of all facets comorlslno the watersheds. SYffiCiently between them such as flsh. The apatial organizatioI1 These simi1ariti;s were displayed in multivariat; space, allowing a€ these habitat types can form logical sampling units for €131,. clustering of baslns an the basis Of many variables at a time. sample sites would not be simply a randomly chosen lOOm reach but This procedure doe8 not require predetermination of priority of would be selected to include a habitat cluster. Replicates of any variable although only vaclables considered to represent these kinds of clusters could be sampled. Capacity were used. ThlS type of system for classification on any scale is uS'fU1 and efficient given the ready availability Of The stream reach 1s c,lassified by the class of network in digital topographic map data from USGS. More information about which it 1s embedded plm the capacity of the reach. The reach applicability Of computer classification Of land systems can be Capacity (C) should be used in its classification. Proxy obtained from Dale 1rCnllough at the Columbia River Inter-Tribal variables ere given below. Reach performance (P) SnOuld be Fish Comml4sion. establzshed as a baseline and then periodically monitored. Classification of all watersheds nUSt StaTt rrth aelaction Reach classification of a given sdc~i?*j>~r+a. With every change in drainage area proceding downstream, the charactee Of the watershed changes. (AI u~~erbank condition (above mean annual peak flow line A~SO, the 3verage stream bed slupe change3 downstream. Drainage iutwari'horizontall~100 it) area and map-derrved 4trsrn slope for the half mile upstream from C: 'slope gradient: slope form the basin ciiomxth set the framework foc farther attempts to bedrock classify watersheds. Theee variables set the bounds for system SO11 type capacity. Change in bas>" capacity with change in drainage area ie reflected in the "river continuum" conc-pt of Vannote et al. (1980). Management principles vary likewise On a continuum down a drainage swt*?rk (1.e. longitudinally). It must also be tecognized that management should vary from region to region, zone to zone, etc. (or laterally). A Ela8SifzCatLOn system sets (81 lower bank condition (from mean annual peak flaw line to up a regronaliaatron on theory and experience. Future channel edge) experimentation and monitoring help confirm the utility Of the C: bedrock type cla~~ifl~ati~nand suggest possible change% This framework P: substrate type and Size composition a9tablishes logical tlnlts for management. Experience will % bedrock exposed dictate whether ade?iliCP mdnaJBment Of a ~>dtloilalforest Can 4 Of OYertianging banks by hnbztst type occilc using a given hierarchrcal level or a lower one. (c) stream Given any national forest, classification systems such as C: aedrock type Bailey's. Mcc~llo~gh'sand Friasell's in sequence could be mapped gradient of stseam bed over 0.5 OT 1.0 mile employed to work down through large to small spatial systems. A P: substrate type: SLZ~composition national foreLit shoul 1 be ilcoken down into eco-region and at % bed fines by depth least to zone8 at the next lower level. At its simplest level % enbeddedness (in riffles, Pools) geology could be used to identify zones in an eco-region. The % bedrock exposed by habitaC

40 41 % surface area and Volume of reach in habltat types Watershed classification (see Bisson's habitat cla9rLfication) depth distribution by habitat C: watershed 19 ClaSsified by class of watershed system, mean helyht of boulder eize classes above bed zone, regran, etc. in which it Is embedded discharge--flox frequency distribution; Dear flows drainage area Selliinent discharge in Ceiation to water discharge gradient of Btream bed in downstream 0.5 to 1.0 mile .later chemistry a180 see explanation above of additional variables used %Of overall drop in bed elevation over 0.5 miles due In description Of capacity of watershed to falls over bedrock, logs, Chutes, cascades, riffles P: aerial photographic analysis (1:12000) of VegetatlOn Covet density, height, specles (D) DiolDYY Use timber stand types, stocking density available ~n C: SPeCt-4 DO01 (fleh, invertebrates, algae, aquatic mapped suzveys macrophytes, beavers, OtrlFC aquatic vertebrates) aerial photo analysis of 8 bare ground; degree of P: Iuvenile fish counts eros~on hazard from watershed; evidence of mass smnult counts plus spawning ground surveys farlure hazard and historical failures Invertebrate species colnposltlo" fish species compo5ltion

(E) morphology, StrUCtUCe c: Sl""OSltV prOXtolt> to reachee in network Of different stream ocdec A good classifLCation system 18 the proper basis for a good potential solar radratmn analysis of reach monitoring plan. A good classlficatlon system which is aCCOUnting for topographic shading progressively validaced and refined with experience will be a P: calculation of solar radiation accounting for good framework for future monitoring and land management as Shading by riparian zone system performances change through the years. Such a framework provides the means for effective management at minimal costs. Stream network ClaaSiflCation Other types of monitoring scheme8 could reduce costs even mora but at a loss of understanding of the systems and a lose of C: class of watershed predictive ability. network structure potential solar cadiation analysis of network Use Of a classification system would allow a cost savings accounting foc topographic shading through its broad geographic scope. That is, some watersheds or aerial photographic analysis of distribution of map= streams in one natronal forest could represent behavior of a pools class of system found predominantly in an ad3oining national spatial analysis hy gravity model of distribution Of forest. Duplication in monitoring efforts IS then reduced. 8011 types In watershed relative to downstream study reach. This methodology is a framework for The type of general classrflcation system proposed also CYRllllRtlYe effects analysis lends itself to adoptran by many drfferent agencies with Interest P: calculation of solar radiation accounting for shading in environmental monitoring. For example, one primary capability by riparian zone determinant used in classrfication is geology. The mixture of aerlal~hoto,~raa,,lcan~ly~i~(l.l~000)of vegetation rock types Of a watershed set the general chemrcal regime for cover density, height, ~pecie~i surface and groundwater on the watershed. This 1s a partial degree Of damming of reaches in network by beaver detecminant of aquatic productivity, ~ens~tivityto acid rain, activity or log jams and to "Utrlent enrichment. Therefore, a Classrfrcation system aerial photographic analysis (1:2000) Of mainstem to iQ an appropriate framework for monitoring of acid rain by EPA, ~l~terminewhether reach ie representative Of selcies nutrient problems by a State Environmental Quality agency, and of reaches in mainstem; distribution of large wood management of Vatersheds and their resources by the USFS.

The CosQinations of rock types found in Watersheds above a given reach plus overall bed slope of the reach are determinants Of system capacity for aquatic macrophyte distribution. Scientific studies by aquatic botanists become more eignificant eColOgicellY by enabllnq linkage Of the Physical and bioloaioal

1-4-123 use a general classification system as a monitoring framework on a large regional bas18 would be considerably aided by geographic Physical computer analysis. These methods allow overlaying maps of many resources and prodUCtlOn of integrated maps. Such capabilities What is the average natural 8~'osioOrate from watersheds Of have been explored by many agencies Such as Forest Service, USGS, a given class? and EPA. What percentage over natural erosion rate is due to different degrees of management ~ilYdtecfihedS of a given claas? What are the rate8 of re~overyof atream reaches of Provision for Adequate Monitorinq different classes in terms of reduction in bed fines, depth dlrrtribution, 8 Surface area by habitat type, surface substrate size composition, mean channel width, riparian veyetation If a reg10naliZation or classification system were developed A~"s,C.r?"~-,. to adequately represent wateeshedlstream types, an ~mportant what is the effectiveness Of mitigation methods? benchmark for monitoring would be established. The Forest What is the relationship b*t#een iquantity of sediment Service'm point of origin in discussions of monitoring 1s what It delivered and increase In embeddedness Or flnee? ChOOaes to budget for monitoring and not what is adequate. It is What percent over natural erosion rates can be handled by our Position that we must first determine what is necessary for different classes of reach WlthOUt changing % bed fines? proper management of resources and then determine how this can be What 1s the extent Of downstream impact (e.9.. sediment, achieved. MODitOrlng funds should be linked to the receipts from temperature increase) to the mainstein fro*" a disturbance ma3Or land dlstueblng aCtlYitie8 -- timber, grazing and mining. originating at a given reach. Thxs type of study IS necessary to Unfortunately, grazing, Which is a ma~orcause of "on-point establish the appropriate scale for measurement of cululatlve source stream degradation, is a money-losing venture of the effects throughout a large basin? Forest SeT'YLEB which cannot provide funds from receipts for Use in Stream pCOt---tiOn and monltorlng. The US Government, if It considers It I" the ~nterestof the few ranchers to subsldlne Implementinq E Monltorlnq Plan grazing, should a180 consider the interests of other "sera of public rangeland who enpy stream and range in good condition. This neces~ltatesadequate funding for protection, In the development of a network Of monitoring Stations, rehabilitation, and monitoring. consideration must be given to the kinds of variables and intensity of sampling given to each station. Because some types Of monitoring are more labor Intensive, it may be better to do a -Some InveSti ationa which can be Facilitated good job sampling ~n a few carefully chosen stations than to -nltoring Framework dilute the effort by extensive sampllng without a real plan formulatdd. For elample, stream hydrograph Station9 are expensive to run and maintain. The USGS may or may not have A good monitorLoy ECamewOrk provides the basis for a refined adequate coverage to represent watershed classes. Usually their und*rstandinia of many biological and physical relationships of StatiOrlS do not Well represent amall drainages. Hydrographic importance to land managers. Amonq the auestlons which can be regimes can often be correlated to other Systems with similar explored are climate, geology, and soils. Most invertebrate sampling programs are labor intensive but provide a good biological index of year- Biologlc.+I round environmen@al Conditions not a18 clearly afforded bY migratory fish, whlch are BUb3BCt to downstream and OceanLC What 14 the carrying capacity of stream of different effects. Meaningful studies on anadromous fish can be performed classes and states within a class (zonal or sub-zonal level t but the best of these may require careful monitoring of redd study)? EOunt~associated with smolt Output. Smolt Output measurement What is the relatxonship between carrying capacity and =equireir investment in weirs. .mveoiie fish counte nay suffice stream flw and temperature regime (regional level Study)? for general monitoring on most streams. However, a certain What 14 the relationsnip of carrying capacity to extent of ateeamclass maybe represented by an index stream for which more watershed and riparian zone management (i.e. spatial organization intensive Studtes BUCh as Smolt Output can be done. Such streams of timber stand history and erosion sources in relation to the may be those important in the US/Canada Pacific Salmon Treaty downstream study reach)? negotiations because of the Opportunity to track pr'oduction of What IS the threShOlrl a€ hLOl0giCal response for €ry significant anadromous atockS and their contribution to ocean emergence from gravel in relation to percentage of bed fines? fisheries.

Some Of the monitoring variables Can be handled by

44 45 experienced crews of two to four covering extensive reaches on ~umerousStreams per summer. Fred Everest and James Sedell (USFS Forest Science Lab, Corvallis, OR) have had stream survey crews covering physrcal and brologlcal paranetere On numerous streams for years. MCCUllOUgh (CRITFC) also ha8 eXtenSlve experience measuring physical characteriatlcs of long stream reaches in Northwest Oregon. There are a lot of advantages in having some degree of monitoring on a large percentage of streams. This would enable confirmation of trl’i utility of the classifzfatlon and would provide an extensive basellne from which to assess further change. Adequate monitoring ala0 requires long-term sampling of Streams which ace key indrcatore because Of thelr fish stocks Or representative blo-physical condltmns. Both intensive and extensive monitoring should be based on a good watershed/stream classification and an Inter-agency monitoring Committee should be established to guide planning and review Of monltocing in the NO= thwest .

1-4-125 Response to Public Comment

Section 5 Newspaper Articles Chronicling Publication of the Draft Documents and Supplement to the DElS 1-5-1 ~ Forest Service prepares 15-year resource plan

A pdelo the managemolt Of mens " MI- m the OchOEo NB- The Oehoro National Fomt

k managemeni for up to 150 yean. The daumenlr under review (SR FOREST. pge 31 Federal Register Notice p. 32533 9/12/86 Vol. 51 NO.177

National Forest and Crooked River National Grassland. Land and Resource Management Plan. Due: December 20,1988. Contact: David 3choco forest plan I Senators' vote I Dpen for comments on forest funds 5l.phonI. Manson Crook. Jefferson, llrrncy and Dcs~ "ll.fl" Std writ., chutes rouoty lihrarrer. PRlNEVlLLE - A proposed The puhbr may comment (on Ind mansement pian for the the propod plsn and anvironmen. mchoco National Forest would in- tal impact slatemint until Dee. 20. causes ripples ,em the timber harvest slightly After that date comment3 wlli he ver the next lo years. improve analyzed and a fial plan drrvn up By S1ephmi. Mwim money to reach lands reieased for 9,000 acres along streams and A series of open howss to ~"11"'" SI.H wri,., multaple "Sell fouomng resoluLio" rovide 13,000 cords of lirewmd answer quetims about the pian as I A Soate vote Tuesday to in. of the 1984 Oregon Wlldemess Hili mually. scheduled to heen m mid-October. &ea* the Forest Service's road- the spokeowoman said. The rap04 plan plots the with the firat meetme set from 4 lo tiailding bvdget b 168 million next The Forest Service i3 ''not Ync(lmfort8ble'' with an inerearni ilue o? the 947.567.aeie forest 7 p m. Ott. 14 in the Rineville Fire Xear a nymy of vC the oext 10 years and looks llall. CtiVity m Central Olego" fOreSl$. road bud et, said Chad Olsen, staff 50 years into the future. It con. An Oct. 15 meid% IS irhcd Despite the vote, agency ofti- director for pro m development Sm.l I1 altematiws. one of uhjrh "led from 4 ta 7 p.m in the &Is say there are no immediate and budget for tK Forest Sen,xe's I preferred h the Forest Sernce commons room at Oiiiidivn Junior plans to hwld roads 00 roadless Region 6 office in Portland. Joe Me& puhk affain offi~ High khooi in Redmond. and a msin the Dellchutes and Ochoco Olsen said there are areas on or for the Ochao forest. sald the mwuag duhg the same hours w11 dational forests. =me national forest8 where more ,Ian is only a oromsal and the be held at Msdias Hwh School (lrf. roads are needed. 30. However. Larry Mullen. plan. An open home also rdhe hrid mff officer with the UCS from 6:30 to 730 m Nov 19 at , Lswson LeCate. vice chairman chutes National Forest. nud his tatement. the Pan Ma" Cd Pruhna A of the Oregon chapter of the Sierra office haa no plans toenter roadlei, "In no way is that work cast in discunrian for those holding per- Club. is ~ritiehngB provisim that area8 for the next 6ve years, eiccpt tone." Mead. $aid mits to grave catlk m lhe ioresf would prohibit the puhbc hom perhaps for geothermal e~plora Highlights of the Forest Sew- d follow. filing appeals M timber des tioo. ce's preferred alternaflve include: Earl Laper. llchoco forrst bought hack vnder B federal buyout Jm Meade. public affars nffi -An ioemue in annual timber planning staff offirrr. sad forest @an last year and scheduled to be COT for the Ochcco National Forest. isles from 124 million la 133 officials will also br aunilni~le LO rpaold m upcoming years. donboard feet. About 123 md- give prewtations 00 the plan lo ."A lot of thmgr have happened ion board feet wovid inelude peen groupsin the mea. since those sales were made." said 'mu-logs. 71 pereeot of which .Sfe said people readmq fhr plliii LeOau. of Rend. "It exem ts all of Under B pmpmed maneeemen' would be ponderosa pme. should use the revsewer E ywdr, those buyback tibor &P,,from plan for the forest. about 121 mh The remauliog timber to be rhlch 'mihe. where specific Infni~ any klnd of review." of roads would bo built into road $old would include logs in the mslion can be found ~n the dixu The Senate voted 53 to 42 less area9 in the next 50 years iorest s+MdS Salvage pr0gGam merits. Tuesday to increase the Porest Meade said md kewmd. For more information or ti Service's road.building budget Whde local officials may havr arrange a presentation on the pm from the $178 millioo requested by no plans to build in10 roadies, plan. call XLpade or f.ayw P the agency fo a246 million and to are-. ktiafp sad nuch dec8rwn. 147-6247. incrps* next ear's timber des are pabl,cal md if Congress order. valrms to 11 2 hmhoard feet. the Forest Service fa build the vlglfish itrams. The vote foUored me last uwk roads. they wIJbo budt. -Enough land ta upp purl 2, If people want lo pee changer 360 elk m the first decade By the in thc bud@ kcale nard. ihev 6fth decade of the pian the nuinher wdi hare to prosuie Cangres~ would decrssre to 2.550 berruse of LeGale srgued that not ailcIv thetimber propam. in the pubbc to appeal t1mhi.r -The roleclion of 26.350 ,%a scheduled to bo redd "vir- am3 of ol!gowth forest not ~n lskr the notion thst there Iforwt~8 a0demer.i areas are ubbc re~o~rce~.'' Plesaid rimborcompmrs yvt (1 second chance to buy the des, ihut the public will no1 get B chanu, k object. Matp alra objeed to anoth~ ei provision af the hili dmrlmg time Fmst Service to manage nationd fore$ta under current plans pending

I J

1-5-3 Debate on Ochoca plan heats up By Sbphmnl. Mont~n from 4 lo 7 pm. Tuesday m ths Bull.lI" Sldl Will., Pnnevllle Fm Hall, 5W N Belk. . PRINEVILLE 1 A wmod nm Sl Another omhouse has

"Wi are conmmez about the 01 managng the forest aver lhhe departwe mpeet." and Job Mor iert 10 to 15 emOne 01 them 1s BM, logglng manager et Ochwa nnfened by Forest Service Lumber Co m Prmeville Uepar The propod plan outline^ how lure 18 the practice of cutting more loiesl aflicrals would mplement timber mually thm the number of the preferred allernalive . hoard feel that cm he m(yn ha& The OIM. which 29 sider lo

leased the plan and eecompanymg The totJdowsble sale quanth draft enwanmental mpael state ty would decrease to 69 on men1 a month ago. gwmg the, boerdfeetaller60years pubhc untd Dee 20 to "men1 on If the Foreal Service imple lhhseonlents merits ,la preferred altem*twe B Ochwo forest officials wiU be &OD m the sale (IUM~L~Yover time

Mill stays in local hands

1-5-4 THE OCHOCO NATIONAL FOREST Issues considered c CROOKED RIVER NATIONAL GRASSLAND inforest plan ...... * * affect Prineville * WILL BE HOSTING * * PUBLIC MEETINGS ON THE * * PROPOSED FOREST PIAN * * AND DRAFT ENVIRONMENTAL * *...... IMPACT STATEMENT * SCHEDULED MEETINGS: PRINEVILLE OCTOBER 14TH-4 PM TO 7 PM PRlNNlLLE FIRE HALL RFnMON9 OCTOBER 15TH-4 PM TO 7 PM OBSIDIAN JR HIGH SCHOOL-CMMS RM MITCHELL OCTOBER 23RD-7 PM TO 9 PM MITCHELL COMMUNITY HALL MADRAS OCTOBER 30TH-4 PM TO 7 PM MADRAS HIGH SCHOOL-RM 12A & B BURNS NOVEMBER 6TH-4 PM TO 7 PM MUSEUM CLUB ROOM PAULINA NOV igm-630-730 PM GEN MTNG. 730 PERM~TTEES-PAW-MAW CLUB For Additional Information Contact: Earle Layser, OCHOCO NATIONAL FOREST-447-6247

1-5-5 Forest plan comments asked

Open house mblie Enfor- Forest supervisor by Dee 20 morion merlinge ior the Ochoco Copieo of the draft plan can be Neuunal Fowor Drsfr Prooowd obtained from the Snow Mom Plan and Drsfr Envuonmmtal tnln Dlslrlet offrce rn Hmes or Impact Statement began m bemenaged:' hesard cxn be seen at the Harney Coun- PnnenUe and Redmond on Oct When finahzed the ~lanmne ty Library 14 and 15 document. will . gwd. A pubhe informstion meeting management of the Oehoco on the Ochao plan wdbe held National Forest and Crooked m Burns on Nov 6 st the River Natrons1 Graoolands far Museum Clubroom from 4 to 7 thenextIOto15vears em lntere~tedpersons are invited "Forest personnel will be to subrmt written comment on available to &scuos the forest how they feel about the draft planning dauments and we en document. courage everyone who has an ''A= people regpond to our antemilt in the Oehao forest plsnmng documents it will be and grasslands to attend meof very helpful for them to include the meetinzs Dave Ritter supportive reasons for rherr UQ sbacher for& SU~~NIOO~. oaid thouehtsI Thus will helo in "We WPU have &splays to corporate the public comment help provide B simplrstic over. in10 the final plan ' Rmllei- view of the forest plenmng sbschersnrd process and hghhght the key Written Comments must be msueo which the dsn IS received by the Ochao Natmnsl

1-5-6 Forest Service holds info meeting I Representatives of the Ochoco National Foreat will hola an open house Nov. 11 from 4-7 p.m. at the heyCounty Museum Club Room to diqms the Ochoco National Foreat Plan. htmt Ranger Fred Harnisch and other forest employees will explain

Editorial The Ochaco Natmnal Forest is prepmng a forest plan to gmde ita management declsrans into the next decade and beyond The form that plan d take is stlll undetermmed, but it will certarnly have profound lmphcatwns for Hamey County The forest-mde plan is the fust of its kmd for the Ochoco, and wdl address 12 major areas of eoncem from biggame habitat to hberharvest The Forest Semce has developed 11 altematmes that reflect a mde range of ophona on the 12 issues The tlmber harvest ranges from 34 percent less than current levels under one alternative. to 17 percent more under another The number of AUM'a (anunal umt months) allotted vanes from 23 percent more than now to 12 percent less Big game habitat wll support mcreased populahons under d the altermhves, rangmg from 76 percent to 91 percent more than current levels Acreage specifically dedicated to old growth habitat d range from twce the minumum level to only the mimmum level Itself, 17,800 acres There uecurrently about 80,000acres of old growth habitat on the forest The alternatives offer a range of choices for the amount of roadleas area rangmg from only that now in wilderness to several additional roadless areas and more mlderness Firewood taken from the forest is bed closelv to the tlmber harvest. as most fuewaad is provlded by loggmg residue It may vary from hgh levels to low, depandmg on the ph Other issues addressed by the alternahves are social and economc effects, npman management, the transportahan system. xemc qualrhes. snag management. and wmter sports By law. the Foreat Semce must name a preferred alternahve. but Fred Hanusch. the ranger for the Ochoco's Snow Mountam Dlstnct, sad that dws not mean that the preferred alternahve will become the chosen plan In fact, he md, maybe none of the 11 alternatives will be chosen Pubh comment and response may lead to the formulahon of an en- tuely new plan The pwple of Harney County have a lot at stake in the forest's plan Wntten commenta WIU be received until Dec 20 Send them to Foreat SU~~MSO~.Oehoco Nshonal Forest, P 0 Box 490. PnnenUe. Ore, 01754 AU documents me wadable at the Hines office

1-5-7 Land- plan review slated PRlNEVlLLE - The last scheduled o n house on the yposed land management plan for the Ochao !&md Foreor and rwked River Nalimd Grassland wdl he held tonight m Psuhne The open house bepno 81 6 30 p m m the Pau Mau Club A meeting to discuss grsring I~PICSon the forerr wdl follow at 7 30 pm The US Forest Service %illhe avalsble to speak io other groups about the plan For information about sehdnhng a presentation. call Jae Meade at 447 6247

YIw+Rm Ir*lcr HtWSPMtR ELIWING SLIQ Pro-economy The COEDC sent letters Fn day 10 virtually every government body. ehamhar of commerce and N.m.0rD.W forest plan mlergovemmentd ageney I" the li; fhELPb, 5- tn county maaskmg them to mi9 _*h*F,hWd -I support as ked suehresoiutlcns Hemmeway sad 1h.m are "ar %&,d.of2 Centraloregoneilipsandeoun gummts on both add' ahout the 0.I.dU.I tw have bpeo'asked to oppose any impact the US Forest Service's 11- a0

YIDI*OIY, ImWCI wwin ciiming SUP Mill manager prefers alternative B

BYTERRI LOWRY which IS eoneentratlng On Wbl the nrrue." McClarn said Johnbhelk. general manager whal 11 refers to as Alternative "Allernatwe B comes EloPelt lo of Oehao Lumber Co . rpake lo E E Deparlure, 15 a PrPfWlPd maintaining the exisling sale the members and guertr of lhe alternalive by the fares1 Sewlee ,program and economic con- lribulmn lhe Ochoeo Crwk County Chamber Of Cam- for managing lhe national fowl from melee Legslatwe Commillee for the next 10 years Thal dleF Forest," Meclam staled Tuesday mornrng on behalf of natwe enlails reducing the the mill mduslry and ills stand 850 000 sereas CUrrenllY ~ng1l5 planned limber target Under lhrs plan, lhere will be on the possible lmplementallm har;erted for timber lo 26O.Dn According loShelk. Ihe mill 1"- less emphasis placed on elcar of the Oehoeo Forerl Plan acres dustry has devised Allernalive euitmg. and more emphasis ..The (LBUC at hand 1s B local ~ecauseof the reduced R-PIUS. which "13 the better gwen to lhe salvaging of dead he IUUB. and If It IS pUl lnl0 effect. number of acreage from which ' and dying trees. said ThC the forest ~ervleeplan will have to cut and select trees. lhe wall plan alee will enhance and ex- a direct effecl on the CommUnl- iyofttmkrw~ll no1 belhesame, pand campground facihlies and ly " Shelk raid Shelk raid The yield of provide 32,000 acres of old He slressed the imparlance of pander- pine will be reduced growth foresl while leaving eommunily members gelltng as 40 preen1 about lhat much over the next much idormatlonabout theplan The new plan would also Len yeas. he said as pmrable and then making reduce the availability of dustry'r allernallve known their opinions hy wuntlng fxrewwd. which IS prhaps one "This IS definitely a communi- Furlhemore. MeClam staled. to lhe forest rvprvirar by Dec of the mest lmwrtant lmpaCl5 ty mue, and you can bet 1'11 be lhe AlternaliveBplanwlll main on !he eommumly. Shelk mid knoekmg at dwrs 10 make PO- tam lhe current planned polen- conservative erlimales by lhe p~eof the community aware of tial limber yield

*".~iwliii 10.l,l ,.. iiiwintc. xu Forest Service accused of overcuttinq

1-5-8 Shelling begins in battle over Ochoco forest future

to increased current cut and lhe Get facts about B Plus plan ~ele~tivelylogs old grawlh everywhere m the forest the forest plan allowing low value Douglas and While Fir lo predominate !n the TOlhe Edilor Alternative B-Irrerpansible future Thesustamedyieldin the and rhorlsighled Oehoeo Nahonal Forest 1s 78 The propared land and mllhon board feet per year Cut h% more than IhiS will lead 10 a resource management plan of drop in produetion the fulure lhe Ochoeo National Forest and The average annual cut from Crwked River National Grass. 1975 through 1984 war 1101 land contains ash1 181 OPlION mllll~nboard feet Plan B pr- plus three 131 deparlwes flom Fer lo increase the volume by Plans B. E. and H In addrlion. 10 percent now At lhis rate I Norlhwest Resoureer. a have heen lold. the old gro& hwmess enlily hired by lwal Ponderma Pine will he gone Woodproduels companies has from the Oehwor 18 years propared a "B PIns" plan for a In summary. Alternative B grand lala1 Of LWelYe 1121 PlaN was never mean1 to be laken lo seleel from Information SerlOYElY 11 IS a Dlannlne regarding lhe eontenls of lhere plans IS contained m three volumes and eight maps hat would requiremonths of study la Mills' spokesman understand well We have until December 20. 1985 to make our OpiniON regardmg there plaN known to lhe Forest Supervisor rips Ochoco plan and I urge all residenls to do IO 81 Darld Brdy The USFS will lhen make a deci- hon related jobs the Forest Senrice Bvllsfln Correr on.", elmswdl re~ultfrom 119 preferred sim lhat may wellaffecta11 of us PRINEV~LLE P~~~~~~II~ f0rlhene~t3 wan solel's - allernatlve lumber mdl aperahro opposs the MeClan sad 19 percent of the hope thal a g&d one US Forent Scnee'o favored Ian So. where ad &ternau~.e B tunbemd part of the forapt was now eomefromandwhyam lagamst for future management of the 8th being mans ed for full tmmber wo National Forest B re resenta yield. hulunfer the referred alter it7 The Resource Planning Act mlls rqulrer that a SpeelNm of live for the told the h"vdle native the ares wo& be cut to 49 plans bedevelopdrangmgfrom , Cbty Council Tuesday percent maximum commodity (timber Jim MeClan. spehg for the He challenged Forest Serv~e and eatUel prcd~cu~nto max- Crook County tunber mdurtry and elms that tmhsr euttmg was imum amemty management of wwd remanufacturing firms, told mcampstible with other forepi uses lhe forest eaNjldenng all men the eouneil that the ra osed man and that clear cutting yielded agement an wou~tadlverse~yaf tQckei regrowth than selective cut , fect the frms. and through them your OPlnlOn tlw, , the entire commuaty Tlu~1% not a wildernerr IP Harry H Rinehart M 0, hlcClm mid 85 pertent Fellow AAFP 1 of we,'' swd MeClnn This IS B PrmevlUes labs were dependent m~ltiplru~eilime The wlldemerp mere would be no scenic cor- upon the timber mdustry and thst larue has,,&eady heen deerded by ndar left along Highway 2s or 2 3 other jobs were dependent an C0"grPSP anywhere else Riparian each tunber lab. allhou h the For He urged the city 8s an entity (stream bank) management in est Service hsn aisertei that on1 and council members indmdudly I onrhalf B lob results from eaci to write to the Forest Service timber lob before the Dee 20 deadhe for

~ If the Forest Service's "pn public comment to voice their opm fsned allomstne" for manapg ions pnthemue iim oulside wilderness arms the Oehoeo IO enacted McClon The Forest Senrice really doer mere are "0 PlOVlOlDN lor sad 11 would harm merchants. want to hear from you hlrClm wlnler and Summer range for prafessional eopls and govern $aid deer and elk Snags lefl would mentii 8% wdas the lumber and City Admmrsrrator Henry wpport only 20 prccnl of the remanufaelurm mdustrles He Hartle told the e~uncdthat the patenllal pOP"I.UO" Of eavlly noted that xhWk alone drew SI 1 Centr~OregonEconomic Dpvplop nerung arm" In adbum to don last year from tares on men1 Cauncd also was exmmmg me above. lhe B-deparlure tunher fm roperties the I1 dremar~vesm tho Foreat guaranleen eaonomic &sur The tim%ermduslry jobs that Sorvlce management proposal and for CmokCountymmyearndue would he lo& MeClaun sard. would waspreparmg a draft r9901~110n he better paymg than the 63 mrea

1-5-9 Supervisor speaks on forest plan cent more under another alter. 1% all groups (e"""". natwe tahsU. Ilmber, etc 1. plam and Big game habitat wlll support coneems increased popWatian. under all Economic and swial Issues of propmed alternatIYes. rangxng the commmtv are the orimarv from 76 91 percent more Ulan Eoncernsl Of he forest=servl& current leveb, he Said and wdU be comidered. Rillem- Acreage specifically baeher said Cammunity input designated for old growth on any alternative will have an habitat wdl range from the impact on the final outcome minimum level of 17 percent to "I1 m't going to be easy," he twlee that amount. Falters- Said "Not evervone will be baeher sard Firewood taken from the forest is tied ~loselvto tlmber

low levels. dep&ng~ %"~%; plan Other mues addressed by the plan dlem1I~esare 5ma1 and eeOnDmle effects. rlparfan PI." management. the Lranrportatian "Under the forest sewice plan system. scenic quahlles. snag Ihe nmer of acres olanned for management and winter sports Rittersbaeher painted out Ulat "by law, the forest ~ervieemust name B preferred a1ternat,ve, but Uus denot mean the ew- rent Oehoco Forest Plan will

Stand on forest plan stalled mo"4oRFmHIWQMLR ICll"ICE CUWlWb SUP By Mike Frecmon tmber related employment. mmme LO .he future by mhFdrastic N.m.II1II.L". Bvllefin Sl.lI writer or local government revenues ' de lreduetmn~m the havertl The Bend City Commission has wed from irmher ralor The commrsrimern plan to con 7hp 2%- ridortepped - at least temporardy COEDC has bred an E~UIsider the re~olutmagm hsfore w- SUbUd - a emtrover~ialrequest to put tan1 to study the econome effects the end of the year E.--&, /e itself on record against any of the Ian and the eon~uitant'9 Forest Semee officials sod DiUOllul. ' 0 changes m the Oehoea Yntlon For report r?wuld be finished sometme they hope to have a oew plan for -- 8.1 management plan that mght thsmonth Hemingw~ysad the Oehoco adapted by 1988 After atb, hurt local industry Lrwson LsGata of the Siena that the tunbei mdustry 01 en~ The (.m"smners postponed Chb torthad Wednssdsy that the ronmental groups can file lawsut~ znu;. &z&& action 00 the request Forest Servi~e'~plan str8y0 from ehallenwgthe plan BLUDnd., Yk'"%mug t forward by the Central the prmple oi 'sustaned veld In other bunnenr. the cm" Oregon Economic Development limber harvesting smners approved a pmposal to ark

~ . ns... Couneil until they read r summary According to LeGate the For the ~tatefor SI55 000 to budd af the US Forest Service 3 plan est Service IS iecommandrng a 5 sewer9 rtrwts and water hes LO forOchoco percent mductian m the allowable the west and ai tom ' I d rather glve no opinion timber CY, m Oehoco eoch year for But John Horsiek city plan than eve an unmfoimed one 'sod the "ex1 five years The staggered mg director raid the city 9 Commissioner Ruth Buhgh redwtmn l.eCate sard. 1s designed chances of getting the grant are The Forest Service has come to glve the mbcr industry time to poor The laif time the city appbed up with I1 dfferent options for rcpare for reduced harvests m the for state hrnda for the neighbor regulatmg rordlesr areas timber !uture hd- bardered by hbV 15th and harvesting wddhfe habitat and The Sierra Club and the tmbsr 17th streets and El and Calves other matiers m theochoco One of mdurtry bra ee ohout how much ton BIP~Y~S - appbeation these plans D the preferred alter limbs should% cut u the Ochoco ~mem12th out of B bstof 30 native recommended by the Far to insure that the forest can pr+ The mty compte3 mfh other ell Semlee vide a eteady flow of logs for ribes and mmtw throvghout the City commisemneis received a several decada. LeCate sad ,, state for the hnde letter from Bdl Hemmgwav. exem "Hntory IP w~reuttin Le Tho uty alw, Unu ask the state rive director of COEDC. asking Gate rod 'You nanrge I% SUP for SS50W lottery money '10 lhem to pass B re~obtimop Sing tad ydd You ion 1 mt more developer Lpe Blake em m~rove any 'mcdheatlons to the F"mt than the forest ran reproduce1 now Nefi Road from hE 2ith Street to Service phwhrch would rednee and then make up for 11 ~ometme Tucson Way Blake prow3 to bdd B retmemeot center st the cmerofZ7thandNeff norrlrk rod the chanm of HtWWLR CUWIN6 SUP wmnmg Lhat grant also are pmr Forum nears on Ochoco plan Have YOU bovght any lottery tickas lately? he quipped PRLNEVILI E - A puhhe forum to dseuso the proposed land managementplar and draft environmentalmp~ctStsUment for the y$$""r;u_c.1' L ,'\ Ochoeo N~ti~na!Forest will be held Wedneday in Pnnovde Wumd The anehovr larum beglna at 6 p m m Our Saviours Lutheran . I> Church. on the "mi of Thrrd Street and Haw& Avenue 6:S& R Jim McClm a representative of the timber mdustry, Unu eve a I)Y.OIYIIU preoentatmn on the plan Offrcralo from the Forest Service state 14- 1-H- departments L) Flsh and Wildlife and Forestry also d bp at the 10" Ro re3entnlien of the Ochoca Elk Hunters i\spoelatmn and ponribt the Perra Club also will attend Meanwhrle. Dave Rittersbacher Ochmo fore11 s~pervlsor wlU be on hand to answer que~tmnsabout the document. Untll 7 P m FD.. I "fir.. Thursday and Fnday at forest headquaileis 230 Srth Sl ~n YO" are IeqwIUd LO Cb '") ,mpD,,sn, newepa,e,a,,p PMevllle de .m"Frri,,ng loirALg 0. tba The pubhc ~ommentpnd on the plan endo ne 20 .ori 0, Lh. For.., S.,",rr

1-5-10 Ochoco officials dispute forest industry job claims

E Departure is mg nprap dam. Bkes. lettrr m lo years' knd calllamen Forest plan at reveral~a~ndmoredollarrnot sulfer - we Could afford mismanagement per mde so, Uus 1s a hollo~ pay them many times lheir et input to end goal Furthemore. lhe 1979 rent pmflt5 pr cow no1 10 grz TOthe Edllor LMP ealled for "elce1lenl" thelr cattle on the forest uifh I To the Editor The Propased Forest service management on far more mils sawngs reailzed rrom The Oeha'o National Forest P1an"E Departure" ADepar- of stream than E-Departure. managing the range and for8 Land and Resource Plan prw Iw from samty and a reduchon 10 amma1 Use for granng posd has been available to the As I menhoned last weer. months (AUM'S) If the gOak As ueles as 11 may seem oublle for review for oulte some there IS a margasboard of 12 were not met1 So. halaneally. uree YOU la wnle lo the Fort pmSlble &hoe0 Nahonal FoRst the Farert Senwe has not Im- Land Management plans ( plemenied meaSuTes pertaining ~ ~.... for us to wmmenl onT' by 10 Ripanan habilal recovery m plan I would'hke lo urge all December 20 Theoret~cally~$e it5 lastplan-the credlbdlly gap forest user groups and ~n- Forest Service wdl then relfft beglN Lo RVdIkdf the well f&ded spcial "cot dividualr to please lake time la one plan and use ,t ta Con@ue Speaking of blstory, the modlly interest groups - limb review lhe plan and respond mlsmanagmg the forest pd USF S was uuhaled In 1811 by and catlle Your thought5 are needed grasslands for the next tea lheorgaruc Actwlucb eslablwh- My view II that not one of 1 Dave Mayfield years or.theywrlimod~rys" edhuopurpo~es 1 Watershed 12 plans has any ruklaanli President of the plans and come up mth a pi~teet~.nand 2 Timber menr. mainly kause none Oehoeo Elk Hunter's "mnse~w"plan and do.the managemenLTheU S Supreme Same Uung Cam m 1918 reaffirmed that More on Ulat laler Right now. BLM land swap lel's eval~alethe ForeslSeNIy preferred plan. E-Deparmrr . opens elk range Timber harvest would i m- crease by 1 percent N ule fi16( To the Editor decade then slowly dmp to There 1s a prapmed land ex percent below the current sale change 10 Wheeler County Ulat level Remember the swlam has Ole pssib!bties of pmvldmg yleld of the Oehoeo top of Lmkout ML would be elm- a.W acres of public huntmg. Forest IS 78 million board fe& edloyoul Oolyusruneompmg. fishing. and recreation Thmpm per year The Eurrent sale I the xsounlrj skiels. would be posed exchange would not only II 132 million board feels allowed up there There would promde pnme bird and big year.or~almorll7Umeslhest& be M more miles of mads roryou game range hut also Bo miles of lamed yield - reducing !12Sper? lo ride on the lower slope 01 John Day River access for cent would sUll be 12 times tho Lmkoul- loggmgsecersmads. fishermen I would like 10 wge dl pEON 10 EDnlaCl surbmed yield In essence,! that IS. into a current roadless lnlerestod weke eatmg our seed polat& ?rea the Pnneville R L M olfiee far Bo" applit Picking st park of the plan. information or ta attend the Lwesloek grazing would a#! however. serves hllle p-e publieopnhausemeetingatthe crease by I1percent Now W k The Form Se~ce.like all lame Pnnevllle Fm Hall on Dec 11. really preposterous IO any- governmental 'regulatoiy 1386 at7 p m bureaucracies. wleontmue D Dave Mayfield aid and abet thme special in- grazing pmilleer would nm President teres1 grwps lumber and -1 lo be eompemtd as a pm Ochoeo Elk Hunler's tie) that It was mppmed 10 af their livelihood IS depnde Chamer 0 H A I regdale. kawelhat IS theride on the forest mughrge BuI It their bread IS buttered on cmt of h would be a le The Ripanan (SLreamba Like Wdly Sdlon. who robbed preenlage pint5 01 the emk I Applauds letter managemenl goal IS listed banks. beeally "lhal's where current management and Ims I the money's W. the Forest Ser- revenue from fishems ap on forest plan pael shlement as "Exccllerff~ vice IS depndent upon their recreation The data I condilion In all areas wllll' large limber reeetptr and avadable. mainly from la' To the mmtor anadromouri fish ILalmmb mlnlSeUle grmng reee1pt5 IO It war Indeed refreshing Io head1 or hlgh valued tr$ measure their value and iurufy read DI Rmeharl's leller 8" the Bshenes" There are 8m mild their eiirtenee Htslaneally NO" n ai the central of slreammdesonuleforeslp they haven'l enfdlhe law of Oregoman ICs heartmg lo bow the land and rl mU lake major that there are some within ule eonlronlation for lhem to communrty unllmg lo let their chance. whv elre would ulev long' apm1ons be known on the ,sSye Of The forest and crassland forest plaug. even when lhme Op(N0W IWY go agalNl the tlon of Peltan Dam) &ere are ab" no lu prt Uus goal by eo meam te fencing rues s2.w 6.r mdc. as we11 a

1-5-11 Nordic club meets Tuesday The Central Oregon Nor&c Club %dlmeet at 1 m Tuesdav at Fvst Methdrt Church on Bond St with Daw! Foster of lh Mrmntam Sports @vmg a pr~smtalionon tho new lmne 01 CTOIO country sh equipment Also. representatives of the0choeo Nordic Club unll discuss the new Ochoeo Natianvl Forest plan BS rt prtans Lo wintar recreatlonallsts On Saturday. Bob Woodward wdl !@e B rh skstmg clinie Far mfomation call Woodwardst 389 B8l8 And next Sundry, Tracy Reymoldo 01 Blue Lake Resort wdl had B tour of hm tral system Inler&d skiem should metst 10 am m the Mirror Pond parhng lot The Im IS IS10

Bend Bulletin 12/7/66

Forest plan would reduce harvest

who Me lour set aside area x.eountry ski there. and a list c what E now closed area- that use "0" used a lltue eauuon ream~~whyThey all deservet Wants Lookout could be lomed to the better Of ~amforalttypofrffreation an all of the Oehrro Natmnal en,oy this kautrful seen,e dn"* road open again ores st except the lour set asnde So. if you feel as I do ah rea as. "three ,wddemesr and MS. please help younell as Bandlt SPnW game You could dnnk from and athen have bed to he1 1 hike. Ish hunt. four wheel. several spnngs and re he YOU aU The road we want back eot horseback motorcycle 1-1 af the Ochrrds from the= snowmobde. andlust camp oula In 1919 this road was nppd lot I do not X-EOUO~~Yskn out and the movnlamuarrcored 01 If beeaue I don t know how and smce these rich selfish land am probably lo clumsy and old owne~ihave taken auaY the to learn But more p~werto reereation from hundreds Of those who do The moral of this $tory 1s tho-"& of acres from or- Pnnenlle. ore 97754 dmnry people then we haw 10 .ut Inot be like tharc menuon- ed bep Let's share uhat we Rapand before I2 20-86 count on public land Thank you Now i~reatlmI know abaut have \\ant,ng to share the ow Ilkto Play For (10 yean that I know of there waq a prtmtlive mad golng Bob For I worked with the Forest Ser- Pnne\llle mee and agreed on the three aer~a few miles of the mmt beautiful par1 01 the Ochao Na PS IfIhaverteppedonrom wlderness areas we have I Loa thlnknoUung Ollt. ymhav, worked with the ~rieinalskien banal Forest It was passable lo all typof vehicles as long as stomped on mine

1-5-12 Zonsultant says wrong pla n will jeopardize economv

,".. -.. .. > ..,.>...I *,, .".., , .i .I.q.r..l ...... ,I ,...... '..I .I-..?...-".*...<," ...,s,,c..a...... -.... , .... ,- .,e- ,,.. I ...,, .,_.a-* . , *.. -. :.,..._.". n ._.:.-

§tudv finds 'E-Departure' flaws

Opposition forms to forest plan Br huid Bmlr . ~~~ Bulleltn Corrhspondent PRINEI'ILLE - 0 po~ilionls In hm report. Long warned erystallrzmg ~nCmok Ebmty to a that reduction at the allowable proposed Ochmo Nailanal Forest timber cut would "make it d~ffleull. management plan that would re d "ot ~mpossible. to attract new du~.ethetimhereurby28perepnr remanufacturing plants or for fl" Judge Dick Hoppes sad to modermre existing plantS BP Wednesday that the Crook County cause of tlur It may promote tho Court would almost certslnly pro of low weit af the Car pore modifications to the Forest SorncePlao

to a 10mt gathering of the ea;&; Court and lhe Pimevdle Cty Coun <,I Long WBB hvcd by the Central m mmmel m Crook and Hame). 28 Oregon Economic Development Councll wbch IP asking local goy elnlng hodm throughout Cenlral Oregon to 0 pose any forest plan Derehule. County Long ertlmaled that might Yaad to lob IOSSPS or that ons nonlumher lob would be hurt the Imal economy lost as ao mdmct result of each Stale Sen Gene Tm" and lumbar industry lab lor1 other lnteierled people also attend Long rod thnt beesuse lhe ed IVednerdov s sessm average lumber mdurtr, employe COEDC chief Bdl Hemmgway ems 622706 a year aod the r~er sad Longs complete report would age recreatm employee S9 296 a be available m reverd days The VPW. rt would lake 24 iffieation Forest Senrc s deadline for pubhe em"t on the pian 15D~C 20 Long .ad that derphtc dlre PdLetmns tn the early 803 that the llmbrr 8nduElry would never ComPlPLcly recover from he~PCPI smn Centra1 Oregon mdls am now OvtprodurinC lherr pcok prrform mCPS of the P~PTPCPOW~pmod

1-5-13 I Charges forest plan creates defacto wilderness areas

' eastern Oregon IS different from western Oregon"

State Sierra Club head "Leave Lookout hits ponderosa report Mountain and Silver Creek as roadless areas "

1-5-14 james 0. smith Major changes may n It be needed to fix forest

6choco plan claims disputed By Slephanie Manson That s because the Forest Sow B"ll*li" Stdl WIller >

1-5-15 I--PR,NTYaLEIOTr)nllWO-~~--, -14 Is% Forest Management plan may take year to prepare

Ochoco plan review set

1-5-16 Keep forest on sustained vielr flexible, says ranger

%ate ownership best ONF plan

ylo".,(i",sl IL111CE Council backs Ochoco plan resolution HtWVAPtR ClfVlHG SUP rmehber Ann Graf war added call mg fwpulng r1ght.i to be mm aged ~n such a way BE to benefit both the grazer and lond use Council member Ilon Jay said' hc felt he lacked enouch knowledge of the complex issue 60 did co~ncll member Joc Straus~who said he knew nothing at all about the t~mberindustry belurs hz moved to l'nnevdle. but that the resolul~o~ was so generic and broad based paid he plmnad to wr& hm own that II could do no harm lerts to the US Fore31 Servirr about the plan Mayor Wallace Bae disaped ~aymg.' 11 we could c~ll~~ti~~ly represent the best tnterests of the city I think we should do that Severdl Other eouncd members

1-5-17 Keep Lookout roadless are0

3choco plan comments overwhelm forest staff -Editorial- Appeal The Ochm Nahod Forest Plan, bber at the rate at whlch the foreet IS whatever shape It takes when it becomes pwmg) and for adequate anldhfe was sure final, anll have profound effects on hsbxtat Hmey County Far that mn. and !?.departure would tnple the acres of for plans because pubhe comment has been alow m madlens area. more than double the acres gettrng started. we beheve that the com- devoted pmdyto wddhfe hsbltat. and ment pemod. whch expued Dee 20, nearly double the acres managed for ex- should be extended cellent npanan conmtions The drfference Same hber mduatry apokenmen ch between Mepartwe and current practlce that the proposed plan. Edeparture. MLL m d three area8 amounts to Bome 160.000 reduce by 40 percent the acreage acres not devoted to tmher harvest designated for full tunber harvest Many of these are now avdable for A Seattle econormst chsthat the plan bber productmu. and whde -me of would cost 317 lobe m Grant, Wheeler, them would atdl be managed (harvested). Cmok, and Hmey counties. the four that thew rotahon schedules would be much contam parta of the Ochoeo longer. and tmber harvesta m them would Conversely, a recent tunber mventory draaticdy deerease on the Deechute. National Forest reveals Edeparture calla for shght decreases m that the amount of ponderosa pme grow- tunber harvest m the fmt decade, and mg there IS 39 percent below what wan greatly reduced harvests thereafter The prevroualy thought Lawson LeGate. prem- fmt decadeb harvest levels are held dent of the Oregon Sierra Club, beheves higher than sushned yteld lev& to soften &at the revelahon "probably signals the the blow on countlea and lumber mda In 'path knell for industry efforts to greatly later decades harvests are reduced below .hcreaae loggmg levels an the ,peachutes austamed yreld leds to make up for the md the Ochoco national forests first decades harvests The timber mdustry beheves it 18 not Because of the mevmhle reductions m lhng far increased harvests. Juat a Con- timber harvesta. whch would consrdersbly tinuation of those of the pest The Sierra reduce the revenuea to Hamey. Grant. Club &aims that the past lev$s have Wheeler. and Crook counties m the future. resulted m "rampant avercuttmg and because of the many other imponant Whether a reduction I8 Juatlfied Or not, aspects of the forest plan. the cituens of it seems eertam that adoption Of the the four counties mmly effected desenre Forest Semce's Edeparture Alternative more t" to submit thew comments to the would result m decreased tlmber harvesta Forest Service 3" the Ochoeo Forest Sernce planners aay To request an extension of the comment hat they must do BO to sahsfy federal re- penad. wnte Dave Rittersbseher. Oehoco qwements for a sustained yreld (cutting Nnhond Forest SU~MSW.Box 490. PnnenUe. Ore, 91754

Multiple me concept IS valid

1-5-19 Conlinued imm PsR~I about 80 donbeant feet. he the county court mcermog the wd" Comments deluge Oehao ~lanHe wd the letter lndustv re~resentah~pdsuch would &y elaetly the me 88 Don Witted Snow Mavntam weight mth planners as B letter heh m liroea cite the Foreat from an mmndud He added SerVrCe'8 Ombenehmezk figure Ochoco planners that the Foreat Semee has of 144 donboard feet The received letters fmm the countv benchmark refers to the mm. marts of three of the five mum amount of mber the been form lettera e" from mu; - hes affected by the pmmposed Oehao could pmdurr li all !ta the timber mdusw. e." from _-"IS" avdable acres were devoted The Hamey County hurt ex ~manlyto Umber hmeat Tb premed the d- for mulh aged would OOt mean harveaMK management. and B contmuahon snldemesl areasor othercmnt ai cment mber hmeat levels. lyexemptareas among other hgs LayserwdthattheforestSer The plan supported by the nee 1 requed by federal law to mber mdushv. whch It dsB manase the foreat for multde

"" getmmemore" Forest Semce has recaved vote eountmg. the fact thatmany The . more than 2" EDmmenta - pple.ur~the aifected area feel qvuement one day It gat mom than 600 let. stmngly one way or another d In fact he sad the Och- Na- ters, Layser md The ylmom be taken lnto moslderahon by haslustbeenswamwd planners tional Fareat hse been workmg lor years on 1te plan hause such 1thd we can gsy there's been But he sad that there were also B plan 18 reqdby the 1976 Na- excellent reapone," he wd, ad- tional forest blanagement Act dmg that the Desehutes Nahonal wd that the rmal ph Fareat mewed about 1.W He thereater, order achieve B should be completed m about B the to reaporma dunng recent mm- mstaUled veld Cvrrent mud year "We MU keep the ment *nod for orod try to ita .. timber h-eat levela are abut pubbe informed about OUT pm Plan 133mdlJan bard feet gresl." he md 11'8 not a pmess Layer mdthat more than hdf that lust tpmnates mth a1 the Lavserwd thattheforestisin the "mente received have Continuedon PsgcS eapsble of produemg 137 m&ov close of the .public "ment boardfeetperyDartoperDetutV penal (Dee 20) He wdthat the ohers MU

depnriwe alloas timber hmcste Forest plans at "em cvrrent le"& for 10 years rely heady on tvnber revenues would eee httle change for a d-de Alter that. aqmfieant may change reduettons u) revenue would m - - By Stephanie Monwn dirmrsed by Forest Service Chei Bulletin St.H Wlller Max Peterson Peterson last week Proposed plans that chart the agreed that proposed forest plans iuture oi the Dsrchutali and Oehoco shouldeontsunsomeof themforma national forps~r may have to be tion the councll requested ~vbieerodto publrc mutiny agan That means the nalional for because of timber industry abpt est3 m Ore on and lVarhingion t.""" I."..= that have retared plans wIU hare That means peo le w11I have to pubbsh a sup lement to the mother 90 dm ped- tentative documents Butruiee rad The I? ly ret io bqn m B month - to forests that have not yet released comment on draft plans furl re piano will incorporate the data /n leased Iht war for the Central their draft plans he raid Oregon IOIPILI and five other for The ~upplemeni will contam esie /nOregon md Warhmgton figurer rhowng loggmg levels far Hoaeier lhlr time the plans the part seicral years and predier will contun sup Ihmental informa whaL hariest levels would be 11 tmn ioqueswd the Northsat current land man* m" plans Forest Reiourcer Council raid were followed Butrufle sad John BULIYJI~deputy regional lor Evch draft iorert plan exam ester far the \orrhrestiegion ine~a number of altrrnvlrve slrace I mu \I~llmchid planner for gier io? Ion term management the Deichuwr lorest thrs morning Butrudle sfthe c~uneilman said ofiicsde 01 the Derchutcs for tamed that the dfernaine thal uas csi *ill ark to be exempted irom sup osad to ahou currcnt harvest the new order \fullen sad the lev& dld not drait plan /or the Derehurer d The dlernarive initead out rcadr

1-5-20 Could mean longer review period Group renctg to Supplemental forest info a possibility forest isszrev

S"I. timber dependenl em muniller These plans can be bluepnntr for eeonomx stability by providing high levels of limber OU1pUl uhde pmleellng wildlife watershed and recrea- lion~lvalues Ho~everlhere IS a gut level lea? spreading through these communit$eP lhat our way of life IS mlcad threatened by malor redu~lion~ *Forest tn the woodbarvists from na service- tlonal forests - 25 percent or more - thal sustain logging and mill lobs and the local burmerres lhey suppart We ve heard a lot IaBh aboul getting aside huge aereiges of forest far the spotted OUI a bird that Isn't even on Ihe federal threatened or endangered species 1151 We re going lo hear even more ahoul new minimum- management requirementr [hat were adopted without an) oppor tunity for public commenl and they are dread) having a drastic effecl on harvest l~velo 11s impomnl for all of UI to make our $DICCS heard on the Forest Service planning proeeu before 11's tw late We need 11) organize at llie community level to do Ihls A few rueh communi ly orgamralionr already ex19I. and we're lying ourseIV~S together into an umbiclla group called CPR - Clliiens for Perpetual R~SOUPCS Youream- mumry nee& to be a part of thnr effort. and we'll be glad toshale ideas wilh you You can contact us by anling 10 CPR P 0 BOX 33 Florence. OremnOiiS) Slneerel" About a month ago. a 'Ibnes-Heraldemtonal called far an extension of the pubhe cam Del Phelpr Praident ment penad for the proposed Ochoco National Forest plan because of slowly buddmg public interest It now appears that the comment period may be reopened, but for drfferent reasons A forest industry group. man appeal to the re@onal forester, said that the publre should be even certain information about current management practices and about minimum manwement rpniiirpmentq...... The appeals were rejected, but the re~onalforester has ordered all future plans to mor- miate the kind of information asked for ~ILthe suit It also appears that those seven forests that have already come out mth them plans wdl have to issue suplements to them, and reopen public comment Ochoca Forest Supervisor Dave Rittersbacher beheues that his forest may not have to issue the supplement. because. he said. the InfoormatLon LS already mcluded m the plan But it 1s still uncertain whether a supplement will be required. and a decision IS due neyt week That decision will be made by a panel of forest planners meeting I" Seattle They will decide whcther dlseven forests need to publish supplements. or whether each may he considered individuallv

If a new public comment period 1s opcncd for the Ochoco. it will provide an opportunity y,Iu-~~~, for people to ~VBthe kind of responses that the Forest Service IS looking for - thoughtful and well-reasoned HtWWMR EIIWIHG SLIP During.the initial comment period. most of the commenls received were form letters. BC cording to Ochoco korcst I'lnnner Earl Lnyser Many of them supporlcd the timber tn dustrk's proposal for continued high timber harvests Othors were from snonmobtle I/ .$,*( LLk\.I groups. and from environmentalist organizations km! qLw.i ($ CO~CP~IIS This new period would give people lhe chance to more fully outhnc thew and D_I_u, to EIW the reawns for their views - The plans for our locol forests will, in a lnijie mrdsurc drlrrmine the mix of CCWU~IC ,,!; ' q ' ' I*? YBIUP. aesthetic qualities. and recreational opportunitieq that prowdes the tenum~ .p, ,:( \L7)];A etonomxe 4tdhility and thc bountiful qualttk of hfe that \%e lmd 111 eastcrn Orrgon Thlt ~ coneernsc$eryritizen 111 flnmcy County encourage erery rnl~zento lake nn interest I \,p< We ~n IJ(, themattcr 76

1-5-21 Analysis of publric comment on forest plans continues

Local groups needed Citizen input our lO1eSls. I" large part are Totheator the economic bare 01 U~stnel30 The lQngrange plan0 for the 19 aids legislator natlond lorestn m &egos and Washngtoton now bemg isaued for To the Editor pubLC comment by the US The nulj~ndbOltSofwhathap Forest Sennee are ertramely rm pem m the legislatwe I com- portant to the ppleof these two miltee work It IS here that the states. especidly to those who final farm of legislation 1s ham Lve and work m the &cores of mered out. and m order for this mall trmberdependent cam piwe(s 10 run smwlhly. we rely mYlllUe8 on the lestim~nyof thme from These plans can be hluepnnta bolh the public and private see for eeonormc stahhty by pro tom We m lhe Joint Committee ndmg hgh level^ of tmber out on Trade & Economic Uevelop put Ale pmktlng mldhfe. men1 enioyed an mlere~tmgand watershed. and reereationel enILghtemng meeting Wed, Jan VdWS Hoaever. there 18 B gut level few spieadvlg through them commumties that our way of hie 18 cnstead threatend by major reductions m the wdharvests Iram nstrond laresu - 26 pi ccnt or more - that sustain log sng and MII jobs and the local hwmessess they mppn ~ Weve heard a lot lstely about ;ides a 20 preen1 proleeled decrease m lhe allowable cut setting aside huge areas of farest AS=& this Olan are rom for the spttod oul, a bird that o+ 13" t wen on the federal thrcsten edarendan~eredsw~eshat We re pomp to hesr even more

1-5-22 Ochoco Forest may issue supplement to forest plan

8YJI\IO"IO"*N plans. the pubbe sa8 not made appellants' ~18". ant that they ThrTrmn Herald aware that the current dmction needed to be lwked at Sewn Northwest nati~nnl slternatwe incorporated the re The NFRC and Mark Hat lorests may have to mue 8up Sen quirements of B 1976 law not field have asked the secretsq of plemcnts to their propmd forest now bemg fully implemented amculture to review the relee- plans and reopen public com Current plans would show that tion of the appeals That decision menton them pending n deeiaion we have more trmhr availnble 18 due in about B wcek by the regional foresterij office thm shown ~n the Current dxee htterrbacher md that those . Ochaco National Forest Super- tion plan with these re foreats th8t hew sleady issued visor Dave Riltershachor said qu1rements ,ncorporated plans or draft envmnmcntal ~m that the Orhom may not be re- Another contention of the pact statements may have to wired to issue B riupplement NFRC WPB that those mor publish supplements Those that An appeal hrounht by the Dorated reourements. called hove not ulll have to meorporrte \orthwesL Forest- Heaourres minimum management re the mfomabon in their future Cauricil alleged Llwt the draft en qumments. were adopted doeuments vironmentol impocf atatemem withovl the opportunity lor He mdalso. '1 believc that the Iswed by seven northwest forests puhlle comment informntron is there. (m the undersfnted the current timber The pupfelt that lhe pvblle Oehocok draft environmental ~m harvests ~n thew "current drrec. shovld have the tnfometvm pact h(cment)" said that it tl0" dtPmStiue. He about the current direction niter may be debntable"whcthrr Its m Eorh fwest plan o~thnesmany natives and the hlhIRe made the appmprmte format or loea nllmntlves far manvpng the more und"mhle m the tion tobeundersmdable" forest One of those called the drafts Ritteisbscher added 'I think 'no actlo" ' alternat,re must According to Ilittersbscher. the we're m good shape with Alter show the muIts of trlung no ne appenls were rejected by the native A It rubetsntlrlb meefn tion and continuing current rcgionill foresler on proeedurnl the requirements the (yonal) mdnsgemrnt practices wounds But. he said. '11 was felt officehascomeout wth The MIlC asid that m many lhsl there wa8 some merit to the I Ochoco plan draws comments

To show current direction

YIDI-TOIYT ILliWE Forests to work up new alternatives XIWSPMIRGIIwIHGsLls .fore.t pl04. altornatwes that that shows cment practices mdiied by MhWa Forests that have already issued them plans mll issue mp plementa ewll~lllllgthe cment btionmthoutMMWd pmjeehng what they would In addrtlon. all foreats rnll pm bedMMR'sweremwrprorporated duseadmpray called o moek UP The NWFRC also =ked that by the Forest S~MW that mll different levels of MhWs be show how vmationa m MMR'a develod The Forest Semce anll affect kber harvests. eounthred that there muld be on. azldhfe. water quhty. and old lY one "um level of resourC8 growth 8re88. and other Pmhtron legally and wleo resour~o~The Ochoeo'e moek up tlfidy iustlfiable wdbeondisplayat theHme8of Though the Agriculture ftce m B few months. Hmsch Seeratary demd both appeals he md The supplement should be dmeeted the For& Semee to ad firushcd nt the -e time, he add __.A A pubbc comment pen4 mll b &Wed oldy 0" the NPPlcmcnL Hmmh md Comments will not be sceepted on dements of gualty.and npmadu-. the plan that have already mme The NWFRC averred that the under pubhe eommenl

1-5-23 r, * ,%'I

armd therule we are yl Ule P""' of rev~ewins lhe federal forest

Five Central Oregon rivers UIDl-FoRm Iililcr Ochoco HfWSPRPIR CLIPPIHS SUP I - - ~ included in Hatfield proposal I SlaH mnd wlm r~porfi fitman National Forest. the Wd PORTLAND - Five Central hamson and Sycan ID IVmema Oregon rivm are meluded in legis National Forest. and the McK@ue lation announced Friday hy Sen m Wdlmetta National Forest Mark Hatfield to designate or "One of the most glmg arms study more than two dozen Oregon mos 1s the Klmalh Hner. whxh nvem for protectionunder the Wild &iy wauldkke'" mcludes the propored Salt Caves and Scenic RIW Act Sansewatiomsts are extremely dam." Ken sad Oiher men we Hatfdd, R Ore, sad m Waah pleased m Senator Hatfield's mter feel should he on the hrt are tbe mgton, DC. he mtends to mtm froenomg n~er*." Donoerund Bhben m southeastem duce legl~latlonm Januay to des Kerr sad "But the brt that Sann- Oregon. the Nehalem Rwer. North ignnte or designate for study at tor Hatfield released 19 syli IY a Sanham and Smith least 27 rwors m Oregon 85 wdd. hst of those rivers the &rest ' We're also eancerned that Sen scenic or recreational under the Service has lwked at The Forest stor Hatfield avoided dam sites on \Vdd and Seemc Rmer Act Sprvxe omsonly ahout 25 percent lhe McKeme and Nertucca nv The legislation. which d m of the forest lands m Ore n, so em'' sad Jmes Monteith of the dude sections of the Deschutes. they looked at oul~mg'y 25 Ore OD Natwal Resources Councd Metohus. John Day, Wdbamron percent of the rivers ,.WkIe artms of the Nertucca ill 1 North Fork Crwked rwvers. The raver~ to be mduded li) and Meienzle M an the hrt, the wlil he "the large~tmer protection Hatfdd's hIU are the Derehutes bst doer not mdude dam rites on act m the hxto of the lower 48 and Metohus m Desehutes Nation the nwrs - the \Vvlker Creek dam states." sad 83 Doppeld of the al Forest, the Syean. North Fork on a Nestucca tnhutarv and the Oregon nners Counell Spragoe and Chewaugan m FIP Stmpe Dam on tne south fork of Oregon Dcmocrstie Re s Peter mmt Nstional Forest. the Clack*- lhe MeKenzie River DeFazm and Les Ad!m an mar Raarin Salmon and U'hte m Nstionallv. 74 nws hate re nouneed Fnday they plan to mtro- hfo& Haof National Forest. the duee similm legislation m the North Fork hoked Rwer Des HOW chutes and Crooked Area m Oehoco The Senate hill will inelude National Forest. the Rope m those nver~the U S Forest Service Hogue River Notional Forest. the has mdmted meet lhe rmmmnm North Fork Chetco m Slsloyou entena for wdd, scme or recm National Fore% and the AIS@& tional Stiltus m draft forest plans Nsstueea and Siurlaw li) Sivslaw being released for the 18 national Nalianal Forest forests m Oregon. Hatfteld rad They also induds the Grande My mteiest and lobe of Ore Ronde. Tucman North Fork John =on s rwrli N~S89 long and depp .Day and \Yenaha m Umatds Xa ;s the iiv~rsthcmdvco." Hatfield tional Foiest the Nmth Um qua m sad 'Ow the years, tho in~lina Umpqua Naimnl Form. tfe Lor Lion to dam. dwert or dwelop these tme North Powder Grande Ronde. ~VWQhas iirreased eoomoudy Eagle Creek. Joriph Creek and WNg some of ths omdo leading La North Fork John Day m Wsllowa

go6 EconaMe Development De paifment slud Permanent job/. p losses c More than S386 2 million m planned ylwitmcnts were reporled Oregon during the third quarter seen in forest indust#I~ wd lochard Rulm director of the BOISE Idaho NPll - 4last Ihp lmrnal sad the popnlar gon and studied the effwts of t,, Idaho timber jobs lost m the 1980 Perception has hem that the lndus changing timber industry on the 1982 recessmn were replaced by try 13 and continues to he YI Northwet, sad mills hulk the machae and are gone forever an rcc~19icm future d have the same produel article m Bone State Umver6ity s But the cam of ]oh loss m the we capaCltY hut '1111 employ about bvsmreiavrnal say0 s tmher tndurtry 1s not hgh 40 percent fewer workers The article oted StatistICs a mtrrcted government showing that whde lumber prodvc timber supply the Canadians or tm has largely bounced hack from the mes~mn The fact 13 that the the rffsmon employment lewls of modernization has have not changed the industry and perma When lumber nroduttian oeaks nmlYrd7rod emnlovment. the

1-5-24